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Cliff ERS, Russler-Germain DA, Daval CJR, Kesselheim AS. US Food and Drug Administration's Directive to Deal With Delayed Confirmatory Trials: Lessons From Pralatrexate and Belinostat for T-Cell Lymphoma. J Clin Oncol 2024; 42:3901-3904. [PMID: 39052948 DOI: 10.1200/jco.24.00100] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [MESH Headings] [Track Full Text] [Journal Information] [Subscribe] [Academic Contribution Register] [Received: 01/16/2024] [Revised: 05/21/2024] [Accepted: 06/03/2024] [Indexed: 07/27/2024] Open
Abstract
The FDA's directive to deal with delayed confirmatory trials: lessons from pralatrexate and belinostat for T-cell lymphoma.
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Affiliation(s)
- Edward R Scheffer Cliff
- Program On Regulation, Therapeutics, And Law, Division of Pharmacoepidemiology and Pharmacoeconomics, Department of Medicine, Brigham and Women's Hospital, Boston, MA
- Harvard Medical School, Boston, MA
| | - David A Russler-Germain
- Division of Oncology, Department of Medicine, Washington University School of Medicine, St Louis, MO
- Siteman Cancer Center, St Louis, MO
| | - C Joseph Ross Daval
- Program On Regulation, Therapeutics, And Law, Division of Pharmacoepidemiology and Pharmacoeconomics, Department of Medicine, Brigham and Women's Hospital, Boston, MA
- Harvard Medical School, Boston, MA
| | - Aaron S Kesselheim
- Program On Regulation, Therapeutics, And Law, Division of Pharmacoepidemiology and Pharmacoeconomics, Department of Medicine, Brigham and Women's Hospital, Boston, MA
- Harvard Medical School, Boston, MA
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Heynemann S, Lipworth W, McLachlan SA, Philip J, John T, Kerridge I. Equipoise Remains a Major Consideration in the Ethical Evaluation of Phase 3 Randomized Controlled Trials Involving Precision Oncology Approaches in NSCLC. J Thorac Oncol 2024; 19:1504-1508. [PMID: 39510704 DOI: 10.1016/j.jtho.2024.07.004] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Track Full Text] [Journal Information] [Subscribe] [Academic Contribution Register] [Received: 05/29/2024] [Revised: 07/05/2024] [Accepted: 07/09/2024] [Indexed: 11/15/2024]
Affiliation(s)
- Sarah Heynemann
- Sydney Health Ethics, Faculty of Medicine and Health, The University of Sydney, Sydney, Australia.
| | - Wendy Lipworth
- Department of Philosophy, Macquarie University, Sydney, Australia
| | - Sue-Anne McLachlan
- Department of Medical Oncology, St Vincent's Hospital, Melbourne, Australia; Department of Medicine, Faculty of Medicine, Dentistry and Health Sciences, The University of Melbourne, Melbourne, Australia
| | - Jennifer Philip
- Department of Medicine, Faculty of Medicine, Dentistry and Health Sciences, The University of Melbourne, Melbourne, Australia; Department of Palliative Care, St Vincent's Hospital, Melbourne, Australia; Department of Palliative Care, Peter MacCallum Cancer Centre, Melbourne, Australia
| | - Tom John
- Department of Medical Oncology, Peter MacCallum Cancer Centre, Melbourne, Australia; Sir Peter MacCallum Department of Medical Oncology, The University of Melbourne, Melbourne, Australia
| | - Ian Kerridge
- Sydney Health Ethics, Faculty of Medicine and Health, The University of Sydney, Sydney, Australia; Department of Philosophy, Macquarie University, Sydney, Australia; Department of Haematology, Royal North Shore Hospital, Sydney, Australia
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Olivier T, Haslam A, Burke P, Boutron I, Naudet F, Ioannidis JPA, Prasad V. A novel framework to assess haematology and oncology registration trials: The THEOREMM project. Eur J Clin Invest 2024; 54:e14267. [PMID: 38934596 DOI: 10.1111/eci.14267] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [Key Words] [MESH Headings] [Track Full Text] [Journal Information] [Submit a Manuscript] [Subscribe] [Academic Contribution Register] [Received: 05/23/2024] [Accepted: 06/05/2024] [Indexed: 06/28/2024]
Abstract
BACKGROUND Methodological limitations affect a significant number of oncology and haematology trials, raising concerns about the applicability of their results. For example, a suboptimal control arm or limited access to best care upon progression may skew the trial results toward a benefit in the experimental arm. Beyond the fact that such limitations do not prevent drugs reaching the market, other assessment tools, such as those developed by professional societies-ESMO-MCBS and ASCO Value Framework-do not integrate these important shortcomings. METHODS We propose creating a novel framework with the scope of assessing registration cancer clinical trials in haematology and oncology (randomized or single arm)-that is trials leading to a marketing authorization. The main steps of the methods are (1) assembling a scientific board; (2) defining the scope, goal and methods through pre-specified, pre-registered and protocolized methodology; (3) preregistration of the protocol; (4) conducting a scoping review of limitations and biases affecting oncology trials and assessing existing scores or methods; (5) developing a list of features to be included and assessed within the framework; (6) assessing each feature through a questionnaire sent to highly cited haematologists and oncologists involved in clinical trials; and (7) finalizing the first version of framework. RESULTS Not applicable. CONCLUSIONS Our proposal emerged in response to the lack of consideration for key limitations in current trial assessments. The goal is to create a framework specifically designed to assess single trials leading to marketing authorization in the field of oncology and haematogy.
