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Post-marketing safety and efficacy surveillance of cell and gene therapies in the EU: A critical review

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The implementation of new regulatory tools, such as the PRIority MEdicine (PRIME) scheme, by regulatory authorities in Europe enabled faster patient access to innovative therapies. This early access tool goes along with a clear need for a thorough assessment of safety and efficacy upon marketing authorization. Due to the higher degree of uncertainty when evaluating novel therapies such as advanced therapy medicinal products (ATMPs), post-marketing surveillance studies for these products should be designed to make up the evidential shortfall and provide additional evidence to inform clinical practice. Here, we describe the status and regulatory requirements of post-marketing surveillance for ATMPs, which we found often resembling traditional, pre-market trials, focusing on biological mechanisms and efficacy in narrowly defined patient populations. We close by proposing the pragmatic trial concept as a potential solution to improve data quality and evidence generation in settings closer to real-world.
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CELL & GENE THERAPY INSIGHTS
CLINICAL TRIAL DESIGNS FOR
ADVANCED THERAPIES
EXPERT INSIGHT



Enrico Fritsche, Magdi Elsallab, Michaela Schaden,
Spencer Phillips Hey, Mohamed Abou-El-Enein
         
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
        -

       -

         
       
 
 -
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
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Cell & Gene Therapy Insights

CELL & GENE THERAPY INSIGHTS
DOI: 10.18609/cg.2019.156




Evaluating a marketing-authori-
zation application under the con-
ventional centralized procedure of
the European Medicine Agency
(EMA) can be a lengthy process,
taking up to 210 days (and that
is excluding any additional time
required for applicants to respond
to EMA requests for additional in-
formation). In an eort to support
drug development, the EMA has
devised several early access routes
for drug developers in the EU [1]
where some of them can be uti-
lized via the PRIority MEdicine
(PRIME) scheme [2]. e PRIME
scheme was launched in March
2016, specically to support the
more rapid translation of products
targeting an unmet medical need
by enhancing the early interaction
and dialogue with regulators before
submission of marketing authori-
zation application (MAA), as well
as accelerating the regulatory as-
sessment procedure of MAA [3,4].
While such regulatory tools can
help to more expeditiously satisfy
unmet medical needs, this comes
at the cost of having a less com-
prehensive data set, and therefore,
greater uncertainty about the prod-
uct’s benet-risk balance at the
time of marketing authorization.
However, to oset this initial lack
of data, EMA obligates product
developers to perform extensive
post-marketing studies in order
to generate more robust evidence
supporting the overall safety and
ecacy prole of these products.
Similar policies are adopted by the
US Food & Drug Administration
(FDA) in cases when new drugs are
approved on the basis of limited
evidence [5,6]. Developers of ad-
vanced therapy medicinal prod-
ucts (ATMPs) have proactively
integrated PRIME and other such
regulatory tools into their product
development strategies [7–9]. For
example, by mid 2019, three AT-
MPs (Kymriah®, Yescarta®, and
Zynteglo®) were approved under
the PRIME scheme (although
only Zynteglo beneted from the
accelerated assessment; assessment
of Kymriah and Yescarta were re-
verted to the standard timetable
since major objections were raised
during the regulatory evaluation
and could not be resolved within
the accelerated timetable).
However, the uncertainty about
the benet-risk prole of new-
ly-approved ATMPs is not merely
due to regulatory exibility. ere
are several other features of clini-
cal trials for ATMPs that can leave
critical gaps in the evidence base
concerning product safety and ef-
cacy [10–15]. For example, since
ATMPs often target rare diseases
[16], the pre-market clinical trials
are mostly small, single-arm trials
that face an increased risk of bias
and other translational challenges
[17]. Surveys among ATMP-devel-
opment companies in Europe have
shown that for many rare diseases
of interest, little is known about
disease progression or the chal-
lenges associated with creation and
interpretation of reliable endpoints
for new indications [18]. Selection
of endpoints is of particular impor-
tance since ATMP trials mainly rely
on surrogate endpoints due to the
lack of clinically meaningful ones
for many indications, such as vari-
ous cardiac cell therapy approaches
[19]. However, relying on surrogate
endpoints in pre-market trials only
amplies the uncertainty for how
EXPERT INSIGHT
1507
Cell & Gene Therapy Insights - ISSN: 2059-7800
to appropriately use these products
in the clinical setting [20].
To make up for this epistemic
shortfall, post-marketing stud-
ies are therefore a critical tool for
gathering the much-needed fol-
low-up data, as well as allowing
for additional evidence synthesis
eorts to inform appropriate use
of such products [21,22]. In order
to better understand the character-
istics of the post-marketing studies
associated with ATMPs approval,
we examined the regulatory land-
scape of post-marketing studies
and performed a systematic review
of the European Public Assessment
Reports (EPAR) that is describing
the evaluation of ATMPs autho-
rized via the centralized procedure.


Data on post-marketing clinical
studies (planned and ongoing) of
authorized ATMPs were extracted
from the respective specic Eu-
ropean public assessment report
(EPAR) and the corresponding
page in clinicaltrials.gov registry
for each product. e EPAR search
was based on the “nd medicine”
search function on the EMA web-
site www.ema.europa.eu/en/med-
icines. e cut-o-date for data
entry is November 1, 2019. Rele-
vant data were extracted from the
pharmacovigilance plan that, upon
marketing authorization, each mar-
keting authorization holder MAH
has to provide within a detailed
Risk management plan. Detailed
information on this can be found
within the EPAR, chapter “Risk
Management Plan”, sub-chapter
“Pharmacovigilance Plan”, which
includes a table describing “type
of study/ status”, “categorization
1-3”, “objectives”, “safety concerns
addressed”, “date for submission of
interim or nal reports (planned or
actual)” and optional “milestones
or separate information on “sta-
tus”. is sub-chapter represents
‘additional pharmacovigilance ac-
tivities’, a regulatory term that en-
compasses all pharmacovigilance
activities not considered as routine,
and can include clinical studies or
non-interventional post-authori-
zation safety studies (more details
provided in Box 1). ese activities
can be assigned at the time of mar-
keting authorization to one of three
categories that need to be followed
when implementing post-market-
ing authorization studies on AT-
MPs. Category 1 is mandatory and
comprises post-marketing studies
that are imposed as conditions to
the marketing authorization. ese
studies should provide key infor-
mation to the benet-risk prole
of the product. Category 2 is also
mandatory and entails specic ob-
ligations only in case of a condi-
tional marketing authorization or
a marketing authorization under
exceptional circumstances. Final-
ly, any other studies for investi-
gating a specic safety concern or
evaluating the eectiveness of risk
minimization activities fall under
category 3. Category 3 comprises
activities which are conducted or
nanced by the MAH for investi-
gating specic safety concerns, but
‘do not include studies which are
imposed or which are specic ob-
ligations’ (i.e. excluding categories
1 or 2) [23].
Categorization of each ATMP
to “Gene-“, “Somatic cell-“, or
“Tissue-engineered” was based on
information extracted from the
EPAR of the respective authorized
CELL & GENE THERAPY INSIGHTS
DOI: 10.18609/cg.2019.156

