Independent · non-commercial · publishes on a quarterly cycle|Current cycle 2026 Q3
Compound Evidence InstituteEvidence synthesis · established 2023Graded assessments of compounds, trials, methods and supply
Document set current to 30 July 2026
Public comment period · §2

Draft monograph: semaglutide, version 3 — submissions

The 14 submissions received, published in full with declared interests and secretariat responses.

Document identifier
CEI-CP-005/2
Series
Public comment period
Version
1.0
Published
03 Apr 2025
Last reviewed
03 Apr 2025
Next review
03 Apr 2026
Identifier
10.71829/cei.cp.5
Certainty
Not rated
Cycle
2025 Q1
Window
03 Feb 2025 – 20 Mar 2025
Status
Closed
Submissions
14

§2Submissions and responses

14 submissions were received. Each is published in full below with its declared interest, the secretariat response and the disposition. The Institute publishes submissions it did not accept in the same form as those it did.

Dr Sigrún Vercingetorix, PhD (Bioanalysis) Academic mass-spectrometry core facility · submitting on mass spectrometry
DRAFT-SEMAGLUTIDE-/001 received 04 Feb 2025

A near-isobaric analogue is not distinguished by the identity determination described

The respondent read the draft on Semaglutide alongside the approved labelling for the class, and submits on one matter arising.

The identity determination described in the draft resolves the compound from unrelated substances but would not distinguish it from a closely related analogue whose mass differs by approximately one dalton.

The respondent proposes that the monograph state the resolution required for that discrimination, and state that a nominal-mass instrument reporting an integer mass has not made it.

Declared interest. Has received consultancy fees from a supplier named in the Institute's supplier assessment set within the preceding two years.
Secretariat responseAccepted23 Apr 2025

The secretariat accepts this submission. The point is decisive where one member of a near-isobaric pair is an approved medicine and the other is not.

The analytical section now states the resolving power required to discriminate the pair, names the pair explicitly, and records that an identity claim made below that resolution is not conformant with the identity standard.

Dr Lorcan Zaleski-Mbeki, MD, MPH University department of public health · submitting on pharmacovigilance
DRAFT-SEMAGLUTIDE-/002 received 08 Feb 2025

Local reactions are omitted from the adverse-event table because the trials reported them separately

This is a submission on the draft covering Semaglutide, from a respondent whose work is with the people taking compounds of this class rather than with the trials that produced them.

Injection-site reactions are reported in the source trials in a table of their own and do not appear in the systemic adverse-event table the monograph reproduces. The result is that the most common adverse experience of a subcutaneously administered compound is absent from the monograph’s adverse-event section.

The respondent proposes that local reactions be carried in the same table as systemic events, with the reporting convention of the source trial recorded in a footnote.

Declared interest. Holds a personal shareholding, below the Institute's materiality threshold, in a diversified fund with pharmaceutical sector exposure. No direct holding in any named company.
Secretariat responseAccepted21 Apr 2025

The secretariat accepts this submission. The omission arose from following the source tables and it produced a misleading total.

Local reactions are now carried in the adverse-event table wherever the source trials report them, footnoted with the convention each trial used.

Dr Fenella Lavrentiev, MD, FRCP Endocrine surgery service · submitting on endocrinology
DRAFT-SEMAGLUTIDE-/003 received 12 Feb 2025

Glycaemic trials and weight-management trials are drawn on interchangeably

The respondent has read the draft monograph on Semaglutide against a caseload in which incretin analogues are prescribed daily.

The compound has two trial programmes with different populations, different doses and different endpoints. The monograph draws on both without saying which programme a given estimate came from, so a reader takes a weight figure obtained at one dose in one population as though it applied at the other.

The respondent proposes that the programme be named against every effect estimate in the assessed-outcome table.

Declared interest. Has received honoraria for educational lectures from a marketing-authorisation holder of a compound named in the draft, within the preceding three years.
Secretariat responseAccepted06 Apr 2025

The secretariat accepts this submission. The two programmes are separable and were not being separated.

Every effect estimate now names its programme, and the assessed-outcome table is split where a compound has more than one.

