WORKSHOP ON CLINICAL OUTCOME ASSESSMENTS (COAS) IN CANCER CLINICAL TRIALS April 26, 2016 Silver Spring, MD Co-sponsored by WELCOME WORKSHOP ON CLINICAL OUTCOME ASSESSMENTS (COAS) IN CANCER CLINICAL TRIALS April 26, 2016 Silver Spring, MD Paul G. Kluetz, MD OHOP Stephen Joel Coons, PhD PRO Consortium
Registration Packet Contents Welcome Letter Workshop Agenda Presenters and Panelists Biographical Sketches Pre-Registrant List Workshop Feedback Form Active Participation is Encouraged Before you speak, please step to a microphone or let us bring a microphone to you The workshop is being audio recorded Please turn off cell phones or set to vibrate Overall Goals of the Workshop Provide a forum for international drug development stakeholders to hold an open and constructive dialog in
an evolving area of regulatory and health care policy Discuss methods to thoughtfully and scientifically incorporate the patient voice into cancer drug development to better inform regulatory, reimbursement, and treatment decisions Encourage a sustained collaborative effort to continue to work toward improved alignment and strategic use of PRO measures in cancer trials Workshop Sessions Session 1: Reviewing the Patient-Reported Outcome (PRO) Data Needs of Stakeholders: What Questions Are We Asking? Session 2: Using Multiple Instruments to Create a Comprehensive PRO Assessment Strategy in Cancer Trials Session 3: Existing Options for Assessing PatientReported Physical Function Session 4: Physical Function Data in Cancer Trials:
Data Collection, Analysis, and Interpretation Session 1 Reviewing the Patient-Reported Outcome (PRO) Data Needs of Stakeholders: What Questions Are We asking? WORKSHOP ON CLINICAL OUTCOME ASSESSMENTS (COAS) IN CANCER CLINICAL TRIALS April 26, 2016 Silver Spring, MD Co-sponsored by Disclaimer The views and opinions expressed in the following slides are those of the individual presenters and should not be attributed to their respective organizations/companies, the U.S. Food and Drug Administration or the Critical Path Institute.
These slides are the intellectual property of the individual presenters and are protected under the copyright laws of the United States of America and other countries. Used by permission. All rights reserved. All trademarks are the property of their respective owners. Session Participants Chair Stephen Joel Coons, PhD C-Path Presenters Paul G. Kluetz, MD FDA Daniel OConnor, MD MHRA and EMA Keith Tolley, MPhil Tolley Health Economics Ltd. Joseph OConnell, MD InventivHealth Panelists
Mary Lou Smith, MBA, JD Research Advocacy Network Naomi Aronson, PhD Blue Cross Blue Shield Association Chiun-Fang Chiou, PhD Janssen Patient-Reported Outcome Measures in U.S. Regulatory Review of Cancer Products Paul G. Kluetz Office of Hematology and Oncology Products U.S. Food and Drug Administration This talk represents current thinking in an evolving area of scientific and health care policy The views expressed do not necessarily reflect the official position of the U.S. Food and Drug Administration 11
FDAs Use of PRO Data in Oncology FDA reviews the safety and efficacy of cancer therapies Primary and secondary endpoints of submitted trials are most commonly radiographic measures and overall survival PRO data most commonly exploratory endpoints Reviewed as important supportive data during the benefit:risk determination Inclusion of PRO results in product labeling has been challenging 12 Patients Would Like to Know How They May Feel and Function When Taking a Cancer Therapy FDA labeling is only one potential source of PRO and COA data obtained in a clinical trial
FDA clinical and statistical reviews for new drug and biologic products available online http://www.accessdata.fda.gov/scripts/cder/drugsatfda/index.cfm Published literature- Rigorous PRO and other COA data can and should be published contemporaneously with primary efficacy and safety manuscript 13 U.S. Drug Labeling Allows for Drug Marketing and Promotion Federal Food, Drug & Cosmetic Act (FD&C Act) Prescription drug promotion must Not be false or misleading Have fair balance Be consistent with the approved product labeling Include claims substantiated by adequate and well-controlled clinical studies
14 FDA Labeling Considerations If claiming treatment benefit (Drug X decreases cancer pain) Requires substantial evidence with pre-specified endpoint definition, statistical testing and control of Type I error Requires well-defined and reliable assessments in adequate and wellcontrolled trials Whether a claim of benefit, or describing safety data, labeled data must be interpretable and effects should be related to the drug Purpose of conducting clinical investigations of a drug is to distinguish the effect of a drug from other influences Adverse events for which there is some basis to believe there is a causal relationship between the drug and the occurrence 15 Integrating More of the Patient Experience in FDA Labeling
Labeled PRO data has typically been generated from proximal symptom and functional outcome assessments more directly related to the effect of the drug (Rock 2007, PMID: 17991927) We are interested in exploring opportunities for PRO assessments in cancer trials that may be suitable to help inform patients and providers in product labeling 16 Proximal symptom and functional outcome assessments For labeling considerations, proximal symptom and functional outcome assessments are favored and are important components of HRQoL Proximal concepts are not the