ATMP [24–33]. According to EMA
classication, gene therapy prod-
ucts function by inserting ‘recom-
binant’ genes into the body, usu-
ally to treat a variety of diseases,
including genetic disorders, cancer
or long-term diseases. Somatic-cell
therapy products contain cells or
tissues that have been manipulat-
ed to change their biological char-
acteristics or cells or tissues not
intended to be used for the same
essential functions in the body. Tis-
sue-engineered products contain
cells or tissues that have been mod-
ied so they can be used to repair,
regenerate or replace human tissue
[34,35].
e last published information
on the post-marketing studies
was collected by searching Clin-
icaltrials.gov database using the
tradename, international non-pro-
prietary name or, if available, clin-
icalTrials.gov identiers (Data-cut-
o: November 1, 2019).



e results of our data extraction
for the 10 EMA-aproved AT-
MPs are presented in Table 1. e
composition of the post-authori-
zation studies of ATMPs was an
equal split between interventional
studies (50%) and observational
studies (50%) (Figure 1). 35% of
the interventional studies includ-
ed were already ongoing at the
time of marketing authorization
(MA), and the applicant would
be required to provide an update
on the results of the studies, while
15% were newly designed studies.
e newly planned interventional
trials have generally adopted de-
signs that resemble pre-market tri-
als—eg., using single-arm designs,
small sample sizes, or short-term
follow-up periods with primary
outcomes often focused on answer-
ing hypothesis from pre-marketing
scenarios, focusing on a narrow
study population rather than test-
ing real-world scenarios in a broad-
en population (Table 1). Observa-
tional trials were either long term
fBOX 1
The regulatory framework for post-markeng studies.

-
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
-
[57,58]  
    

   [35]     
 
 
        -
 
 

 [57]        

[59]
[36]  



-

        
-
 
    [35] 
 [59] -
-


        -
       [25,26] 

-


-

[60]


EXPERT INSIGHT
CELL & GENE THERAPY INSIGHTS
1509
1509 DOI: DOI: 10.18609/cg.2019.156 Cell & Gene Therapy Insights - ISSN: 2059-7800
fTABLE 1
Overview of addional pharmacovigilance acvies in post-markeng sengs for all currently marketed ATMPs within Europe.
Class of ATMP Name of ATMP
(# of PMAS) Category Study design Idener Pivotal
(main study)
Sample
size
Follow-up
length Study objecves to full PMAS requirement Status at
me of MA






  X   
1-
  X   


  X   
  X   
2  X 170   
1  X  
 






  X  
 

  X 920  
 
  X  
 
  X   
  X   


1
  X   
1  X 




1  🗸 




1  X   

  X 1250   


1-
  X   
1
  X   


1
  X 50   
  🗸   
  X  

  X  
 


1  X   
  X   
  🗸290 


 
  X 105 




  X 125  
 
 Intervenonal studies planned at me of markeng authorizaon, Intervenonal studies ongoing at me of markeng authorizaon, Observaonal studies planned at me of markeng authorizaon, Observaonal studies ongoing at
me of markeng authorizaon.



EXPERT INSIGHT
CELL & GENE THERAPY INSIGHTS
1510
1510 DOI: DOI: 10.18609/cg.2019.156 Cell & Gene Therapy Insights - ISSN: 2059-7800
fTABLE 1 (CONT.)
Overview of addional pharmacovigilance acvies in post-markeng sengs for all currently marketed ATMPs within Europe.
Class of ATMP Name of ATMP
(# of PMAS) Category Study design Idener Pivotal
(main study)
Sample
size
Follow-up
length Study objecves to full PMAS requirement Status at
me of MA









  X 100  
 

  X  
 

  X  
 

  X   


1  X  

2  🗸 




2  🗸15  
 
2  🗸   
Tissue-




2  X   

  X  
 

  X   


   🗸102  
 
   🗸75  
 
 Intervenonal studies planned at me of markeng authorizaon, Intervenonal studies ongoing at me of markeng authorizaon, Observaonal studies planned at me of markeng authorizaon, Observaonal studies ongoing at
me of markeng authorizaon.



EXPERT INSIGHT
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Cell & Gene Therapy Insights - ISSN: 2059-7800
follow up of the patients treated
in premarketing studies or mostly
a registry study to collect data on
particular safety and ecacy pa-
rameters in real-world settings.
e number of total post-mar-
keting studies ranged from two to
nine across the 10 ATMPs (Fig-
ure 2). e sample size of the trials
ranged from 15 to 1250 patients
(Table 2), with most of the tri-
als intending to enrol fewer than
200 patients (Figure 3). Duration
of follow-up in trials ranged from
12 to 180months (Table 2), which
is mostly dependent on the use
of viral vectors in the treatment
since these products require lon-
ger follow-up for safety-related
fFIGURE 1
Percentage of post-markeng authorizaon study types at MA for all
marketed ATMP.
fFIGURE 2
Number and types of post-markeng authorizaon studies submied by each applicant.




CELL & GENE THERAPY INSIGHTS
DOI: 10.18609/cg.2019.156
1512
parameters. Half of applicants
(50%) included Phase III interven-
tional trial designs that tradition-
ally focus on product ecacy as a
primary endpoint and usually form
the basis of the regulatory submis-
sions and authorization (Figure 4).
Most of these trials (86%) were
initiated before the MA but only a
few of them represent pivotal trials
upon which the MA was acquired
and the rest continued to perform
these trials as part of the post-mar-
keting surveillance phase which
would have traditionally been in-
cluded in a MA submission pack-
age (Table 1).




