Trial-Termination Early-Warning — live risk dashboard

Three tiers of early-termination risk, monitored continuously. The AI detects, aggregates, and triages signals and drafts the alert; the SRC / DSMB / medical monitor, the PM, and the account lead make every call. Rows marked ADV come from the advanced engine — Optimal Transport (Wasserstein drift) and nested Active Inference (free-energy surprise) — which surfaces risk continuously and earlier than a threshold rule. Values below are illustrative.

PARTICIPANTAMBER
DLTs · safety · PK exposure · 17 signals monitored
S-1042 — candidate Hy's-Law / DILI: ALT 3.4× ULN + total bili 2.1× ULN (DLT window, day 9)
S-1039 — ΔQTcF +48 ms (watch >30, alert >60 ms)
Cohort 4 — within-participant AE cluster trending Grade 2 → 3
⊳ free-energy spike on S-1042 since day 7 — EFE recommends an unscheduled LFT ADV
On-device local LLM · zero egress
STUDYAMBER
Dose-escalation · enrollment · QTLs · 29 signals monitored
Cohort 4 DLT rate 1/6 — within the 3+3 escalation rule
Screen-failure 38% vs 25% plan — enrollment KRI breached
Safety QTL (SAE rate) — within tolerance limit
⊳ Wasserstein drift of cohort LFT distribution ↑ vs reference barycenter (tail mass moving) ADV
Cloud Claude (aggregate) + on-device drill-down
CLIENT / SPONSORAMBER
Commercial early-warning · 19 signals monitored
AR: $420K > 60 days past due — payment-aging breach
Sponsor comms cadence −40% MoM — relationship watch
2 scope-reduction change-orders this quarter
⊳ sponsor-behavior Wasserstein drift ↑ vs baseline — relationship cooling ADV
Cloud Claude · CRM / finance / public filings

Early-warning feed

09:12PARTICIPANTS-1042 candidate Hy's-Law signal — flagged on-device, medical monitor + SRC notified, expedited-reporting clock started
08:55PARTICIPANT⊳ Active-inference free-energy on S-1042 elevated since day 7 — EFE recommends an unscheduled LFT (medical-monitor approval pending) ADV
08:40STUDYScreen-failure KRI breached (38% vs 25%) — PM notified; feasibility review proposed
08:05STUDY⊳ Wasserstein drift of the cohort-4 LFT distribution rising vs the pooled reference — transport map points to the upper tail ADV
Yest 16:05CLIENTAR > 60 days breach ($420K) — account lead alerted; finance escalation drafted
Yest 11:20PARTICIPANTS-1039 ΔQTcF +48 ms — intensified ECG monitoring flagged to medical monitor
2 d agoSTUDYCohort 4 cleared the 3+3 rule (1/6 DLT) — SRC packet pre-assembled
termination-level risk   watch / precursor   within limits   |   On-device participant-level safety/PK, zero egress   Cloud Claude non-sensitive ops/commercial   |   ADV = continuous / anticipatory signal from the advanced engine (Optimal Transport + Active Inference)

The hybrid architecture

Sensitivity decides the engine. Participant-level safety, PK, and unblinded data never leave the device — they run on a local LLM. Non-sensitive operational and commercial signals run on cloud Claude (API + BAA). A scoring layer rolls signals up to a tier RAG status; humans own every decision.

Data sourcesEDC / validated safety DB · central lab (LFTs) · ECG · IXRS · CTMS · Smartsheet · finance/AR · CRM · sponsor comms · web (public filings)
↓
Routing by data sensitivityparticipant-level safety / PK / unblinded → on-device · non-sensitive ops / commercial → cloud
On-device local LLMparticipant safety/PK signals — zero egress, Part-11 audited
Cloud Claude (API + BAA)study-ops KRIs & client/commercial signals — under BAA
↓
Advanced engine — Optimal Transport + nested Active Inferenceruns inside each tier (on-device for participant-level): Wasserstein drift vs a pooled reference, and active-inference free-energy / EFE — continuous, anticipatory, geometry-aware signals on top of the rule-based KRIs. How it works →
↓
Scoring & aggregationweighted KRIs / stopping rules roll individual signals up to a Participant / Study / Client RAG status — not an autonomous verdict
↓
Alert & escalationsafety → medical monitor / SRC / DSMB · study → PM · client → account lead — with a human-acknowledgement & disposition log
The rule. The AI flags and prepares; validated tools and humans decide. Reported safety numbers come from the validated safety database, never the LLM. The medical monitor / SRC / DSMB make every DLT and safety determination; the PM owns the study; the account lead owns the client signal.

