Clinical Trial Endpoints from Mobile Technology: Regulatory Considerations September 29, 2016

Similar documents
An Approach to Outcome Measure Development: A Regulatory Perspective

Performance Outcome Measures: A Regulatory Perspective

Update on the Clinical Outcome Assessment Qualification Program and COA Compendium

Approach to Clinical Trials in Drug Development : Eosinophilic Esophagitis (EoE) Outline. Outline

in alphabetical order:

Study Endpoint Considerations: Final PRO Guidance and Beyond

Patient-Reported Outcomes (PROs) and the Food and Drug Administration Draft Guidance. Donald L. Patrick University of Washington

Overcoming Challenges in Outcome Measurement in Rare Diseases and Pediatric Populations

Update on CDER s Drug Development Tool Qualification Program

PANEL QUESTIONS FOR REGULATORY CONSIDERATION

Donald L. Patrick PhD, MSPH, Laurie B. Burke RPh, MPH, Chad J. Gwaltney PhD, Nancy Kline Leidy PhD, Mona L. Martin RN, MPA, Lena Ring PhD

Task Force Background Donald Patrick. Appreciation to Reviewers. ISPOR PRO GRP Task Force Reports

NHC Webinar Series on Clinical Outcome Assessments. Patient-Reported Outcomes and Patient-Centered Outcomes: Is There a Difference?

Developing a Pediatric COA Measurement Strategy A Case Study in Asthma

Actigraphy-based Clinical Study Endpoints: A Regulatory Perspective

Table of Contents. Clinical Outcome Assessments (COAs): A Conceptual Foundation

Thinking with the End in Mind: From COA Instrument to Endpoint

MEASURING PATIENT AND OBSERVER-REPORTED OUTCOMES (PROS AND OBSROS) IN RARE DISEASE CLINICAL TRIALS - EMERGING GOOD PRACTICES TASK FORCE

Patient-Reported Outcomes to Support Medical Product Labeling Claims: FDA Perspective

Clinician-reported Outcomes (ClinROs), Concepts and Development

Lessons learned along the path to qualification of an IBS outcome measure*

September 30, Eric BASTINGS, MD. Acting Director Division of Neurology Products (DNP) Center for Drug Evaluation and Research (CDER)

FDA s Patient-Focused Drug Development Initiative

Addressing Content Validity of PRO Measures: The Unique Case of Rare Diseases

What is a Special Interest Group (SIG)?

Patient Reported Outcomes

OBSERVER-REPORTED OUTCOMES IN CLINICAL TRIALS: CHALLENGES AND SOLUTIONS

FDA Regulatory Considerations for NASH Clinical Trial Endpoints Stephanie O. Omokaro, MD

Advancing Use of Patient Preference Information as Scientific Evidence in Medical Product Evaluation Day 2

Documents Regarding Drug Abuse Assessments

Patient-Centered Endpoints in Oncology

Clinical Trials for Rare Diseases in CDER

AAPS Views on Bioanalytical Method Validation Harmonization (on Behalf of AAPS Bioanalytical Community)

Disclaimer. ISPOR 22 nd Annual International Meeting May 24, 2017 Boston, Massachusetts, USA

Regulatory Considerations for Seamless Oncology Drug Development Expansion Cohorts

Concepts and Case Study Template for Surrogate Endpoints Workshop. Lisa M. McShane, Ph.D. Biometric Research Program National Cancer Institute

PCWP meeting with all eligible patient & consumer organisations 26 Nov 2015 Swedish Medicines Agency proposals for patient engagement

OA Biomarkers: What is required for validation and qualification? Part I. Evaluation Frameworks

TOBACCO PRODUCT OR MEDICAL PRODUCT?

