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ICH E17 General Principles for Planning and Design of MRCTs
I chun Lai MD, MS Team Leader/Medical Reviewer Division of New Drugs
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DISCLAIMER This presentation was not officially cleared, and the views offered here do not necessarily represent the official positions at MOHW, including TFDA.
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Outline Background & Current Status Key Considerations Conclusion
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Background & current status
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ICH Organization http://www.ich.org/about/organisation-of-ich.html
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ICH Guideline Process Step 1: Building scientific consensus
EWG Step 1: Building scientific consensus Step 2: SC Agrees on draft text Step 3: Open for public consultation Step 4: Adopting harmonized guidelines Step 5: Implementing guidelines in ICH regions SC: Steering Committee (changed to General Assembly) EWG: expert working group IWG: implementation working group IWG
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ICH E17 Process Topic endorsed by steering committee in June 2014 EWG
Lisbon Portugal, Nov 2014 Fukuoka Japan, June 2015 Jacksonville USA, Dec 2015 E17 Step 2 version, May 2016 Osaka Japan, Nov 2016
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Key considerations
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Table of Contents 1.Introduction Objectives/ Background Scope/ Basic Principles 2.General Recommendations 2.1 Strategy-related Issues to Clinical Trial Design & Protocol- related Issues to 2.2.9
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E17 Objective Increasing the acceptability of MRCTs in global regulatory submissions What is a MRCT? A clinical trial conducted in more than one region under a single protocol
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What is a “Region”? Region Regulatory region
Geographic region, country, or regulatory region Regulatory region A region for which a common set of regulatory requirements applies for drug approval (e.g., European Union, Japan).
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MRCT? A clinical trial conducted in
Northern Taiwan + Southern Taiwan ? Japan + Taiwan + China + Korea ? E17 objective: increasing the acceptability of MRCTs in global regulatory submissions
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Old vs New Drug Development Strategy
Independent strategy ICH E5: bridging approach New: E17 MRCT
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E17跟E5有什麼不同? E5 Ethnic factors E17 MRCT
直接在planning stage就納入所有應考慮的regions 直接進行MRCT 以MRCT的結果進行查驗登記 已經完成的 試驗結果 是否可以外推至 另一個region
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E17 Simultaneous Confirming Parallel
Bridging Sequential E17 Simultaneous Confirming Parallel
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Independent vs Global strategy
歐洲 各自為政 Phase I Phase II Phase III Phase I Phase II Phase III 亞洲 Phase I Phase II Phase III 團結力量大 歐亞美洲
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MRCTs in Overall Development Program
MRCTs can play an important role in drug development programmes beyond their contribution at the confirmatory stage. For example, exploratory MRCTs can gather scientific data regarding the impact of extrinsic and intrinsic factors on (PK/PD) and other drug properties,facilitating the planning of confirmatory MRCTs. MRCTs may also serve as the basis for approval in regions not studied at the confirmatory stage through the extrapolation of study results
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Basic Principles: Promote MRCT
MRCTs are generally the preferred option for investigating a new drug for which regulatory submission is planned in multiple regions The underlying assumption of the conduct of MRCTs is that the treatment effect is clinically meaningful and relevant to all regions being studied while also acknowledging that some regional variation is expected
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Severe disease with better response
因疾病嚴重度不同:Region I的response< Region II Overall treatment effect applies to all regions some regional variation is expected
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Consideration of Ethnic Factors (1)
As in ICH E5, ethnic factors are defined as Intrinsic factors (eg. genetic, physiological) Extrinsic factors (eg. medical practice) Should be identified during the planning stage, information about them should be collected and evaluated when conducting MRCTs MRCTs should be designed to provide information to support an evaluation of whether the overall treatment effect applies to subjects from participating regions
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Consideration of Ethnic Factors (2)
Evaluation of subgroups defined by intrinsic and extrinsic factors Pre-specified in the protocol & SAP Plausibly predictive of differential response to treatment examples of subgroups Disease stage (mild/mod/severe) Race and/or ethnicity (Asian, Black, Caucasians) Genetic factors (polymorphisms of drug metabolizing enzymes)
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New Concept: Pooled Regions