Dr Leonhard Quenneville, MD, PhD Metabolic medicine service, tertiary centre · submitting on clinical pharmacology
DRAFT-SEMAGLUTIDE-/004 received 13 Feb 2025

The document should state what a reader ought to do

The draft on Semaglutide is a substantial document and the respondent has confined this submission to one matter.

The draft assesses evidence and stops. The respondent, a practising clinician, states that a reader arriving at the document with a decision to make is left to convert an assessment into an action without help, and proposes that each document close with a recommendation.

The respondent argues that other evidence bodies issue recommendations and that declining to do so transfers the difficult part of the work to the reader.

The respondent has read submission 001 above and makes this submission independently of it.

Declared interest. Is a practising clinician who prescribes compounds in the class under assessment. No financial relationship with any manufacturer.
Secretariat responseNot accepted26 Mar 2025

The secretariat does not accept this submission, and records that the point is a reasonable one rather than a misunderstanding.

The Institute assesses evidence and does not issue recommendations, because a recommendation embeds values and a resource context that the Institute does not hold and cannot state. That constitutional limit is published on the methodology page and is not varied by consultation. The submission remains published in full.

Dr Delphine Trelawney, MD, PhD Academic clinical pharmacology unit · submitting on clinical pharmacology
DRAFT-SEMAGLUTIDE-/005 received 14 Feb 2025

The pharmacokinetic section does not connect half-life to the dosing schedule

This submission concerns Semaglutide and makes one point.

The draft reports a half-life and, separately, a dosing interval. The respondent, a clinical pharmacologist, states that the relationship between the two is what determines accumulation and time to steady state, and that the monograph leaves the reader to derive it.

The respondent proposes that time to steady state be stated explicitly, with the assumption from which it was derived.

Declared interest. Has received travel support to attend a scientific meeting from a manufacturer of a compound named in the draft.
Secretariat responseAccepted12 Apr 2025

The secretariat accepts this submission. The derivation is short, it is decision-relevant, and leaving it to the reader invites it to be done wrong.

The pharmacokinetic section now states approximate time to steady state alongside the half-life and dosing interval, with the assumption of first-order elimination stated, and records where the assumption is not supported for this compound.

Dr Quentin Zimmerthal, PhD (Chemistry), CChem Independent analytical consultancy · submitting on analytical chemistry
DRAFT-SEMAGLUTIDE-/006 received 19 Feb 2025

Quantitative claims are reproduced without the method that produced them

The respondent submits on the draft monograph for Semaglutide. The observation arises from teaching the material rather than from prescribing it.

Several figures in the draft are quoted from sources that determined them by different methods. A figure obtained by one determination and a figure obtained by another are not comparable, and the draft places them in the same sentence without distinguishing them.

The respondent, an analytical chemist, proposes that every quantitative claim carry the method that produced it at the point of use rather than in the reference.

Declared interest. Holds a personal shareholding, below the Institute's materiality threshold, in a diversified fund with pharmaceutical sector exposure. No direct holding in any named company.
Secretariat responseAccepted29 Mar 2025

The secretariat accepts this submission. Placing two figures side by side is an implicit claim that they are the same kind of quantity, and in the cases identified they were not.

Every quantitative claim now carries the determination that produced it at the point of use, and figures obtained by non-comparable methods are no longer presented in the same row or sentence.

Dr Ludmila Tollemache, MD, MSc University department of public health · submitting on health-technology assessment
DRAFT-SEMAGLUTIDE-/007 received 23 Feb 2025

The monograph should state what the compound costs

The draft on Semaglutide was read in full. The respondent notes at the outset that this class has an unusually deep randomised evidence base, and that a monograph on it is fairly judged against a higher standard than one on a compound with none.

The respondent states that a reader deciding whether to pursue treatment needs to know what it costs, and that omitting price makes the assessment less useful than it could be.

The respondent proposes that a price range be recorded for each compound with the source and date.

This submission is made by a respondent with a different professional interest in the outcome from the one behind submission 002.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseNot accepted15 Apr 2025

The secretariat does not accept this submission. Price varies by jurisdiction, payer, presentation and date to a degree that no single figure could survive, and a stale price is worse than no price.