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Affiliation(s)
- Timothée Olivier
- Department of Oncology, Geneva University Hospital, Geneva, Switzerland
| | - Alyson Haslam
- Department of Epidemiology and Biostatistics, University of California San Francisco, San Francisco, California, USA
| | | | - Isabelle Boutron
- Université Paris Cité and Université Sorbonne Paris Nord, Inserm, INRAe, Centre for Research in Epidemiology and Statistics (CRESS), Paris, France
- Centre d'Épidémiologie Clinique, Hôpital Hôtel Dieu, Paris, France
- Cochrane France, Paris, France
| | - Florian Naudet
- Inserm, CIC 1414 (Centre d'Investigation Clinique de Rennes), Rennes 1 University, Rennes, France
- Inserm, Irset (Institut de recherche en santé, environnement et travail), Rennes 1 University, Rennes, France
- Institut Universitaire de France, Paris, France
| | - John P A Ioannidis
- Meta-Research Innovation Center at Stanford (METRICS), Stanford University, Stanford, California, USA
- Department of Medicine, Stanford University School of Medicine, Stanford, California, USA
- Department of Epidemiology and Population Health, Stanford University School of Medicine, Stanford, California, USA
| | - Vinay Prasad
- Department of Epidemiology and Biostatistics, University of California San Francisco, San Francisco, California, USA
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Rodriguez LR, Gormley NJ, Lu R, Amatya AK, Demetri GD, Flaherty KT, Mesa RA, Pazdur R, Sekeres MA, Shan M, Snapinn S, Theoret MR, Umoja R, Vallejo J, Warren NJH, Xu Q, Anderson KC. Improving Collection and Analysis of Overall Survival Data. Clin Cancer Res 2024; 30:3974-3982. [PMID: 39037364 PMCID: PMC11398985 DOI: 10.1158/1078-0432.ccr-24-0919] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [MESH Headings] [Grants] [Track Full Text] [Journal Information] [Subscribe] [Academic Contribution Register] [Received: 03/20/2024] [Revised: 04/26/2024] [Accepted: 06/25/2024] [Indexed: 07/23/2024]
Abstract
Advances in anticancer therapies have provided crucial benefits for millions of patients who are living long and fulfilling lives. Although these successes should be celebrated, there is certainly room to continue improving cancer care. Increased long-term survival presents additional challenges for determining whether new therapies further extend patients' lives through clinical trials, commonly known as the gold standard endpoint of overall survival (OS). As a result, an increasing reliance is observed on earlier efficacy endpoints, which may or may not correlate with OS, to continue the timely pace of translating innovation into novel therapies available for patients. Even when not powered as an efficacy endpoint, OS remains a critical indication of safety for regulatory decisions and is a key aspect of the FDA's Project Endpoint. Unfortunately, in the pursuit of earlier endpoints, many registrational clinical trials lack adequate planning, collection, and analysis of OS data, which complicates interpretation of a net clinical benefit or harm. This article shares best practices, proposes novel statistical methodologies, and provides detailed recommendations to improve the rigor of using OS data to inform benefit-risk assessments, including incorporating the following in clinical trials intending to demonstrate the safety and effectiveness of cancer therapy: prospective collection of OS data, establishment of fit-for-purpose definitions of OS detriment, and prespecification of analysis plans for using OS data to evaluate for potential harm. These improvements hold promise to help regulators, patients, and providers better understand the benefits and risks of novel therapies.
