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Case Study: Managing a Major Protocol Deviation in an Oncology Clinical Trial

Patricio Ledesma

Sofpromed's CEO and Founder. Global Director of Clinical Operations. 15+ years of experience in managing clinical trials.

13 November, 2026

Lessons Learned from a Gynecological Cancer Study

By Patricio Ledesma, Founder and CEO, Sofpromed

Table of Contents

Over the last 15 years, I have learned that no clinical trial is perfect.

Even in well-managed studies with experienced investigators, protocol deviations can occur.

What differentiates a high-performing clinical research organization from an average one is not whether protocol deviations occur.

The difference is how quickly the deviation is identified, assessed, reported, corrected, and prevented from happening again.

At Sofpromed, patient safety, data integrity, and regulatory compliance are always our top priorities.

In this case study, I would like to share a real-world example based on a situation similar to those that can occur in oncology clinical research. 

Certain details have been modified for confidentiality purposes, but the operational and quality management principles presented here accurately reflect our approach to managing major protocol deviations and implementing effective Corrective and Preventive Action (CAPA) plans.

Study Background

The study was a multicenter Phase II trial in recurrent gynecological cancer.

The objective was to evaluate a novel targeted therapy in patients with platinum-resistant ovarian cancer.

The trial involved multiple European sites.

Sofpromed was responsible for:

  • Clinical operations
  • Monitoring
  • Regulatory affairs
  • Medical writing
  • Data management
  • Biostatistics
  • Pharmacovigilance
  • Project management
  • Quality assurance

The study had been recruiting successfully for approximately twelve months when the issue occurred.

The Inclusion Criteria

Among several protocol requirements, two inclusion criteria were particularly important.

Inclusion Criterion #4

Patients must have demonstrated radiological disease progression within the previous 6 months before screening.

Inclusion Criterion #7

Patients must have received no more than two prior lines of systemic therapy for recurrent disease.

These criteria were considered critical because they defined the target patient population for efficacy evaluation.

The Issue Was Identified

During a routine monitoring visit, one of our Clinical Research Associates performed a detailed source data verification review.

The CRA noticed a discrepancy between information documented in the electronic Case Report Form and information contained in the hospital medical records.

A deeper review revealed two important findings.

The patient had experienced documented radiological progression approximately 9 months before screening rather than within the required 6-month window.

In addition, the patient had received a third line of systemic therapy that had not been captured properly during screening.

This meant the patient failed not one but two key inclusion criteria.

According to the protocol, the patient should not have been enrolled.

This was immediately classified as a major protocol deviation.

Immediate Actions

At Sofpromed, major deviations trigger escalation procedures without delay.

The CRA informed:

  • The Project Manager
  • The Clinical Lead
  • The Sponsor Medical Monitor
  • The Quality Assurance team
  • The Principal Investigator

Within 24 hours, an internal deviation review meeting was organized.

The first priority was patient safety.

The second priority was evaluation of data integrity.

The third priority was regulatory reporting obligations.

Initial Assessment

Several questions needed immediate answers.

Was the Patient at Risk?

The Medical Monitor reviewed all available safety information.

Fortunately, no unexpected adverse events had occurred.

The investigational treatment remained medically appropriate.

No immediate safety concerns were identified.

Did the Deviation Affect Trial Integrity?

Yes.

The patient did not belong to the intended study population.

This could potentially impact efficacy analyses.

The statistical team was informed to assess possible implications.

Was This an Isolated Event?

At that moment, this was unknown.

Additional review activities were initiated.

Root Cause Investigation

Whenever a major deviation occurs, Sofpromed conducts a formal root cause analysis.

Many organizations stop at identifying the error.

We focus on understanding why the error occurred.

A multidisciplinary investigation team was formed.

The team included:

  • Clinical Operations
  • Quality Assurance
  • Data Management
  • Medical Monitoring
  • Regulatory Affairs
  • Site Personnel

Using a structured root cause methodology, we reconstructed the entire screening process.

Findings

The investigation revealed several contributing factors.

Issue 1: Medical Record Complexity

The patient had received treatment at two different hospitals.

Historical treatment records were fragmented.

The screening physician reviewed only part of the available records.

As a result, one prior treatment line was overlooked.

Issue 2: Radiology Interpretation Timing

The investigator used a clinic note referencing disease progression but did not verify the original scan date.

This resulted in an incorrect assessment of eligibility.

Issue 3: Site Staff Turnover

The site's experienced study coordinator had recently left.

A newly appointed coordinator had not yet completed advanced protocol eligibility training.

CAPA Development

Following the root cause analysis, Sofpromed initiated a formal CAPA process.

The CAPA focused on both corrective and preventive measures.

Corrective Actions

The immediate corrective measures addressed the specific issue.

Corrective Action 1

The deviation was documented formally in the Trial Master File.

Corrective Action 2

The patient case was reviewed by the Sponsor Medical Monitor.

Corrective Action 3

The protocol deviation was entered into the sponsor's quality management system.

Corrective Action 4

A complete review of all source records was performed to ensure no additional eligibility issues existed.

Corrective Action 5

A statistical impact assessment was initiated.