No price is recorded. The monograph records the presentations available and the regulatory status in each jurisdiction, which are the facts the Institute can verify and maintain. The submission remains published in full.

Quentin Whitmarsh-Obi, MSc (Clinical Pharmacy) Regional hospital pharmacy department · submitting on medicines information
DRAFT-SEMAGLUTIDE-/008 received 27 Feb 2025

References should carry a persistent identifier for every cited source

Having reviewed the draft on Semaglutide, the respondent makes a single submission, on the view that one point put clearly is more use to the secretariat than six put together.

Several references in the draft carry a journal, a year and a volume but no persistent identifier. The respondent states that retrieval of such a reference is materially slower and that identifiers should be supplied throughout.

The respondent asks in the alternative that where an identifier exists but is not carried, the omission be explained rather than left as a gap the reader must interpret.

Submission 002 concerns the same document. The respondent’s point is a different one.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted in part27 Mar 2025

The secretariat accepts the second limb of this submission and declines the first. Identifiers are supplied wherever the Institute holds one. Where the Institute does not hold an identifier it will not supply one, because a reconstructed identifier that resolves to the wrong record is a worse defect than an absent one.

Every reference without a persistent identifier now carries an explicit statement that the identifier is not held by the Institute, so that its absence is a recorded fact rather than an apparent oversight.

Vittoria Ylönen, MSc (Epidemiology) Health-technology assessment agency · submitting on public health
DRAFT-SEMAGLUTIDE-/009 received 27 Feb 2025

The monograph should not describe how the compound is supplied outside a regulated route

The respondent works on cardiometabolic outcomes and read the draft on Semaglutide with that literature in view.

The respondent states that describing presentations observed in unregulated supply risks being read as a guide to obtaining them, and asks that the material be removed.

The respondent accepts that the information is accurate and objects to its presence rather than to its content.

Declared interest. Holds a personal shareholding, below the Institute's materiality threshold, in a diversified fund with pharmaceutical sector exposure. No direct holding in any named company.
Secretariat responseNoted, no amendment31 Mar 2025

The secretariat notes this submission and records the concern as a real one that the draft had already considered.

No amendment arises. The monograph describes what is supplied and names no supplier, price or route of acquisition, and it carries the standing statement that the Institute assesses evidence and does not recommend use. Describing a presentation a reader may already hold is the condition of being useful to that reader.

Dr Yehudit Yorkstone, PhD (Chemistry), MRSC Academic peptide-chemistry group · submitting on peptide chemistry
DRAFT-SEMAGLUTIDE-/010 received 27 Feb 2025

Mechanistic claims for a peptide fragment are carried without evidence that the fragment acts as described

This is a submission on Semaglutide.

The respondent states that the draft repeats a mechanistic account originating in supply documentation rather than in the primary literature, and that the account attributes activity to a fragment on the basis of the activity of the parent molecule.

The respondent proposes that any mechanistic claim be traceable to a primary source and removed where it is not.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted18 Apr 2025

The secretariat accepts this submission. A mechanism repeated from marketing material has no evidential status regardless of how widely it is repeated.

Mechanistic claims not traceable to a primary source are removed, and those retained carry their source and a statement of whether the underlying work was conducted in vitro, in animals or in humans.

Dr Yusuf Whitmarsh-Obi, MD, MSc (Clinical Trials) University department of public health · submitting on evidence synthesis
DRAFT-SEMAGLUTIDE-/011 received 07 Mar 2025

Every contributing trial shares one sponsor and the monograph does not say so

This submission addresses the draft monograph on Semaglutide. The respondent went through the document twice, once as a specialist and once as a reader arriving without the background.

The respondent, who has published a systematic review of this literature, states that all of the contributing trials for the principal outcome were conducted by a single sponsor, and that this is a property of the evidence base rather than a criticism of any individual trial.

The respondent proposes that sponsor concentration be recorded as a characteristic of the evidence base in the certainty assessment rather than as a note in the discussion.

Declared interest. No financial interest. Has published a systematic review reaching a different conclusion from the draft, which the respondent declares as a non-financial interest.
Secretariat responseAccepted10 Apr 2025

The secretariat accepts this submission. Sponsor concentration bears on what an independent replication would add, and the draft recorded it where a reader was least likely to see it.