only PRO data to assess or measure, but they have been the focus of our analysis to consider for potential inclusion in product labeling Figure from Kluetz et al., Focusing on Core Patient-Reported Outcomes in Cancer Clinical Trials: Symptomatic Adverse Events, Physical Function, and Disease-Related Symptoms, 2016, Clinical Cancer Research, Epub 2016, Jan 12. Patient Reported Outcome Data Held to the same standard as any other data that supports the safety and efficacy of a treatment What is the objective of a PRO assessment? If primary or key secondary endpoint to determine efficacy, trial design should be consistent with that goal Blinding Enrichment for symptomatic or functionally impaired patients Example: Jakafi (ruxolitinib) 18
Safety in a Changing Therapeutic Context Current Drug Development Era: Prior Drug Development Era: Mechanism: Cytotoxic Chemotherapy Intermittent Intravenous Administration Shorter Duration of Treatment Adverse events typically Neuropathy, Mucositis, Bone Marrow Suppression, Fatigue, Nausea/vomiting, Diarrhea, Hair Loss, Taste Changes
Mechanism: Diverse, including Cytotoxic, Immune, Antibodies, Small Molecule targeting Various Pathways. Continuous Daily Oral Administration becoming more common More Prolonged Duration of Treatment Adverse events can differ depending on mechanism and target. Systematic PRO assessment of symptomatic adverse events with a flexible PRO instrument could be of value 19
Safety and Tolerability How will I feel and function while taking this therapy? While there is a role for efficacy assessment with PRO, FDA is also evaluating new and existing PRO measures to inform safety and tolerability Descriptive data on symptomatic adverse events and how patients function and carry out their activities while on cancer treatment Safety and Tolerability is a PRO measurement Opportunity Safety is a key trial objective across all stages of drug development Systematic assessment of symptomatic adverse events can add important descriptive data to complement existing clinician reported safety assessments Can physical function describe the tradeoff between efficacy and toxicity? FDA: One of Many Stakeholders Who Utilize PRO Data Panel 1 will hear perspectives from several key stakeholders
who incorporate patient reported outcome data in their decision making Figure from Kluetz et al., Focusing on Core Patient-Reported Outcomes in Cancer Clinical Trials: Symptomatic Adverse Events, Physical Function, and Disease-Related Symptoms, 2016, Clinical Cancer Research, Epub 2016, Jan 12. The Goal for PRO Measures Common Goal that We All Share: Reliable and responsive PRO assessments that help inform a drugs effect on patients is EVERYONEs goal Optimizing PRO data is not a regulatory issue, it is a scientific issue Exploring Clinical Outcome Assessments (COA) including PRO measures in the Evaluation of Oncology Therapies Increasing FDA statistical, COA staff and clinical reviewer resources and expertise related to COA measurement in oncology Interacting with COA academic and international policy stakeholders
Continuing to learn from patients in patient-focused drug development meetings and other interactions 22 Reviewing the Patient-Reported Outcome (PRO) data needs of stakeholders: What questions are we asking? - EU regulators view Dr Daniel O'Connor Medical Assessor - MHRA Disclaimer The views expressed do not necessarily reflect the official position of the MHRA, the EMA or their committees 24 European regulatory framework
Member States (MS) have one or more medicines Competent Authorities UK authority is the Medicines and Healthcare products Regulatory Agency MS & the European Medicines Agency (EMA) work together in a regulatory network EMA is the medicines regulatory agency of the EU, the EMA co-ordinates, through its scientific committees the evaluation of new oncology medicines Scientific Committees are made up of experts from the EU countries, as well as representatives of patient and healthcare-professional organisations Working parties are convened to carry out specific tasks in their respective fields
Scientific Advisory Groups provide independent scientific recommendations Scientific advice is given by the Scientific Advice Working Party There is an extensive collection of EU scientific/ regulatory guidance documents 25 In total, the EMA works with a network of over 4,500 external European experts Involving the patient in regulatory activities
26 The Patients' and Consumers' Working Party (PCWP) provides a platform for exchange of information and discussion of issues of common interest between EMA and patients and consumers Patient involvement in regulatory activities is growing and diversifying year on year The inclusion of patients in protocol assistance procedures began in 2005 Patient experiences adds a valuable dimension http ://www.ema.europa.eu/docs/en_GB/document_library/Report/2015/10/WC5001950 83.pdf Guidelines Guidelines provide a basis for practical harmonisation
of how MS/EMA interpret & apply the requirements for the demonstration of quality, safety & efficacy (questions we are asking) Main oncology guideline is the Guideline on the evaluation of anticancer medicinal products in man The revised 2012 guideline refers to a proposed Appendix 2, PRO measures in oncology 27 Appendix 2: PRO measures The oncology working party held a workshop on health-related quality of life
(HRQL) in 2012, bringing together relevant experts to help inform on the content of the new PRO appendix in oncology The appendix will be imminently published following a public consultation and extensive revision of a reflection paper Key message The importance of the patients point of view on their health status is fully acknowledged and such information may be used in drawing regulatory conclusions regarding treatment effects, in the benefit risk balance assessment or as specific therapeutic claims 28 Use of PRO measures in oncology studies The PRO appendix has 19 pages, 8 sections and 53 references
