Controlling complexity for regulator-ready protocol

Recent data from the Tufts Center for the Study of Drug Development (CSDD) highlights a troubling trend in clinical research: protocol complexity is increasing along with the number of amendments—many of which are avoidable. Despite sponsors’ efforts to write more robust protocols, excessive complexity often leads to inefficiencies, delays and costly modifications that could have been prevented with a more strategic approach.

Regulatory feedback can further extend timelines and increase the operational burden for sponsors, sites and patients. By focusing on protocol optimisation from the outset, sponsors can strike the right balance between completeness and complexity, reducing amendments while ensuring regulatory compliance and enhancing patient-centricity.

Completeness vs complexity

There is an observable shift in protocol development: while today’s protocols may have fewer gaps, they often introduce unnecessary complexity. This is reflected in Tufts CSDD data, which shows a rise in the number of endpoints – including non-core and exploratory endpoints – as well as increased procedures and overall execution burden.

With greater access to digital data and tools to capture it, many sponsors have adopted a “more is better” mindset – adding endpoints in hopes of extracting maximum insight. However, this can lead to bloated study designs and operational efficiencies.

Protocols complexity continues to rise

+75%
of clinical trial protocols require at least one substantial amendment
25%
approximately 1 in 4 procedures in phase 2 and 3 protocols supported non-core endpoints

37%
increase in total mean endpoints in phase 3 trials from 2016-2021
42%
increase in total number of procedures in phase 3 trials from 2016-2021

This increase in complexity doesn’t just impact operations, it directly affects patients. Broader patient participation requirements make recruitment and retention more difficult.¹ As protocols grow more intricate, keeping them scientifically sound, operationally viable and patient-friendly requires a more strategic and streamlined approach.

Data source: Tufts CSDD Impact Report. Vol 25; 3. May/June 2023.

The hidden costs of amendments

Even as sponsors invest more time and resources into developing comprehensive protocols, amendments remain both common and costly. Tufts CSDD data shows that 75% of clinical trial protocols require at least one major amendment, with phase 2 trials experiencing the highest rates at 89%.²

A major driver of these amendments is regulatory agency feedback – often triggered when protocols fail to fully anticipate evolving compliance expectations or overlook practical considerations like patient access.

Every amendment adds complexity, extending study timelines, disrupting site coordination and reducing patient engagement. Financially, a single protocol amendment can cost between $140,000 and $500,000, depending on trial complexity.³ These costs go beyond budget impacts – they slow trial continuity, strain site resources and risk data integrity.

Studies show that amendments can increase trial duration by several months and contribute to higher staff turnover at research sites

Research also shows that amendments increase administrative workload and prolong study duration.⁴ By refining protocol strategies early, sponsors can mitigate these disruptions, reducing the need for amendments while maintaining regulatory compliance and operational efficiency

Closing the gap: Designing for regulatory approval

To minimise amendments and delays, sponsors must understand regulators’ evolving expectations, particularly their focus on reducing patient burden without compromising data integrity. Integrating these priorities from the beginning is essential.

One key element is listening to the patient voice. ICON’s protocol optimisation process incorporates insights from site and patient burden assessments to provide a clearer picture of real-world feasibility and patient experience.

Striking the right balance between scientific rigor, regulatory compliance and patient-centricity can help close the gap between initial protocol submission and regulatory approval. Since study assessments and study designs are the most commonly amended protocol areas4, every assessment should be clearly justified and essential.

Embedding regulatory strategy early in protocol design reduces the likelihood of non-compliance and accelerates approval timelines.

The power of protocol optimisation

ICON’s three-tiered protocol optimisation framework integrates:

Foundational protocol elements for trial efficient execution
Multidisciplinary expertise to align study design with regulatory expectations
Quantifiable data insights to support better decision-making

Optimised protocols facilitate faster regulatory review and approval, as well as keep development on track by avoiding overcomplication and unnecessary data collection.

Our approach helps sponsors ask the right questions early, ensuring that each protocol is designed to answer the primary scientific question, without adding unnecessary burden. With expert regulatory guidance and quantifiable feasibility insights, ICON helps sponsors make more confident, holistic decisions that drive better outcomes across their clinical development programs.

Contact us to learn how we can help you reduce patient burden, optimise resources and drive faster, more cost-effective outcomes.

References:

¹Tufts CSDD Impact Report. Vol. 26; 5. September/October

² Tufts CSDD Impact Report. Vol 25; 3. May/June 2023

³ Getz KA, Stergiopoulos S, Short M, et al. The Impact of Protocol Amendments on Clinical Trial Performance and Cost. Therapeutic Innovation & Regulatory Science. 2016 Jul;50(4):436-441. DOI: 10.1177/2168479016632271. PMID: 30227022.

⁴Tufts CSDD Impact Report. Vol. 25; 2. March/April