Participant-level signals

All 17 are participant-level safety/PK — processed on-device, zero egress. The AI flags candidate DLTs and safety patterns early, before the formal cohort review, and pre-assembles the SRC packet. It never adjudicates the DLT.
SignalDetection (what the AI does vs. validated/human)EngineThreshold / KRIEscalation
Candidate DLT in the DLT-evaluation window
Safety
RED - a confirmed DLT can halt escalation, define the MTD early, or terminate the dose level/cohort
Rule-based: local LLM matches AE grade/term/onset-day/attribution against the prespecified DLT criteria for the assigned dose and flags candidate DLTs in near-real-time; it pre-assembles the case narrative and the running cohort DLT tally for the SRC. The validated safety DB holds the authoritative numbers; the LLM never adjudicates.
src: Validated safety DB + EDC AE/CM eCRF; IXRS for dose/cohort assignment; protocol DLT-criteria table
On-deviceAny AE meeting the protocol DLT definition (e.g. Grade >=3 non-heme, Grade 4 heme, febrile neutropenia, or any individual-stopping-rule AE) within the DLT window for that dose; design-specific (3+3 / BOIN / mTPI-2 / CRM / accelerated titration)Immediate flag to medical monitor and SRC/SMC chair ahead of the formal cohort review; pause further dosing/escalation per protocol pending adjudication
Sentinel-participant adverse response (FIH)
Safety
RED - blocks cohort dosing and can stop the dose level / escalation
Rule-based + model-assisted: local LLM watches sentinel-participant AE/vital/lab streams against the cohort-release criteria and raises a stop-the-cohort flag the moment a sentinel breach appears, before remaining participants are dosed.
src: Validated safety DB + EDC; bedside vitals/telemetry; IXRS sentinel flag; protocol sentinel-dosing rule
On-deviceAny clinically significant AE / vital-sign / lab change in a sentinel participant within the protocol sentinel window that breaches the cohort-release criteriaHalt dosing of remaining cohort participants; notify PI and medical monitor immediately; convene SRC before proceeding
SAE / death / life-threatening event
Safety
RED - a related/unexpected SAE or death can stop the dose level or terminate the study
Rule-based: local LLM detects seriousness criteria / Grade 4-5 / fatal outcome on entry, drafts the expedited-reporting case summary and links it to dose, exposure, and concomitant meds for the medical monitor. Authoritative seriousness/causality determination is human + validated PV system.
src: Validated safety DB (SAE form) + EDC; PV intake
On-deviceAny SAE, death, or life-threatening (Grade 4/5) event regardless of attributionImmediate medical-monitor and SRC notification; feeds SUSAR/expedited-reporting clock; sponsor + PV informed
Individual AE cluster / severity-grade escalation
Safety
AMBER - precursor pattern; can convert to a DLT and gate escalation
Model-assisted: local LLM trends each participant's AE grades over time, clusters related MedDRA terms, and surfaces an upward severity trajectory before any single event crosses the DLT line. Triage/explanation only; no decision.
src: Validated safety DB + EDC longitudinal AE records (by MedDRA SOC/PT)
On-deviceGrade escalation across visits for the same PT, or >=2-3 related AEs clustering in one participant, trending toward a DLT-defining gradeEarly heads-up to medical monitor and SRC ahead of the cohort review; flag participant for intensified monitoring
Hy's Law / drug-induced liver injury signal
Safety
RED - a Hy's-Law case is a serious DILI signal that can stop dosing for the participant and the program
Rule-based (eDISH logic): local LLM evaluates ALT/AST, total bilirubin, ALP against ULN multiples per participant, flags Hy's-Law pattern and component breaches, and assembles the eDISH plot context. Confirmatory repeat-test and adjudication are human + validated lab/safety DB.
src: Central-lab LFT feed (ALT, AST, total bilirubin, ALP) + EDC; baseline normals
On-deviceALT or AST >3x ULN AND total bilirubin >2x ULN AND ALP <2x ULN with no alternative cause (Hy's Law); component watch-flags at ALT >3x/5x/8x ULNUrgent medical-monitor alert; close monitoring / repeat LFTs per protocol; participant stopping rule and SRC review
QTcF prolongation / ECG abnormality
Safety
RED at >500 ms / >60 ms delta (potential individual stopping rule and escalation halt); AMBER at watch thresholds
Rule-based per ICH E14: local LLM compares QTcF and delta-QTcF against thresholds, flags new arrhythmia / conduction change, and links the finding to PK exposure timing. Cardiologist/core-lab read is authoritative.
src: Central ECG core-lab feed (QTcF, PR, QRS, morphology) + EDC; baseline ECG
On-deviceQTcF >500 ms OR delta-QTcF >60 ms from baseline (watch at >450/480 ms or delta >30 ms); new clinically significant arrhythmia or >25% PR/QRS changeAlert medical monitor / cardiac safety reviewer; participant ECG stopping rule; SRC review before next dose
PK exposure outlier vs safety-margin / NOAEL cap
PK-PD
AMBER/RED - overexposure can gate escalation and trigger early dose-cap or stopping
Statistical: local LLM screens each participant's Cmax/AUC against the prespecified exposure cap and against the cohort distribution (outlier detection), flagging supratherapeutic exposure even before an AE manifests. Validated PK software/pharmacometrician owns the formal NCA values.
src: Bioanalytical/PK dataset (Cmax, AUC) + EDC dosing; NOAEL-scaled exposure cap from the IB/preclinical package
On-deviceIndividual Cmax or AUC exceeding the NOAEL-scaled safety-margin cap, or a statistical outlier vs cohort (e.g. > predefined SD/percentile)Flag to clinical pharmacologist / medical monitor and SRC; informs go/no-go on the next dose level
Unexpected accumulation across MAD dosing
PK-PD
AMBER - can force regimen change or stop the MAD cohort
Statistical: local LLM tracks each participant's trough/exposure trajectory and accumulation ratio (Racc) against the model-predicted ratio, flagging nonlinear or supra-predicted accumulation that raises steady-state safety risk.
src: Bioanalytical/PK trough + profile data across dosing days + EDC; predicted accumulation ratio from SAD/modeling
On-deviceObserved accumulation ratio exceeding the predicted Racc by the prespecified margin, or rising troughs without plateau (nonlinear PK)Alert pharmacometrician / medical monitor; reassess MAD dose/regimen and steady-state exposure cap with SRC
Vital-sign / hemodynamic event
Safety
AMBER/RED depending on severity and recurrence; can trigger individual stopping and inform cohort review
Rule-based + model-assisted: local LLM compares vitals against protocol alert bands and baseline, detects post-dose hemodynamic shifts time-locked to dosing, and surfaces the trend for the medical monitor.
src: EDC vitals + bedside telemetry/orthostatics; validated safety DB
On-deviceVital signs breaching protocol clinically-significant thresholds (e.g. SBP <90 / >180 mmHg, HR <40 / >120 bpm, SpO2 <92%, temp >=38.5C) or a protocol vital-sign stopping ruleNotify PI / medical monitor; apply participant stopping rule; SRC review if recurrent across the cohort
Immunogenicity / infusion (hypersensitivity) reaction
Safety
RED for anaphylaxis/severe reaction (participant stop + program signal); AMBER for milder/asymptomatic ADA
Rule-based: local LLM flags reactions time-locked to infusion (rash, bronchospasm, hypotension, fever) and links emerging ADA-positive results to clinical events; assembles the case for review.
src: EDC AE + infusion-reaction CRF; central-lab ADA/immunogenicity assay; validated safety DB
On-deviceGrade >=2 infusion/hypersensitivity reaction, anaphylaxis (any grade), or treatment-emergent ADA positivity associated with a clinical event or PK lossImmediate medical-monitor alert; premedication/rate-change or stop per protocol; SRC review
Individual protocol stopping-criteria breach
Safety
RED for the participant; contributes to cohort-level escalation decision
Rule-based: local LLM continuously evaluates each participant's safety data against the full protocol individual-stopping-criteria checklist and fires the moment any single criterion is met, regardless of whether it also qualifies as a DLT.
src: EDC + validated safety DB + labs/ECG/vitals; protocol individual-stopping-rule table
On-deviceAny breach of the protocol-defined individual stopping/withdrawal criteria (the specific lab/ECG/vital/AE limits listed in the protocol)Immediate flag to PI / medical monitor; stop that participant's dosing per protocol; document and inform SRC
Participant withdrawal / dropout / early discontinuation
Operational
AMBER - threatens cohort decision validity and can delay or invalidate the dose-level call
Rule-based: local LLM tracks disposition vs the DLT window and flags participants who become non-DLT-evaluable (incomplete window), which can require replacement to keep the cohort decision valid.
src: EDC disposition/EOT records; IXRS; visit-attendance data
On-deviceWithdrawal / discontinuation / lost-to-follow-up before completing the DLT-evaluation window, dropping evaluable n below the design requirementAlert PM and medical monitor; trigger participant replacement per protocol to preserve cohort DLT-evaluability
Dosing non-compliance / PK-affecting deviation
Quality
AMBER - affects data integrity and can confound the dose-level safety/PK decision
Rule-based + model-assisted: local LLM cross-checks actual vs planned dose, timing, and sampling windows, flags non-compliance and deviations that affect exposure or DLT attribution, and drafts the deviation note.
src: EDC dose-administration + deviation log; eCRF; bioanalytical sampling-time records
On-deviceAny dosing deviation (wrong dose/time/route, missed/double dose) or sampling-window breach that affects safety or PK evaluability of the participantFlag to PM / medical monitor and clinical pharmacologist; assess impact on DLT-evaluability and exposure; log deviation
Eligibility violation / enrolled-in-error
Quality
AMBER/RED - a safety-relevant eligibility breach can require participant withdrawal and signals site/quality risk
Rule-based: local LLM re-checks screening data and post-enrollment findings against the I/E criteria and flags eligibility violations in already-dosed participants (e.g. a screening lab/ECG/medical-history exclusion missed at enrollment).
src: EDC screening/eligibility eCRF; central-lab screening labs; medical history
On-deviceConfirmed inclusion/exclusion breach in an enrolled-and-dosed participant (e.g. exclusionary lab/ECG/comorbidity/con-med present at dosing)Immediate notification to PI / medical monitor; protocol-deviation report; assess participant safety and DLT-evaluability impact; SRC awareness
Wasserstein drift vs pooled reference ADV
OT · drift
AMBER — continuous precursor, earlier than a threshold rule
Optimal Transport: (sliced-)Wasserstein distance, participant vs reference; the transport map localizes WHICH grades/exposures drive the shift. Decision-support — flags for review, makes no determination.
src: central-lab / ECG / PK streams (on-device)
On-deviceW-distance leaves its control band, trending toward worsening (complements the rule-based DLT/Hy's-Law triggers)Early flag to medical monitor; intensify monitoring on the implicated measures
Free-energy spike (participant generative model) ADV
Active inference
AMBER — anticipatory deviation signal
Active inference: variational free energy (negative log model-evidence), precision-weighted per participant. Decision-support only.
src: participant safety/PK observations (on-device)
On-deviceFree-energy exceeds its rolling bandFlag for medical-monitor review; raise the participant's monitoring precision
EFE-recommended monitoring action (active sampling) ADV
Active inference
AMBER — proactive monitoring recommendation
Active inference EFE = epistemic (information-gain) + pragmatic (reach the preferred/safe state) value. A SUGGESTION for human approval — never an autonomous clinical or dosing action.
src: participant state + protocol-allowed assessments
On-deviceEFE-optimal action exceeds a value-of-information thresholdRecommend the data-collection action to the medical monitor for approval

Study-level signals

29 signals: the dose-escalation stopping rules, enrollment/feasibility KRIs, safety QTLs (ICH E6(R3)), data-quality and operational risk. Aggregate, de-identified KRIs run on cloud Claude; any participant-level drill-down stays on-device.