The appendix covers general aspects of the use of PRO endpoints in oncology studies: o Specific sections on symptom PRO measures and Health Related Quality of Life (HRQL), clinical trial design and clinical importance o PRO: A PRO includes any outcome evaluated directly by the patient himself or herself and is based on patients perception of a disease and its treatment(s) o PRO measures (PROMs) are the tools and/or instruments that have been developed to ensure both a valid and reliable measurement of these PROs Key aim By outlining broad principles of scientific best practice rather than prescribing a particular approach to PRO selection and application, the appendix aims to encourage developments in the methods and application of PROs in the oncology regulatory setting 29 Why include PRO assessment? Provide a patient focused assessment of the burden and impact of disease, by
understanding how a treatment impacts on patient functioning and well-being Add information on the clinical benefit of a therapy by complementing efficacy and safety data with patient-reported evaluation Assess the relationship/ agreement between clinical reported endpoints and other patient-reported endpoints Attempt to differentiate two treatments, where the primary endpoint is an objective measure Provide information to facilitate more accurate future patient-physician communication in terms of the quality of the survival time remaining for the patient and the burden of treatment-related morbidities and disease-related patient impacts 30 General recommendations for PRO measures An assessment or rationale for the extent to which the inclusion of PRO measures can provide added value in the clinical trial setting Consider whether the collection of PRO data can detect meaningful effects and make
a difference to the study conclusions and benefit risk balance assessment A clear hypothesis lead strategy is strongly recommended and measures should be selected based on the scientific rationale PROM should be considered early in the development programme Consideration should be given to patient involvement in the study design process and in the evaluation of study feasibility PRO data reporting should be adequately performed and PRO data should be treated with the same importance as other clinical data 31 Which instrument(s) to choose? There are many instruments in the published literature The new PRO appendix does not cover the validation of instruments nor does it make specific recommendations regarding which instrument to select, but: o Important to select the most appropriate instrument(s), in line with the study objectives and the characteristics of the patient population o The most appropriate and valid PRO measures have often involved patients
in their development o PRO measures should be acceptable to the population in which they will be administered, both in terms of the questions they ask and the overall burden to the patient o PRO instruments and assessments should be capable of detecting clinically meaningful effects o Consider special populations (children, adolescents & young adults, elderly, palliative setting, patients with rare diseases) and linguistic and cultural validation 32 EMA HRQL guidance is also available Discusses the place that a HRQL may have in the drug evaluation process and gives some broad recommendations on its use in the context of already existing guidance
documents (2005) HRQL goes beyond efficacy and safety assessments, which are the basis for drug approval 2016 Oncology WP work plan: This is an overarching guidance in need of updating A Concept paper to be agreed Q2 2016 33 Clinical importance and added-value The importance of the patients point of view on their health status is fully acknowledged and such information may be used in drawing regulatory conclusions However, poorly defined PRO objectives and lack of a priori specification of the expected effect have hampered the usefulness of PROs in regulatory decision
making But PRO information can enhance decision making by providing a better understanding of the potential impact of both the disease and treatment on a patient PRO instruments and assessments must be capable of detecting clinically meaningful effects Added value may be derived if patients and clinicians have a more complete picture of the expected impact of a treatment on the patients perception of adverse reactions and on disease related symptoms 34 . What (questions) are we asking for? We want to capture the patients perspective during the drug development process and at regulatory approvals This is reflected by increasing patient involvement in scientific advice, EMA committees and the launch of a specific PRO appendix in oncology PRO appendix aims to encourage developments in the methods and application
of PROs in the oncology regulatory setting PRO measure should be considered early in the development programme Careful planning and an in-depth analysis of whether the inclusion of PROM is likely to make a potential difference to the study conclusion should be made PRO data should be treated with the same importance as other clinical data Scientific advice at the EMA (+ parallel with FDA) can help with the challenges 35 Thank You [email protected] 36 A European Health Technology Assessment Perspective Keith Tolley Director, Tolley Health Economics Ltd.
