A Practical Perspective from Patricio Ledesma
Table of Contents
When I speak with biotech companies, pharmaceutical sponsors, and clinical development teams, I often notice the same pattern.
The questions may come from different organizations.
The therapeutic areas may be different.
The studies may range from Phase I first-in-human trials to global Phase III pivotal programs.
But the underlying statistical programming concerns are remarkably similar.
Sponsors want confidence.
They want quality.
They want regulatory compliance.
And they want submission-ready deliverables that will stand up to scrutiny from authorities such as the FDA, EMA, MHRA, PMDA, and Health Canada.
Over the years at Sofpromed, I have participated in hundreds of discussions with sponsors regarding CDISC implementation, ADaM derivations, TLF production, SAS validation, and submission readiness.
In this article, I will discuss the most common statistical programming questions sponsors ask and explain why these topics matter so much.
CDISC Standards & Regulatory Compliance
Question 1: How are SDTM and ADaM datasets implemented?
This is probably the most common question sponsors ask.
Before a sponsor can submit data to regulators, raw clinical data must be organized according to CDISC standards.
The process typically follows a structured flow.
Table 1: Stages from EDC data collection to TLF production
| Step | Output | Purpose |
| EDC Data Collection | Raw Data | Original clinical observations |
| Data Cleaning | Clean Database | Query resolution completed |
| SDTM Mapping | SDTM Domains | Regulatory-standard datasets |
| ADaM Derivations | Analysis Datasets | Statistical analyses |
| TLF Production | Tables, Listings & Figures | CSR and submission outputs |
Table 2: Typical SDTM domains
| Domain | Description |
| DM | Demographics |
| AE | Adverse Events |
| CM | Concomitant Medications |
| EX | Exposure |
| LB | Laboratory Data |
| VS | Vital Signs |
| EG | ECG Data |
| MH | Medical History |
After SDTM creation, the data are transformed into ADaM datasets.
ADaM datasets support statistical analyses.
Table 3: ADaM dataset examples
| ADaM Dataset | Purpose |
| ADSL | Subject-Level Analysis Dataset |
| ADAE | Adverse Event Analysis |
| ADLB | Laboratory Analysis |
| ADVS | Vital Signs Analysis |
| ADTTE | Time-to-Event Analyses |
| ADPC | Pharmacokinetic Concentrations |
| ADPP | Pharmacodynamic Analyses |
Sponsors want assurance that every derivation follows CDISC standards and regulatory expectations.
They also want to understand whether reusable, validated programming standards are being used.
Question 2: Is the define.xml file accurate and complete?
A define.xml file acts as the metadata roadmap for a regulatory submission.
Regulators rely heavily on it.
A technically correct dataset submission can still generate regulatory questions if define.xml documentation is incomplete.
Table 4: Key components of define.xml
| Component | Purpose |
| Variable Metadata | Describes each variable |
| Controlled Terminology | Explains code lists |
| Computational Methods | Documents derivations |
| Value-Level Metadata | Explains parameter subsets |
| Origin Information | Identifies source data |
| Reviewer Comments | Supports reviewer understanding |
Sponsors typically ask:
- Are all variables described?
- Are computational algorithms documented?
- Are codelists correctly referenced?
- Are derivation methods traceable?
- Does the file validate against current standards?
A high-quality define.xml reduces review risks substantially.
Question 3: How is data traceability maintained?
Traceability is a cornerstone of regulatory compliance.
Regulators expect to trace any result back to its source.
A sponsor may ask:
"Can you demonstrate exactly how this efficacy endpoint was derived?"
The answer should always be yes.
Table 5: Data traceability flow in a clinical study
| Layer | Example |
| Source Data | CRF Blood Pressure |
| SDTM | VS Domain |
| ADaM | ADVS Dataset |
| Statistical Output | Change from Baseline Table |
| CSR | Clinical Study Report |
Table 6: Example of data traceability chain
| Variable | Source |
| AVAL | Derived Analysis Value |
| ABLFL | Baseline Flag |
| CHG | Change from Baseline |
| PCHG | Percent Change |
| TRTEMFL | Treatment Emergent Flag |
Every analysis variable should have documented lineage.
This is especially important during regulatory inspections.
Validation & Quality Control
Question 1: How are SAS programs validated?
Sponsors understandably place tremendous emphasis on validation.
A programming output is only valuable if it can be trusted.
Table 7: Common validation approaches in statistical programming
| Method | Description |
| Double Programming | Independent replication |
| Peer Review | Code review by second programmer |
| Log Review | Verification of execution logs |
| Dataset Validation | Dataset-by-dataset comparison |
| Output Validation | Table-by-table comparison |
Table 8: Relative effort of validation methods
| Method | Time Requirement | Risk Reduction |
| Manual Review | Low | Moderate |
| Peer Review | Moderate | High |
| Double Programming | High | Very High |
| Automated Validation | Moderate | Very High |
Double programming remains one of the most respected methods because two independent programmers produce the same result separately.
If both outputs match, confidence increases significantly.
Question 2: How are discrepancies between the Statistical Analysis Plan (SAP) and outputs resolved?
This question appears in nearly every study.
The SAP defines what analyses should be performed.
The statistical programming team implements those analyses.
Occasionally discrepancies emerge.