SignalDetection (what the AI does vs. validated/human)EngineThreshold / KRIEscalation
Cohort DLT rate breaches dose-escalation stopping/de-escalation rule
Safety
RED — direct excess-toxicity termination / early-MTD risk; highest-priority safety stop signal
Rule-based (3+3: ≥2/3 or ≥2/6 DLTs) or model-assisted (BOIN/mTPI-2/CRM boundary table; Bayesian early-stop Pr(tox at lowest dose>target)>0.95). The VALIDATED tool computes the rate and boundary; the local LLM only flags that a boundary is approaching/met, drafts the SRC pre-read, and explains contributing cases — it never declares the DLT or the stop.
src: Validated dose-escalation tool fed by the safety database + DLT adjudication log; EDC/eCRF DLT window data
On-deviceDLT count at dose ≥ the design's de-escalation/elimination/stop boundary, or Bayesian stop probability exceeded; also an 'amber' pre-alert at one DLT short of boundaryImmediate escalation to SRC/SMC and medical monitor for the dose-escalation decision (hold escalation / de-escalate / declare MTD / stop); DSMB notified
Aggregate AE/SAE rate vs background/expected
Safety
RED/AMBER — emerging-safety-profile deterioration; potential safety termination
Statistical trend test (observed-vs-expected, CUSUM/Poisson rate comparison) by the validated safety analytics; local LLM aggregates, narrates the emerging-profile shift and drafts the benefit-risk pre-read. Reported counts always come from the validated safety DB, never the LLM.
src: Validated safety database (aggregate); MedDRA-coded AE tables; IB/background reference rates
On-deviceAggregate SAE/AE rate exceeding the protocol/charter expected band or a significant upward CUSUM signal vs prior cohorts/backgroundEscalate to medical monitor / SRC / DSMB and pharmacovigilance for benefit-risk review
Cohort lab / ECG (QTcF) shift
Safety
AMBER/RED — organ-toxicity or cardiac-safety signal that can halt escalation
Statistical: cohort mean shift, proportion above CTCAE/regulatory thresholds (e.g., QTcF >450/480/500 ms, ΔQTcF >60 ms), Hy's-Law-pattern aggregation. Validated lab/ECG analytics compute; local LLM clusters and explains the dose-response trend.
src: Central-lab feed + ECG core-lab (validated), aggregated by cohort/dose
On-deviceCohort proportion or mean exceeding pre-defined organ-safety/QTcF thresholds, or a dose-response trend across cohortsEscalate to medical monitor / SRC / DSMB; cardiac-safety or hepatic-safety review
Safety Quality Tolerance Limit (QTL) breach
Quality
AMBER — systemic data-reliability/safety-quality risk; reputational + reliability termination risk
Rule-based threshold crossing per the ICH E6(R3) RBQM plan; cloud Claude flags the breach, drafts the documented root-cause/CAPA narrative and routes it. QTL is a quality trigger, not an auto-stop.
src: Aggregate EDC + safety DB QTL metrics; RBQM/CSM platform (de-identified)
Cloud ClaudeQTL parameter outside its pre-specified acceptable range (with secondary/warning limit for early alert)Escalate to PM / quality lead / sponsor for root-cause assessment and possible protocol/process change; document per E6(R3)
Enrollment lag vs plan (recruitment KRI)
Enrollment
AMBER — feasibility & timeline termination risk
Rule-based actual-vs-planned variance + trend/forecast; cloud Claude computes the gap, projects completion date and drafts the recruitment-risk brief.
src: CTMS / IXRS-IWRS enrollment feed; recruitment plan (de-identified counts)
Cloud ClaudeCumulative enrollment < X% of plan for ≥N weeks, or projected last-participant-in slips past the critical-path milestoneEscalate to PM and sponsor; feasibility/site-add or de-scope discussion
Screen-failure / screen-to-enrollment ratio breach
Enrollment
AMBER — feasibility / cost-overrun termination risk
Rule-based ratio vs assumption + trend; cloud Claude trends the ratio and identifies driving eligibility criteria from de-identified screen-fail reasons.
src: CTMS / EDC screening logs; IXRS (de-identified aggregate ratios)
Cloud ClaudeScreen-failure rate above the protocol-assumed band, or worsening trend across cohortsEscalate to PM / medical monitor; consider protocol amendment to eligibility
Futility / low probability of meeting the primary objective
Operational
RED/AMBER — futility / program non-viability termination risk
Model-assisted: dose-escalation model projection / conditional-power / predictive-probability from the validated tool; local LLM narrates the futility scenario where participant-level exposure/safety is involved.
src: Validated dose-escalation model + PK exposure summaries; SAP interim analysis (de-identified projections)
On-devicePredicted primary-objective success below the pre-specified futility bound, or MTD/exposure trajectory off-targetEscalate to DSMB/SRC and sponsor for futility/continue decision
Query rate & query-aging KRI
Quality
GREEN/AMBER — data-quality & lock-timeline risk
Rule-based KRI thresholds + aging buckets; cloud Claude trends rate/aging by site and drafts the data-management escalation.
src: EDC query management (de-identified aggregate metrics)
Cloud ClaudeQuery rate above KRI limit or % queries open >X days above threshold / rising trendEscalate to data management lead / PM; site follow-up
Missing-data & overdue-CRF trend
Quality
AMBER — reliability & lock-timeline risk
Rule-based completeness KRI + trend; cloud Claude flags critical-variable gaps and drafts the completeness alert.
src: EDC completeness metrics (de-identified aggregate)
Cloud ClaudeMissing critical-data % or data-entry lag above KRI limit / upward trend; ties to a safety QTL when criticalEscalate to data management / PM; if safety-critical, medical monitor
Protocol-deviation rate & trend
Quality
AMBER/RED — GCP-conduct & reliability termination risk
Rule-based KRI + trend with severity weighting; cloud Claude trends and clusters deviation types, drafts the GCP-risk brief. Important-deviation clustering can feed a QTL.
src: CTMS / EDC deviation log (de-identified aggregate; severity-coded)
Cloud ClaudeCritical/important deviation rate above KRI limit or rising trend, or a single critical safety deviationEscalate to PM / quality / medical monitor; CAPA, possible for-cause review
IXRS / randomization & drug-assignment integrity
Operational
AMBER/RED — integrity & safety termination risk
Rule-based anomaly detection on transactions; cloud Claude flags aggregate error trend, local LLM handles any participant-level/unblinding drill-down.
src: IXRS/IWRS transaction logs + drug-accountability (de-identified aggregate; participant-level for the specific event)
On-deviceAny unblinding/wrong-dose dispensing event, or IXRS error rate above thresholdEscalate to PM / medical monitor (safety) and quality; possible for-cause
Central statistical-monitoring data-integrity anomaly
Quality
AMBER/RED — data-integrity / fraud termination & reliability risk
Statistical (validated CSM): unsupervised multivariate tests, digit-preference & variance tests, site-outlier profiling. The CSM tool computes the signal; cloud Claude narrates and prioritizes the flagged sites, drafts the central-monitoring report — it does not adjudicate fraud.
src: RBQM/CSM platform over all EDC data (validated statistical engine; de-identified aggregate site profiles)
Cloud ClaudeCSM anomaly score / p-value past the platform threshold for a site or variable cluster; under-reporting flag vs study meanEscalate to quality / biostatistics / PM; targeted SDV or for-cause audit
Site / operational performance outlier
Operational
AMBER — site-conduct & reliability risk
Model-assisted site-profiling / weighted composite KRI ranking; cloud Claude ranks sites, explains the driving metrics, drafts the site-management plan.
src: CTMS + EDC + IXRS composite site scorecard (de-identified aggregate)