WORKSHOP ON CLINICAL OUTCOME ASSESSMENTS (COAS) IN CANCER CLINICAL TRIALS April 26, 2016 Silver Spring, MD Co-sponsored by Overview What role does PRO evidence play in HTA of new cancer pharmaceuticals in Europe (UK, Germany as examples)? What might change the role of PRO measures and their inclusion in HTA? 11 years experience as an assessor with one of the UK HTA bodies (Scottish Medicines Consortium) and extensive work supporting and advising company submissions to the National Institute for Health and Clinical Excellence (NICE) HTA: the classic 4th hurdle for market access!
Source: http://blog.kantarhealth.com/blog/blogger-profiles/susan-suponcic/susan-suponcic/2011/09/09/no-longer-a-milestone---market-access-as-a-mindset HTA in UK and Europe Network of HTA organisations in Europe appraise new technologies for value assessment on behalf of public payers: NICE (National Institute for Health and Clinical Excellence) in the UK, IQWiG in Germany, CVZ and TLV in Sweden, AHTAPol in Poland, and emerged HTA in Russia, Slovenia, Romania Support negotiations on reimbursement and value based pricing of new pharmaceuticals Anti-cancer pharmaceuticals are routinely subjected to HTA in the UK: The PD-1 inhibitor Opdivo (nivolumab) has been turned down as a treatment for locally advanced or metastatic squamous non-small cell lung (NSCLC) whose disease has progressed after prior chemotherapy, with NICE saying it is simply too expensive (Dec 2015). NICE's final rejection of Kadcyla (trastuzumab emtansine) for HER2-positive, unresectable locally advanced or metastatic breast cancer after treatment with trastuzumab and a taxane comes despite Roche offering undisclosed discounts on the drug's 90,000-a-year list price, and after the drug was also turned down by the Scottish Medicines Consortium (SMC) (Dec 2015). NICE supported the use of Xtandi (enzalutamide) in patients whose prostate cancer has spread after the failure
of first-line therapy but for whom chemotherapy is not yet necessary. [The drug] can delay the need for chemotherapy, is well-tolerated and improves survival, said NICE, and is an appropriate use of NHS resources, with an incremental cost-effectiveness ratio of 34,500 compared to best supportive care (Dec 2015). Patient-relevant outcomes in cancer HTA A core principle of Value Assessment of new pharmaceuticals conducted by HTA bodies such as NICE and IQWiG is that the benefits of treatments are patient relevant. Methods guidance for both bodies state this means evidence to support: Mortality benefits Patient Reported Outcomes (PRO) measures describing how the patient feels and functions: Morbidity/disease symptoms Health related quality of life (HRQoL): impact on physical, psychological and social wellbeing as perceived by the patient. Treatment satisfaction/convenience Extent of harm/adverse events
NICE and IQWiG NICE: Remit is to assess comparative clinical and cost-effectiveness of selected health technologies in order to offer guidance to the National Health Service in England and Wales: Perform technology appraisals of all new cancer drugs (from 2016): recommend for use, for coverage with evidence development or not recommend IQWiG: Remit is to conduct therapeutic benefit assessment and health economic evaluation in order to support Ministry of Health (G-BA) decisions on reimbursement of new pharmaceuticals and pricing negotiations in Germany Categories: major additional therapeutic benefit, considerable, minor, unquantifiable, unproven, none, less
Both HTA bodies review the drug trial evidence base to assess and appraise PRO data so for cancer this primarily includes the HRQoL impact of experiencing symptoms of disease and disease progression, being in remission (PFS) with complete or partial response, adverse events associated with treatment. However, qualitative input from patients plays an important part! But diverging approaches!
