Scales of justice and legal book in courtroom
By Thomas Wicks

Global clinical trial disclosure is increasingly complex, especially as sponsors work to keep pace with country-specific regulations while maintaining consistent corporate standards. Biopharmaceutical companies often rely on local affiliates or clinical research organizations (CROs) for submissions, but this decentralized approach can create compliance blind spots and inefficiencies. Rather than imposing a centralized “command and control” system, sponsors can adopt a flexible but structured model that sets global requirements and governance while enabling local expertise to drive submissions. The following seven-step plan outlines a practical framework for harmonizing processes, ensuring compliance, and optimizing resource use—ultimately striking the right balance between centralized oversight and local autonomy.

The CLARITY Model is at the heart of this approach, a seven-step blueprint for building a robust yet agile disclosure function. Each letter represents a key pillar:

The CLARITY Model
Establish a global disclosure governance framework
  • Create a cross-functional governance body (such as a Disclosure Council or Center of Excellence) that sets minimum standards, policies, and KPIs for global disclosures. This body should:
    • Include representatives from key regions and functional areas (regulatory, clinical operations, legal, etc.)
    • Be responsible for interpreting global regulations (leveraging tools such as TrialScope Intelligence) and issuing clear guidance with standard operating procedures (SOPs), timelines, and templates)
    • Oversee consistency in how affiliates/CROs conduct disclosures — without micromanaging local operations
    • Conduct quarterly calls and offer newsletters or lunch-and-learns with affiliates/CROs to share updates/best practices and keep everyone aligned
    • Proactively identify potential disclosure risks (e.g., upcoming regulatory changes, areas of noncompliance) and develop mitigation strategies
  • Define global SOPs and local work instructions
    • A baseline global SOP for disclosure activities ensures uniform standards for key disclosure documents (e.g., protocol and results summaries, synopses, and lay summaries). Define standard workflows for review and approval, even if execution is partly local. This fosters consistency.
    • Allow affiliates/CROs to develop local work instructions reflecting country-specific requirements or registry nuances

Why it matters
A well-defined governance structure reduces confusion, accelerates decision-making, and promotes consistent, high-quality disclosures.

Implement a “hub-and-spoke” operating model
  • Responsibilities of the hub (central coordination):
    • Maintain the central knowledge repository, curated by the governance body, for disclosure requirements in every country where the organization conducts clinical trials)
    • Develop standardized templates, training materials, and checklists for local affiliates
    • Provide local affiliates and CROs with a single, pre-approved dataset covering the critical fields required by multiple registries to ensure consistency across disclosures
    • Track global disclosure timelines and performance metrics (e.g., compliance rates, quality metrics)
  • Responsibilities of the spokes (local affiliates/CROs)
    • Retain responsibility for day-to-day disclosure tasks in their respective jurisdictions
    • Escalate issues or uncertainties to the central governance body for resolution

Why it matters
This structure allows regional flexibility while preserving global standards and a unified oversight approach.

Define a clear RACI (responsible, accountable, consulted, informed) matrix
  • Responsibility allocation
    • Assign “responsible” roles at the local affiliate/CRO level for each regulatory submission or major milestone (e.g., registration, results posting, updates)
    • Ensure a designated “accountable” party within the corporate disclosure group who oversees compliance metrics globally
  • Consulted & informed
    • The governance body and relevant subject matter experts (e.g., medical writers, biostatisticians) should be consulted.
    • Senior management and quality assurance should remain informed of critical milestones, issues, or risk areas.

Why it matters
Clarity in roles eliminates duplication of effort, fosters accountability and supports seamless collaboration with external partners

Step-by-step Approach for best results
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  • Phase 1: Establish baseline & quick wins
    • Roll out consistent SOPs, training, and a simplified global tracker
    • Focus on high-volume or high-risk countries first
    • Distribute approved standard disclosure datasets based on the World Health Organization (WHO) trial registration dataset and the ICHe3 results synopsis and include links to disclosed data on ClinicalTrials.gov or the Clinical Trials Information System (CTIS) if available
  • Phase 2: Strengthen oversight & analytics
    • Enhance reporting capabilities (compliance dashboards, escalation triggers)
    • Collect data on adherence to timelines and quality to identify gaps
  • Phase 3: Optimize & scale
    • Integrate advanced automation where possible (e.g., structured data uploads and automated compliance alerts)
    • Implement ongoing process improvements based on feedback and audit findings

Why it matters
By identifying quick wins and scaling gradually, organizations can maintain stakeholder buy-in, build internal capability, and course correct before full global adoption.

