What Goes in a Statistical Analysis Plan, and What Reviewers Flag

A review-ready statistical analysis plan turns protocol commitments into analyses that can be reproduced before unblinding. Here are the components, a worked example and the gaps reviewers flag most.

Written by
Dr. CharlieSenior Medical Writer
Published
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7 minutes
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6 cited
  • Biostatistics
  • Clinical trials
  • Statistical analysis plan
SAP in clinical trials
Finalise
Before unblinding
Estimand attributes
Five, per ICH E9(R1)
Content framework
55 items (Gamble et al.)
Top reviewer flag
Vague or post-hoc methods

Quick answer

  • The protocol says what the trial measures; the SAP says exactly how it will be analysed.
  • Define estimands, populations, models, missing-data and multiplicity rules before unblinding.
  • Link every derived variable to its ADaM source and output table.

01What is a statistical analysis plan? SAP vs protocol

A statistical analysis plan (SAP) translates protocol commitments into analyses that can be reproduced before unblinding. The protocol describes objectives, design, eligibility and endpoints; the SAP specifies estimands, analysis populations, models, missing-data procedures and reporting rules. That is the core of SAP vs protocol: protocol amendments change how the trial is run, while SAP amendments change how it is analysed, and both need documented approval.

Throughout this article, a hypothetical antihypertensive trial, with change in systolic blood pressure from baseline to Week 12 as the primary endpoint, illustrates each decision. The protocol names the outcome and time point; the SAP states the change score, population, covariates and contrast.

02Statistical analysis plan components for clinical trials

The statistical analysis plan components below are those reviewers check first.

Objectives, hypotheses and populations. State the objectives, endpoint hierarchy, treatment comparison, significance level, power and assumptions, and align the hypothesis with the primary estimand. Define populations operationally: under intention-to-treat (ITT), participants are analysed as randomised; a full analysis set (FAS) may approximate ITT with justified exclusions; the per-protocol set applies predefined adherence criteria; the safety set usually includes dosed participants, analysed by treatment received. Define protocol deviations before unblinding.

Endpoint analyses. Specify each endpoint’s method, treatment effect, covariates, contrast, assumptions and reporting (Table 1). For the Week 12 example, ANCOVA models baseline-adjusted change and reports the adjusted mean difference with its confidence interval. A mixed model for repeated measures (MMRM) includes treatment, visit, their interaction and baseline; prespecify the covariance structure and a fallback if the model fails to converge, rather than choosing a structure after seeing results.

Table 1. Statistical analysis plan example: endpoint types and what the SAP must specify
EndpointPossible methodEssential SAP specifications
ContinuousANCOVAChange, baseline covariate, adjusted mean difference and confidence interval
Repeated continuousMMRMTreatment, visit, interaction, covariance structure and convergence
BinaryLogistic regressionOutcome coding, covariates, odds ratio and sparse-data strategy
Time-to-eventCox modelEvent, censoring, time origin, hazard ratio and proportional hazards
CountPoisson or negative binomialDistribution, exposure offset, overdispersion and rate ratio

03Estimands, intercurrent events and missing data

An SAP in clinical trials must say how post-randomisation events affect the treatment effect. ICH E9(R1) describes an estimand through five attributes: population, treatment, variable (endpoint), handling of intercurrent events and population-level summary [3].

Suppose a participant stops treatment because of an adverse event before Week 12. Under a treatment-policy strategy, the Week 12 value is used regardless of discontinuation. Under a hypothetical strategy, the analysis estimates the outcome as if discontinuation had not occurred (Figure 1). The two answer different clinical questions, so the SAP should justify its choice.

Statistical analysis plan components
Figure 1. Two intercurrent-event strategies for the same discontinuation answer different treatment-effect questions. Author-prepared illustration.

Discontinuation is an intercurrent event; a missing Week 12 measurement is a missing-data problem. For repeated measures, MMRM is a common primary analysis under a missing-at-random assumption. If multiple imputation is used, document the imputation model, variables and pooling. Sensitivity analyses, such as delta adjustment or a tipping-point analysis, should test departures from the primary assumption [1, 3].

04Sample size, interim analyses and safety

Align the sample-size calculation with the primary estimand and analysis. For continuous endpoints, state the target difference, standard deviation, significance level, power, allocation ratio and expected dropout; for time-to-event endpoints, the target hazard ratio, required events, accrual and follow-up. For interim analyses, define timing, information fraction, stopping boundaries and how alpha is spent, plus data monitoring committee access to unblinded data [2]. For safety, define treatment-emergent adverse events, the coding dictionary and version, the observation period and denominators [2].

05Programming specifications and ADaM traceability

Define analysis datasets and derivations. ADSL holds subject-level information such as treatment and population flags; Basic Data Structure (BDS) datasets support parameter- and visit-level analyses through variables such as PARAMCD, AVISIT, BASE and CHG. For the Week 12 change, trace the source assessment, baseline selection and CHG derivation to the model and the output table. Our guide to SDTM vs ADaM works through a baseline example, and TLFs in clinical trials shows how outputs map back to the SAP.