Common desire for PRO evidence AND RCTs are primary source of treatment effect data = A high need for a range of COAs in cancer drug trials However, the reality is somewhat different.. For NICE, PRO measures usually quantify an impact on HRQoL that translates (with survival) into Quality Adjusted Life Years (QALYs) for the evaluation of costeffectiveness (NICE Methods Guidance, 2013). Evidence base should include a generic HRQoL instrument/questionnaire (e.g. EQ5D) NICE allow mapping from other health-related quality of life measures or health-related benefits observed in the relevant clinical trial(s) to EQ5D Disease-specific utility instruments have been developed but little expressed in NICE methods guidance The EORTC-8D is a subset of the QLQ-C30 that has had an algorithm developed to convert responses into utility estimates (Rowen et al, 2011) For IQWiG, economic evaluation plays a smaller role and they do not state a preference for QALY outcomes (although they do allow it)! IQWiG methods guidance (April 2015) states that Parallel to the use of a generic
instrument, disease-specific instruments to determine quality of life in clinical studies should be applied. The mapping of disease-specific to generic instruments is therefore discouraged. Case studies: (1) Kadcyla Assessment of Kadcyla (trastuzumab emtansine) Patient population HER2-positive metastatic breast cancer, with prior treatment with anthracyclines, taxanes and trastuzumab Comparator Lapatinib + Capecitabine Primary clinical evidence Randomised, open label phase III study vs. apatinib + capecitabine with PFS and OS as coprimary endpoints (EMILIA)
NICE recommendation Not recommended IQWiG benefit assessment Indication of major added benefit Survival benefits Significant median of ~ +6 months OS benefit (PFS of +3.2 months) Cost-effectiveness (NICE) +167k per QALY gained PRO/HRQoL measures in trial
Time to symptom progression as a proxy for HRQoL in one RCT defined as a decrease of 5 points or more from baseline score on the Trial Outcome Index of the Functional Assessment of Cancer Therapy-Breast Cancer (FACT-B) = +2.5 months benefit (p=0.01). EQ 5D utilities of 0.71 and 0.69 for treatment with Kadcyla and comparator respectively Impact of PRO on HTA appraisal: NICE guidance (TA371, Dec 2015) Appraisal Committee (AC) noted that trastuzumab emtansine prolonged survival, with less toxicity than Lapatinib + Capecitabine. Generally accepted the utility values for PFS, but made no mention of the other PRO data in the final consideration of the evidence. Impact of PRO on HTA appraisal: IQWiG Extract report (Mar 2014)
IQWiG concluded that added survival benefit was considerable, and HRQoL assessment provided a hint of considerable added benefit for white ethnicity patients (+3.8 months median time to symptom progression). Case studies: (2) Xtandi Assessment of Xtandi (Enzalutamide) Patient population Metastatic hormone-relapsed prostate cancer in people who have no or mild symptoms after androgen deprivation therapy has failed, and before chemotherapy is indicated Comparator Placebo (BSC/watchful waiting) Clinical evidence
A randomised, placebo-controlled trial with co-primary endpoints of OS and radiographic PFS (PREVAIL) NICE recommendation Recommended (with confidential price discount) IQWiG benefit assessment Indication of considerable added benefit for men aged <75 and major added benefit for men 75 Survival benefits Statistically significant median OS benefit of +2.2 months HR=0.71 (95%CI:0.60 0.84) - affected by cross-over confounding. IQWiG analysis focussed on greater survival benefits in patients 75 years (OS benefit of +6.1 months)
Cost-effectiveness (NICE) +27,036 per QALY gained PRO/HRQoL measures in trial Functional Assessment of Cancer Therapy Prostate (FACT-P) and EQ-5D whilst on treatment. FACT-P decrease in score (worse HRQoL) from baseline in both arms, but clinically meaningful deterioration (>6 point decrease) only seen for placebo. (NICE) Statistically significant additional time till worsening HRQoL of +5.7months (IQWiG) EQ 5D higher end of treatment utility for enzalutamide vs placebo (+0.02) (NICE) Impact of PRO on HTA appraisal: NICE Guidance (TA377, Jan 2016) Focus of AC discussion was on OS estimates, and methods for dealing with crossover bias. No discussion of the FACT-P results in the AC consideration of evidence The utility value estimates were a key driver in the cost-effectiveness, so of high importance.