Cloud ClaudeComposite site-risk score above threshold or KRI breaches on ≥N metricsEscalate to PM / CRA lead; targeted monitoring, retraining, or site closure
Timeline slip & budget-burn vs milestones
Financial
AMBER — timeline & cost termination/de-scope risk
Rule-based earned-value / schedule-variance + forecast; cloud Claude computes schedule & cost variance, projects end-date and burn, drafts the program-risk brief.
src: CTMS / Smartsheet project plan + finance (de-identified milestone & cost metrics)
Cloud ClaudeCritical milestone forecast past baseline by >X, or cost-to-progress variance beyond thresholdEscalate to PM / program lead and sponsor; replan / change-order discussion
SUSAR / expedited-reporting clock breach
Pharmacovigilance / regulatory timeliness
Critical
Clock countdown vs 7/15-day deadline; backlog of un-reconciled serious events pending causality/expectedness assessment
src: Safety database / PV system (validated); investigator awareness timestamps
On-deviceAlert at T-minus-X days before 7- or 15-day deadline; any breach = criticalDraft expedited-report status alert to PV/medical monitor and regulatory; never auto-submit or auto-assess causality
Clinical hold / partial hold / IND safety-report regulatory action
Regulatory standing
Critical
Detect hold notice receipt; or aggregate-serious-event pattern crossing IND-safety-report logic
src: Regulatory correspondence inbox, FDA/agency portals, sponsor regulatory team; safety aggregate from validated DB
On-deviceAny hold/partial-hold = critical; aggregate pattern = warning to medical monitorDraft regulatory-action alert; flag dosing-pause implications; humans own filing and hold response
DSMB / IDMC / SRC recommendation-to-stop or pause
Safety-governance decision
Critical
Recommendation = stop/pause/modify/hold-escalation; or sponsor non-adoption of a safety recommendation
src: DSMB/IDMC charter outputs, SRC minutes, recommendation letters
On-deviceAny stop/pause recommendation = critical; modify/no-escalate = warningDraft governance-recommendation alert and route to PM/sponsor; committee owns the recommendation, sponsor owns the decision
DSMB/SRC meeting-cadence & dose-escalation-decision data-package readiness
Safety-governance operations
Warning
Days-to-meeting vs data-readiness; missed/no-quorum meeting; package incompleteness at the gate
src: Committee charter cadence, meeting scheduler, data-cleaning/lock status of the cohort package
On-devicePackage not ready by T-minus-N business days = warning; missed gating meeting = critical (blocks escalation)Draft readiness/cadence alert to data management and PM; humans schedule and decide
Aggregate benefit-risk / emerging-safety-profile shift (DSUR-style)
Aggregate safety surveillance
Warning
Disproportionality / trend on cumulative MedDRA-coded events vs prior cohorts and reference; central-tendency drift
src: Validated safety database, central labs/ECG, cumulative exposure
On-deviceStatistically/clinically meaningful upward shift in a term cluster or organ systemDraft emerging-profile summary for medical monitor / aggregate-safety review; never re-characterize benefit-risk autonomously
Bioanalytical assay failure / sample-integrity loss affecting PK
Bioanalytical / data integrity
Warning
Run-rejection rate, QC/calibration failures, ISR pass-rate breach, missing/excursion samples per cohort
src: Bioanalytical lab LIMS, sample-accountability/courier logs, QC/ISR reports
On-deviceISR pass-rate < acceptance (e.g., regulatory ISR criteria), or assay-run rejection / sample-loss above tolerance for a gating cohortDraft PK-integrity alert to clinical pharmacology/PK scientist; flag escalation-decision risk; humans adjudicate data usability
Investigational product supply: stock-out / expiry / shipment & cold-chain failure
Supply chain / IP accountability
Warning
Projected days-of-supply vs enrollment plan; expiry runway; excursion quarantine; release delay
src: IXRS/IRT supply module, depot inventory, QP/QA release status, temperature-monitoring logs
Cloud ClaudeProjected supply < lead time to next cohort; remaining shelf-life < dosing window; any cold-chain quarantine of gating stockDraft supply-risk alert to clinical supply/PM; humans manage resupply and QP release
Specialty-vendor / lab / ECG-core / IXRS outage or performance failure
Vendor operational integrity
Warning
Turnaround-time SLA breach, missed/late data feeds, system-uptime drop, reconciliation mismatch count
src: Vendor SLA dashboards, data-transfer/reconciliation logs, helpdesk/incident tickets
Cloud ClaudeSLA breach on a gating deliverable (e.g., safety labs/ECG before dosing review), or feed gap > toleranceDraft vendor-performance alert to vendor manager/PM; humans manage escalation/contingency
Informed-consent invalidity / re-consent trigger breach
Compliance / human-participant protection
Critical
ICF version mismatch vs current approved; re-consent not completed within window after new safety info; IRB continuing-review lapse
src: IRB/EC approval records, ICF version control, participant consent log, amendment tracker
On-deviceAny dosed participant on a superseded ICF, or re-consent overdue past defined window = critical compliance flagDraft consent/re-consent alert to clinical operations/regulatory; humans manage IRB and re-consent
Protocol-amendment churn / substantial-amendment frequency
Protocol stability
Warning
Amendments per unit time vs benchmark; share that are substantial/safety-driven; shortening interval
src: Protocol version control, amendment log, IRB/EC submission tracker
Cloud ClaudeAmendment rate or substantial-amendment count above benchmark for study phase/durationDraft amendment-churn trend to PM/sponsor; humans assess design and program implications
Site for-cause / sponsor / regulatory inspection findings (data integrity / GCP)
Quality / inspection
Critical
Critical/major finding count, for-cause trigger, fraud-pattern flags from CSM, repeat/un-resolved CAPA
src: Audit/inspection reports, monitoring CAPA log, central statistical monitoring outputs, regulatory inspection notices
On-deviceAny critical finding or for-cause/fraud signal; major-finding accumulation above toleranceDraft inspection/audit-risk alert to QA/PM/sponsor; humans own CAPA and regulatory response
Cohort distributional shift across escalating doses (Wasserstein) ADV
OT · drift
AMBER — continuous dose-escalation safety drift
Optimal Transport on aggregate distributions; the transport plan shows which severity grades / exposure ranges drive the shift.
src: aggregate (de-identified) cohort safety/PK
On-deviceW-distance trend exceeds the cohort-to-cohort control bandSurface to the SRC ahead of the escalation review
Study-level free-energy drift (model evidence) ADV
Active inference
AMBER — futility / safety / feasibility precursor
Active inference at the study level; the QTLs encode the 'preferred' states (prior preferences C). Free energy over aggregate states.
src: aggregate study KRIs
Cloud ClaudeSustained free-energy rise above bandPM review; SRC if safety-driven
EFE-guided risk-based monitoring allocation ADV
Active inference
GREEN — optimization of effort, not a risk itself
Active inference precision/EFE ranks monitoring targets; decision-support for the monitoring plan.
src: site/cohort KRIs + uncertainty
Cloud ClaudeEFE ranking of targetsFeed the risk-based monitoring plan; CRA tasking (human-approved)
Site data-distribution anomaly (Optimal Transport) ADV
OT · quality
AMBER — data-integrity early warning
OT distance, site vs pool; a large distance = outlier site. Decision-support; triggers for-cause review.
src: per-site aggregate (de-identified) data
Cloud ClaudeSite W-distance beyond the pool's toleranceFlag for central-monitoring / for-cause review