06What reviewers flag in a statistical analysis plan

Vague or post-hoc specifications. “Appropriate tests will be applied” cannot be executed. Name the model, covariates, contrast and diagnostics, and define subgroups before comparative results are seen (Table 2) [1].

Protocol–SAP discrepancies. Reconcile endpoints, assessment times, populations or sample-size assumptions that differ, decide whether a protocol amendment is needed, and keep dated approvals.

Weak missing-data, multiplicity or sensitivity strategies. Excluding participants with missing outcomes can bias results. Where there are several confirmatory endpoints, define the testing families and control the overall Type I error rate (family-wise error rate) with a prespecified method, such as Bonferroni, Holm, fixed-sequence (hierarchical) testing or gatekeeping [4].

Incomplete programming and QC rules. Unclear derivations, visit windows, censoring or denominators produce inconsistent results. Specify independent programming and checks across the SAP, ADaM, TLF shells and clinical study report.

Table 2. Vague SAP wording that reviewers flag, and a more defensible version
Weak specificationMore defensible specification
Missing data will be handled appropriately.State the assumption, method, model variables and sensitivity analyses.
Appropriate tests will be used.Name the endpoint model, contrast, covariates and diagnostics.
Outliers will be assessed.Define criteria; do not delete observations automatically.
Subgroups will be analysed.Define variables, cut-offs and interaction tests.

07When to finalise a statistical analysis plan

ICH E9 expects the SAP to be finalised before the blind is broken, with the dates of finalisation and unblinding recorded [2]. Gamble and colleagues recommend writing it early, before data are collected, with the blind review as the last chance to amend it [1]. A blind review may reveal data-quality issues, but it must never be used to choose methods based on treatment differences. Record every amendment with its rationale and date.

08Statistical analysis plan template and QC checklist

A statistical analysis plan template is only useful when every decision is explicit. Use Table 3 as a final check. Gamble and colleagues’ 55-item recommendations give a content framework rather than a regulatory checklist [1]; SPIRIT 2025 [5] and CONSORT 2025 [6] guide the protocol and the report, and neither replaces a full SAP.

Table 3. Statistical analysis plan template: quality-control checklist
Quality checkWhat to verify
Objectives and endpointsDefinitions, hierarchy, estimand alignment and assessment times
Populations and deviationsITT, FAS, PP, safety set and exclusion rules
EstimandsFive attributes and intercurrent-event strategies
Sample sizeEffect, variability, power, significance, allocation and attrition
Endpoint analysesModel, contrast, covariates, assumptions and diagnostics
Missing dataPrimary assumption, method, alternatives and interpretation
Multiplicity and interim looksTesting family, error control, timing and boundaries
Safety and subgroupsEvent definitions, coding, denominators and interaction tests
Programming and outputsADaM derivations, software, TLF specifications and QC
GovernanceVersion, amendments, approvals and responsibilities

09Conclusion

A well-specified statistical analysis plan makes a trial’s analysis transparent and reproducible. Prespecifying estimands, models, missing-data strategies, multiplicity control and programming rules answers most reviewer questions before unblinding, rather than after.

Questions

What is a statistical analysis plan?

A document that prespecifies a trial’s analyses: populations, estimands, methods, missing-data procedures, multiplicity control and reporting rules.

How do you write a statistical analysis plan?

Translate protocol objectives into hypotheses, populations, estimands, endpoint models, sample-size assumptions, missing-data and multiplicity strategies and programming specifications, then approve it before unblinding.

Why do reviewers challenge an SAP?

Usually for vague methods, protocol inconsistencies, unsupported missing-data assumptions, weak sensitivity analyses, multiplicity errors or thin programming detail.

References

  1. Gamble C, Krishan A, Stocken D, et al. Guidelines for the content of statistical analysis plans in clinical trials. JAMA. 2017;318(23):2337–2343. https://doi.org/10.1001/jama.2017.18556
  2. International Council for Harmonisation. E9: Statistical principles for clinical trials. 1998. https://www.fda.gov/media/71336/download
  3. International Council for Harmonisation. E9(R1): Addendum on estimands and sensitivity analysis in clinical trials. 2019. https://www.fda.gov/media/148473/download
  4. US Food and Drug Administration. Multiple endpoints in clinical trials: guidance for industry. 2022. https://www.fda.gov/media/162416/download
  5. Chan AW, Boutron I, Hopewell S, et al. SPIRIT 2025 statement: updated guideline for protocols of randomised trials. BMJ. 2025;389:e081477. https://doi.org/10.1136/bmj-2024-081477
  6. Hopewell S, Chan AW, Collins GS, et al. CONSORT 2025 statement: updated guideline for reporting randomised trials. BMJ. 2025;389:e081123. https://doi.org/10.1136/bmj-2024-081123
Dr. CharliePubrica · Senior Medical Writer

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  • Published by Pubrica

How to cite this article

Dr. Charlie. (2026, October 31). What Goes in a Statistical Analysis Plan, and What Reviewers Flag. Pubrica. https://pubrica.com/academy/biostatistics-and-statistical-programming-services/statistical-analysis-plan-clinical-trial/

This article is general information for researchers, not legal, regulatory or funding advice. Check the current requirements of your journal, funder, ethics committee or regulator before you act on it.

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