Impact of PRO on HTA appraisal: IQWiG Extract Report (Mar 2015) IQWiG concluded a major added benefit for survival outcomes (over 75), but a hint of a major benefit in HRQoL based on significantly longer time to worsening in FACT-P. However, stated there was no evaluable EQ 5D data so added benefit not proven. Limitations of using PRO data in cancer HTAs In the UK at least all roads lead to the QALY, for HTA-based decision-making with the dominance of the EQ5D The German benefit assessment approach naturally places a greater emphasis on results from PRO measures for HTA, but impact still limited in relation to the impact of traditional clinical endpoints in cancer trials, in particular survival. Historically, PRO endpoints and measures have not been routinely included in clinical trials or well specified (designed for regulatory or HTA approval)
A systematic review of RCTs in breast cancer 1990-2009 found only 24% included a PRO measure, and mostly as a secondary endpoint (~80%) (Brettschneider et al, 2011) Most common instrument was cancer specific EORTC questionnaires (~50%) (Brettschneider et al, 2011) A systematic review of 75 most recent HTA focussed trials in the UK up to 2013 found only 33% included PRO measures, and of these 61% were incomplete (e.g. in terms of PRO rationale, data collection methods, training, interpretation in relation to traditional endpoints) (Kyte et al 2014) Trials increasingly appear to be including the EQ5D and QLQ-C30 or FACT questionnaires, but are often sub-optimal for the needs of HTA e.g. Only administered up to 28 days beyond treatment end = does not provide What could improve wider PRO measure use and impact within HTA? 1. Continued work to improve the inclusion and specification of validated PRO measures in clinical trial protocols (e.g. aided by Appendix 2, PRO measures in oncology)
2. An agreed common set of cancer specific and generic (utility based) measures for inclusion in cancer RCTs (as key secondary endpoints): Area for EMA and HTA collaboration? 3. More real world/observational studies and pragmatic RCTs in cancer with a range of validated PRO measures 4. There is movement towards coverage in evidence development or other post launch managed access schemes in Europe for cancer drugs (e.g. 2016 cancer drugs fund in UK), hence PRO measures need to be integrated into the post launch data collection aligned to these schemes. References Brettschneider et al. Informative Value of Patient Reported Outcomes. GMS Health Technology Assessment 2011; Vol 7; 1-15 Kyte et al. Systematic evaluation of the Patient-Reported Outcome (PRO) content of clinical trial protocols. Plos-one
2014; Vol 9 (10); 1-12 Rowen et al. Deriving a preference based measure for cancer using the EORTC QLQ-C30. Value in Health 2011; Vol 14 (5) An Industry Perspective Caught in the Middle Joseph OConnell, MD VP, Hematology Oncology Area Lead InventivHealth Clinical WORKSHOP ON CLINICAL OUTCOME ASSESSMENTS (COAS) IN CANCER CLINICAL TRIALS April 26, 2016 Silver Spring, MD Co-sponsored by Disclosures I have no conflicts to disclose I will not be discussing any information related to specific ongoing clinical research projects which inVentiv Health supports
Historic perspective Development Planning for pharmaceutical companies assets often relegates PRO/ HEOR to a diminished importance: - Leadership for development of the overall Clinical Plan is in the hands of a Clinician or Asset Lead with an MD or PharmD background; - Input to Phase 1 design: key roles for Pharmacology and Safety; - Phase 2 planning: Regulatory Strategy and Commercial Projections become more relevant. HEOR is largely seen as necessary to satisfy regional regulatory strategy (e.g. EU), and inform economic analyses in highly regulated healthcare environments, not as information that is valuable to prescribers and patients. Why the traditional resistance to early collection of PRO data in the course of clinical development? On the Sponsor study team Unfamiliarity with the terminology and conceptual basis: Concepts such as content validity and minimally important difference are not part of the training and education of clinical, statistics and commercial colleagues;
US-centric approach: Lack of impact on FDA label equates with minimization of the importance of PRO endpoints. Culture of lack of commitment to doing it right compromises the output (improper administration and missing data). For the Sponsor Budget: Cost of administration, monitoring, analysis is seen as not worth the $ that alternatively could go to pK analysis, central radiology reading and other competing budgetary priorities. At the Site: Perception that patients are burdened by too many questions; Site resistance due to interruption in patient flow at the clinic. The Historic Reality: The impact of a new drug on PRO is minimal when the clinical benefit is a relatively small increment on the patient with metastatic cancer !
