How to evaluate medications in Multiple Sclerosis when placebo controlled RCTs are not feasible



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University of Florence Dept. of Neurosciences Careggi University Hospital Dept of Neurosciences How to evaluate medications in Multiple Sclerosis when placebo controlled RCTs are not feasible Luca Massacesi, MD massacesi@unifi.it EMA, London October 2013

outlines Needs to be met in MS Comparative clinical trials Non-inferiority design

MS course: relation between clinical and magnetic resonance imaging (MRI) measures EXAPNDED DISABILITY STATUS SCALE (EDSS) Pre-clinical phase Relapsing-Remitting MS (RRMS) Secondary-Progressive MS (SPMS) CNS lesions MRI years

Background - In RR MS Disease Modifying Treatments (DMT), effective on clinically relevant outcome measures are available and approved. - Efficacy or safety and therefore Therapeutic Index (TI: efficacy/safety ) is variable and for each DMT is not optimal - Clinical needs other than efficacy, not optimally met by these DMTs, are: - safety - patient compliance - administration convenience - costs

In MS clinical needs different from efficacy often unmet In the presence of DMTs approved for MS, new treatments are still worth to be developed for this indication, aiming also to superiority of pharmacological characteristics other that efficacy as: safety patient compliance administration convenience costs

Condition for aiming to improvements on characteristics different from efficacy In MS, if new DMTs (or new formualtion of already approved DMTs) with better pharmacological characteristics will be developed, the efficacy must be at least equivalent to that of the currenly available treatments

Example New Interferon Beta 1a, IM, formulation (pegylated, allows less frequent injections): evaluated in a short RCT vs placebo showing efficacy similar to the old formulation (same molecule) administrated weekly (AAN 2013; ECTRIMS 2013) Head to head comparison with the approved formulation lacking; In this case superiority not hypothesized: could non inferiority design be recommended?

Comparative trias design alternative to superiority AIM : to prove that efficacy of an experimental treatment (S) is at least equivalent to that of a reference treatment (T) that acts as control; Needed to compare medications differing only as for characteristics other than efficacy Equivalence : when the two treatment under study exert indistinguishable activity on the most clinically relevant outcome measures, in spite of some variability Equivalence cannot be proved as for: δ= 0, n= Non-inferiority with respect to a predetermined difference can be proved

Non inferiority design

Non inferiority design represents a virtual comparison with Placebo of a given treatment S Assumptions: If the efficacy of an experimental treatment (S) is superior to that of a reference treatment (T) known to be superior to placebo, also S efficacy is superior to placebo; Conditions: Previous phase II or III placebo controlled RCTs consistent among them, allowing precise evaluation of : the dimensions of the effect: E = S / P (S - P) Therefore efficacy of S would have been superior to Placebo, if this intervention would have been included in the trial distribution and frequency of the endpoint(s), in the same patient population has been reliably estimated

Method: non-inferiority Treatment S is noninferior to control treatment T if the lower CI (one tail) of its effect, falls within a predefined margin M named noninferiority margin M value: arbitrary clinically meaning ful predefined

Non inferiority margin M estimate numero eventi 8 7 6 5 4 3 2 1 0 Dati da RCT storici Placebo Farmaco T effetto T-P Calculation: clinically meaningful fraction of the Effect (E) of the reference treatment (T) vs Placebo resulting from high quality phase II or III trials. M= 1 E T/P x

The treatment S is non-inferior when its effect vs the comparator T results within a predefined margin named non-inferiority margin

The null hypothesis in comparative head to head RCTs Comparing treatments with different efficacy, superiority of one treatment is assumed: the null hypothesis is no difference and the alternative is difference Comparing treatments with similar efficacy, equivalence is not assumed; the null hypothesis is difference and the alternative is no difference

Superiority trials: null hypothesis: H 0 = m 1 / m 2 = 1; or H 0 = m 1 - m 2 = 0 alternative hypothesis: H 1 = m 1 - m 2 > δ; or H 1 = m 1 - m 2 > δ Sample size is inversely proportional to a predefined δ How to compare efficacy between treatments if no or little difference is assumed? Equivalence (δ = 0): not feasible because n=. Non inferiority trials : null hypothesis: H 1 = m 1 / m 2 > δ: or H 1 = m 1 - m 2 > δ alternative hypothesis: H 0 = m 1 / m 2 = 1; or H 0 = m 1 - m 2 = 0 Sample size is inversely proportional to a predefined δ n ( ) q k = 2 sd δ 2

The treatment S is non-inferior when its effect vs the comparator T results included within a predefined margin named non-inferiority margin

CAVEAT: M estimate M value is clinically meaningful if M is established through a reliable estimation of the T effect size vs placebo For this purpose the following conditions must be fulfilled: different high quality reference trials that evaluated T efficacy vs placebo must be available their results must be consistent the effect size vs placebo must be large enough to allow establishment of a clinically meaningful size of M The patient population and therefore the dimensions of the outcome measure selected as the primary end point must be stable along time

IFN efficacy vs. placebo in reference studies TRIAL treatment Betaferon (ΒIFN 1b, 1993) PRISMS (ΒIFN 1a 44, 1997) PRISMS (ΒIFN 1 a 22, 1997) n relapse n./2y n relapse n./2y n relapse n./2y Β IFN 122 1.68 187 1.73 189 1,82 1.74 Placebo 155 2.54 184 2.56 184 2,56 2,55 delta 0,86 0,83 0,74 0.81 ratio 1,51 1,48 1,40 1,46 relapse rate ratio Placebo/βIFNs = 1.46

Statistics Non-inferiority 1.46, the relapse rate ratio between the placebo and the βifns group, detected in 2 pivotal historical trials (PRISMS; Betaferon) Treatment S will be considered non-inferior to βifns if the 95% C.I (one side) of the ratio between relapse rates in the S group and in the βifns group will be < 1.23 non inferiority margin M a priori established, as 50% of the excess to 1.0 (= 1.23)

CAVEAT: protocol violations If none of the patients included, assume the assigned drug, non inferiority is granted Both intention to treat (ITT) and per protocol (PP) analysis must be carried out and must give equivalent results.

Effect on Relapse Rate over 2 years 0.7 0.6 P= 0.06 0.5 0.4 annualized relapse rate 0.3 AZA IFN 0.2 0.1 6E-16 I year II year I +II year -0.1

RR: between A and B scenario

Head to head Comparison of a Beta Interferon 1a and Copaxon (Mikol et al., 2008)

Summary In RRMS comparative trial will be increasingly used for developing new medications Some of them will not aim to evaluate superiority of efficacy but of other pharmacological characteristics For this purpose, high quality well conducted non inferiorty design may represent a reasonable option

Thanks for your attention massacesi@unifi.it