Leverage an integrated technology platform
  • Centralized tracking & documentation
    • Even if local teams complete the submissions, deploy a single global tracking platform (or extend your existing system, e.g., TrialScope Disclose) for real-time updates and oversight
    • Maintain a standardized data collection form within the disclosure platform to automate data entry and reporting for major registries
    • Store documents (e.g., submission confirmations, approval notices, or PDF copies of the registry records) in a unified, auditable repository accessible to all stakeholders
  • Role-based access & permissions
    • Assign different permission levels so local teams and CROs can manage their disclosures without accessing sensitive data or losing central visibility
    • Enable central staff to monitor deadlines, compliance statuses, and submission completeness
  • Modular configuration
    • Configure the system with region-specific modules or workflows so local affiliates see only what is relevant for their jurisdiction while the core functionality and data remain standardized

Why it matters
By centralizing data and workflows on a unified platform, organizations minimize duplicative tasks, enhance data consistency and accuracy, and maintain real-time visibility across all affiliates and CROs.

Standardize training & continuous engagement
  • Training curriculum & certifications
    • Develop and deliver a structured training curriculum (e.g., e-learning, periodic “lunch-and-learn” sessions) to ensure consistent knowledge of global and local disclosure requirements.
    • Offer “certification” for affiliates and CROs—reinforcing competence and accountability.
  • Regular touchpoints & feedback loops
    • Host quarterly or semi-annual meetings with affiliates to review updates in disclosure regulations, share best practices, and discuss lessons learned.
    • Conduct feedback sessions to capture local challenges early, allowing central teams to update SOPs or training materials.

Why it matters
A culture of compliance, bolstered by strong leadership support and shared success, drives consistent quality and continuous improvement across geographies.

Conduct periodic audits & quality checks
  • Global & local audits
    • Perform periodic internal audits of selected disclosures to ensure consistency and accuracy
    • Where CROs are involved, include disclosure compliance and the accuracy of standard data usage as key performance indicators in contract evaluations and renewal decisions
    • Involve central quality assurance (QA) teams and local representatives to collaborate on corrective actions
  • Performance metrics
    • Track metrics such as on-time disclosure and the number of findings from internal audits or inspections
    • Use these insights to refine training, update SOPs, and recalibrate roles or responsibilities

Why it matters
Regular quality checks maintain ongoing vigilance, quickly detect gaps or inaccuracies, and foster a culture of accountability within both the central team and external partners.

By following these principles, organizations can unify their global disclosure strategy while respecting local nuances. The CLARITY Model establishes a clear governance framework, empowers affiliates and CROs, outlines practical steps to enhance or implement technology, and ensures continuous training and auditing to maintain high-quality clinical trial disclosures worldwide.



Implementation timeline

Transitioning from a decentralized approach to a centrally coordinated disclosure requires a high-level plan. Below is a proposed nine-month roadmap outlining the key milestones and tasks required to transition from a decentralized clinical trial disclosure approach to a centrally coordinated model. Divided into distinct phases, from governance and SOP revisions through technology deployment and performance measurement, this timeline provides a structured blueprint for organizations looking to improve consistency, reduce compliance risks, and streamline the disclosure process across all regions.

