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The Adjudicators: Role and Responsibilities of the CEC Roxana Mehran, MD Professor of Medicine (Cardiology) and Health Evidence Policy Director of Interventional Cardiovascular Research and Clinical Trials The Icahn School of Medicine at Mount Sinai, New York, NY Chief Scientific Officer Cardiovascular Research Foundation, New York, NY Cardiovascular Research Technology - CRT February 23-26, 2013 Washington, DC Roxana Mehran, MD Consulting: AstraZeneca, Johnson and Johnson, Merck and Company, Inc., and Abbott Laboratories Grant Support: Bristol-Myers Squibb, Sanofi, The Medicines Company, Lilly and Daiichi Sankyo Honoraria: Regado Bio-Sciences Roxana Mehran, MD Institutional Grant/Research Support : Bristol-Myers Squibb/ Sanofi Lilly/ Daichii Sankyo The Medicines Company Consulting Fees/Honoraria Abbott Vascular Astra Zeneca Merck Regado Biosciences Janssen (J+J) Clinical Events Committee: Why Do we need it? • Clinical trials are the cornerstone to approval of Drugs/devices • The quality and independence of the conduct of the clinical trials is central to evaluate the results of any study • CEC provides blinded, unbiased, independent assessment of critical endpoints using source documents and expert evaluation CEC Responsibilities • The CEC is an organization formed to review specific information obtained from research subjects who are participating in a clinical trial. • The committee is empowered to make judgments regarding this information and to draw conclusions about pre-specified events that may or may not have happened during the course of a clinical trial. • The committee may or may not agree with conclusions drawn by the investigator from a specific site; in this case the committee’s conclusion will serve as the final decision for submission to regulatory authorities and/or for the purposes of reporting and publication. Responsibilities • To review specific information available for research subjects participating in the trial and experiencing pre-specified events (endpoints) • To use the most up-dated scientific, technical and clinical information in order to reach their conclusions • To draw the conclusions independently from those of treating physician, PI or sponsor (if different from those of the site investigator, the CEC’s conclusion will be considered final) Adverse Event Reporting • Adverse event: Any untoward or unfavorable medical occurrence in a human subject, including any abnormal sign (for example, abnormal physical exam or laboratory finding), symptom, or disease (Definition from1996 International Conference on Harmonization E-6 Guidelines for Good Clinical Practice) Serious Adverse Event • Any event temporally associated with the subject’s participation in research that meets any of the following criteria: results in death is life threatening (places the subject at immediate risk of death from the event as it occurred) requires inpatient hospitalization or prolongation of existing hospitalization (Definition from1996 International Conference on Harmonization E-6 Guidelines for Good Clinical Practice) Serious Adverse Event -2 • Results in a persistent or significant disability/incapacity • Results in a congenital anomaly/birth defect • Any other adverse event that, based upon appropriate medical judgment, may jeopardize the subject’s health and may require medical or surgical intervention to prevent one of the outcomes listed above (Definition from1996 International Conference on Harmonization E-6 Guidelines for Good Clinical Practice) Composition of the CEC • Typically the committee is composed of odd number of members with at least three members present during each meeting (Quorum). • The members should include those with expertise in the field as it relates to the trial: Cardiologists, Interventional Cardiologist, Cardiothoracic surgeon, Neurologist (especially if Stroke is a primary endpoint event) • The committee is supported by team to facilitate a timely review of cases identified as having potential endpoints, as well supervising the flow of work and adherence to the CEC Charter Important Tips: • Develop standardized CEC processes Meeting schedule and required attendees Signature form for each meeting Adjudication process Meeting minutes Tracking process for event adjudication status • Develop a reconciliation process For events discovered by the CEC during adjudication that meet study endpoints but were not coded or reported as such by site staff Reconciliation of the clinical database site reported events against CEC adjudicated events and all