Advancing regulatory science and assessment of FDA REMS programs: A mixed-methods evaluation examining physician survey response

Evolution of Cross-Sectional Survey Protocol Quality Over Time: A Case Series of Index U.S. REMS Knowledge Survey Protocols (2007-2020)

INTRODUCTION

Surveys are commonly used to assess effectiveness of FDA-required risk evaluation and mitigation strategies (REMS) for drugs and biologics in the United States.

OBJECTIVE

The aim of this study was to assess the scientific rigor of REMS knowledge survey protocols submitted to FDA and compare protocols before and after FDA's 2012 public workshop and 2019 draft guidance.

METHOD

A content analysis of index survey protocols submitted to FDA (2007-2020) for single-product REMS with elements to assure safe use (39 programs, 78 protocols) was conducted. Each protocol was scored against 52 core essential elements (CEE), abstracted from FDA's guidance and grouped into six domains: study objective (n = 5), study design (n = 18), survey instrument (n = 9), participant recruitment (n = 7), survey administration (n = 9), and statistical analysis plan (n = 4). Scores were collected by time periods: (A) Oct 2007 to Jul 2012; (B) Aug 2012 to Feb 2019; (C) Mar 2019 to Dec 2020; and compared using logistic generalized linear mixed models adjusting for domain, survey population, vendor, program, and protocol.

RESULTS

There were 30 (38.5%), 40 (51.3%), and 8 (10.3%) protocols submitted in time period A, B, and C, respectively. Adjusted marginal means of elements present (on the probability scale) by time period were 0.5816 (SE = 0.0242), 0.6429 (SE = 0.0229), and 0.7543 (SE = 0.0394). The likelihood of missing a CEE declined over time (adjusted p-value = 0.0094, time period A vs C). The statistical analysis plan domain had the most improvement; study design remained the weakest domain with the scientific justification CEE particularly underrepresented.

CONCLUSION

The rigor of REMS knowledge survey protocols improved over time consistent with FDA's efforts to advance regulatory science, but gaps remain.

Developing a short screener for acquiescent respondents

BACKGROUND

Acquiescent response style (ARS) refers to survey respondents' tendency to choose response categories agreeing to questions regardless of their content and is hypothesized as a stable respondent trait. While what underlies acquiescence is debatable, the effect of ARS on measurement is clear: bias through artificially increased agreement ratings. With certain population subgroups (e.g., racial/ethnic minorities in the U.S.) are associated with systemically higher ARS, it causes concerns for research involving those groups. For this reason, it may be necessary to classify respondents as acquiescers or a nonacquiescers, which allows independent analysis or accounting for this stylistic artifact. However, this classification is challenging, because ARS is latent, observed only as a by-product of collected data.

OBJECTIVES

To propose a screener that identifies respondents as acquiescers.

METHODS

With survey data collected for ARS research, various ARS classification methods were compared for validity as well as implementation practicality.

RESULTS

The majority of respondents was classified consistently into acquiescers or nonacquiescers under various classification methods.

CONCLUSIONS

We propose a method based on illogical responses given to two balanced, theoretically distant multi-item measurement scales as a screener.

Evaluation of patient/caregiver and healthcare provider knowledge, attitudes and behavior for safety and use of pexidartinib

Aim: Pexidartinib was approved for the treatment of tenosynovial giant cell tumors with a required Risk Evaluation and Mitigation Strategy (REMS) to ensure its safe use. As required by the REMS, a survey was conducted to document the knowledge, attitudes and behavior (KAB) of patients/caregivers and healthcare providers (HCPs) regarding the risk of serious and potentially fatal liver injury due to pexidartinib, the need for liver testing prior to and during treatment and the need for patient counseling about this risk. Patients & methods: The KAB survey was conducted among 40 patients and 18 HCPs enrolled in the pexidartinib REMS. Results: Among patients, 87.5% demonstrated understanding of key risk message (KRM) 1 (risk of serious liver injury), 87.5% demonstrated understanding of KRM2 (liver testing requirement) and 77.5% demonstrated understanding of both KRMs. Among HCPs, 83.3% demonstrated understanding of KRM1, 88.9% demonstrated understanding of KRM2, 100% demonstrated understanding of KRM3 (patient counseling) and 83.3% demonstrated understanding of all three KRMs. Conclusion: The KAB surveys demonstrated that the educational goals of the pexidartinib REMS were being achieved.