Sponsor concentration is now stated with the certainty rating, and the monograph records how many independent sponsors contributed evidence to each assessed outcome.

Dr Henrike Jastrzębska, MD, PhD Metabolic medicine service, tertiary centre · submitting on clinical pharmacology
DRAFT-SEMAGLUTIDE-/012 received 11 Mar 2025

The analytical section is longer than the clinical assessment it accompanies

This submission concerns Semaglutide and a convention used across the Institute’s output.

The respondent states that the analytical section occupies more of the monograph than the assessment of clinical effect, and that the proportions imply the Institute considers the analytical question the more important one.

The respondent proposes that the analytical material be moved to the standards series and referenced rather than reproduced.

This point is adjacent to the one made in submission 003 and the respondent puts it in a form the secretariat can act on.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted in part29 Mar 2025

The secretariat accepts this submission in part. The general analytical material is moved to the standards series and referenced. The compound-specific material stays, because a reader holding a certificate for this compound needs to know what that certificate does and does not establish for this compound.

The analytical section is reduced to compound-specific content and cross-references the relevant standards for the general procedure, which shortens it substantially without removing what is not available elsewhere.

Dr Vittoria Quintanilha, MD, MSc (Clinical Trials) Independent evidence-synthesis consultancy · submitting on evidence synthesis
DRAFT-SEMAGLUTIDE-/013 received 15 Mar 2025

Registered trials that never reported are absent from the monograph

This submission concerns the draft on Semaglutide. The respondent assesses incretin-class evidence for a national body and comments in a personal capacity.

The respondent states that the trial list appears to be drawn from published reports, and that registered trials which completed without a report are therefore invisible. The proportion of a programme that never reported is itself a finding about the evidence base.

The respondent proposes that every registered trial of the compound be listed, with its reporting status, whether or not a report exists.

Declared interest. Holds a personal shareholding, below the Institute's materiality threshold, in a diversified fund with pharmaceutical sector exposure. No direct holding in any named company.
Secretariat responseAccepted20 Apr 2025

The secretariat accepts this submission. A trial list built from publications reproduces publication bias in the shape of the document.

The trial list now includes every registered trial the Institute identified, with its reporting status stated, and the monograph reports the proportion of registered trials for which no result has been posted or published.

Dr Marisol Dunmore-Ekpo, MD, MSc (Clinical Trials) Independent evidence-synthesis consultancy · submitting on evidence synthesis
DRAFT-SEMAGLUTIDE-/014 received 15 Mar 2025

Open-label extension data are presented alongside randomised data without distinction

The respondent submits on Semaglutide, on a matter that is not specific to this draft but is visible in it.

Long-term figures in the clinical section come from open-label extensions in which every participant received the active compound and those who did not tolerate it had already withdrawn. They are printed in the same table as randomised comparisons and in the same typeface.

The respondent proposes that extension data be presented in a separate table, or at minimum in a separately labelled block, and that the surviving-population problem be stated once where it arises.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted17 Apr 2025

The secretariat accepts this submission. An extension estimate answers a different question from a randomised one and should not be read as though it answered the same one.

Extension data now appear in a separate table headed as uncontrolled follow-up, with a standing note on differential withdrawal.

References cited on this page

References are numbered in order of first citation in this document. Each superscript in the text links to its entry below.

  1. International Organization for Standardization. ISO/IEC 17025:2017 General Requirements for the Competence of Testing and Calibration Laboratories. ISO/IEC Standard 2017;3rd edition. identifier not held by the Institute

Identifiers are reproduced only where the Institute holds them. Where a digital object identifier or PubMed identifier is not shown, the Institute has recorded the journal and year and has not constructed an identifier.

Nothing published by the Institute is medical advice, a diagnosis, a prescription, a treatment recommendation or a purchasing recommendation. Compounds supplied for research use are not approved for human or veterinary use in any jurisdiction, and a favourable analytical assessment of a supplier is not a statement that any product is safe or effective. The Institute publishes certainty ratings and never recommendations. No telephone number, messaging handle or ordering channel appears anywhere on this site.