PRO measure implementation complicates the conduct of studies Deciding on which PRO measure to deploy. Obtaining and distributing translations. Instructing sites at Site Initiation Kickoff When to collect; How to collect: Who responds, etc.
Additional monitoring burden in data-heavy Phase 1 trials Baseline not missing; All questions answered; Timing prior to other procedures. Data Output and Statistical analysis require a resource commitment, when the major focus is on establishing safe dose and estimating efficacy. Prior to Phase 2 readout and Proof of Concept: is it worth the effort? Quote: The value of PROs to patients and prescribers The efficacy of chemotherapy in incurable malignancies is usually assessed through response rates, toxicity, disease-free survival, and OS. However, these parameters do not allow for an assessment of the overall therapeutic benefit because they do not provide information about the clinical condition of the patients, their experience while undergoing treatment, or the quality of their survival.
Treatment choices that patients make are influenced by numerous factors, including the value they place on potential improvements in survival. Studies have shown that cancer patients want to have QOL information to help in their decision making, and that most oncologists are unwilling to prolong survival at the expense of worsening QOL, although QOL considerations play a relatively small role in treatment decisions in current practice Andrea Bezjak et al. JCO 2006;24:3831-3837 Case Study: Erlotinib in Non-small Cell Lung Cancer Tavceva label: Tarceva is also indicated for the treatment of patients with locally advanced or metastatic NSCLC after failure of at least one prior chemotherapy regimen. 1 The Registration Study, BR.21: Double-blind phase III trial Previously treated NSCLC Randomly assigned to erlotinib 150 mg daily or placebo
Primary study outcome = Overall Survival QOL: EROTC QLQ-C30 EORTC QLQ-LC13 The primary end points for QOL analysis were time to deterioration of three common lung cancer symptoms: cough, dyspnea, and pain. 2 1 http://www.ema.europa.eu/. 2 Andrea Bezjak et al. JCO 2006;24:3831-3837 BR.21 PRO outcomes in a positive P3 study Or The bad old days of incremental benefits Time to quality-of-life deterioration for (A) cough (B) dyspnea (C) pain. Patients with advanced NSCLC who have previously been treated with (and progressed during or relapsed after)
chemotherapy are expected to deteriorate. In that clinical setting, a benefit may be defined not only as an improvement in baseline symptoms, but also as a delay in progression of symptoms.1 Couldnt we have predicted this deterioration?? P2 results: ORR 12.3 %, PFS 9 weeks; P3: PFS 2.2 vs 1.8 month for placebo 2 1Andrea Bezjak et al. JCO 2006;24:3831-3837 2 Perez-Soler JCO August 15, 2004 2006 by American Society of Clinical Oncology The present: Erlotinib and Personalized Medicine Erlotinib in unselected patients (BR.211):
Median PFS 10 .3 weeks Erlotinib versus chemotherapy in First Line patients with EGFR mutations (EURTAC2) Median PFS 97 months 1Shepherd, NEJM, July 2005 2 Rosel, Lancet Oncology; March 2012 Improved drug targeting = Changing Times in Drug Development: Increased Expectations for Benefit American Society of Clinical Oncology Perspective: Raising the Bar for Clinical Trials by Defining Clinically Meaningful Outcomes Ellis, JCO,March 2014 Pre-2005
2005-2013 Future New Therapies with Incremental Benefit. Measurable improvement in symptoms are neither expected nor sought Targeted Therapies move the Goalpost for achievable and meaningful Clinical Benefit PROs are frequently included in publication and presentations of trial results 02/23/2020 EGFR Tyrosine Kinase Inhibitors No longer seen as substantially benefiting patients unless there tumor
has a sensitizing EGFR exon 19 deletion or exon 21 point mutation. Approved in 1st line due to improved PFS compared to standard chemotherapy: Erlotinib Gefitnib Afatinib Margins of benefit in symptoms and QoL measures are similarly more robust than in unselected patients (next slide) 1Shepherd, NEJM, July 2005 2 Rosel, Lancet Oncology; March 2012 Impact of an EGFR TKI on QoL in appropriately selected population Results from the longitudinal analysis of global health status/quality of life (QoL) and functional scale domains for afatinib compared chemotherapy. 2013 by American Society of Clinical Oncology