Client / sponsor-level signals

19 commercial early-warnings that a sponsor may cancel, de-scope, or not renew — non-sensitive business data on cloud Claude. This is signal & triage for the account team, not a verdict; the relationship owner decides.
SignalDetection (what the AI does vs. validated/human)EngineThreshold / KRIEscalation
AR / payment aging breach
Financial
AMBER→RED: hard early signal of de-scope/non-payment/termination risk; oldest, most reliable financial tell
Rule-based aging buckets computed by the validated finance system; Claude AGGREGATES across invoices, correlates with disputes/cadence, and DRAFTS the AR-risk brief. Reported dollar figures come from ERP, never the LLM.
src: Finance/AR sub-ledger + ERP (system of record), contract payment terms from CLM/CTMS
Cloud ClaudeAny material invoice >60 days past Net-30/45 terms, OR total past-due trending up 2+ consecutive periods, OR a single invoice in dispute >$XAccount/BD lead + PM + finance/AR controller; escalate to relationship-governance call
Change-order / scope-reduction / hold trend
Commercial
AMBER→RED: directional de-scope often precedes full cancellation
Rule-based on CO direction/value + status aging; Claude classifies CO sentiment (reduce vs. expand), flags stall/hold patterns, and explains. PM validates.
src: CTMS / Smartsheet / CLM change-order log, contract scope, project plan
Cloud Claude≥2 reduction/hold COs in a quarter, OR a CO unsigned/stalled >30 days, OR cumulative scope down vs. baseline contract valueAccount lead + PM; trigger scope/relationship review with sponsor
Cancellation-rate / backlog-erosion spike
Commercial
AMBER→RED: leading indicator of revenue loss; feeds book-to-bill / NDR
Statistical vs. benchmark — Claude compares realized erosion to the ~4%-of-prior-quarter-backlog cancellation baseline and flags excess; finance validates the numbers.
src: Backlog/financial-planning system, CTMS revenue forecast, contract value
Cloud ClaudeQuarterly backlog burn on this program exceeds ~4% baseline cancellation rate, OR forecast revenue revised down >X% unrelated to milestonesAccount lead + portfolio/finance leadership
Communication cadence drop
Commercial
AMBER: classic B2B churn precursor; soft but early
Statistical anomaly on cadence/latency vs. the relationship's own baseline. Claude reads METADATA/cadence (not sensitive bodies) and de-identified summaries; flags the drop. Account lead interprets.
src: Sponsor comms metadata (email/calendar), CRM activity log, meeting minutes
On-deviceMeeting/email cadence down >40–50% vs. trailing baseline, OR median response latency doubles, OR a governance meeting cancelled/not rescheduledAccount/BD lead; proactive re-engagement / health check
Sentiment decline in sponsor comms
Commercial
AMBER: corroborating signal, weak alone — pair with cadence/disputes
Model-assisted NLP sentiment/topic on de-identified comms; Claude trends sentiment and surfaces representative quotes, with confidentiality guardrails. Human reads context — sentiment is noisy, triage-only.
src: Email/meeting-minutes text (de-identified), CRM notes, escalation log
Cloud ClaudeSentiment trend negative for 2+ consecutive periods, OR ≥N negative/escalation-flagged messages in a windowAccount lead; loop in PM/relationship sponsor
Loss of internal champion
Commercial
AMBER→RED: champion loss frequently precedes vendor switch
Rule-based on stakeholder activity + public role-change detection; Claude flags champion silence or exit and maps remaining relationship coverage. Account lead confirms.
src: CRM stakeholder map, comms metadata, LinkedIn/press (public), org changes
Cloud ClaudeChampion comms cease >X weeks, OR public departure/role change, OR new unknown decision-maker insertedAccount/BD lead; rebuild multi-threaded relationship
Milestone dispute / escalation flag
Commercial
AMBER→RED: disputes are both a cause and a pretext for termination
Rule-based on escalation/dispute events; Claude clusters recurring complaint themes and links to invoice/CO status. PM/quality validate the facts.
src: CTMS milestone log, escalation/issue tracker, meeting minutes, contract
Cloud Claude≥1 formal escalation, OR ≥2 milestone/acceptance disputes in a quarter, OR sponsor micromanagement spike (a trust tell)PM + account lead; quality/governance review
Sponsor pipeline / portfolio reprioritization
Commercial
RED: #1 non-financial cause of early-phase cancellation
Model-assisted web/filing monitoring; Claude detects pipeline-graphic changes, 'strategic review', 'focusing resources' language, and trial-status flips, then summarizes asset-specific risk. BD lead corroborates.
src: Public 8-K/press/earnings calls, clinicaltrials.gov status, conference abstracts, CRM intel
Cloud ClaudePublic deprioritization/shelving language for this asset/TA, OR pipeline removal, OR clinicaltrials.gov status → suspended/withdrawnAccount/BD lead + portfolio leadership; renewal-defense plan
Sponsor financial health / runway
Financial
RED: insolvency-driven termination ignores trial performance
Model-assisted filing analysis; Claude extracts cash, burn, and quarters-of-runway, flags going-concern language, and trends. Figures cited to the filing, not invented. Finance/BD validate.
src: Public 10-Q/10-K, 8-K, press, IR decks, analyst notes; (private) news of raises/runway
Cloud ClaudeCash runway < ~12 months (or below next-milestone date), OR going-concern qualification, OR failed/withdrawn raise, OR debt covenant breachAccount/BD lead + finance + leadership; assess pre-payment/credit terms
Layoffs / restructuring signal
Financial
AMBER→RED: strong corroborator of runway/reprioritization risk
Rule + model-assisted news monitoring; Claude detects layoff/restructuring events for the sponsor and links to affected programs. BD lead confirms relevance to our asset.
src: Public press / layoff trackers / WARN notices / 8-K / LinkedIn (public)
Cloud ClaudeAny announced layoff/restructuring/program-cut at the sponsor, especially clinical-ops or our TAAccount/BD lead; proactive status check on our program
Sponsor M&A / acquisition / reverse-merger
Commercial
RED: step-change; acquirers routinely cut acquired Phase 1 programs
Model-assisted news/filing monitoring; Claude flags rumor→announcement→close and cross-references OUR change-of-control / termination-for-convenience terms. Legal/BD validate.
src: Public M&A news/8-K/definitive agreements, rumor trackers, CRM intel, our contract terms (CLM)
Cloud ClaudeM&A rumor/announcement/definitive agreement involving the sponsor; change-of-control clause present in our MSAAccount/BD lead + legal + leadership; engage acquirer early
Competitive / adjacent-program readout
Commercial
AMBER→RED: can trigger a 'why continue?' reprioritization
Model-assisted web monitoring keyed to target/MoA/indication; Claude summarizes the competitive event and reasons about spillover risk to our asset. Scientific/BD leads judge relevance.
src: Public readouts, ASCO/AACR/JPM abstracts, FDA actions, press, clinicaltrials.gov
Cloud ClaudeCompetitor approval or strong readout in same indication, OR adjacent/same-MoA program safety or efficacy failureAccount/BD lead + scientific lead; sponsor strategy check-in
Contract end-date / renewal & option-exercise window
Commercial
AMBER: cleanest, earliest deterministic lead time — act before it goes red
Rule-based deterministic countdown; Claude tracks days-to-decision and un-exercised options and DRAFTS the renewal-defense brief. PM/account lead own the play.
src: Contract/CLM metadata, CTMS milestones, option schedule, notice-period clocks
Cloud Claude<90 days to contract end / renewal / option-exercise date, OR option past its trigger milestone un-exercisedAccount/BD lead + PM; launch renewal/extension campaign
Relationship governance / KOL-strategy pivot flags
Commercial
AMBER→RED: governance + leadership pivots reshape vendor decisions
Rule + model-assisted; Claude flags governance-meeting anomalies, detects new sponsor leadership / strategy-pivot language, and surfaces RFP-shopping tells. Account lead interprets intent.
src: Governance meeting minutes/cadence, CRM intel, public leadership-change news, RFP/procurement signals
Cloud ClaudeCancelled/skipped governance meeting, OR new CMO/CSO/dev-strategy change, OR detected competitive RFP / second-CRO sourcingAccount/BD lead + relationship sponsor; executive re-engagement
Same-compound / cross-study & class safety signal
Cross-program safety intelligence
Critical
New same-compound/class serious finding, regulatory safety communication, competitor program safety halt for the target/class
src: FAERS/FDA safety communications, ClinicalTrials.gov, literature, sponsor cross-study safety, regulatory bulletins
On-deviceAny credible same-compound or mechanism-class serious safety eventDraft cross-study/class safety brief to medical monitor/sponsor; humans assess applicability and action
Competitor approval / pivotal readout (positive OR negative) reshaping program value
Competitive / market intelligence
Warning
Competitor approval/designation event; pivotal-trial readout in same indication/target/MoA
src: FDA/EMA approval trackers, competitor press/IR, ClinicalTrials.gov, conference/abstract readouts, analyst coverage
Cloud ClaudeAny first-in-class approval or major pivotal readout in the same indication/targetDraft competitive-event brief to PM/BD/sponsor relationship lead; humans assess portfolio impact
FX / contract-currency & funding-tranche exposure
Financial / contractual
Warning
FX move beyond contract tolerance band; missed/at-risk funding tranche; going-concern flag; covenant breach
src: FX rates vs contract baseline, sponsor SEC/financial filings, funding/milestone tranche schedule, going-concern disclosures
Cloud ClaudeFX deviation beyond agreed band; any funding tranche slip or going-concern disclosureDraft financial-exposure alert to finance/PM/account lead; humans manage contract and currency hedging
Sponsor-behavior drift (Wasserstein) ADV
OT · drift
AMBER — commercial early warning
Optimal Transport on engagement features; a rising distance = the relationship cooling.
src: CRM / finance-AR / comms metadata (non-sensitive)
Cloud ClaudeW-distance beyond the baseline bandAccount / BD lead review
Program-level free-energy (commercial surprise) ADV
Active inference
AMBER — program/contract-risk precursor
Active inference at the client level; decision-support for the account team.
src: program milestones / comms / AR
Cloud ClaudeSustained free-energy riseAccount lead + leadership review

Detection, scoring & escalation

How individual signals become a tier risk level and an alert — and the platform pieces that run it.