Our analysis suggests that a high
degree of variability between trial
designs of ATMPs in post-market-
ing settings cthat can be explained
by the wide range in evidence gen-
erated from clinical studies at the
time of MAA, the rarity of the in-
dication and the specic character-
istics of the product itself (whether
fFIGURE 4
Frequency of study phases submied as post-markeng authorizaon studies.
fTABLE 2.
Summary stascs of post-markeng authorizaon design pa-
rameters among ATMPs.
Sample size Follow-up (months)
  25
 2 0
  
  
  
 15 12
 1250 
fFIGURE 3
Frequencies of sample sizes specied in the post-markeng studies of
ATMPs.
EXPERT INSIGHT

Cell & Gene Therapy Insights - ISSN: 2059-7800
it is genetically modied or not).
is inherited variability requires
developers to devise a post-mar-
keting strategy based on a case-by-
case scenario. Moreover, many of
the post-marketing trials, intended
to address the critical benet-risk
knowledge gaps for ATMPs, are
phase III interventional trials that
may not be well suited to inform
routine clinical use of the products.
e sample sizes of post-marketing
trials are relatively small for studies
that should aim to reect real-life
situations. Further analysis of the
data also showed high variability in
the follow-up periods specied for
each study (Figure 5). ese obser-
vations add the challenge of iden-
tifying a clear cut-o between pre-
and post-marketing studies and the
exact added value of PMAS.
e dominant trial paradigm
for decades has been explanatory
in its orientation—which is to say
that trials have been designed to
test experimental interventions un-
der “idealized” or “laboratory-like”
conditions that are optimized to
detect a treatment eect. Explana-
tory trial designs thus generally in-
volve strict intervention protocols,
many patient inclusion/exclusion
criteria, and high-resourced settings
in an eort to control for system-
ic errors (e.g. confounding, bias)
and deliver statistically credible re-
sults of high internal validity [36].
In the pre-market setting, this ap-
proach to trial design makes good
sense, since the primary question
from a regulatory perspective may
be of the form: How will this new
intervention work for this particular
patient in a controlled setting? By
contrast, in the post-market setting,
the primary question is a dierent
form: “Can this new intervention
be benecial once available to the
wider population?” Addressing this
question requires a more pragmat-
ic orientation to trial design, which
often involves more exible proto-
cols, broader and more heteroge-
neous patient populations, and a
mix of dierent healthcare settings.
For instance, early evidence of the
real-world ecacy performance of
Yescarta, a CAR T cell-based prod-
uct used in treatment of non-Hod-
gkin lymphoma (NHL), showed
that the ecacy signals generated
once the product was used in clin-
ical practice, applied to more het-
erogeneous population are slightly
inferior to that generated from the
clinical trial [37].
is raises the question of
whether it is more sensible to
continue reproducing data in
post-marketing settings within the
framework of phase III-type trials
or rather introduce more exible
designs that would account for re-
al-world heterogeneity.
fFIGURE 5
Frequencies of follow-up periods specied in the post-markeng studies of
ATMPs.
CELL & GENE THERAPY INSIGHTS
DOI: 10.18609/cg.2019.156





Pragmatic trials are meant to in-
form a clinical or policy decision
by evaluating the eectiveness of
interventions in real-world clini-
cal practice [38]. We believe that
the distinction between explana-
tory and pragmatic trial concepts
may be valuable here when de-
signing post-marketing trials that
are needed to ensure safe and re-
liable use of ATMPs and full the
requirements of multiple stake-
holders (regulators, HTA bodies,
payers etc.) [39].
For ATMPs, the major draw-
backs of an explanatory orientation
are the small sample size due to low
incidence levels, a short time frame
of observation, limited or com-
plete exclusion of distinct patient
population such as vulnerable pop-
ulations (e.g., children, elderly and
pregnant women) and patients with
comorbidities (e.g., neurological or
hematological disorder, autoim-
mune disease or infections) [40].
More heterogenic outcome data
would be of particular value for
these products, due to commonly
underlying heterogenic baseline
parameters immanent to the types
of rare diseases that are frequent-
ly of interest. us, it seems that
more pragmatic trials would be
suitable for ATMP post-market-
ing safety and ecacy surveillance.
Although the data from pragmatic
trials is noisier, it can nevertheless
provide a more representative pic-
ture of whether an intervention ac-
tually has utility in clinical practice
(or how its utility may vary from
one set of conditions to the next).
However, when characterizing
explanatory and pragmatic trial
concepts, it is crucial to observe
that the explanatory/pragmatic
distinction is not a dichotomy, but
a multi-dimensional continuum.
In recognition of this point, or-
pe et al. implemented the PRag-
matic-Explanatory Continuum In-
dicator Summary (PRECIS) tool,
which breaks down a trials prag-
matism (or lack thereof) along 10
dierent dimensions as described
in their published report [41].
As a result of subsequent ex-
tensive discussion on the concept
of pragmatism within clinical re-
search methodology [40,42–50],
the requirements for characteriz-
ing a study as pragmatic trial were
optimized and validated, leading
to the implementation of PRE-
CIS-2 [51]. is improved tool
represents a nine-spoked ‘wheel
with nine domains based on trial
design decisions. e features of
PRECIS-2 were summarized in
Box 2.
fBOX 2
The Pragmac-Explanatory Connuum Indicator Summary 2
(PRECIS-2) wheel (adapted from Loudon et al., 2015 [51]).
1. “Eligibility” domain  

2. “Recruitment” domain      

3. “Seng” domain
4. “Organisaon” domain

5. “Flexibility: delivery” domain    

6. “Flexibility: adherence” domain    
          

 “Follow up” domain
8. “Primary outcome” domain     

9. “Primary analysis” domain   

EXPERT INSIGHT
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Cell & Gene Therapy Insights - ISSN: 2059-7800