Table 9: Examples of discrepancies in statistical analyses
| Potential Discrepancy | Example |
| Population Definition | SAP differs from protocol |
| Endpoint Definition | Update after SAP finalization |
| Missing Data Rule | Unclear imputation guidance |
| Subgroup Analysis | Additional sponsor request |
| Statistical Method | Ambiguous methodology |
Table 10: Discrepancy resolution process
| Step | Activity |
| 1 | Identify discrepancy |
| 2 | Discuss with lead statistician |
| 3 | Assess protocol consistency |
| 4 | Document decision |
| 5 | Update specifications |
| 6 | Revalidate outputs |
Sponsors expect complete documentation of every decision.
Question 3: How are SAS logs and error/warning flags handled?
This is another very common audit question.
Every SAS log should be reviewed.
Table 11: SAS log review expectations
| Log Item | Required Action |
| ERROR | Must be resolved |
| WARNING | Investigate and document |
| Uninitialized Variable | Investigate |
| Data Conversion Note | Review impact |
| Missing Values Generated | Evaluate validity |
Table 12: Example log quality metrics
| Metric | Target |
| Errors | 0 |
| Unresolved Warnings | 0 |
| Critical Notes | 0 |
| Documented Exceptions | 100% |
Clean logs are a hallmark of mature programming teams.
Data Handling & Edge Cases
Question 1: How are missing data, partial dates, or imputed values handled?
Clinical trial data are rarely perfect.
Missing dates and incomplete information are common.
Sponsors want to know exactly how those situations are managed.
Table 13: Common partial date examples
| Reported Date | Issue |
| 2026-03-UN | Missing Day |
| 2026-UN-UN | Missing Month and Day |
| UN-UN-UN | Entire Date Missing |
Table 14: Common imputation methods
| Scenario | Possible Rule |
| Missing Day | First Day of Month |
| Missing Month | January |
| Missing AE Start Date | Conservative Treatment-Emergent Assumption |
| PK Missing Concentration | Protocol-Specific Handling |
Every imputation rule should be predefined.
Consistency is essential.
Question 2: How are adverse events (AEs), concomitant medications, or lab data anomalies managed?
This topic generates many sponsor questions.
Real-world clinical datasets contain complications.
Table 15: Typical data challenges
| Challenge | Example |
| Duplicate Records | Same event entered twice |
| Overlapping Events | Date collisions |
| Partial Dates | Missing onset dates |
| Coding Updates | MedDRA version changes |
| Blinded Data | Restricted access datasets |
Table 16: AE programming checks
| Validation Area | Example Check |
| Treatment Emergence | TRTEMFL logic |
| Severity | Missing grades |
| Relationship | Missing causality |
| Seriousness | SAE consistency |
| Coding Quality | MedDRA hierarchy review |
Laboratory data undergo similar validation.
Extreme values.
Duplicate visits.
Reference range changes.
Unit conversion discrepancies.
All require systematic review.
Efficiency & Deliverables
Question 1: Are macros and automated workflows modular and documented?
Sponsors increasingly evaluate programming infrastructure.
They do not simply review final deliverables.
They assess the programming environment itself.
Table 17: Characteristics of high-quality macros
| Characteristic | Benefit |
| Reusable | Faster development |
| Parameterized | Flexible execution |
| Validated | Lower risk |
| Documented | Easier maintenance |
| Version Controlled | Better compliance |
Table 18: Benefits of automation
| Benefit | Impact |
| Reduced Manual Steps | Fewer errors |
| Faster Turnaround | Better timelines |
| Standardized Outputs | Consistency |
| Improved Audit Readiness | Inspection support |
At Sofpromed, we strongly encourage standardized, reusable programming frameworks because they improve both quality and efficiency.
Question 2: How are TLFs formatted for review?
Sponsors spend enormous amounts of time reviewing Tables, Listings, and Figures.
Presentation quality matters.
Even perfectly correct results can slow review cycles if formatting is poor.
Table 19: Typical TLF deliverables
| Deliverable | Format |
| Tables | RTF, PDF |
| Listings | RTF, Excel |
| Figures | PDF, PNG |
| Patient Profiles | |
| Safety Reports | PDF, RTF |
Table 20: Key formatting requirements
| Area | Requirement |
| Fonts | Consistent corporate style |
| Pagination | Correct page numbering |
| Footnotes | Dynamic and accurate |
| Titles | SAP-compliant wording |
| Decimal Places | Statistical consistency |
Table 21: Common regulatory submission TLF characteristics
| Characteristic | Importance |
| Reproducibility | Critical |
| Consistency | Critical |
| Readability | High |
| Traceability | Critical |
| Auditability | Critical |
Modern SAS programming frequently uses PROC REPORT, ODS RTF, ODS PDF, and automated reporting frameworks to generate submission-ready outputs.
Conclusions
In my experience, sponsors are not simply hiring statistical programmers to write SAS code.
They are looking for regulatory partners.
They want confidence that their data can withstand regulatory review.
They want SDTM and ADaM datasets that follow CDISC standards.
They want traceability from source data to final outputs.
They want validated programs.
They want clean SAS logs.
They want high-quality Tables, Listings, and Figures.
Most importantly, they want a team that understands both statistics and regulatory science.
At Sofpromed, our statistical programming teams work alongside biostatisticians, clinical data managers, medical writers, and regulatory specialists to help sponsors achieve exactly that goal.
Whether the project is a Phase I oncology study, a rare disease program, a global Phase III trial, or an integrated submission package, the questions sponsors ask tend to be remarkably similar.
The difference lies in how effectively those questions are answered.
And that is where experienced statistical programming teams create real value for clinical trial sponsors.














