Title: Labeling claims for patientreported outcomes A regulatory perspective
1Labeling claims for patient-reported outcomes(A
regulatory perspective)
- FDA/Industry Workshop
- Washington, DC
- September 16, 2005
- Lisa A. Kammerman, Ph.D.
- Division of Biometrics 2
Center for Drug Evaluation and Research
2Disclaimer
- Views expressed in this presentation are those of
the speaker and not, necessarily, of the Food and
Drug Administration.
3Introduction
- Start early in development program
- Instrument selection
- Role of outcome in clinical study
- Issues to address
- Development and validation
- Clinically meaningful difference
- Implementation
4Introduction
- Trial Design
- Conduct of clinical study
- FDA review
- Instrument
- Study results
- And then . Labeling Claims
5To support a PRO claim
- Reliable and valid instrument
- Instrument measures concepts claimed
- Instrument measures impact of an intervention
- Well-controlled investigations
6Early in product development
- Identify endpoints
- Identify desired claims
- Discuss with FDA
7Selection of PRO Instrument
- Measures the claimed treatment benefit from the
patients perspective - Measures both the positive and negative benefits
of the intervention
8Selection of PRO Instrument
- Specific to the intended population
- Specific to the characteristics of the conditions
or disease treated
9Selection of PRO Instrument
- Three possible choices
- Existing instrument
- Modification of existing instrument
- New instrument
10Document, document, document!
- Development of instrument
- Patient involvement
- Population
- Goals
- Validation of instrument
- Format, wording
- Cultural issues, multinational studies
- Drug intervention studies
11Document, document, document!
- Concepts what will be measuredExamples
- Pain severity
- Psychological function
- Physical function
12Document, document, document!
- Domain Q concept Examples
- PFSF Desire, Responsiveness, Disinterest
- Physical function symptom improvement, physical
abilities, ADL
13Document, document, document!
- Clinically meaningful difference
- Prospective plan
- Patient involvement
- Planned use in clinical study
- Primary evidence for efficacy
- Value-added
- Intended population
14Document, document, document!
- Implementation
- Training and instructions
- Format
15Trial Design Issues
- Prospectively defined
- Blinding
- Use of instrument
- Standardized instructions
- Standardized training
- Training and blinding of interviewers
- Recall to baseline
16Trial Design Issues
- Data capture
- Paper
- Electronic
17Role of PRO as an endpoint
- Primary evidence of efficacy
- Value-added
- Pre-specify
- Report findings, regardless of statistical
significance and direction
18Analysis Plan
- Missing data
- Entire instruments
- Domains
- Items
- Visits
- Multiple endpoints
19And finally Labeling!
- Well-controlled studies
- Instrument reliably and validly measures the
concepts claimed - Convey both positive and negative effects
- Specific to the concept measured
20Summary
- Start early in clinical development program
- Talk to FDA review divisions
- Document, document, document
- Development of instrument
- Validation of instrument
- Clinically meaningful difference
- Implementation
21Summary
- Study Design
- Blinding
- Use of instrument
- Prospectively defined
- Analysis plan
22Summary
- Labeling
- Conveys both negative and positive effects
- Specificity to concepts measured