To concretely illustrate how we
believe pragmatic, post-market-
ing trials for ATMPs should be
designed, we applied a PRECIS-2
analysis to hypothetical trials for
the two marketed CAR-T cell ther-
apies, tisagenlecleucel (Kymriah®,
Novartis) and axicabtagene cilo-
leucel (Yescarta®, Kite Pharma/Gil-
ead). In what follows, we discuss
particular PRECIS-2’s dimensions
that are relevant to our case study
and how we believe trials of Kymri-
ah and Yescarta should be oriented
along the pragmatic spectrum.
Eligibility criteria
Current post-marketing studies
for Yescarta and Kymriah relied
on restricted enrollment according
to the authorized indication with
deliberate consideration of contra-
indications, special warnings, and
precautions for use (see Annex I,
Summary of product characteris-
tics) [52,53]. An exception to this
was given in case of enrolling spe-
cial patient populations not covered
at marketing authorization, there-
by addressing missing information
according to the RMP (e.g. use in
HBV/HCV/HIV infection, use in
patients with active Central Ner-
vous System (CNS) involvement in
malignancy). However, to be more
pragmatic and better inform clini-
cal use, we believe that there should
be greater exibility in the eligibil-
ity criteria, for example, allow for
patients with dierent schemes of
pre-conditioning lymphodepleting
therapies. is exibility will enable
further exploration of the eects of
dierent treatment schemes on the
product outcome, and thereby ll-
ing some of the critical information
gaps for distinct patient popula-
tions, e.g. co-morbidities, variable
pre-treatment or age groups. e
EBMT registry could be useful here
as well since it enables entering stan-
dardized data that can be analyzed
in larger post-marketing studies.
Organizaon
To deliver clear information on
what kind of expertise and resources
are needed to deliver the interven-
tion of interest, current approach-
es to post-marketing trials tend to
focus on interventions being only
performed by physicians/hospitals
that are specially trained within the
control distribution program as a
risk minimization measure. Given
the risks associated with Kymriah
and Yescarta, we believe that this is
the right approach and that a more
pragmatic design along this dimen-
sion is not necessary.
Flexibility of delivery
Relating to mechanisms on how
to deliver the intervention, cur-
rent post-marketing concepts for
Kymriah and Yescarta CAR-T cell
products focus on administration
only within the authorized dosing
regimen. However, clinicians may
often have to adjust dosing in prac-
tice, for example, for patients with
low baseline T-cell concentrations
in leukapheresis starting materials.
A more pragmatic approach would
thus include administration of
products that do not meet the com-
mercial specications. However, an
CELL & GENE THERAPY INSIGHTS
DOI: 10.18609/cg.2019.156

important pre-requisite to allow
for this kind of approach would be
that no overwhelming safety con-
cerns have been identied during
manufacture and release of such
out-of-specication (OSS) product.
is would enable a deeper inves-
tigation of the dose-response rela-
tionship for OSS concentration lev-
els of the CAR-T cell product. For
instance, the authorized dosage of
Kymriah is 0.2-5x106 CD19+ CAR
T-cells (body weight-based), with
a maximum dose of 2.5x108 CAR
T-cells (non-body weight-based).
However, even lower dose ranges
(e.g. ≤0.03 x 106) in acute lympho-
blastic lymphoma trials showed a
clinical response [54].
Flexibility of adherence
A pragmatic approach here would
ideally deviate as little as possible
from standard practice by avoid-
ing highly stringent time frames for
study visits, thus increasing exi-
bility and patient adherence. Less
stringent follow-up visits may be
also motivating for practitioners, in
reducing the associated monitoring
and workload without jeopardizing
patients safety.
Follow up
e procedure for follow up under
current post-marketing settings re-
lies on an evaluation period of up to
15 years for safety and ecacy sur-
veillance after CAR-T cell adminis-
tration. When applying pragmatic
trial concepts in the post-marketing
settings, post-market studies need to
interface with the patient registries
and rely on them, which in turn will
be the most pragmatic ‘information
engine’ in the long-run. is has the
potential to enhance patient compli-
ance and commitment for a longer
follow up period and promote pa-
tient consent to register data in the
EBMT registry and use it, for in-
stance, as a source of external con-
trol data for comparative purposes.
Primary outcome
e current post-marketing trials
for Kymriah and Yescarta aim at
further characterization of safety
proles, specically related to Cy-
tokine Release Storm (CRS), neu-
rotoxicity, infections, prolonged cy-
topenias, growth and development,
reproductive status and pregnancy
outcomes. Some trials aim to char-
acterize further the ecacy prole
related to Overall Response Rate
(ORR), CD19 CAR T-cell level,
incidence/exacerbation of pre-exist-
ing comorbidities, relapse/progress
disease, incidence death and moni-
toring of replication-competent len-
tivirus. A pragmatic approach along
this dimension could apply a more
concise set of outcomes, particularly
the ones that interfere with patients’
daily productivity and quality of life
while keeping additional tests or vis-
its to a minimum. In order for the
pragmatic approach to provide add-
ed value outside of the controlled
environment of an explanatory trial,
it should also incorporate relevant
patient decision-making criteria to
provide meaningful evidence and
build upon the evidence generated at
the time of MAA.
Primary analysis
ere was no access to detailed sta-
tistical analysis plans to evaluate
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Cell & Gene Therapy Insights - ISSN: 2059-7800
primary analysis mechanisms under
the current conventional post-mar-
keting setting for Kymriah and Yes-
carta. For a pragmatic trial approach
here, including a heterogeneous
patient population and planning
for sub-group analyses would al-
low for detecting clinically-relevant
safety and ecacy signals. Indeed,
given the limited data that is often
available for ATMPs, we would rec-
ommend a maximally pragmatic
approach to the primary analysis of
post-marketing trials to try and in-
clude as much patient-relevant data
as possible.



While the new regulatory tools de-
veloped by EMA to facilitate rapid
marketing authorization in cases
of major public health interests are
warranted, these tools must be ac-
companied by sound post-autho-
rization strategies to generate long
term evidence for safety and ecacy.
e current regulatory landscape
for conducting post-authorization
studies is very complex and demands
an enormous eort from the MAH
to navigate. As we have shown,
there is a wide variety in post-mar-
ket study designs for ATMPs, both
for studies that are required by the
regulatory authorities and for those
studies conducted voluntarily by the
MAH to investigate a specic safety
concern or to evaluate the ecacy/
eectiveness of risk minimization
activities (classied in category 1, 2
and 3). However, within that variety,
we observed that many post-mar-
keting surveillance trials for ATMPs
adopt explanatory trial design fea-
tures and are focusing on answering
hypotheses that a more suitable to
pre-market trials. us, we believe
that there is room for improvement
in terms of designing (or mandating)
post-market trials of ATMPs that
will better meet the information-
al needs of patients, clinicians, and
payers.
We have suggested that applying
the tools of pragmatic trial design
(as made explicit by the PRECIS-2
framework) may help to ll this
gap. In particular, RWD generated
from registry-based pragmatic trials
would have great potential to gen-
eralize ndings and better inform
the use of ATMPs across diverse
patient populations. However, there
are certainly challenges regarding
data quality, as patient populations
will become more divergent, thus
increasing the risk for confounding
and a higher degree of diuse data
generated. On the other hand, the
aggregation of clinical data collected
from RWD can increase the robust-
ness of meta-analyses derived from
post-marketing studies. In a recent
report, regulators from the Swedish
Medical Products Agency called for
more attention to methodological
basics of post-marketing studies
that can help generate reliable re-
sults and armed the regulatory
value of the pragmatic trial concept
regardless of labelling the studies as
‘pragmatic’ or ‘real-world evidence’
[55]. Moreover, the eld of ATMP
may learn from medical device eval-
uations, where regulatory agencies
already implemented guidance on
how to apply real-world data for
regulatory decision-making [56].
While all aspects of the approach
of a pragmatic trial do not need to
be implemented at once, working on
improving the current post-market-
ing study methodology and supple-
menting it with new ideas can help
CELL & GENE THERAPY INSIGHTS
DOI: 10.18609/cg.2019.156

to enhance the current practice (Box
3). We believe that such an approach
would not only be benecial for
MAHs but also for regulators and
health insurance providers, to obtain
real-world data from clinical routine
faster after marketing authorization
for ATMPs.
fBOX 3
Consideraons for using pragmac trial concepts for
post-authorizaon safety and ecacy studies (both
observatonal and intervenonal).
 