database entries (multiple Core Lab database entries- QCA, IVUS, ECG, etc.) and CEC adjudicated outcomes Clinical Event Committees: Tips • Include CEC members who are Independent from the study Knowledgeable in the therapeutic area being studied Experienced in the conduct of clinical research • Train CEC members to Study protocol, study definitions, CEC procedures, case report forms, adjudication forms Prior to the Start of the Adjudication Process • Train CEC members to Study protocol- a full understanding of the protocol is essential prior to start of any adjudication Study definitions-All members should be familiar and agree on their interpretation of the study definitions CEC procedures, case report forms, adjudication forms Goals • Unbiased, independent assessment of events • Identification of events through review of reported events • Fair and non-judgmental adjudication of endpoints---Blinding required • Quality control and consistent adjudication Conclusions • CEC process must be consistently rigorous to maximize the clinical and research value of the clinical data obtained continually evaluated throughout the trial • CEC harmonization is paramount to assure confidence in the quality and interpretation of large sets of clinical data • However, we must remain cautious not to take away the true independence of CEC! Randomized Trials vs Observational Studies: Advantages and Disadvantages Roxana Mehran, MD Professor of Medicine (Cardiology) and Health Evidence Policy Director of Interventional Cardiovascular Research and Clinical Trials The Icahn School of Medicine at Mount Sinai, New York, NY Chief Scientific Officer Cardiovascular Research Foundation, New York, NY Cardiovascular Research Technology - CRT February 23-26, 2013 Washington, DC Clinical-Decision Making Medicine is the ART of “Balance” Randomized Controlled Trials Observational Registries Evidence-based Medicine Study Design Treatment Assigned by Investigator? No Yes Observational: Nature takes its course, ‘natural experiments’ Cohort: subjects defined by presence/absence of exposure Retrospective: Events have occurred at study onset Experimental Studies (Trials): Randomized or non-randomized Case-Control: subjects defined by presence/absence of disease Prospective: Events have not occurred at study onset Adapted from Aschengrau et al., Essentials of Epidemiology, 2nd ed. 2008 Study Types: Randomized • Defined as: – “Comparative studies with an intervention and control group; assignment of the participants to a group is determined by randomization. Randomization, in the simplest case, is a process by which all participants are equally likely to be assigned to the intervention or control group.” Friedman et al. Fundamentals of Clinical Trials, p. 43. Randomized Trials: Advantages • Removal of bias in allocating participants to one group vs. another (Selection bias) • Randomization produces groups that are similar in both known and unknown confounders (Baseline characteristics table) • Validity of statistical tests is guaranteed • A RCT is the equivalent of controlled ‘experiment’ in clinical research Randomized Trials: Disadvantages • Certain hypotheses cannot be randomized – Impact of bleeding on outcomes • Strict inclusion/exclusion criteria often preclude generalizability (COURAGE: 35K screened 2.8K randomized Randomized Trials: Disadvantages • Poor design Choice of controls Poor Assumptions- Underpowered Inappropriate delta for non-inferiority trials Poor Definitions- not standardized • Poor execution Protocol deviations Crossovers/Withdrawals Absence of blinding Bias in endpoint assessment or adjudication Randomized Trial Interpretation • Intention to Treat (ITT) vs Per Protocol analysis – To maintain the benefits of randomization (i.e. balance in risk factors between comparative groups), analysis must be performed by ITT – Any other analysis (subgroups, per protocol etc.) is a non-randomized comparison and therefore subject to the identical limitations of observational designs Types of Randomized Trials • Superiority – Superiority aims to show that one therapy is definitively different (“better”) than another • Null hypothesis states that event rate with treatment A is equal to event rate with treatment B – Basic superiority question: What is the probability that this difference could have occurred by random chance? • If the probability is less than 5% (arbitrary), then one concludes that treatment A is ‘different’ (i.e. better) to treatment B Types of Randomized Trials • Non-inferiority – Non-Inferiority aims to show that one therapy is no worse than another – Worse