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Affiliation(s)
| | | | - Ruixiao Lu
- Alumis Inc., South San Francisco, California
- American Statistical Association, Alexandria, Virginia
| | - Anup K Amatya
- U.S. Food and Drug Administration, Silver Spring, Maryland
| | | | - Keith T Flaherty
- Massachusetts General Hospital Cancer Center, Boston, Massachusetts
| | - Ruben A Mesa
- Atrium Health, Winston-Salem, North Carolina
- Wake Forest Baptist Comprehensive Cancer Center, Winston-Salem, North Carolina
| | - Richard Pazdur
- U.S. Food and Drug Administration, Silver Spring, Maryland
| | - Mikkael A Sekeres
- Sylvester Comprehensive Cancer Center, University of Miami, Miami, Florida
| | | | - Steven Snapinn
- Seattle-Quilcene Biostatistics LLC., Seattle, Washington
| | - Marc R Theoret
- U.S. Food and Drug Administration, Silver Spring, Maryland
| | - Rukiya Umoja
- American Association for Cancer Research, Washington, District of Columbia
| | | | | | - Qing Xu
- U.S. Food and Drug Administration, Silver Spring, Maryland
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Naci H, Zhang Y, Woloshin S, Guan X, Xu Z, Wagner AK. Overall survival benefits of cancer drugs initially approved by the US Food and Drug Administration on the basis of immature survival data: a retrospective analysis. Lancet Oncol 2024; 25:760-769. [PMID: 38754451 DOI: 10.1016/s1470-2045(24)00152-9] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [MESH Headings] [Track Full Text] [Journal Information] [Subscribe] [Academic Contribution Register] [Received: 12/18/2023] [Revised: 02/24/2024] [Accepted: 03/14/2024] [Indexed: 05/18/2024]
Abstract
BACKGROUND New cancer drugs can be approved by the US Food and Drug Administration (FDA) on the basis of surrogate endpoints while data on overall survival are still incomplete or immature, with too few deaths for meaningful analysis. We aimed to evaluate whether clinical trials with immature survival data generated evidence of overall survival benefit during the period after marketing authorisation, and where that evidence was reported. METHODS In this retrospective analysis, we searched Drugs@FDA to identify cancer drug indications approved between Jan 1, 2001, and Dec 31, 2018, on the basis of immature survival data. We systematically collected publicly available data on postapproval overall survival results in labelling (Drugs@FDA), journal publications (MEDLINE via PubMed), and clinical trial registries (ClinicalTrials.gov). The primary outcome was availability of statistically significant overall survival benefits during the period after marketing authorisation (until March 31, 2023). Additionally, we evaluated the availability and timing of overall survival findings in labelling, journal publications, and ClinicalTrials.gov records. FINDINGS During the study period, the FDA granted marketing authorisation to 223 cancer drug indications, 95 of which had overall survival as an endpoint. 39 (41%) of these 95 indications had immature survival data. After a minimum of 4·3 years of follow-up during the period after marketing authorisation (and median 8·2 years [IQR 5·3-12·0] since FDA approval), additional survival data from the pivotal trials became available in either revised labelling or publications, or both, for 38 (97%) of 39 indications. Additional data on overall survival showed a statistically significant benefit in 12 (32%) of 38 indications, whereas mature data yielded statistically non-significant overall survival findings for 24 (63%) indications. Statistically significant evidence of overall survival benefit was reported in either labelling or publications a median of 1·5 years (IQR 0·8-2·3) after initial approval. The median time to availability of statistically non-significant overall survival results was 3·3 years (2·2-4·5). The availability of overall survival results on ClinicalTrials.gov varied considerably. INTERPRETATION Fewer than a third of indications approved with immature survival data showed a statistically significant overall survival benefit after approval. Notable inconsistencies in timing and availability of information after approval across different sources emphasise the need for better reporting standards. FUNDING None.
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Affiliation(s)
- Huseyin Naci
- Department of Health Policy, London School of Economics and Political Science, London, UK; The Lisa Schwartz Foundation for Truth in Medicine, Norwich, VT, USA.