SignalDetection (what the AI does vs. validated/human)EngineThreshold / KRIEscalation
On-device local LLM backend (sensitive participant-level engine)
Platform / AI engine
n/a
Local open-weight LLM runs RAG/summarization over participant records on-device; zero network egress; the model triages and EXPLAINS, validated tools compute the reportable safety numbers and the SRC/medical monitor makes the call
src: EDC, validated safety/PV database, central-lab, ECG core-lab, IXRS (participant-level)
On-devicen/a — capability; sensitivity classification 'participant-level/unblinded' forces local-only processingDrafts participant-level early-warning narratives for the medical monitor / SRC; no data leaves the device
Cloud cloud Claude (API + BAA) backend (non-sensitive ops/commercial engine)
Platform / AI engine
n/a
Cloud Claude summarizes and triages non-sensitive KRIs and commercial signals; drafts alerts for PM and account/BD lead; validated tools/CSM compute the metrics
src: CTMS, Smartsheet, finance/AR, CRM, sponsor-comms, web (public filings) — de-identified/aggregate only
Cloud Clauden/a — capability; only data classified non-sensitive/de-identified is permitted to the cloudDrafts study-ops and commercial early-warning summaries for PM and account/BD lead
Sensitivity-based routing gateway
Platform / Governance routing
n/a
Rule-based gateway at the connector layer tags each record's sensitivity class and routes accordingly before any model sees it; routing decisions are logged
src: Data-classification metadata on every connector
Validated + humann/a — deterministic policy rule (sensitivity class = local-only vs cloud-eligible)Blocks any participant-level/unblinded payload from reaching the cloud; logs the routing decision to the Part-11 audit trail
Validated data connectors (read-only ingestion)
Platform / Data connectors
n/a
Read-only, validated, time-stamped pulls with each feed tagged by sensitivity class; reportable numbers sourced from validated systems, not the LLM
src: EDC, validated safety DB, IXRS/RTSM, central-lab, ECG core-lab, CTMS, Smartsheet, finance/AR, CRM, sponsor-comms, web (public filings)
Validated + humann/a — capability; connector validation and ALCOA++ lineage requiredFeeds the scoring/aggregation layer and the appropriate (local/cloud) engine
3-tier RAG dashboard view (Participant / Study / Client)
Platform / Visualization
n/a
Renders weighted-KRI roll-up as RAG tiles; sparklines show signal trajectory over time; drill-down routes participant-level detail back through the on-device engine
src: Scoring/aggregation layer (all connectors)
On-devicen/a — display layer; RAG bands inherited from the scoring layer's KRI/QTL thresholdsGives the medical monitor/SRC, PM, and account lead a single triage surface to review and disposition
Scoring & aggregation layer (weighted-KRI roll-up)
Platform / Scoring
n/a
Statistical/rule-based weighted scoring (config-controlled weights and thresholds); explainable — every score links back to its contributing signals; it is triage support, NOT an autonomous verdict
src: All signal feeds (participant, study, client)
Validated + humann/a — capability; per-tier KRI weights and QTL/'acceptable-range' bands are pre-specified and version-controlledSets tier RAG status; any red/amber requires human review and disposition
Alerting & escalation routing
Platform / Alerting
n/a
Rule-based routing on signal category and severity; AI drafts the alert text and rationale, the human owner triages and decides
src: Scoring/aggregation layer + signal metadata
Validated + humann/a — capability; escalation tier triggered by the signal's RAG band and categoryDelivers the right alert to the right decision-maker with SLA tracking
Human acknowledgement & disposition log
Platform / Governance
n/a
Each alert requires an attributable, time-stamped human disposition with rationale before close; enforces 'AI flags, human decides'
src: Alert workflow
Validated + humann/a — capability; no red/amber alert closes without a recorded human dispositionCreates the accountable record that a human owned the call
21 CFR Part 11 audit trail (ALCOA++)
Platform / Compliance
n/a
Rule-based logging with e-signatures and version control; ALCOA++ data lineage; tamper-evident
src: All platform actions and engine outputs
Validated + humann/a — capability; Part-11 / ALCOA++ compliance required for all entriesProvides the regulatory-inspectable record of detection-to-disposition
Tiered refresh cadence
Platform / Operations
n/a
Near-real-time / event-driven for participant safety (EDC, safety DB, IXRS, labs, ECG); daily for study-ops KRIs (CTMS, queries, deviations, Smartsheet); weekly for client/commercial (finance-AR, CRM, sponsor comms, public filings)
src: Per-connector schedules / event triggers
Validated + humann/a — capability; cadence set per data domainEnsures safety signals surface fast while commercial signals refresh on a fit-for-purpose cycle
Explainability & source-citation layer
Platform / Trust
n/a
RAG with mandatory source citation; the model explains WHY a signal fired and links to source; reviewer confirms against the validated safety DB
src: All connectors + scoring layer
On-devicen/a — capability; no uncited safety claim is shown as factLets the human owner trust-but-verify before dispositioning
Role-based access & blinding controls
Platform / Security
n/a
Rule-based RBAC and blinding firewall; the on-device engine and unblinded panels are gated to authorized roles only
src: Identity/access management + sensitivity tags
Validated + humann/a — capability; access tied to authorized role and blinding statusPreserves trial integrity and blinding while still surfacing tier-appropriate signals
Pooled reference priors — Wasserstein barycenters (empirical-Bayes pooling) ADV
Cross-study pooling
the meta layer
OT barycenters + hierarchical / empirical-Bayes priors updated across studies — the cross-study pooling loop that sets every tier's reference.
src: historical cohorts/studies (per-tier sensitivity)
On-devicen/aSets each tier's reference; recalibrated as studies complete
Nested (deep) active-inference hierarchy — participant → study → client ADV
Active inference
the architecture
Deep / hierarchical active inference; a Wasserstein-regularized free energy ties the levels and the pooled priors together.
src: all tiers
On-devicen/aThe nested loop; surfaces tier-coupled early warnings

Advanced engine — Optimal Transport + nested Active Inference

The rule-based KRIs answer "has a line been crossed?". This layer answers the earlier question: "is this trial drifting toward a line, and where should we look next?" It adds three things on top of the thresholds — a geometry-aware drift signal (Optimal Transport), an anticipatory surprise signal (Active Inference), and a nested, pooled structure that ties the three tiers together.

Read this first. This engine is decision-support and advanced analytics — it produces continuous scores and monitoring suggestions, never determinations. The rule-based DLT / Hy's-Law / QTcF / QTL triggers remain the authoritative early-warnings; OT and active inference surface risk earlier and more continuously, they do not replace the rules. Any model-derived signal that would inform a regulated decision must be validated and locked first; the validated tools still own every reported number, and the SRC / DSMB / medical monitor / PM still make every call.

1 · Optimal Transport — the geometry-aware drift signal

A threshold rule fires when one value crosses a line. Optimal Transport instead measures how far a whole distribution has moved. The Wasserstein distance is the minimum "cost" to transport one distribution onto another:

Wp(μ,ν) = ( infπ ∈ Π(μ,ν) ∫ d(x,y)p dπ(x,y) )1/p— the cheapest plan π to move distribution μ (e.g. this cohort's LFTs) onto ν (the reference). The ground metric d(x,y) encodes the outcome geometry — a Grade 1→3 move is farther than 1→2, a large exposure jump farther than a small one — and the order p tunes how heavily the large moves are weighted (W₂ penalizes them more than W₁).

