Non-inferiority trials and switch from non-inferiority to superiority. D Costagliola U 943 INSERM and UPMC Paris 06

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Non-inferiority trials and switch from non-inferiority to superiority D Costagliola U 943 INSERM and UPMC Paris 06

References l ICH E 9 et E10 l Points to consider on biostatistical methodological issues from recent CPMP discussions on licensing applications: superiority, non-inferiority and equivalence

Clinical trial objectives l Trials comparing a new treatment (or a strategy) to a reference treatment Showing the superiority of the new treatment Is N better than R? Pre-treated patients Showing the non-inferiority of the new treatment Is N doing not worse than R? Naive patients Showing the equivalence of the new treatment Is N doing as well as (neither better not worse) R? Bio-equivalence (different formulation of the same drug)

Example - 1

Example - 2

Definition of non-inferiority N is not doing worse than R L N - R = -10% 0 inferior non-inferior superior

Choice of the non-inferiority limit - 1 Clinical decision, not statistical The largest difference clinically acceptable < = difference used in superiority trials of the same domain To warrant that the new product is doing better than placebo in trials with no placebo

A working case in diabetes: HbA1c the risk of death - 1 l In diabetes, for new drugs the most common endpoint is HbA1C l Non inferiority margin usually taken as 0.6 % l Superiority trials usually try to demonstrate a 1% difference

A working case in diabetes: HbA1c the risk of death - 2 l Each 1% reduction in updated mean HbA1c was associated with reductions in risk of l 21% for any end point related to diabetes (95% confidence interval 17% to 24%), l 21% for deaths related to diabetes (15% to 27%), l 14% for myocardial infarction (8% to 21%), and l 37% for microvascular complications (33% to 41%). l No threshold of risk was observed for any end point. Stratton IM et al. UKPDS 35. BMJ 2000;321:405-412

A working case in diabetes: HbA1c the risk of death - 3 l Is it possible to define a non-inferiority limit clinically acceptable in this context?

Choice of the non-inferiority limit - 2 As defining a non-inferiority limit implies to accept some loss There must be some advantage to use the new product easyness safety costs

Example - 3 Non-inferiority limit 13% (between 7 and 15%) Expected success rate 70% (EFV vs IND) One-sided Type I error 2.5% Power 85 %

Other issues Internal validity Limited protocol deviation, lack of adherence, lost to follow-up, and missing data Because they biased the result towards no difference External validity Choice of the reference treatment Known efficacy Placebo group when possible Study population Same as the one in which the reference treatment was shown efficacious Endpoint(s) Same as the one(s) used to show the reference treatment efficacy Expected efficacy from the reference treatment observed in the current trial

Comparison test Superiority (two-sided) H 0 : N = R H 1 : N R Superiority (one-sided) H 0 : N = R H 1 : N > à R Non inferiority (one-sided) H 0 : ( N - R ) = < - L (N is inferior to R) H 1 : ( N - R ) = >= - L (N is non inferior or superior R) The non inferiority limit L influences the result of the analysis

Sample size 1 L is usually smaller than the interesting difference in a superiority trial in the same field The sample size tends to be larger

Hill A AIDS 2008;22:913-921 Sample size 2

Analysis plan Results Confidence intervals of the difference More rarely a p-value Both ITT and per protocol analyses should be conducted and give the same results Analysis of compliance to treatment and protocol deviation (+++)

The conclusion is based on The lower limit of the confidence interval of the estimated difference compared with the non inferiority limit L

Definition of non-inferiority N is not doing worse than R L N - R = -10% 0 inferior non-inferior superior

Exemple - 4 PP : 84% vs 73%, 95% CI : 4-19, N = 487 ITT : 81% vs 70%, 95% CI : 3-18, N = 509

Exemple - 5

Interpreting a non-inferiority trial as a superiority trial No majors issues, but is the difference of clinical significance? Depending on The reference treatment The power The effect size The analysed population The trial quality The p value for the superiority test is derived from the ITT analysis

Example - 6 The right p value for the ITT analysis was p=0.005 (81 % vs 70 %)

Example - 7 What would the gain be? Not listed in the conclusion Difference on the loss of leg fat at W48? Change in LDL-cholesterol? No longer an issue if there is a clinically significant superiority

Conclusion If one accepts a loss of chance, what is the expected gain? The choice of the non-inferiority limit is critical It is a clinical, not a statistical decision Should warrant that the new product is better than placebo Typically 7-12% in the recent trials in HIV The ITT analysis is no longer the main analysis Both ITT and per protocol are important The difference in the number of patients included in each analysis is an indicator of the study quality No major issues in switching from non-inferiority to superiority