Developmental Toxicity Study Designs for Preventive Vaccines: Issues and Challenges

Process for appraising orphan and ultra-orphan medicines and medicines developed specifically for rare diseases Effective from September 2015

PATIENTS REPORTED OUTCOMES IN ONCOLOGY PATIENT- CENTERED DRUG DEVELOPMENT: OPPORTUNITIES & CHALLENGES

COVERAGE WITH EVIDENCE DEVELOPMENT

Health and Quality of Life Outcomes BioMed Central

ISSUE BRIEF Conference on Clinical Cancer Research November 2011

REVIEW MANAGEMENT. Clinical Review of Drugs to Reduce the Risk of Cancer CONTENTS

Multiple Sclerosis Outcome Assessments Consortium (MSOAC) MSOAC Data Acquisition Highlights

Estimand in China. - Consensus and Reflection from CCTS-DIA Estimand Workshop. Luyan Dai Regional Head of Biostatistics Asia Boehringer Ingelheim

FDA s GREAT Workshop. Industry Perspective: Development Activities Towards Phase 3 Endpoints. September 19, 2012

Advancing the Science of Patient Input in Medical Product R&D: Towards a Research Agenda

Outline. Mission. NCCIH Research Priorities HSR Community Conference September 11, National Center for Complementary and Integrative Health

Ken Bridges, MD Global Blood Therapeutics, South San Francisco, CA

Welcome and PRO Consortium Update

Clinical Endpoint Bioequivalence Study Review in ANDA Submissions. Ying Fan, Ph.D.

Introduction and Workshop Objectives

Welcome and PRO Consortium Update

College of American Pathologists

September 23, The Role of In Vitro Diagnostic Tests in Pediatric Master Protocol Development

Re: Docket No. FDA D Presenting Risk Information in Prescription Drug and Medical Device Promotion

Big data vs. the individual liver from a regulatory perspective

Regulatory Experience in Reviewing CV Safety for Diabetes

SHORTENING TIMELINES AND IMPROVING EFFICIENCY IN DRUG DEVELOPMENT -Seamless drug development paradigms

Quality ID #293: Parkinson s Disease: Rehabilitative Therapy Options National Quality Strategy Domain: Communication and Care Coordination

NGS ONCOPANELS: FDA S PERSPECTIVE

Advancing Molecular Diagnostics for Oncology: Partnerships to Accelerate Evidence Development

Oncology Drug Development: A Regulatory Perspective Faculty Presenter

FDA Introductory Remarks Stephanie O. Omokaro, MD

The EU PIP - a step in Pediatric Drug Development. Thomas Severin Bonn,

DEFINING THE REFERENCE STANDARD FOR BIOMARKERS IN NASH: HISTOLOGY VERSUS CLINICAL OUTCOMES

Practical Statistical Reasoning in Clinical Trials

Regulatory requirements for universal flu vaccines Perspective from the EU regulators

NGS IN ONCOLOGY: FDA S PERSPECTIVE

Progress from the Patient-Centered Outcomes Research Institute (PCORI)

Patient Reported Outcomes (PROs) in IBD: What Are They and What Does the Clinician Need to Know?

Critical Path Institute Coalition Against Major Diseases (CAMD) Alzheimer s Clinical Trial Database

Update on Vaccine Regulation: Expediting vaccine development. Phil Krause FDA/CBER/OVRR

Overview Internal review

Quality ID #113 (NQF 0034): Colorectal Cancer Screening National Quality Strategy Domain: Effective Clinical Care

Safeguarding public health CHMP's view on multiplicity; through assessment, advice and guidelines

Proposal Writing. Lynda Burton, ScD Johns Hopkins University

Below is the indication and summary of the most serious and most common risks associated with the use of Naftin Cream, 2%. 2

Collaborating to Develop Digital Biomarkers with Passive Data Collection

Web Meeting Sep 20, Presented by: Kimberly Belsky, DIA AdPromo WG Chair DIA, Inc. All Rights Reserved.

in the ICH Regions Table of Content Annexes to Guideline and 3. Why is Q4B necessary? Q4B Annexes? for Human Use

Quality ID #113 (NQF 0034): Colorectal Cancer Screening National Quality Strategy Domain: Effective Clinical Care

Sterility Assurance and Risk Management: A CDER Microbiologist s Perspective

New Biomarkers The Path to Scientific and Regulatory Approval

Clinical Trial Exit Interviews

Development of a patient-reported outcomes measure (PROM) for NASH that meets regulatory standards

KNOWLEDGE VALORIZATION

2017 OPTIONS FOR INDIVIDUAL MEASURES: REGISTRY ONLY. MEASURE TYPE: Process

BEST PRACTICE CHANGE CONTROL : DECIDING WHEN TO SUBMIT A 510(K) FOR A DEVICE CHANGE. Yuan Xu 18- JAN- 2018

Accelerating Innovation in Statistical Design

Stepwise Knowledge Acquisition in a Fuzzy Knowledge Representation Framework

Naloxone Expanded Access: OTC status Considerations for a Nonprescription Drug Development Program