Why Wasserstein and not KL-divergence? Three reasons that matter for safety:

  • It respects the outcome geometry. Severity ordering and exposure magnitude are built into the cost — so a shift toward worse grades or higher exposure registers as a larger distance, in the right direction.
  • It counts how far the mass moves. A few participants sliding into a dangerous tail move mass a long way in ground-metric units — W registers that, where a mean/threshold summary misses it and KL (being geometry-blind, and prone to blowing up) tells you the distributions differ but not by how far or in which direction. The dangerous part of a dose-escalation shift is that tail movement.
  • It is well-defined on non-overlapping support (where KL → ∞) and gives a smooth distance and a direction — the transport plan tells you which grades/exposures/participants are driving the drift, so the flag is interpretable.

The reference each tier compares against is a Wasserstein barycenter of prior cohorts/studies — the distribution that minimizes the average transport cost to the historical set (this is the pooled prior, below):

μ̄ref = argminμ ∑k λk W22(μ, νk)— a principled pooled reference built from prior cohorts νk, not a hand-picked baseline.

On-device feasibility: 1-D Wasserstein is a closed-form sort (cheap), and sliced-Wasserstein reduces the multivariate case (labs + vitals + exposure jointly) to averaged 1-D projections — light enough to run on the local model for participant-level data, zero egress.

Drives, on the dashboard: participant-trajectory drift, cohort dose-escalation drift, site data-distribution anomaly (central monitoring), sponsor-behavior drift.

2 · Active Inference — the anticipatory surprise signal

Treat the monitor as an agent with a generative model of the trial's expected trajectory. Two quantities fall out, and both are exactly what an early-warning system wants.

(a) Variational free energy — a tractable upper bound on surprise — is an early-warning signal. As each observation arrives, the agent updates its beliefs to minimize free energy (variational Bayesian belief-updating); the free energy upper-bounds the surprise (the surprisal −ln p(o)) — how poorly the model explains what it just saw. The same F has two equal forms — one that shows the bound, one that you actually compute:

F = DKL[ q(s) ∥ p(s|o) ] − ln p(o)  ≥  −ln p(o)  (the bound: the KL is ≥ 0)
  = DKL[ q(s) ∥ p(s) ] − Eq[ ln p(o|s) ]  (complexity − accuracy — what you compute)— minimizing F over beliefs q = perception. Under exact inference the bound is tight (F = −ln p(o) when q = p(s|o)); with a restricted belief family it is a generally non-tight upper bound. Either way, a participant, cohort, or program whose observations are surprising under the expected model drives F up before a frank threshold event.

The trial's safety/quality tolerances (the QTLs, exposure caps, expected enrollment) are encoded as the model's preferred observations (prior preferences C) — which enter the expected free energy below, not the perceptual F above. So there are two distinct early signals worth watching: surprise (F rising — the trial is doing something the model didn't expect) and preference-divergence (outcomes drifting from the preferred QTL state). They usually move together, but not always — a trial can drift toward a fully predicted bad state (low surprise, high preference-divergence), and you want to catch both.

(b) Expected Free Energy = what to monitor next. The agent chooses its next action — here, a monitoring/data-collection action — by minimizing expected free energy over candidate observations:

π* = argminπ G(π),   G(π) = − E[ information gain ] − Eq[ ln p(o|C) ]— the agent minimizes G; because both terms are negated, that maximizes expected information gain and the expected log-preference ln p(o|C) (where C is the preferred / safe outcome — the utility). The epistemic term picks the assessment that most reduces uncertainty about emerging risk; the pragmatic term favors reaching the safe, on-track state. Together they answer "which unscheduled assessment would tell us the most about whether this is a real DLT?"

So the engine doesn't just wait — it recommends an unscheduled LFT/ECG/PK draw, or which site/cohort to monitor next (precision-weighted attention = risk-based monitoring that focuses where information-gain is highest). Every such action is a suggestion for human approval — never an autonomous clinical or dosing action.

Drives, on the dashboard: participant free-energy spike + EFE-recommended monitoring; study-level free-energy drift + EFE-guided RBM; program-level free-energy.

3 · The nested / cross-study pooling structure

This is where the two methods compose. The three tiers are not three separate dashboards — they are one deep (hierarchical) active-inference model that minimizes a single hierarchical free energy by local message-passing. Each tier's beliefs are the top-down priors for the tier below; each tier's prediction errors (surprise) propagate up; and the levels run at different timescales (fast at the bedside, slow at the program). Because the levels are coupled in the model, a participant DLT propagates upward as study- and program-level risk instead of staying siloed.

CROSS-STUDY POOLINGWasserstein-barycenter priors, learned across prior cohorts / studies (empirical Bayes) — recalibrated as each study completes
sets & recalibrates each tier's priors ▸
slow · weeks–monthsCLIENT / PROGRAMgenerative model of the program & sponsor trajectory
OTsponsor-behavior driftAIprogram free-energy
↓ top-down priors (predictions)bottom-up prediction errors (surprise) ↑
medium · days–weeksSTUDYdose–toxicity, enrollment & QTL beliefs
OTcohort distribution driftAIstudy free-energy · EFE→RBM
↓ top-down priors (predictions)bottom-up prediction errors (surprise) ↑
fast · minutes–daysPARTICIPANTeach participant's expected safety / PK trajectory
OTparticipant-trajectory driftAIfree-energy spike · EFE→next assessment
↓ observations: central-lab LFTs · ECG / QTcF · PK exposure · AEs — processed on-device (zero egress)

Cross-study pooling (empirical-Bayes pooling) sets the priors. Each level's generative model — expected AE rates, the dose–toxicity prior, the enrollment curve, the "preferred" QTL states — has hyperparameters estimated by pooling across prior cohorts/studies (an empirical-Bayes / hierarchical prior). In the hierarchy the higher level supplies the prior for the level below; what is pooled from the population is the hyperprior that shapes those priors. Concretely, the Wasserstein barycenter of past cohorts is used as the reference a new cohort is scored against, and it recalibrates as each study completes — so a new study starts population-informed instead of from scratch. That cross-study hyperprior is the "meta".

The tie that binds: a Wasserstein-regularized objective. Using an Optimal-Transport cost in place of (or alongside) the KL term in the variational objective makes the divergence geometry-aware and well-defined on non-overlapping support — the same property that made W the right drift metric now makes the belief-updating robust, and it lets the pooled barycenter prior enter directly. The honest trade-off: once you swap KL for W it is no longer the strict variational free energy, so the clean "upper bound on surprisal" guarantee above relaxes into a geometry-aware regularizer — a deliberate, advanced design choice, not a free lunch. OT supplies the metric; active inference supplies the dynamics; cross-study pooling supplies the priors.

What this buys you over thresholds alone. (1) Earlier — drift and surprise rise before a line is crossed. (2) Geometry- and tail-aware — it catches mass moving toward danger, not just a single value. (3) Anticipatory — it proposes the most informative next assessment instead of waiting. (4) Coherent across tiers — one nested model, so participant-level risk correctly propagates to study and program risk, with priors that get smarter every study.

Honesty & validation

  • Advanced ≠ validated. These are advanced methods. Treat their outputs as triage and prioritization until the specific implementation is validated and version-locked; the rule-based triggers and the validated safety/dose-escalation tools remain authoritative for any regulated decision.
  • Frozen for reproducibility. If a model-derived signal ever feeds a submission or a stopping decision, the model, the reference barycenters, and the thresholds must be frozen and documented (the same model-freeze argument as the rest of the program) so a result is reproducible.
  • Participant-level stays on-device. The participant-tier OT and active-inference computation runs on the local model with zero egress; only de-identified aggregates inform the cloud tiers.
  • The action is a suggestion. EFE recommends what to observe; a human orders it. Nothing about dosing, escalation, or termination is automated.

Governance — the AI flags, humans decide

  • The AI never makes a safety or termination call. It detects, aggregates, triages, explains, and drafts the alert. The medical monitor / SRC / DSMB make DLT & safety determinations; the PM owns the study; the account lead owns the client signal.
  • Participant-level safety / PK / unblinded data never leaves the device. The local LLM runs on-prem / on-device with zero egress. Only non-sensitive operational & commercial signals use cloud Claude (under BAA).
  • Validated tools own the numbers. Reported safety numbers come from the validated safety database; cohort DLT-rate / stopping-rule math comes from the validated dose-escalation tool — never an LLM.
  • Early-warning, not auto-action. A flag triggers a human review and a disposition, logged with a 21 CFR Part 11 audit trail (ALCOA++). Nothing is paused, escalated, or terminated by the system itself.
  • The client tier is decision-support for the account team — surfacing commercial signals, never a unilateral judgement about a sponsor.