 

 
 

 

 

  

  


Contribuons: All named authors take responsibility for the integrity of the work as a whole, and have given their approval
for this version to be published. Fritsche E, Elsallab M and Schaden M contributed equally as authors on this arcle. Hey SP
and Abou-El-Enein M contributed equally as senior authors.
Acknowledgements: None.
Disclosure and potenal conicts of interest: The authors declare that they have no conicts of interest.
Funding declaraon: MS received funding from the Erasmus SMT Mobility Program during her work on this project.
ME received funding from the Arab-German Young Academy of Sciences and Humanies (AGYA), a project of the Ber-
lin-Brandenburg Academy of Sciences and Humanies, funded by the Federal Ministry of Educaon and Research (BMBF).
The project was parally funded from the European Union’s Horizon 2020 research and innovaon programme under grant
agreement No. 825392 (Reshape) and No. 820292 (Restore)

Copyright: Published by Cell and Gene Therapy Insights under Creave Commons License Deed CC BY NC ND 4.0 which
allows anyone to copy, distribute, and transmit the arcle provided it is properly aributed in the manner specied below.
No commercial use without permission.
Aribuon: Copyright © 2019 Fritsche E, Elsallab M, Schaden M, Hey SP, Abou-El-Enein M. Published by Cell and Gene
Therapy Insights under Creave Commons License Deed CC BY NC ND 4.0.
Arcle source: Invited; externally peer reviewed.
Submied for peer review: Oct 2 2019; Revised manuscript received: Nov 2 2019; Publicaon date: Nov 18 2019.
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Cell & Gene Therapy Insights - ISSN: 2059-7800
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Enrico Fritsche
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Mohamed Abou-El-Enein
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... This is translated into less comprehensive clinical data at the time of marketing authorization (MA), and therefore, greater uncertainty about the product's benefit-risk balance. 11 For instance, Zalmoxis authorization was mainly based on promising results of an open-label, non-randomized phase I-II study, supported by the preliminary efficacy and safety data from the first 17 patients of an ongoing phase III controlled study. The final results from this controlled study failed to confirm any benefit at post-marketing level and the drug had to be withdrawn. ...
... It should be mentioned that although most of the products were approved based on single-arm designs, some of their competitors conducted controlled studies to support the MA for the same indication, e.g., Spinraza, 15 or planned controlled post-marketing trials, e.g., Kymriah or Yescarta. 11 By contrary for cell therapies, it should be noted that even though Zalmoxis and Alofisel were granted with an orphan designation, phase III studies were conducted including a comparator arm. 16,17 With these types of flexible and expedited developments with the ATMPs, the current landscape of biological therapies has initiated a shift from traditional clinical developments to a highly product-specific one. ...
... The profile of the planned interventional trials to further assess effectiveness resemble pre-market trials in terms of design, i.e., using single-arm designs, reduced sample sizes, and are focused on a narrow study population. 11 In some cases, generation of evidence post-launch can be particularly challenging, especially when it requires long-term follow-up, since participants may be lost during the trial due to different causes (i.e., cure of the disease, depression, among others) or may be reluctant to participate when the pharmaceutical is already launched. The latter is more evident when the study is randomized. ...
Article
Full-text available
Advanced therapy medicinal products (ATMPs) are innovative therapies that mainly target orphan diseases and high unmet medical needs. The uncertainty about the product’s benefit-risk balance at the time of approval, the limitations of nonclinical development and the complex quality aspects of those highly individualized advanced therapies are playing a key role in the clinical development, approval and post-marketing setting for these therapies. This article reviews the current landscape of clinical development of advanced therapies, its challenges and some of the efforts several stakeholders are conducting to move forward within this field. Progressive iteration of the science, methodologically sound clinical developments, establishing new standards for ATMPs development with the aim to ensure consistency in clinical development and the reproducibility of knowledge is required, not only to increase the evidence generation for approval but to set principles to achieve translational success in this field.
... This accelerated pathway provides active support to efficiently develop agents for unmet medical needs and does not require large datasets. This is counterbalanced by a need for more stringent post-market safety and efficacy evaluations (13). ...
... These concerns are being addressed by longer follow-up periods and implementation of extensive post-marketing authorization studies (post authorization safety and efficacy studies). Such an approach also addresses the uncertainties about products' benefit-risk balance at the time of marketing authorization (13). Indeed, the post market authorization and approach to assess safety and efficacy in lieu of traditional randomized clinical trials is being formally explored by FDA (33,34), commonly referred to as Real World Evidence (RWE) by analyzing Real World Data (RWD), see below. ...
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Advanced Therapy Medicinal Products (ATMPs) comprising cell, gene, and tissue-engineered therapies have demonstrated enormous therapeutic benefits. However, their development is complex to be managed efficiently within currently existing regulatory frameworks. Legislation and regulation requirements for ATMPs must strike a balance between the patient safety while promoting innovations to optimize exploitation of these novel therapeutics. This paradox highlights the importance of on-going dynamic dialogue between all stakeholders and regulatory science to facilitate the development of pragmatic ATMP regulatory guidelines.
... In addition to clinical trials, it is important to monitor the safety and long-term efficacy of CGT drugs. Regulatory authorities face obstacles in developing post-marketing surveillance programs and long-term follow-up to assess the sustainability of responses, potential long-term adverse effects, and actual outcomes in the 21st century [70,71]. States should develop national regulations and procedures for the post-marketing surveillance of biomaterials in phase IV clinical trials (Drugs and Cosmetics Act). ...
... 23 Ensuring and monitoring long-term data collection through post-approval studies and surveillance as a regulatory prerequisite can help overcome this limitation. 24 Where feasible, data should be collected and curated to facilitate access and analysis by independent investigators. These efforts could also benefit from initiatives such as the National Patient-Centered Clinical Research Network (https://pcornet.org/), the National Institutes of Health Collaboratory (https://commonfund.nih. ...
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The emergence of new cell and gene-based therapies (CGTs) utilizing innovative technologies has recently intensified. Long-standing efforts in publicly funded biomedical research have resulted in breakthrough therapeutic approaches for patients with devastating and life-threatening diseases. Transformative gene-based therapeutic tools include human genome editing technologies, refined transposon systems, and synthetic immunoreceptors, such as chimeric antigen receptor (CAR) T cell and natural killer cell engineered immunotherapies. Cancer has been a leading disease target, with the treatment of B cell malignancies yielding compelling clinical outcomes, resulting in the regulatory approval of several CAR T cell therapies. Concurrently, intensive research on solid tumor indications is underway. Similarly, rare diseases are prominent targets for gene therapy and gene editing technologies. Founded on these scientific advances, next-generation CGTs are expected to transform into treatment options for a wider spectrum of conditions. Moreover, while these treatments, to-date, target mostly patients with advanced illnesses, future therapies may be introduced at earlier disease stages, even as primary therapeutic options. Here, we highlight some of the obstacles inherent in CGT evidence generation and research reproducibility and recommend concerted actions on how they can be overcome.
