Title: DMC Issues from a Pharmaceutical Industry Perspective
1DMC Issues from a Pharmaceutical Industry
Perspective
- Steven Snapinn
- Amgen
- FDA-Industry Workshop
- September 15, 2005
2Outline
- Assessing the Need for a DMC
- Independence of the DMC
- Scope of the DMCs Responsibilities
- Issues in Setting the Stopping Boundaries
- How Are Decisions Made?
- Case Study 1 PRISM-PLUS
- Stopping for Futility
- Case Study 2 CONSENSUS II
3Assessing the Need for a DMC
- Considerations
- Seriousness of the Medical Condition
- Uncertainty of Efficacy and Safety
- Size of the Trial
- Duration of the Trial
- Benefits of Having a DMC
- Credibility
- Experience
- Neutrality
4Internal vs. External DMCs
- Early Development
- Safety Monitoring by Study Team
- Dose Escalation Decisions
- Efficacy Monitoring by Internal DMC
- Independent of Study Team
- Phase III
- External DMC Typical
5Independence of the DMC
- Committee Membership
- DMC Independent of Sponsor
- No Sponsor Participation in Closed Session
- Preparation of Interim Reports
- Regulatory Guidance Frowns on This Being a
Sponsor Responsibility - Sponsors Typically Contract Independent Group
6The Case for an Unblinded Sponsor Statistician
- Firewall
- Familiarity with the Study
- Control of the Allocation Schedule and Interim
Results - Sponsors Risk
- Quality Assurance
- Data Leaks
- What Constitutes Independence?
7Scope of the DMCs Responsibilities
- Safety Monitoring
- Efficacy Monitoring
- Timeliness and Accuracy of the Database
- Protocol Adherence?
- Sample Size Re-estimation?
- Requests for ad hoc Analyses
8Issues in Setting the Stopping Boundaries
- Stopping Boundaries for Safety
- Stopping Boundaries for Efficacy Protect
Patients in the Trial or Protect All Patients? - Require Overwhelming Evidence or Moderate
Evidence? - Are Patients Fully Informed?
9Issues in Setting the Stopping Boundaries
(continued)
- Review of Efficacy Data for Risk/Benefit
Assessment Only - Set Extreme Efficacy Criterion (eg, 0.0005)
- Protection for Sponsor
- Group Sequential vs. Conditional Probability
10Other Issues
- Partial vs. Full Unblinding
- Information Sharing Across DMCs
- Monitoring Noninferiority Trials
11How Are Decisions Made?
- Decision-Making Authority
- Independent Steering Committee
- Sponsor
- Sponsors Awkward Position
- Reclaiming Type I Error
- Efficacy Boundary Crossed But Trial Continues
- Futility Boundaries
12Case Study PRISM-PLUS
- Patients with Acute Coronary Syndrome
- Non-Q-Wave Myocardial Infarction
- Unstable Angina Pectoris
- Evaluation of Tirofiban, an Inhibitor of Platelet
Aggregation
13PRISM-PLUS Study Design
- Three Treatment Arms
- Control Arm Heparin Alone
- Monotherapy Arm Tirofiban Alone
- Combination Arm HeparinTirofiban
- Composite Endpoint
- Refractory Ischemia/Readmission for UAP
- Myocardial Infarction
- Death
14Study Organization
- Oversight by an Independent Steering Committee
- Sponsor Representatives Attend SC Meetings
- Makes Decisions on DMC Recommendations
- Data Monitored by an Independent DMC
- No Sponsor Representative (Other than Unblinded
Statistician) - Recommendations on Trial Modification to SC
15Interim Results of PRISM-PLUSComposite Endpoint
Time Point Heparin (N351) Tirofiban (N345) Combination (N336)
2 Days 24 (6.8) 26 (7.5) 19 (5.6)
7 Days 59 (16.8) 59 (17.1) 39 (11.6)
30 Days 78 (22.2) 81 (23.5) 63 (18.8)
16Interim Results of PRISM-PLUSDeath
Time Point Heparin (N351) Tirofiban (N345) Combination (N336)
2 Days 1 (0.3) 2 (0.6) 0 (0.0)
7 Days 4 (1.1) 16 (4.6) 5 (1.5)
30 Days 14 (4.0) 21 (6.1) 7 (2.1)
17Summary of Results
- Composite Endpoint Rates Similar in Heparin and
Tirofiban Groups - Death Rate Higher in the Tirofiban Group
- 7-Day Mortality
- 16/345 vs. 4/351 - p-value 0.006
- Pooling Heparin and Combo Groups
- 16/345 vs. 9/687 - p-value 0.001
- Is This Sufficient Evidence?
18The Pharmaceutical Sponsors Dilemma
- DSMB Recommended Discontinuation of the Tirofiban
Arm - Steering Committee Felt That the Evidence Was
Insufficient - Representatives of the Sponsor Were Present at
the Meeting - Can the Sponsor Allow Randomization to Continue
when the DMC Believes That Patients Will Die
Unnecessarily?
19Final Results of PRISMDeath
Time Point Heparin (N1616) Tirofiban (N1616)
2 Days 4 (0.2) 6 (0.4)
7 Days 25 (1.6) 16 (1.0)
30 Days 59 (3.6) 37 (2.3)
20Stopping for Futility
- Inability of a Trial to Meet Its Objectives
- Operational vs. Statistical
- Goal Is to Preserve Resources
- No Ethical Imperative
- Group Sequential vs. Conditional Probability
- Frequentist vs. Bayesian Methods
21Stopping for Futility (continued)
- One-Sided vs. Two-Sided Boundaries
- Can Alpha Be Reclaimed?
- Cost in Power and Secondary Objectives
- Need for Prior Agreement
22Case Study CONSENSUS II
- 9000 Patients with Acute Myocardial Infarction
- Comparison of Enalapril and Placebo
- Primary Endpoint is 6-Month Mortality
- Assumed Rates 12.0 vs. 9.6
23CONSENSUS II Interim Monitoring
- Key Design Features
- Frequent Interim Analyses
- Terminate If Interim Results Clearly Indicate
Lack of Benefit - Monitoring Plan Based on Conditional Probability
- Future Rates Assumed Between Current Rates and
Originally-Assumed Rates - Alpha Reclaimed
24CONSENSUS II Interim Results
All Rand. Pts Pts w/6 Mo. FU Cond. Prob
Analysis Enal PBO Enal PBO Rej. Acc.
1st 40/6725.9 31/6334.9 None None
6th 178/20798.6 159/20827.6 38/35610.7 34/3519.7 1.1 16.5
7th 242/26909.0 215/26938.0 89/74412.0 74/72410.2 0.1 58.4
Final 312/304410.2 286/30469.4 164/147511.1 146/14779.9 0.01 94.8
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26CONSENSUS II Lessons Learned
- Stopping for futility is a difficult problem
- Without Clear Trend Toward Efficacy or Harm
Theres No Ethical Imperative - Without Hope for Benefit Patients Should Not Be
Subjected to Risks - Prior Agreement Required
- Within DMC
- Between DMC and Trial Leadership
27CONSENSUS II Lessons Learned (continued)
- Stopping Boundary
- Flexibility Is an Advantage
- Reclaiming Alpha May Not Be Appropriate
- Basing Conditional Probabilities Only on Patients
With Complete Follow-Up Was a Disadvantage