Standing it up

Phase 1 — the safe wins (cloud)

  • Study & client tiers first: wire enrollment / KRI / QTL feeds and the finance-AR / CRM / sponsor-comms signals into cloud Claude; build the Study and Client RAG panels behind a human-review queue. De-identified / non-sensitive only.

Phase 2 — the on-device participant tier

  • Stand up the on-device local LLM in the validated environment; connect the safety DB / central-lab / ECG feeds; encode the DLT criteria, Hy's-Law / eDISH logic, QTcF and PK-exposure thresholds; route every participant-level signal on-device with zero egress.
  • Wire the alerting to the medical monitor / SRC and the disposition log.

Phase 3 — scoring, escalation & audit

  • The weighted roll-up to tier RAG, the escalation routing, the Part-11 audit trail and human-acknowledgement, and the cross-study safety view for the same compound.

Worked example — a DLT early-warning fires

Day 9, cohort 4 (dose escalation)

Participant S-1042's central-lab feed posts: ALT 3.4× ULN, total bilirubin 2.1× ULN, ALP 1.3× ULN. The on-device local LLM evaluates the eDISH logic, recognizes a Hy's-Law pattern, and — because it's inside the DLT window for this dose — flags a candidate DLT. Nothing left the device.

Within minutes

The model pre-assembles the case: the LFT trajectory, the eDISH context, the participant's dose & exposure, concomitant meds, and the running cohort DLT tally vs the 3+3 rule. It drafts the alert and routes it to the medical monitor and the SRC chair — ahead of the scheduled cohort review — and logs the flag with a Part-11 audit entry.

The humans decide

The medical monitor orders a confirmatory repeat LFT; the SRC convenes. Per protocol, further dosing/escalation pauses pending adjudication. The validated safety database holds the authoritative numbers; the SRC makes the DLT determination. The dashboard's Participant panel goes red, the Study panel flags the cohort, and a cross-study check runs for the same compound.

The payoff

The signal surfaced on day 9, not at the cohort meeting on day 21 — with the SRC packet already built, the data never leaving the device, and a human making every call.

FAQ

Does the AI stop a study or a dose? No. It is an early-warning system — it flags, aggregates, and drafts; the SRC / DSMB / medical monitor and the PM make every decision.

Why on-device for the participant tier? It's participant-level safety / PK / unblinded data. On-device with zero egress is the only way to use AI on it without a data-residency problem.

Where do the numbers come from? Validated systems — the safety database and the validated dose-escalation tool. The LLM never produces a reported safety number or a DLT-rate verdict.

Is the client tier appropriate? It's commercial decision-support for the account team — surfacing AR, communication, scope, and sponsor-health signals — not a judgement the system makes on its own.

How does it relate to the rest of the program? It's the risk-monitoring layer of the hybrid AI strategy: on-device local for sensitive data, cloud Claude (API + BAA) for non-sensitive — the same routing principle, pointed at early-termination risk.

What are the "ADV" / Optimal-Transport / Active-Inference signals? An advanced analytics layer on top of the thresholds: Optimal Transport (Wasserstein) measures how far a distribution has drifted from a pooled reference (earlier and more tail-sensitive than a single value crossing a line), and nested Active Inference treats the monitor as a generative model whose surprise is an early-warning and whose expected free energy recommends the most informative next assessment. They are decision-support — advanced, not yet validated — and never override the rule-based triggers or the humans.

Walkthrough transcript

The complete narration of the walkthrough video, as readable text.

1. Part 1

This is a short walkthrough of the trial-risk early-warning dashboard. The idea is simple: catch the risk that a trial might have to stop — early, and across three levels: the individual participant, the study as a whole, and the client relationship. It runs on a hybrid of cloud Claude (under a BAA) and on-device local models. And throughout, the AI only detects, aggregates, and triages. It never makes the safety or termination call. Let me show you how it works.

2. Part 2

Early-phase trials can stop for reasons that build up quietly. A participant's safety signal. A cohort's toxicity creeping toward the stopping rule. Or a sponsor going cold on the program. The trouble is that the first formal look is often the cohort review or a governance meeting — and by then we are days or weeks behind. The dashboard watches all three of these continuously, so the earliest mover is visible long before that meeting.

3. Part 3

Here is the dashboard itself. Three panels — participant, study, and client — each with a simple red, amber, green status, the top signals underneath, and the engine that powers it. Below the panels is a live early-warning feed. Right now everything is amber: a candidate liver signal on one participant, an enrollment limit breached at the study level, and a payment-aging flag on the client side. Each panel rolls its signals up to a status — but that status is a prompt for a human, not a verdict the system reaches on its own.

4. Part 4

The participant tier is the most sensitive, so it runs entirely on-device, with zero egress. It flags candidate dose-limiting toxicities inside the evaluation window: Hy's-Law liver signals, QTc prolongation, PK exposures beyond the safety margin, and escalating adverse-event clusters. The key word is early. It surfaces the pattern and pre-assembles the safety-committee packet before the formal cohort review. What it does not do is adjudicate the toxicity. That is the medical monitor and the Safety Review Committee.

5. Part 5

The study tier watches the trial's trajectory against its own rules: the cohort toxicity rate against the stopping rule, enrollment and screen-failure limits, the safety quality-tolerance limits from ICH, and central data-quality signals. These are de-identified, aggregate numbers, so they run on cloud Claude — with any participant-level drill-down dropping back to the on-device model. The project manager owns these calls, with the safety committee on anything safety-related.

6. Part 6

The third tier is the commercial one — the early warning that a sponsor might cancel, de-scope, or not renew. Payment aging, a drop in communication, scope-reduction change orders, and the sponsor's own financial and pipeline health. This is non-sensitive business data, so it sits on cloud Claude. And I want to be clear about what this tier is. It is decision-support for the account team, surfacing signals. It is never a judgment the system makes about a sponsor.

7. Part 7

Underneath, one rule decides where everything runs: sensitivity. Participant-level safety and unblinded data go to the on-device model, and never leave the validated environment. Non-sensitive, aggregate operational and commercial data go to cloud Claude, under a business-associate agreement. And here is the rule that governs the whole thing. The AI flags, aggregates, triages, and drafts the alert — it never makes the safety or termination call. The reported numbers come from the validated safety database, never the model. Every flag triggers a human review and a logged disposition, and nothing is paused or terminated by the system itself.

8. Part 8

There is an optional advanced layer for teams that want it. Instead of waiting for a threshold to be crossed, it watches for drift and surprise. Optimal transport measures how far a distribution has moved from a learned reference, in a way that respects clinical severity. Active inference treats the monitor as a model of the expected trajectory, so rising surprise is itself an early warning — and it can even recommend the most informative next test to run. It is decision-support only: the threshold rules stay authoritative, the methods were independently checked, and it is validated and frozen before it ever informs a regulated decision.

9. Part 9

Here is how it comes together. Day nine of cohort four: a participant's labs post a Hy's-Law pattern. The on-device model recognizes it, and because it is inside the evaluation window, flags a candidate toxicity — without any data leaving the device. Within minutes it assembles the case and routes it to the medical monitor and the committee chair, ahead of the scheduled review. The humans take it from there: a confirmatory test, the committee convenes, dosing pauses per protocol. The payoff is the timing. This surfaced on day nine, not at the cohort meeting on day twenty-one — with the packet already built, and a human making every call.

10. Part 10

Building it is staged. First, the safe wins: wire the study and client tiers from existing operational and commercial feeds into cloud Claude, behind a human-review queue, with de-identified data only. Second, the on-device participant tier in the validated environment, with the safety logic encoded and alerting wired to the medical monitor. Third, the scoring, escalation, and audit trail — and, optionally, the advanced engine, validated and frozen before it informs anything. Each phase delivers value on its own.

11. Part 11

So, in one line: catch termination risk before the meeting, and let humans make every call. It is earlier — a liver signal on day nine, not day twenty-one. It is three tiers on one screen. It is governed by design — sensitive data on-device, validated tools owning the numbers, and the committees and project managers deciding. And it fits the program: a phase-one pilot deliverable on the same hybrid stack — no new principle, just a new target. Thanks for watching.