The answer, I have found, is one that many new regulatory coordinators find uncomfortable. Equal treatment feels fair. It feels thorough. Giving every study the same process, the same review intensity, the same oversight checkpoints seems like the safest default. And it is, in fact, the most common approach at sites where the portfolio is small enough that the RC can sustain it through sheer effort. But equal treatment is not proportionate treatment, and at portfolio scale, the difference becomes consequential.

A Phase IV post-marketing observational registry with a straightforward data collection plan and a coordinator who has managed it successfully for three years does not carry the same compliance risk as a Phase I first-in-human dose-escalation study with a novel biologic, a complex safety monitoring plan, and a coordinator who completed training six weeks ago. Treating them the same means you are either over-investing in the registry -- consuming hours that produce no incremental safety benefit -- or under-investing in the dose-escalation study, where a missed safety signal or a protocol deviation could directly harm a participant. Probably both.

ICH E6(R3) makes this explicit. The guideline's Principle 7, Section 7.1, establishes that a quality management approach should be implemented across all stages of the trial process. Sections 7.2 and 7.3 clarify that this approach should be proportionate -- focused on activities essential to participant protection and data reliability rather than applied uniformly to all processes. And Annex 1, Section 3.10.1, provides the risk identification, evaluation, and control framework that makes proportionality operational. This lesson takes that framework and applies it to a problem E6(R3) does not directly address: how the regulatory coordinator stratifies an entire portfolio of studies to determine where quality controls must be intensive and where standard processes suffice.

The answer, I have found, is one that many new regulatory coordinators find uncomfortable. Equal treatment feels fair. It feels thorough. Giving every study the same process, the same review intensity, the same oversight checkpoints seems like the safest default. And it is, in fact, the most common approach at sites where the portfolio is small enough that the RC can sustain it through sheer effort. But equal treatment is not proportionate treatment, and at portfolio scale, the difference becomes consequential.

A Phase IV post-marketing observational registry with a straightforward data collection plan and a coordinator who has managed it successfully for three years does not carry the same compliance risk as a Phase I first-in-human dose-escalation study with a novel biologic, a complex safety monitoring plan, and a coordinator who completed training six weeks ago. Treating them the same means you are either over-investing in the registry -- consuming hours that produce no incremental safety benefit -- or under-investing in the dose-escalation study, where a missed safety signal or a protocol deviation could directly harm a participant. Probably both.

ICH E6(R3) makes this explicit. The guideline's Principle 7, Section 7.1, establishes that a quality management approach should be implemented across all stages of the trial process. Sections 7.2 and 7.3 clarify that this approach should be proportionate -- focused on activities essential to participant protection and data reliability rather than applied uniformly to all processes. And Annex 1, Section 3.10.1, provides the risk identification, evaluation, and control framework that makes proportionality operational. This lesson takes that framework and applies it to a problem E6(R3) does not directly address: how the regulatory coordinator stratifies an entire portfolio of studies to determine where quality controls must be intensive and where standard processes suffice.