is defined by pre-specified Δ that is arbitrarily assigned. – Null Hypothesis: Event rate (Tx) – Event rate (Control) ≥Δ – Alternative Hypothesis: Event rate (Tx) – Event rate (Control) < Δ Summary: Randomization • Each patient has equal chance of getting a new or standard treatment • It cannot be predicted in advance • Treatment groups should have similar baselines • Helps keep ancillary care and patient evaluation handling identical • Avoids bias 28 Observational Studies: Retrospective • Defined as: – All events have happened already, and patients’ information is collected from the past (through chart review, phone calls, etc) • Pros – Inexpensive – Fast to execute – Rarely any ethical/regulatory hurdles • Cons – Subject to bias – unable to address causality – very low level of evidence Observational Studies: Case Control • Defined as: – Patients with events of interest (cases) are identified and then compared to patients without events (controls) • Pros – Useful to study rare diseases/outcomes, – Fast to execute – Inexpensive • Cons – Difficult in choosing ideal control group, bias Observational Studies: Cohort • Defined as: – A group of patients followed until they have events (very common – Framingham, Dallas Heart, etc.) • Pros – Best design for studying cause of a condition, course of disease, or risk factors – Correct time sequence to provide strong evidence • Cons – expensive – Time consuming – unable to prove causality – (ASSOCIATION ≠ CAUSALITY!) Observational Studies: Prospective Single Arm • Defined as: – Following patients undergoing therapy for evaluation of outcome of interest • Pros – Able to detect low frequency safety events – A good post-market tool – Real world – Track Practice Trends • Cons – Selection Bias – Un-measured Confounders can skew the data – unable to prove causality What are Unmeasured Confounders? Obvious prognostic factors that aren’t collected - E.g. LVEF, renal function, concomitant medications Less obvious factors that aren’t collected - E.g. socioeconomic status, education, compliance, frequency of physician visit Physician’s own practice bias Variables difficult or impossible to measure - E.g. genotype, endothelial function, extent of atherosclerosis - Other factors which have not yet been implicated in disease pathophysiology (but will in the future!) Which Registry is Right? SCAAR Registry March 8th, 2007 3 year mortality increased 18% with DES Ontario Registry October 4th, 2007 3 year mortality decreased 29% with DES Randomized Controlled Trials vs. Observational Registry Studies The Essential Elements: 1. Unmeasured confounders are inherent in all registries; their impact cannot be overcome by even the most sophisticated statistical analyses, leading to frequently incorrect results and bias in interpretation based on preconceived beliefs 2. By eliminating the effect of unmeasured confounders, prospective RCTs represent the highest level of scientific achievement, and when appropriately performed must be the predominant driver of clinical (and policy) decision-making Observational Registries 1) Adavanteges of registries include their real-world nature with few exclusion criteria, large size, and low cost 2) Invaluable to identify low frequency safety events, and practice patterns 3) However, registries are limited by variable quality of data collection, minimal/absent monitoring, and lack of independent event adjudication and core labs 4) However, unmeasured confounders are inherent in all registries; which can lead to incorrect results and bias in interpretation based on pre-conceived beliefs 5) As a result, registries should not be used for comparative effectiveness analysis, other than to generate hypotheses to be tested in appropriately powered randomized trials Randomized Controlled Trials 1) Prospective RCTs represent the highest level of scientific achievement, and when appropriately performed should be the predominant driver of clinical (and policy) decision-making 2) However, randomized trials may also be of variable quality, and if under-powered may generate false negative and positive findings 3) Secondary endpoints and subgroup analyses from RCTs should be considered hypothesis-generating only, unless pre-specified and appropriately powered 4) Randomized trials and registry studies are complementary! To fully characterize the safety and efficacy of therpies (drugs or devices), high quality, well powered RCTs enrolling “real world” patients must be performed, followed by high quality post-market approval registry surveillance studies What really matter? Quality QUALITY QUALITY