The patient remained in safety analyses but was flagged for evaluation in efficacy populations according to the Statistical Analysis Plan.

Preventive Actions

The preventive actions focused on avoiding recurrence.

Preventive Action 1: Eligibility Checklist Revision

Sofpromed developed an enhanced screening checklist.

Investigators now had to verify:

  • Original radiology dates
  • Complete treatment history
  • External medical records
  • Source document confirmation

before enrollment authorization.

Preventive Action 2: Dual Eligibility Review

For future enrollments, eligibility confirmation required review by both:

  • Investigator
  • Study Coordinator

before patient registration.

Preventive Action 3: Retraining

All site personnel participated in mandatory protocol retraining.

Training focused specifically on:

  • Eligibility criteria
  • Source documentation
  • Prior treatment verification
  • Screening documentation

Training completion was documented and tracked.

Preventive Action 4: Enhanced Monitoring

For the next three months, the monitoring plan included:

  • 100% eligibility verification
  • Additional remote review
  • Increased screening oversight

Preventive Action 5: Cross-Site Communication

The lessons learned were shared across all participating sites.

This prevented similar issues elsewhere in the study.

Regulatory Reporting

One area where many organizations become nervous is regulatory reporting.

The key principle is transparency.

Once the deviation was confirmed and assessed, Sofpromed worked closely with the sponsor to determine reporting obligations.

A deviation report was prepared describing:

  • The event
  • Root cause
  • Impact assessment
  • Patient safety assessment
  • CAPA measures

The sponsor submitted the required notifications according to applicable national requirements and ethics committee procedures.

The reporting package clearly demonstrated:

  • Rapid identification
  • Immediate escalation
  • Structured investigation
  • Robust CAPA implementation
  • Ongoing oversight

Because patient safety was not compromised and appropriate action had been taken promptly, regulators viewed the response favorably.

Follow-Up Activities

CAPA effectiveness must be verified.

An ineffective CAPA is worse than no CAPA.

Over the following months, Sofpromed conducted follow-up reviews.

We monitored:

Metric Result
New eligibility deviations 0
Sites retrained 100%
Screening checklist compliance 100%
Eligibility verification compliance 100%
CAPA actions completed 100%

No similar deviations occurred during the remainder of the study.

This demonstrated CAPA effectiveness.

Lessons Learned

This event reinforced several important lessons.

First

Major protocol deviations must be identified quickly.

The sooner the issue is discovered, the easier it is to manage.

Second

Root cause analysis is essential.

Organizations should focus on understanding why the error occurred.

Not simply documenting what happened.

Third

Site training remains one of the most effective preventive measures.

Many deviations originate from knowledge gaps rather than negligence.

Fourth

Monitoring remains a critical quality control mechanism.

In this case, the deviation was detected through careful source data review performed by the Sofpromed CRA.

Fifth

Transparency with sponsors, ethics committees, and regulatory authorities builds trust and demonstrates quality.

Conclusions

As CEO of Sofpromed, I have seen many organizations view protocol deviations as failures.

I see them differently.

A deviation is an opportunity to strengthen processes.

Quality is not demonstrated when everything goes perfectly.

Quality is demonstrated by how an organization responds when something goes wrong.

In this case, a patient with recurrent gynecological cancer was enrolled despite failing two critical inclusion criteria.

The deviation was identified.

The patient was assessed.

The issue was investigated.

The appropriate regulatory reporting was performed.

A robust CAPA was implemented.

Most importantly, effective preventive measures ensured the issue was not repeated.

This is the type of quality-focused approach that Sofpromed applies across all clinical trials, helping sponsors maintain patient safety, data integrity, and regulatory compliance throughout every stage of clinical development.

Patricio Ledesma

Patricio Ledesma (B.Eng Concordia University, Montreal, Canada and Master’s Degree in Clinical Trials, University of Seville, Spain) is the Head of Clinical Operations and Founder at Sofpromed CRO. Patricio is a professional consultant providing comprehensive, one-stop expert advice and guidance to biotechnology and pharmaceutical companies worldwide in the field of clinical trials and drug development. He is personally and enthusiastically devoted to helping biotech Chief Executive, Operations, Scientific, Medical, and Regulatory Officers in the planning and execution of phase I-IV clinical trials across North America, Europe, Asia-Pacific, Latin America, and Middle East regions. You can contact Patricio at: +34 607 939 266  pledesma@sofpromed.com 

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Patricio Ledesma

Patricio Ledesma (B.Eng Concordia University, Montreal, Canada and Master’s Degree in Clinical Trials, University of Seville, Spain) is the Head of Clinical Operations and Founder at Sofpromed CRO. Patricio is a professional consultant providing comprehensive, one-stop expert advice and guidance to biotechnology and pharmaceutical companies worldwide in the field of clinical trials and drug development. He is personally and enthusiastically devoted to helping biotech Chief Executive, Operations, Scientific, Medical, and Regulatory Officers in the planning and execution of phase I-IV clinical trials across North America, Europe, Asia-Pacific, Latin America, and Middle East regions. You can contact Patricio at: +34 607 939 266 pledesma@sofpromed.com