For sample size planning & evaluating consistency across regions 如果有相似的intrinsic/extrinsic factors Some regions may be pooled at the design stage 例如把歐洲視為一個pooled region Or 把台、日、韓、陸視為一個pooled region (East Asia)
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New Concept: Subpopulation
Overall population Overall study population included in MRCT Subpopulation Defined by one or more intrinsic/extrinsic factors May span across multiple regions Pooled subpopulation
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Response可能依ethnicity之不同而有variation
Group B in Region I is a subpopulation Group B in Region II is a subpopulation 把Region I & II的Group B加在一起=pooled subpopulation Ex: Hispanics in North & South America, Caucasians in Europe & North America Group B that can largely be enrolled from Region I could alternatively be enrolled globally (eg. Region II)
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Pooled regions/pooled subpopulations
Belongs to subgroup analysis In order to evaluate treatment effect consistency May provide a basis for regulatory decision making
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Achieve statistical significant results within one or more regions
Evaluate treatment consistency
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Sample size MRCT的sample size取決於test of primary hypothesis
based on combing data from all regions in the trial Sample size allocation to regions or pooled regions should be determined such that clinically meaningful differences in treatment effects among regions can be described without substantially increasing the sample size requirements based on the primary hypothesis
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Allocation to Regions (1)
1st: show similar trends allocate equal number to each region may not be feasible or efficient 2nd: proportion of preservation would be difficult if all regions have this requirement 3rd: proportion to regional size may result in very small sample size within some regions insufficient to support any evaluation of treatment consistency
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Allocation to Regions (2)
4th: achieve stat significance within one or more regions then why conduct MRCT? 5th: fixed min number per region any local safety requirement for min number of subjects is a programme level consideration should not be a key determinant of the regional sample size
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Allocation to Regions (3)
A balanced approach is needed to ensure that the trial is feasible but also provides sufficient information to evaluate the drug in its regional context. Therefore, sample size allocation should take into consideration region size, the commonality of enrolled subjects across regions based on intrinsic and extrinsic factors and patterns of disease prevalence, as well as other logistical considerations to ensure enrolment is able to be completed in a timely fashion
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Basic Requirements Unified hypothesis with common comparators
Clear & specific I/E criteria Primary endpoint should be clinically meaningful in all regions If agreement can’t be reached A single protocol should be developed with endpoint-related sub-sections In this case, since regulatory approvals are based on different primary endpoints by different authorities, no multiplicity adjustment is needed for regulatory decision-making
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Dose Selection (1) In order to select the dose for confirmatory MRCTs,
it is necessary to execute well-planned development programmes during phase I – II that include PK and/or PK/PD studies of applicable parameters, in order to be able to identify important regional differences which may impact dose selection. When applicable, PK investigations should be undertaken in subjects from major subpopulations that are intended to be included in MRCTs (eg, Asian, Black, Caucasians)
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Dose Selection (2) Dose regimens in confirmatory MRCTs should in principle be the same in all participating regions If early trial data show a clearly defined dose/exposure/response relationship that differs for a region, it may be appropriate to use a different dosing regimen in that region, provided that the regimen is expected to produce similar therapeutic effects with an acceptable safety margin
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Consultation with Regulatory Agencies
Encourage discussion with regulatory agencies in the planning stage Understand different regulatory requirements Obtain their agreement with the proposed analysis strategy How the analyses of pooled regions and/or pooled subpopulations may provide a basis for the regulatory decision-making for relevant regulatory authorities
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Ensuring Trial Quality
Ensuring trial quality is of paramount importance Ensure scientific validity of results Follow ICH E6 GCP Centralized & risk-based monitor Build up trial infrastructure & capability Efficient global drug development
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conclusion
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E17: Think Globally Promote MRCTs Harmonized approach
Provide earlier access to new drugs worldwide
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Thank you for your attention
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