Phase 1 (months 1–2): Strategy & governance
Goal: Establish the foundation for a centralized model
  • Form a disclosure governance body (center of excellence)
    • Identify cross-functional stakeholders (regulatory, clinical, IT, legal, etc.)
    • Assign clear roles, responsibilities, and project leadership
  • Conduct current-state assessment
    • Review existing SOPs, tools, and responsibilities for each affiliate/CRO
    • Pinpoint critical gaps in compliance, data consistency, or technology usage
  • Define project scope & objectives
    • Outline what “centrally coordinated” means for your organization (e.g., specific SOPs, technology changes, compliance metrics)
    • Draft a high-level change management plan to align teams on upcoming transitions
Phase 2 (months 3–4): SOP refinement & contract updates
Goal: Create standardized processes and formalize partnerships
  • Update or draft new global SOPs
    • Incorporate standardized datasets, training requirements, and escalation pathways
    • Allow local affiliates to add country-specific work instructions where needed
  • Revise contracts & expectations with CROs
    • Add explicit disclosure timelines, reporting obligations, and quality/compliance metrics
    • Clearly define which party (sponsor vs. CRO) handles specific tasks (e.g., data entry, results posting, etc.)
  • Identify & configure technology needs
    • Implement or upgrade existing solutions (e.g., expanded use of TrialScope Disclose and TrialScope Intelligence) or add new data integrations
    • Define core data fields and reporting workflows for local affiliates
Phase 3 (months 5–6): Pilot & training
Goal: Test the new framework and prepare teams for broader adoption
  • Select a pilot region or therapeutic area
    • Test updated SOPs, technology tools, and contract language on a smaller scale to gather feedback
    • Track key performance indicators (e.g., on-time disclosures, data accuracy)
  • Deliver targeted training
    • Roll out foundational training for affiliates and CROs (SOP changes, contract terms, new technology features)
    • Provide “train-the-trainer” sessions for local/regional champions who will support the rollout
  • Collect feedback & refine
    • Host debrief sessions to identify what worked or needs adjustment
    • Update SOPs, training materials, and system configurations before the global launch
Phase 4 (months 7–9): Full rollout & system integration
Goal: Deploy the centrally coordinated model across all regions
  • Global technology deployment
    • Launch the integrated platform or expanded system modules globally (role-based access, dashboards, automated reminders)
    • Ensure local affiliates and CROs have secure logins and the final data collection forms, such as the TrialScope Core Disclosure Form
  • Implement updated SOPs & contracts
    • Enforce new or revised contracts, ensuring that disclosure timelines and responsibilities are clear
    • Monitor any local affiliate or CRO issues that surface and troubleshoot promptly
  • Maintain ongoing communication & support
    • Conduct regular project status calls to address questions and reinforce best practices
    • Maintain a helpdesk or designated support contact for quick issue resolution
Phase 5 (post implementation): Optimization & measurement
Goal: Establish continuous improvement and measure early outcomes
  • Conduct initial audits & quality checks
    • Review a sample of newly completed disclosures to gauge compliance, data accuracy, and on-time posting
    • Use this data to pinpoint persistent gaps or training needs
  • Measure key metrics
    • Compare actual performance to baseline (e.g., on-time disclosure rates, error rates, etc.)
    • Share findings with senior leadership and local teams to reinforce accountability
  • Refine & scale
    • Based on audit results, refine SOPs, training materials, or technology configurations
    • Plan further enhancements (e.g., automated data integrations, advanced analytics) in the next iteration

This timeline can be accelerated or stretched depending on the organization's size, available resources, and the urgency of managing compliance. However long the transition is planned for, by dividing the transition into clear phases and milestones, sponsors can gradually align teams, reinforce best practices, and successfully operationalize a centrally coordinated clinical trial disclosure model.


Looking Ahead

Organizations can incrementally evolve their disclosure practices by combining a robust governance structure with a pragmatic “hub-and-spoke” model, balancing local autonomy with global standards. Strengthened by global SOPs and technology (deployed in phased, manageable increments) and a supportive culture of compliance and accountability, sponsors can achieve timely, accurate, and consistent global clinical trial disclosures. Distributing approved standard datasets further aligns disclosure across all regions, protecting company confidential information (CCI) and patents while driving high-quality, transparent reporting for stakeholders worldwide. This approach leverages the expertise of local teams while unifying compliance strategy under a cohesive, enterprise-wide framework.

With the CLARITY Model — Central governance, Local empowerment, Accountability & SOPs, Roadmap for improvement, Integrated technology, Training & culture, and Year-round oversight — organizations can solidify a global disclosure strategy that harmonizes compliance requirements with the agility of local affiliates.


Next Steps

While the CLARITY Model and implementation roadmap offer a practical path toward centralized clinical trial disclosure, organizations vary in starting points and specific needs. Understanding where you fall on the “maturity” continuum helps you tailor these strategies effectively and measure progress over time. Here are a few ways to dive deeper and act:

  1. Download our free eBook on the clinical trial disclosure maturity model
    Gain a detailed overview of the key stages organizations typically move through when evolving their disclosure processes, from ad-hoc local submissions to fully integrated global oversight. You’ll see how the CLARITY Model aligns with — and accelerates —each stage of maturity.
  2. Take our free disclosure maturity self-assessment
    Discover your current level of disclosure maturity and identify the next steps needed to advance. This assessment pinpoints gaps and strengths and recommends tactics for improving central coordination.
  3. Contact me for further guidance
    Every organization’s situation is unique. Feel free to reach out if you’d like to discuss your specific challenges or explore how we can help implement a centrally coordinated framework. I’m happy to offer tailored insights and strategies.

 

About the author

Headshot of Thomas Wicks.

Thomas Wicks

Head of Transparency Operations, Citeline

ライフサイエンス分野で20年以上の経験を持つ戦略リーダーであり、現在はCitelineの透明性業務責任者を務めています。業界をリードするTrialScopeの情報開示ソリューションの戦略を指揮し、透明性に関する深い知識と実績を持っています。

トーマスは、情報開示要件や透明性のトレンドについてのオピニオンリーダーとしても高く評価されており、これまでに60以上のカンファレンスで講演し、40以上の出版物を執筆しています。また、裁判の透明性を尊重するソリューションを加速させることを使命とし、チームに力を与えることに情熱を注いでいます。

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