James Chih-Hsin Yang et al. JCO 2013;31:3342-3350 Accelerated approval provides opportunities for sponsors but requires a different development paradigm 2014 2015 Standard Development Paradigm 2016 Phase 1 2017 2018
2019 Phase 2 2020 2021 2022 Phase 3 NDA 2023 Launch
Proof of Concept 2014 2015 2016 2017 2018 2019 2020 2021
2022 Registrational Intent Accelerated Pathway Dose Finding E x NDA Launch
Registrational Intent ESOE PD/RR signal KEY: Ex = Expansion Phase PD/RR = Pharmacodynamic/response rate ESOE = Early sign of Efficacy GO/NO-GO Proof of Concept circa 24 MONTH DIFFERENCE BETWEEN
STANDARD AND ACCELERATED PLANS 2023 Case Study: Phase 1 study of nivolumab (2012)1 A maximum tolerated dose was not reached. Initially, 5 expansion cohorts of ~ 16 patients each were enrolled: melanoma, NSCLC, renal-cell cancer, prostate cancer, colon cancer On the basis of initial signals of activity, additional expansion cohorts of approximately 16 patients each were enrolled for: melanoma (doses of 1.0 or 3.0 mg/ kg, followed by cohorts randomly assigned to 0.1, 0.3, or 1.0 mg/ kg); lung cancer (randomly assigned to a dose of 1.0, 3.0, or 10.0 mg/kg), renal-cell cancer 2015 Press Release: The U.S. Food and Drug Administration today approved Opdivo (nivolumab) to treat patients with advanced (metastatic) renal cell carcinoma 2
Q: Will the opportunity to learn about PRO impact in P1/2 be lost, due to the rapidity of the development path?? Where to fit in PRO Measures? 1 Topalian, et.al. N Engl J Med 2012; 366:2443-2454 FDA Press Release, Nov 25, 2015 New US reimbursement environment and emergence of Value criteria: an emerging impact on PRO strategy There is a multiplicity of rapidly emerging therapeutics for payers to evaluate: Myeloma: 5 new drugs in 2015. Overall Survival improved dramatically in last decade, and up to 7 new submissions expected in next 2 years Multiple new indications for PD-1/ PD-L1 antibodies; NSCLC: 8 new approvals in last 18 months; On the horizon: CART-cell therapy, new Antibody-drug conjugates; etc., etc. $$$ Payers and Physician Groups seek to devise optimal Clinical Pathways, as physicians are placed at risk for the Total Cost of Care. Focus on Value.
Outcome / Cost = Value Whose Quality (Payer? Patient? Society?) What measure of Outcome: OS? PFS/ ORR? Who speaks the Patient Voice? Caught in the Middle: Changes in Efficacy, Approval Process and Access intersects with Clinical Development Voice of Advocacy Pre-2005 2005-2013 New Therapies with Incremental Benefit. The Middle
Future Accelerated Approvals In Oncology Improvement in symptoms little attended in development Targeted Therapies move the Goalpost for achievable and meaningful Clinical Benefit PROs are frequently included in publication and presentations of trial results New Reimbursement Environment Quality Value
PRO moves front and center 1 1 Gross, Emmanuel, Jama Oncology, Jan 2016 2 Jensen, Snyder, JCO, Feb 2016 3 Porter, Larsson, Lee, NEJM, Feb 2016 2 3 Summary: Clinical Development plans are changing as we look for bigger gains. Pharma and Regulatory Agencies collaborate on more rapid approval process.
Patients and Payers are gaining a Voice in what should be paid for. Q: How and When do Sponsors collect valid and relevant PRO data??? Panel Discussion Reviewing the Needs of all Stakeholders: Where are They Similar and Where do They Differ? Session Participants Chair Stephen Joel Coons, PhD C-Path Presenters Paul G. Kluetz, MD FDA Daniel OConnor, MD MHRA and EMA Keith Tolley, MPhil Tolley Health Economics Ltd. Joseph OConnell, MD InventivHealth
Panelists Mary Lou Smith, MBA, JD Research Advocacy Network Naomi Aronson, PhD Blue Cross Blue Shield Association Chiun-Fang Chiou, PhD Janssen WORKSHOP ON CLINICAL OUTCOME ASSESSMENTS (COAS) IN CANCER CLINICAL TRIALS April 26, 2016 Silver Spring, MD Co-sponsored by