... All drugs that receive market authorization in Canada are subject to post-market surveillance by Health Canada and the Public Health Agency of Canada. Given the challenges posed by rare disease research for personalized medicine, Canada has approved these therapies with requirements for post-market surveillance that aim to fill the evidentiary gap [28]. However, the post-market requirements frequently lack transparency and are subject to delays-further reinforcing accessibility issues on the basis of socioeconomic status. ...
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This article identifies the potential sources of inequity in three stages of integrating cystic fibrosis personalized medicines into the Canadian healthcare system and proposes mitigating strategies: (1) clinical research and diagnostic testing; (2) regulatory oversight and market authorization; and (3) implementation into the healthcare system. There is concern that differential access will cast a dark shadow over personalized medicine by stratifying the care that groups of patients will receive—not only based on their genetic profiles, but also on the basis of their socioeconomic status. Furthermore, there is a need to re-evaluate regulatory and market approval mechanisms to accommodate the unique nature of personalized medicines. Physical and financial accessibility ought to be remedied before personalized medicines can be equitably delivered to patients. This article identifies the socio–ethical and legal challenges at each stage and recommends mitigating policy solutions.
... GRTs are usually a one-time administration product with long-to very long-term benefits. Although evidence and experience may be scarce with approved GRTs, a 10-year period or more durability of efficacy is anticipated so far, and real world-evidence generation are required for as long as 15 years (38). For several GRTs, there are already 7 years of evidence supporting the therapies, which have maintained efficacy. ...
Preprint
Gene replacement therapies (GRTs) are increasingly expected to reach the market. Current healthcare systems are struggling to fund such valuable, costly therapies. GRTs are highly valuable as they extend life through sustained, long-term efficacy or by saving on the costs of a current high-cost standard of care. Some payers have implemented payment models, which do not address the budget impact on the year of acquisition or administration of costly GRTs. This study aims to (1) introduce amortization as an accounting tool within the context of healthcare, specifically for GRTs, (2) present a systematic literature review (SLR) on the amortization or depreciation of pharmaceuticals and medical devices, (3) assess the rationale and feasibility as well as the pros and cons of the amortization of GRTs, and (4) provide recommendations for future steps for the introduction of amortization for GRTs. The limited literature, identified in the SLR, has proposed amortization as a solution for costly, highly valuable GRT funding, but did not fully investigate and detail amortization and its feasibility. This paper further details and illustrates amortization as a promising method for these GRTs by facilitating market and patient access. Current accounting principles and guidelines must evolve to apply amortization to GRTs.
... Registry contributions to strengthen gene therapeutic evidence have been discussed in the literature. 41 A wide variety of post-market study designs for ATMPs is described in a recent paper by Fritsche et al. 42 The authors report that many ATMPs' post-marketing trials adopt explanatory trial-design features that focus on answering hypotheses that are more suitable to premarket trials. They therefore suggest that real-world data generated from registry-based pragmatic trials could better inform the use of gene therapies across diverse and global patient populations, as well as across additional stakeholders (regulators, clinicians, and payers). ...
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The rapid expansion of the gene therapy pipeline in recent years offers significant potential to treat diseases with great unmet medical need. However, the unique nature of these therapies poses challenges to regulating them within traditional frameworks, even when developing in a single country. Various factors exacerbate the issues in commercializing products across regions, including the lack of established regulatory frameworks for developing gene therapy products in many jurisdictions. While some countries have established separate regulatory frameworks for advanced therapies/regenerative medicine products, differences exist between them. Recommended solutions to overcome these hurdles include fostering convergence among countries with separate regulatory frameworks for these products and utilizing reliance and recognition for countries without such frameworks. Additionally, regulators who choose to establish new dedicated frameworks for regulating gene therapies should consider the inclusion of key elements such as expedited regulatory pathways that offer early engagement with regulators, innovative clinical trial design, and adequate post-market confirmatory studies. Increasing the alignment of regulatory pathways across countries will be crucial to facilitating the development of, and access to, gene therapies on a global scale.
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Background: Gene therapy, altering the genes inside human cells, has recently emerged as an alternative for preventing and treating disease. Concerns have been expressed about the clinical value and the high cost of gene therapies. Objective: This study assessed the characteristics of the clinical trials, authorizations, and prices of gene therapies in the United States and the European Union. Research design: We collected regulatory information from the Food and Drug Administration (FDA) and the European Medicines Agency (EMA) and manufacturer-listed prices from the United States, UK, and Germany. Descriptive statistics and t tests were conducted in the study. Results: As of January 1, 2022, the FDA and EMA authorized 8 and 10 gene therapies, respectively. The FDA and EMA granted orphan designation to all gene therapies except talimogene laherparepvec. Pivotal clinical trials were nonrandomized, open level, uncontrolled, phase I-III, and included a limited number of patients. Study primary outcomes were mainly surrogate endpoints without demonstration of direct patient benefit. The price of gene therapies at market entry ranged from 200,064to200,064 to 2,125,000 million. Conclusions: Gene therapy is used to treat incurable diseases that affect only a small number of patients (orphan diseases). Based on this, they are approved by the EMA and FDA with insufficient clinical evidence to ensure safety and efficacy, in addition to the high cost.