NCCIH Natural Products Technical Assistance Webinar: Exploratory Clinical Trials and Studies of Natural Products

Clinical Utility of Diagnostic Tests

Framework for Defining Evidentiary Standards for Biomarker Qualification: Minimal Residual Disease (MRD) in Multiple Myeloma (MM)

GLOOKO DREAMED FOR ANDROID USER GUIDE

Placement of Biomarker Analysis in a CLIA or Bioanalytical Laboratory

Transcription:

Clinical Trial Endpoints from Mobile Technology: Regulatory Considerations September 29, 2016 Elektra J. Papadopoulos, MD, MPH Clinical Outcome Assessments Staff Office of New Drugs Center for Drug Evaluation and Research, FDA

Disclaimer The views expressed in this presentation are those of the speaker, and do not necessarily represent an official FDA position. I have no actual or potential conflict of interest in relation to this activity. 2 2

Patient Centered Outcomes Those outcomes important to patients survival, function, or feelings as identified or affirmed by patients themselves, or judged to be in patients best interest by providers and caregivers when patients cannot report for themselves Donald L. Patrick, Ph.D., MSPH May 20, 2013 3

Clinical Benefit: How do we define it? A positive clinically meaningful effect of an intervention, i.e., a positive effect on how an individual feels, functions, or survives. How long a patient lives How a patient feels or functions in daily life Can be demonstrated as either: A comparative advantage in treatment of the disease or condition; OR A comparative reduction in treatment-related toxicity Clinical benefit is described in labeling in terms of the outcome of interest measured 4

Clinical Benefit: How do we measure it? Clinical Outcome Assessment (COA) An assessment that describes or reflects how an individual feels, functions or survives Typically measure symptoms, overall mental state, or the effects of a disease or condition on how the patient functions A biomarker* is not an assessment of how an individual feels, functions or survives *Biomarker: A defined characteristic measured as an indicator of normal biological processes, pathogenic processes, or responses to an exposure or intervention. Examples: molecular, histologic, radiographic, or physiologic characteristics. Source: http://www.ncbi.nlm.nih.gov/books/nbk338448/#ix-b 5

Types of Outcome Assessments Clinical outcome assessments (COAs) Patient reported outcomes (PROs) Clinician-reported outcomes (ClinROs) Observer reported outcomes (ObsROs) Performance outcomes (PerfOs) Biomarker-based outcomes 6

Performance Outcome (PerfO) Working Definition Note: Measures of activity level/gait as measured by activity monitors can be considered examples of PerfOs. http://www.ncbi.nlm.nih.gov/books/nbk338448/#ix-p 7 7

FDA Review of Clinical Outcome Assessments Does the instrument measure the outcome of interest? Well-defined and reliable (21CFR 314.126) Appropriate for the target population Appropriate for the target indication Adequate measurement properties Content validity- for a PerfO may be informed by a number of sources (e.g., literature, clinicians, patients, caregivers) Construct validity Reliability Ability to detect change 8

Validation of a Mobile- Technology-Based PerfO (Slide 1/2) A multi-step process- Analytical validation*: Establishing that the performance characteristics of a tool (i.e., device and algorithm) are acceptable in terms of its sensitivity, specificity, accuracy, precision, and other relevant performance characteristics using a specified technical protocol E.g., For an activity monitor targeting step count: Is the number of steps recorded an accurate representation of the true number? This a complex issue and cannot be assumed in the real world. But, for the purpose of discussion at this workshop, we will assume that analytic validity has already been established. 9

Validation of a Mobile- Technology-Based PerfO (Slide 2/2) Validation of the measurement s usefulness in a clinical trial: Is the measurement reflective of a defined clinical benefit that s relevant and important to a patient s daily life functioning? How do we go from measurement to endpoint? How do we aggregate the measurements into a meaningful endpoint? What does the endpoint represent? How do we interpret the meaningfulness of intra-patient change? Are there normative data to use as a reference point for interpretation? 10