| | - Yichen Zhang
- Department of Pharmacy Administration and Clinical Pharmacy, School of Pharmaceutical Sciences, Peking University, Beijing, China
| | - Steven Woloshin
- The Lisa Schwartz Foundation for Truth in Medicine, Norwich, VT, USA; The Center for Medicine in the Media, Dartmouth Institute for Health Policy and Clinical Practice, Geisel School of Medicine at Dartmouth, Lebanon, NH, USA
| | - Xiaodong Guan
- Department of Pharmacy Administration and Clinical Pharmacy, School of Pharmaceutical Sciences, Peking University, Beijing, China
| | - Ziyue Xu
- Department of Pharmacy Administration and Clinical Pharmacy, School of Pharmaceutical Sciences, Peking University, Beijing, China
| | - Anita K Wagner
- The Lisa Schwartz Foundation for Truth in Medicine, Norwich, VT, USA; Department of Population Medicine, Harvard Medical School and Harvard Pilgrim Health Care Institute, Boston, MA, USA
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West HJ, Pennell NA. Lessons from ADAURA: Can we improve on a positive trial? Cancer 2024; 130:659-664. [PMID: 37962066 DOI: 10.1002/cncr.35112] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [Key Words] [MESH Headings] [Track Full Text] [Journal Information] [Subscribe] [Academic Contribution Register] [Indexed: 11/15/2023]
Abstract
Although ADAURA (ClinicalTrials.gov identifier NCT02511106) was a positive trial that produced a significant improvement in both disease‐free survival and overall survival, the limited crossover to postprotocol osimertinib and some other methodological issues detract from the cancer community’s ability to distinguish the benefits of timing of osimertinib versus overall access to osimertinib at a later point. Discrete refinements can be applied to global, randomized phase 3 trials to ensure their design optimally addresses the key clinical question while reducing disparities in best management practices based on resources across health care systems.
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Affiliation(s)
- Howard Jack West
- Department of Medical Oncology, City of Hope Comprehensive Cancer Center, Duarte, California, USA
- AccessHope, Los Angeles, California, USA
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Shachar SS, Korzets Y, Shepshelovich D, Zlothover N, Amir E, Tibau A, Goldvaser H. Reporting of post-protocol therapies in metastatic breast cancer registration clinical trials: A systematic review. Cancer Treat Rev 2024; 122:102666. [PMID: 38064877 DOI: 10.1016/j.ctrv.2023.102666] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [Key Words] [MESH Headings] [Track Full Text] [Journal Information] [Subscribe] [Academic Contribution Register] [Received: 09/18/2023] [Revised: 11/07/2023] [Accepted: 11/27/2023] [Indexed: 01/01/2024]
Abstract
BACKGROUND As the treatment for metastatic breast cancer (MBC) often includes sequential lines of therapy, data on post-protocol treatment in clinical trials are valuable in the assessment of long-term outcomes. The objective of this study was to assess the reported data on post-protocol therapy in clinical trials supporting US Food and Drug Administration (FDA) approval of drugs for MBC. METHODS All initial and subsequent publications related to FDA approved indications for MBC between January 2000 and February 2023 were identified. Collected data included study design, patients' characteristics and whether reporting on post-protocol therapy was available. Differences in study design and population between studies with and without data on post-protocol therapy were evaluated. FINDINGS Forty-one indications for MBC were identified. Data were evaluated from 249 publications or abstracts, comprising 20,152 patients. Reporting of post-protocol therapy was available for 22 (53.7 %) indications. Reported data were often incomplete. Reporting has not improved over time with reported data in 50 % and 55.2 % studies between 2000 and 2010 and 2011-2023 (p value for the difference = 1.0), respectively. Studies with OS as their primary endpoints were associated with significantly higher reporting of post-protocol therapy, (p = 0.02). Other characteristics of study design and population were comparable between studies with and without data on post-protocol therapy. CONCLUSIONS Data on post-protocol therapy in trials supporting FDA approval of drugs for MBC are available for only half of the indications. As subsequent lines of therapy may have a crucial role in patients' outcome, post-protocol reporting should be included in the regulatory submission and be made available publicly.
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Affiliation(s)
- Shlomit Strulov Shachar
- Sourasky Medical Center, Oncology Institute, Tel Aviv, Israel; Faculty of Medicine, Tel Aviv University, Tel Aviv, Israel.
| | - Yasmin Korzets
- Sourasky Medical Center, Oncology Institute, Tel Aviv, Israel; Faculty of Medicine, Tel Aviv University, Tel Aviv, Israel.
| | - Daniel Shepshelovich
- Columbia University Medical Center, Division of Internal Medicine, New York, NY, USA.
| | - Noa Zlothover
- The Hebrew University Faculty of Medicine, Jerusalem, Israel.
| | - Eitan Amir
- Division of Medical Oncology, University of Toronto and Princess Margaret Cancer Centre, Toronto, Canada.
| | - Ariadna Tibau
- Department of Oncology, Hospital de la Santa Creu i Sant Pau, Institut d'Investigació Biomèdica Sant Pau and Universitat Autònoma de Barcelona, Barcelona, Spain.
| | - Hadar Goldvaser
- The Hebrew University Faculty of Medicine, Jerusalem, Israel; Oncology Institute, Shaare Zedek Medical Center, Jerusalem, Israel.
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