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With gene replacement therapies (GRTs) increasingly and rapidly reaching the healthcare marketplace, the vast potential for improving patient health is matched by the potential budgetary impact for healthcare payers. GRTs are highly valuable given their potential life-extending or even curative benefits and may provide significant cost-offsets compared with standard of care. Current healthcare systems are, however, struggling to fund such valuable but costly therapies. Some payers have already implemented specific financing models to account for the new treatment paradigms, but these do not address the budget impact in the year of acquisition or administration of these costly technologies. This health policy analysis aimed to assess the rationale and feasibility of amortization, within the context of financing healthcare technologies, and specifically GRTs. Amortization is an accounting concept applied to intangible assets that allows for spreading the cost an intangible asset over time, allowing for repayment to occur via interest and principal payments sufficient to repay the intangible asset in full by its maturity. Our systematic scoping review on the amortization of healthcare technologies found a very small literature base with even that being unclear and inconsistent in its understanding of the issues. Where amortization was proposed as a solution for funding costly, but highly valuable GRTs, the concept was not fully investigated in detail, nor was the feasibility of the approach fully challenged. However, by providing clear definitions of relevant concepts along with an example of amortization models applied to some example GRTs, we propose that amortization can offer a promising method for funding of extraordinarily high-value healthcare technologies, thereby increasing market and patient access for these technologies. Nonetheless, healthcare accounting principles and financing guidelines must evolve to apply amortization to the rapidly developing GRTs.
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Although there is great potential for cell and gene therapies, most of those currently approved for clinical use, particularly CAR-T cell products, were evaluated in pivotal trials of less than 100 patients. Having such limited data means that there may be a larger-than-usual gap between what is known about the safety and efficacy of these therapies and what clinicians need to know to reliably judge their benefits; and what payers needs to know to establish sound reimbursement policies. Integrating cell and gene therapies into routine clinical practice will therefore require robust mechanisms to report, track, and coordinate further evidence development—to ensure that clinicians and payers have access to the evidence they need. In what follows, we outline some of the challenges inherent in cell and gene therapy evidence development. We then close by presenting a novel model of evidence synthesis that we believe could help to overcome these challenges.
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Advanced therapy medicinal products (ATMPs) require evaluation by the European Medicines Agency's Committee for Advanced Therapies prior to being placed on the European market, subject to a Marketing Authorisation granted by the European Commission. In common with other medicinal products, various regulatory pathways are available for taking ATMPs through clinical trials to market authorisation, and the regulatory pathway taken will depend on a product's characteristics and the target patient population. With the industry poised to deliver more late-stage clinical and commercial ATMPs for serious diseases with high unmet medical need (e.g., T cell immunotherapies for cancer), bringing medicines to patients through optimized regulatory strategies and expedited pathways is assuming greater importance. The European Medicines Agency's priority medicines (PRIME) scheme was introduced in 2016 specifically to enable this, and eligibility has been granted to 19 ATMPs as of the fourth quarter (Q4) 2018. Furthermore, two chimeric antigen receptor (CAR) T cell therapies, Yescarta and Kymriah, have recently completed their journeys through the scheme to Marketing Authorisation. This review discusses how the regulatory pathway for any particular ATMP, with or without PRIME designation, is determined and navigated.
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The pragmatic clinical trial addresses scientific questions in a setting close to routine clinical practice and sometimes using routinely collected data. From a regulatory perspective, when evaluating a new medicine before approving marketing authorization, there will never be enough patients studied in all subgroups that may potentially be at higher risk for adverse outcomes, or sufficient patients to detect rare adverse events, or sufficient follow-up time to detect late adverse events that require long exposure times to develop. It may therefore be relevant that post-marketing trials sometimes have more pragmatic characteristics, if there is a need for further efficacy and safety information. A pragmatic study design may reflect a situation close to clinical practice, but may also have greater potential methodological concerns, e.g. regarding the validity and completeness of data when using routinely collected information from registries and health records, the handling of intercurrent events, and misclassification of outcomes. In a regulatory evaluation it is important to be able to isolate the effect of a specific product or substance, and to have a defined population that the results can be referred to. A study feature such as having a wide and permissive inclusion of patients might therefore actually hamper the utility of the results for regulatory purposes. Randomization in a registry-based setting addresses confounding that could otherwise complicate a corresponding non-interventional design, but not any other methodological issues. Attention to methodological basics can help generate reliable study results, and is more important than labelling studies as ‘pragmatic’.
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ATMPs are expected to provide a major contribution to the field of next generation medicines. Acknowledging the innovative nature of these products, EU lawmakers and regulatory bodies have not insisted on conventional rigid regulatory expectations, but have installed a number of flexible tools to facilitate marketing and patient access. Here, we discuss the early access pathways available in the EU for ATMPs that developers should be aware of and benefit from.
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Objective To characterize the prospective controlled clinical studies for all novel drugs that were initially approved by the Food and Drug Administration on the basis of limited evidence. Design Systematic review. Data sources Drugs@FDA database and PubMed. Study inclusion All prospective controlled clinical studies published after approval for all novel drugs initially approved by the FDA between 2005 and 2012 on the basis of a single pivotal trial, pivotal trials that used surrogate markers of disease as primary endpoints, or both. Results Between 2005 and 2012 the FDA approved 117 novel drugs for 123 indications on the basis of a single pivotal trial, pivotal trials that used surrogate markers of disease, or both (single surrogate trials). We identified 758 published controlled studies over a median of 5.5 years (interquartile range 3.4-8.2) after approval, most of which (554 of 758; 73.1%) were studies for indications approved on the basis of surrogate markers of disease. Most postapproval studies used active comparators—67 of 77 (87.0%) indications approved on the basis of single pivotal trials, 365 of 554 (65.9%) approvals based on surrogate marker trials, and 100 of 127 (78.7%) approvals based on single surrogate trials—and examined surrogate markers of efficacy as primary endpoints—51 of 77 (66.2%), 512 of 554 (92.4%), and 110 of 127 (86.6%), respectively. Overall, no postapproval studies were identified for 43 of the 123 (35.0%) approved indications. The median total number of postapproval studies identified was 1 (interquartile range 0-2) for indications approved on the basis of a single pivotal trial, 3 (1-8) for indications approved on the basis of pivotal trials that used surrogate markers of disease as primary endpoints, and 1 (0-2) for single surrogate trial approvals, and the median aggregate number of patients enrolled in postapproval studies was 90 (0-509), 533 (122-3633), and 38 (0-666), respectively. The proportion of approved indications with one or more randomized, controlled, double blind study using a clinical outcome for the primary endpoint that was published after approval and showed superior efficacy was 18.2% (6 of 33), 2.0% (1 of 49), and 4.9% (2 of 41), respectively. Conclusions The quantity and quality of postapproval clinical evidence varied substantially for novel drugs first approved by the FDA on the basis of limited evidence, with few controlled studies published after approval that confirmed efficacy using clinical outcomes for the original FDA approved indication.
