Who Owns Clinical Supply, and What Happens When Nobody Does?

Daryn Bergey, CSC

By Daryn Bergey
Clinical Supply Consulting


How stronger clinical supply processes, vendor oversight, and supply network design brought structure to ongoing studies

Summary: At this sponsor, Chemistry, Manufacturing, and Controls (CMC) was running the clinical supply function end to end and learning as they went. Ownership sits differently at different companies, Clinical Operations, Regulatory, and Quality all own it elsewhere, but the pattern that follows is common: work keeps moving, and almost none of it is written down. This is what it took to put a foundation underneath it.

Who was running clinical supply, and why it was a risk

When I entered the organization, Chemistry, Manufacturing, and Controls was running the clinical supply function end to end, learning as they went. That approach kept work moving. It also left the organization without defined processes, clear ownership, or oversight that could handle more studies.

The risk was concentration. Execution depended on individual knowledge rather than repeatable systems. The priority was to build an operating model that could support ongoing studies, vendor transitions, audits, forecasting, and future expansion.

Which clinical supply procedures did not exist

The organization lacked formal procedures for key clinical supply activities. That created risk and made execution dependent on who happened to know the process.

Implementing standard operating procedures created consistency, clarified expectations, and established a foundation for compliant execution across studies and vendors.

SOPs became a practical roadmap for how work should be initiated, reviewed, escalated, and closed. That structure mattered more as the supply model grew more complex and more partners became involved.

One clarification worth making, because it comes up constantly with sponsors: not every procedure that touches clinical supply is a clinical supply SOP. Vendor qualifications sit with Quality. Study closeout sits with clinical operations, while drug reconciliation sits with clinical supply. Knowing which function owns which procedure is part of what makes the structure hold.

What happens when vendors have never been audited

Some of the sponsor’s existing clinical supply vendors had never been audited. That created compliance and quality risk that nobody had visibility into.

Quality owns vendor qualification and auditing. Clinical supply supports it, and that support matters because clinical supply is closest to how the vendor performs against study needs. Supporting those audits closed the open gaps and gave the organization better visibility into vendor capabilities, quality systems, and readiness to support clinical trial requirements.

We also implemented a new packaging and labeling vendor relationship. Setting up that capability required coordination across operational, quality, and study needs, so the vendor model could support both immediate execution and longer-term growth.

How do you transfer packaging and labeling vendors mid-study?


This does not come up often. When it does, the planning burden is high, because supply, labeling, documentation, accountability, and timelines must all stay controlled while patients are still being dosed. The goal is to move the work without disrupting patients, sites, or study continuity.
What that looked like here:

• Nothing carried over. Documentation did not transfer between vendors. Everything had to be set up at the new vendor.
• Material moved in two batches, deliberately, to prevent a supply issue during the transition.
• The experience reinforced the value of having clear processes, defined roles, and strong vendor communication in place before a major operational change, rather than building them during one.

What changed once forecasting was in place


Before forecasting existed, the sponsor was reacting. The practical workaround was to label excess so they would never run out. That solved the immediate problem but created cost and expiry exposure.

Establishing forecasts let the team anticipate demand, manage supply planning, and reduce reactive decision-making. Better visibility into future needs meant the clinical supply function could support studies ahead of time rather than behind it.

Forecast horizon: a forecast should run to the end of the study. A six-month view on a nine-month study will fail, and it will fail late enough to hurt.

Why finished clinical trials stay open

We also closed out a lingering study.

Closeout is easy to deprioritize when new work is demanding attention. But an unresolved study creates operational clutter, documentation gaps, and unnecessary risk that sits on the books indefinitely. Worth stating plainly, because it is a common misunderstanding: returning material does not close a study. It is not until the material is destroyed that the study can be closed.

The clinical supply operations takeaway

Transforming clinical supply operations starts with practical fundamentals: documented processes, vendors that have been audited, audit readiness, network flexibility, reliable forecasting, and disciplined study closeout.

In this case, the work shifted the organization from a reactive model to a structured, inspection-ready clinical supply function, one the sponsor’s own team could run.

Clinical Supply Consulting works alongside teams at every stage, building the function from scratch, strengthening one that already exists, or stepping in for a specific gap like a vendor transition or an audit. If any part of this sounds familiar, let’s talk.

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