Good Measurement Principles http://www.fda.gov/downlo ads/drugs/guidancecomplia nceregulatoryinformation/g uidances/ucm205269.pdf FDA PRO Guidance defines good measurement principles to consider for well-defined and reliable (21 CFR 314.126) PRO measures All COAs can benefit from the good measurement principles described within the guidance But, judgment and flexibility are needed! 11

12 12

13 13

www.diahome.org DIA 14

Evidentiary Considerations for Performance Outcomes I. Identify Context of Use (For Discussion) and Concept of Interest V. Modify Instrument Identify a new COU Change instrument content (includes procedures for administration/data collection) Translate and culturally adapt Evaluate modifications using spokes I IV Document all changes Consider submitting to FDA for qualification of new COA, as appropriate. IV. Longitudinal Evaluation of Measurement Properties/ Interpretation Methods Assess ability to detect change and construct validity Identify responder definition(s) Provide guidelines for interpretation of treatment benefit and relationship to claim Document all results Update user manual Submit to FDA for COA qualification as effectiveness endpoint to support claims. PerfO III. Cross-sectional Evaluation of Other Measurement Properties Assess score reliability and construct validity Confirm administration procedures & training materials Prepare user manual Document measure development Consider submitting to FDA for COA qualification for use in exploratory studies prior to longitudinal evaluation. SPOKE III Obtain patient and SME input to determine concept of interest (concept measured should be of relevant and important to patients) Determine intended population Determine intended application/characteristics (type of scores, mode and frequency of administration) Perform literature/expert review Develop hypothesized conceptual framework (if the performance outcome is a composite of multiple scores) Position COA within a preliminary endpoint model II. Select or Create Instrument and Evaluate Content Validity Define tasks that are intended to reflect aspects of daily functioning consistent with the concept of interest and patient population Generate evidence based on patient input /caregiver/expert input (as appropriates) that the tasks are relevant for the population and reflect the concept of interest Develop administration procedures & training materials Pilot test PerfO to obtain patient and administrator input (including documentation of understanding) prior to larger scale studies Refine (as needed) and finalize instrument content Other???

The Importance of the Context of Use Benefit-risk is based on totality of the evidence in the patient population of interest No single outcome assessment is sufficient on its own Different classes of outcome measures used in various combinations to support regulatory decisions Clinical outcome assessments (e.g., patient reported outcomes, clinician reported outcomes, performance measures) Biomarkers Survival The endpoint hierarchy with descriptions of measures and concepts should explain the relationships of endpoints in a clinical trial 16 16

Hypothetical Example: Chronic Fatigue Syndrome PRO: Fatigue and other symptoms PRO: Daily activities PerfO (Clinic-based): Exercise capacity PerfO (Mobile technology-based): Activity level Others 17

Pathways for FDA Clinical Outcome Assessment Review & Advice 1 2 3 IND/NDA/BLA Pathway DDT COA Qualification Pathway Critical Path Innovation Meetings Pathway Within an individual drug development program Investigational New Drug (IND) submissions to FDA Potential to result in labeling claims Outside of an individual drug development program Development of novel COAs for use in multiple drug development programs addressing unmet measurement needs Potential to result in qualification of COA Outside of an individual drug development program Potential for general CDER advice on specific methodology or technology (e.g., PRO) in its early stages of development Meetings are informal, nonbinding discussions DDT = Drug Development Tool; COA = Clinical Outcome Assessment; PRO = Patient-Reported Outcome NDA = New Drug Application; BLA = Biologics Licensing Application 18

Summary Evidentiary considerations for a mobile-technology based PerfOs are broadly similar to PROs and other types of COAs; Flexibility and judgment important in evaluation But, additional evidence is needed to demonstrate The performance characteristics of the mobile device have sufficient sensitivity, specificity, accuracy, and precision The PerfO score and ultimately the endpoint represent important and relevant aspects of patients real world functioning As with any measure, we need to understand how much within-patient change in score makes a difference in patients lives 19 19

For more information Clinical Outcome Assessment Qualification Program Webpage (includes Roadmap): http://www.fda.gov/drugs/developmentapprov alprocess/drugdevelopmenttoolsqualification Program/ucm284077.htm Critical Path Innovation Meetings (CPIM): http://www.fda.gov/drugs/developmentapprov alprocess/druginnovation/ucm395888.htm 20

Thank you! 21 21