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The Priority Medicines (PRIME) scheme was launched by the European Medicines Agency (EMA) in 2016 to expedite the development and approval of promising products targeting conditions with high unmet medical need. Manufacturers of PRIME drugs receive extensive regulatory advice on their trial designs. Until June 2018, EMA granted PRIME status to 39 agents, evaluated in 138 studies (102 initiated before and 36 after PRIME eligibility). A third of studies forming the basis of PRIME designation were RCTs and a quarter were blinded. There was no statistically significant difference between trials initiated before and after PRIME designation in terms of randomised design and use of blinding. However, significantly more efficacy studies included a clinical endpoint after PRIME designation than before, and significantly fewer included surrogate measures alone. There were no statistically significant differences between the trial designs of PRIME and non‐PRIME‐designated products.
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The use of data from the real world to address clinical and policy-relevant questions that cannot be answered using data from clinical trials is garnering increased interest. Indeed, data from cancer registries and linked treatment records can provide unique insights into patients, treatments and outcomes in routine oncology practice. In this Review, we explore the quality of real-world data (RWD), provide a framework for the use of RWD and draw attention to the methodological pitfalls inherent to using RWD in studies of comparative effectiveness. Randomized controlled trials and RWD remain complementary forms of medical evidence; studies using RWD should not be used as substitutes for clinical trials. The comparison of outcomes between nonrandomized groups of patients who have received different treatments in routine practice remains problematic. Accordingly, comparative effectiveness studies need to be designed and interpreted very carefully. With due diligence, RWD can be used to identify and close gaps in health care, offering the potential for short-term improvement in health-care systems by enabling them to achieve the achievable.
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A comparative analysis of assessment procedures for authorization of all European Union (EU) applications for advanced therapy medicinal products (ATMPs) shows that negative opinions were associated with a lack of clinical efficacy and identified severe safety risks. Unmet medical need was often considered in positive opinions and outweighed scientific uncertainties. Numerous quality issues illustrate the difficulties in this domain for ATMP development. Altogether, it suggests that setting appropriate standards for ATMP authorization in Europe, similar to elsewhere, is a learning experience. The experimental characteristics of authorized ATMPs urge regulators, industry, and clinical practice to pay accurate attention to post-marketing risk management to limit patient risk. Methodologies for ATMP development and regulatory evaluations need to be continuously evaluated for the field to flourish.
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Conventional cancer clinical trials can be slow and costly, often produce results with limited external validity, and are difficult for patients to participate in. Recent technological advances and a dynamic policy landscape in the United States have created a fertile ground for the use of real-world data (RWD) to improve current methods of clinical evidence generation. Sources of RWD include electronic health records, insurance claims, patient registries, and digital health solutions outside of conventional clinical trials. A definition focused on the original intent of data collected at the point of care can distinguish RWD from conventional clinical trial data. When the intent of data collection at the point of care is research, RWD can be generated using experimental designs similar to those employed in conventional clinical trials, but with several advantages that include gains in efficient execution of studies with an appropriate balance between internal and external validity. RWD can support active pharmacovigilance, insights into the natural history of disease, and the development of external control arms. Prospective collection of RWD can enable evidence generation based on pragmatic clinical trials (PCTs) that support randomized study designs and expand clinical research to the point of care. PCTs may help address the growing demands for access to experimental therapies while increasing patient participation in cancer clinical trials. Conducting valid real-world studies requires data quality assurance through auditable data abstraction methods and new incentives to drive electronic capture of clinically relevant data at the point of care.
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Importance Drugs treating serious or life-threatening conditions can receive US Food and Drug Administration (FDA) accelerated approval based on showing an effect in surrogate measures that are only reasonably likely to predict clinical benefit. Confirmatory trials are then required to determine whether these effects translate to clinical improvements. Objective To characterize preapproval and confirmatory clinical trials of drugs granted accelerated approval. Design and Setting Publicly available FDA documents were reviewed to identify the preapproval trials leading to accelerated approval between 2009 and 2013. Information on the status and findings of required confirmatory studies was extracted from the FDA’s database of postmarketing requirements and commitments, ClinicalTrials.gov, and matched peer-reviewed publications. Follow-up ended on April 7, 2017. Exposures Granting of accelerated approval. Main Outcomes and Measures Characteristics of preapproval and confirmatory studies were compared in terms of study design features (randomization, blinding, comparator, primary end point). Subsequent regulatory decisions and estimated time between accelerated approval and fulfillment of regulatory requirements were summarized. Results The FDA granted accelerated approval to 22 drugs for 24 indications (19 for indications involving cancer treatment) between 2009 and 2013. A total of 30 preapproval studies supported the 24 indications. The median number of participants enrolled in the preapproval studies was 132 (interquartile range, 89-224). Eight studies (27%) included fewer than 100 participants and 20 (67%) included fewer than 200. At a minimum 3 years of follow-up, 19 of 38 (50%) required confirmatory studies were completed, including 18 published reports. Twenty-five of the 38 (66%) examined clinical efficacy, 7 (18%) evaluated longer follow-up, and 6 (16%) focused on safety The proportion of studies with randomized designs did not differ before and after accelerated approval (12/30 [40%] vs 10/18 [56%]; difference, 16%; 95% CI, −15% to 46%; P = .31). Postapproval requirements were completed and demonstrated efficacy in 10 of 24 indications (42%) on the basis of trials that evaluated surrogate measures. Among the 14 of 24 indications (58%) that had not yet completed all requirements, at least 1 of the confirmatory studies failed to demonstrate clinical benefit in 2 (8%), were terminated in 2 (8%), and were delayed by more than 1 year in 3 (13%). Studies were progressing according to target timelines for the remaining 7 indications (29%). Clinical benefit had not yet been confirmed for 8 indications that had been initially approved 5 or more years prior. Conclusions and Relevance Among 22 drugs with 24 indications granted accelerated approval by the FDA in 2009-2013, efficacy was often confirmed in postapproval trials a minimum of 3 years after approval, although confirmatory trials and preapproval trials had similar design elements, including reliance on surrogate measures as outcomes.