Use of blinded independent central review of PFS in definitive trials

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Use of blinded independent central review of PFS in definitive trials Lori E. Dodd, PhD Biostatistics Research Branch National Institute of Allergy and Infectious Diseases 1

Progression-free survival Use of PFS an area of active debate. Not generally: a measure of clinical benefit, nor a surrogate for overall survival. For purposes of my talk, we agree that PFS is an important primary endpoint for regulatory approval. A trial with a PFS primary endpoint requires strong evidence that treatment effect is large. 2

Concerns about PFS assessments by site Progression assessments vary by reader Discrepancy rates in timing and presence of progression are high (typically > 30%) Concern about potential reader bias from local evaluators, who know treatment assignment, has lead to requirement for blinded independent central review 3

What is Blinded Independent Central Review? BICR No Yes NA NA LE No No Yes NA A BICR No No?? LE No Yes NA NA A BICR PD information lost for this patient Week 6 Week 12 Week 18 Week 24 4

The potential bias trade-off Estimation of true effect on PFS remains elusive: Local evaluations: suspicion of subjective bias Blinded independent central review: potential informative censoring 5

Blinded Independent Central Review does not eliminate concerns about biased treatment effect estimates. Potential for informative censoring is possible pitfall of BICR Discrepancy rates between BICR reads can be high too Meta-analysis of published trials (7) reporting both BICR and LE showed similar treatment effects. In spite of high discrepancy rates, both approaches produced similar conclusions about treatment efficacy 6

27 randomized phase III trials in solid tumors Both local evaluation and BICR Correlation between hazard ratios: 0.95

33 randomized phase III trials in solid tumors Both investigator assessment and blinded independent central review Correlation between hazard ratios: 0.91

Options Use overall survival Clinically meaningful endpoint and time of death not subjective Use complete-case BICR Costly, time-consuming, and rarely necessary Use local evaluations Double-blinded trials. Ensure local radiologists are suitably trained and blinded to treatment assignment Use BICR on a subset as an audit of internal trial results Two published audit methods Less effort than complete-case BICR but adds cost, time, and complexity 9

Local Evaluations Double-blinded trials: BICR not required. Concerns about side-effects revealing treatment assignment may limit use of double-blinding BUT, a partially blinded trial (e.g., >90% of subjects) may have greater value than an unblinded trial. (An area worthy of research) Unblinded trials: blind local evaluator to treatment assignment and assure appropriate training Would this be more burdensome than BICR? Aside: Extent to which local reads are evaluated with knowledge of treatment assignment is unknown 10

Options Use overall survival Clinically meaningful endpoint and time of death not subjective Use complete-case BICR Costly, time-consuming, and rarely necessary Use local evaluations Double-blinded trials. Ensure local radiologists are suitably trained and blinded to treatment assignment Use BICR on a subset as an audit of internal trial results Two published audit methods Less effort than complete-case BICR but adds cost, time, and complexity 11

Two published audit methods: Method A: On a subset demonstrate BICR hazard ratio is statistically significant and clinically meaningful. (Dodd et al., Biometrics 2011) Method B: Compare discrepancy rates (between BICR and LE) between treatment arms (Amit et al. 2011) If difference between arms is high, this suggests bias. 12

Differential discordance BICR No Yes NA NA LE No No Yes NA A BICR No No?? LE No Yes NA NA B Week 6 Week 12 Week 18 Week 24 13

July 24, 2012 ODAC meeting All committee members agreed that an audit approach should be considered Members advised against complete elimination of BICR Presence of audit cited as mechanism for preventing bias Need for threat of full BICR No recommendations for specific audit method Methodology not ripe yet. 14

EMEA guidelines Open to audit concept In general the confidence in the quality of the trial will increase if the trial results from the BICR do not differ from the investigator assessments to any important degree. Procedures for independent review shall be defined prospectively 15

Two audit methods Forthcoming paper from FDA retrospectively compares the two approaches in 26 randomized phase 3 registration trials. (Zhang et al, in revision) Demonstrates feasibility of this approach, but prospective evaluation still needed. One case (carcinoid) in which differential discrepancy rate consistently failed to identify bias when it should have. 16

Moving forward Collection and storage of all images a requirement for regulatory approval Practical details regarding audit implementation requires more consideration Sampling with site stratification? In settings with known difficulties with interpretation, should we consider interim monitoring of discrepancy rates (ignoring treatment assignment)? 17

Moving forward BICR audit may be best strategy today but technological advances may offer alternative solutions: real-time BICR reads ensure local reviews are blinded Dr. Harrington, ODAC meeting: If there is a truth, it s the way treatments will be administered in the clinic once approved. True effect of drug on PFS endpoint may be best estimated in double-blinded trial 18

Thanks to my collaborators! NCI: Ed Korn Boris Freidlin Jeff Abrams James Doroshow Carl Jaffe Larry Rubenstein NIAID: Jessie Gu Martha Nason Others: Robert Gray, Harvard Renzo Canetta, BMS William Bushnell, Consultant Suman Bhattacharya, Medivation Rajeshwari Sridhara, FDA 19