, Dilip R. Karnad2 and Snehal Kothari3
(1)
Cardiac Safety Services Quintiles, Durham, North Carolina, USA
(2)
Research Team, Cardiac Safety Services Quintiles, Mumbai, India
(3)
Cardiac Safety Services Global Head, Cardiac Safety Center of Excellence Quintiles, Mumbai, India
The approval decision does not represent a singular moment of clarity about the risks and benefits associated with a drug – preapproval clinical trials do not obviate continuing formal evaluations after approval (Institute of Medicine of the National Academies 2007).
14.1 Introduction
The fundamental importance of safety assessments has been emphasized many times in previous chapters. We have discussed “engineering safety” into new molecular entities, safety evaluations in nonclinical studies, and safety evaluations in preapproval clinical trials. While data collected in preapproval investigations and clinical trials are clearly very important, it is appropriate here to acknowledge that they have limitations. With regard to preapproval clinical research, Olsson and Meyboom (2006, p. 229) commented as follows:
Given our focus on preapproval randomized clinical trials to date, these statements may initially sound somewhat surprising. However, they are true. The strength of preapproval randomized clinical trials is that they are comparative, not necessarily representative (see Senn, 2007): they are essential to the process of new drug development, but evaluation of a drug must not stop once marketing approval has been granted. As the Institute of Medicine of the National Academies (2007) observed, “The approval decision does not represent a singular moment of clarity about the risks and benefits associated with a drug – preapproval clinical trials do not obviate continuing formal evaluations after approval.” The necessity for both pre- and post-approval clinical investigations is captured in the term lifecycle clinical development.
The randomized controlled clinical trial is the method of choice for the objective and quantitative demonstration of the efficacy and tolerability of a new medicine. Nonetheless, such studies have limitations in discovering possible adverse events that may occur, in particular those that are rare or develop after prolonged use, in combination with other drugs, or perhaps due to unidentified risk factors. Clinical trials are inherently limited in duration and number of patients, and, significantly, patients are selected prior to inclusion. In other words, the conditions of a trial are artificial compared with the real-life use after the introduction of a medicine.
Useful information in the postmarketing realm can be gathered in various ways. One way is via therapeutic use (Phase IV) clinical trials. Other avenues come from the realm of clinical practice. In clinical practice, individuals are not participants in a clinical trial who have been randomized to one of the trial’s treatment arms: prescribing physicians make treatment decisions with each of their patients on a case-by-case basis such that each individual receives an active treatment (an approved pharmaceutical agent) that, to the best of physician’s knowledge, has a favorable benefit–risk balance for that individual. Important information about a drug’s safety and efficacy (now termed effectiveness) can be gathered in a non-randomized manner by collecting data in various ways discussed in this chapter.
Another topic addressed in this chapter concerns the extent to which a drug’s labeling, initially predicated on preapproval data but certainly modifiable in due course based on the collection of compelling postmarketing data, is heeded by prescribing physicians. Clinical pharmacists who are part of a clinical team working in an inpatient setting are well placed to look for physicians’ prescribing decisions that may not be in accordance with information in a drug’s label and therefore carry a degree of unwanted proarrhythmic risk.
At the end of the chapter, we consider the pharmacologic treatment of drug-induced QT prolongation and torsades. While we hope that these drug-induced outcomes occur as infrequently as possible, it is appropriate to consider the actions that should be taken when they do occur.
14.2 Limitations of Preapproval Clinical Trials
From a drug safety perspective, one key issue in drug development is the (very) low probability of observing (very) rare adverse events in preapproval clinical trials, even in large therapeutic confirmatory trials. Such side effects are probabilistically much more likely to surface once the drug is widely used, and unfortunately some of these side effects may be extremely serious. The “rule of threes” is instructive here (Strom 2005). The number of individuals participating in a clinical trial that would be needed to be 95 % confident that a single case of an identified adverse event of interest would be seen is approximately three times the reciprocal of the frequency of the event in the general population. That is, for an event that occurs in 1/1,000 individuals, a sample size of 3,000 subjects would provide 95 % confidence of observing at least one event. For adverse events that are considerably more rare (e.g., rhabdomyolysis, torsades), much larger sample sizes would be needed (e.g., 30,000 and 300,000 for events with frequencies of 1/10,000 and 1/100,000, respectively). Trials of this magnitude are infeasible from both cost and time perspectives. Cobert (2007, p. 11–12) commented on this phenomenon as follows:
Therapeutic use clinical trials and postmarketing surveillance therefore play critical roles in cardiovascular drug safety and indeed in many other domains of drug safety.
Should the [adverse drug reaction] be dramatic and rapidly discovered, such as torsades de pointes, aplastic anemia, or rhabdomyolysis, there will be a torrent of recriminations about why this was not discovered earlier during the [preapproval] clinical testing. The correct response is that the testing of only 5,000 to 10,000 patients could not pick up such a rare event. This response is usually lost in the clamor.
A second issue concerns the fact that preapproval clinical trials typically employ relatively homogeneous participant samples. For example, potential participants who have other illnesses or medical conditions, including renal and hepatic impairment, are typically excluded, as are those taking (at least certain) concomitant medications. Additionally, the age range of participants can be fairly limited. A third issue concerns the length of time that a patient may take the new drug: for chronic diseases this is likely to be (very) much longer than the treatment period in preapproval clinical trials. The long-term safety of a drug that is suitable for chronic administration is therefore not fully known at the time that the drug is approved. Fourthly, and of particular salience for certain drug classes, its propensity for abuse is not known, nor is the likelihood that patients will develop a dependency on the drug (some of the discussions in the following chapter touch upon this issue).
Another important point concerns how drugs are actually taken by patients. Howren (2013) observed as follows:
While the negative effects of patient nonadherence have been known for decades (Howran 2013) and authoritative sources such as the World Health Organization and the American Heart Association put average nonadherence among those with chronic diseases around 50–75 %, the literature still reveals a predominance of discussions of, and further research into, the problem rather than offering immediate action plans (Turner 2013). This topic is addressed in the following chapter in Sect. 15.6.
Adherence is a term used to describe the extent to which an individual’s behavior coincides with health-related instructions or recommendations given by a health care provider in the context of a specific disease or disorder. The term has been used extensively in psychology and medicine in reference to acute, chronic, and preventive treatment regimens (e.g., a course of prescribed medication, wound self-care), preventive health screenings, dietary restrictions, exercise recommendations, and other health behaviors.
14.3 Therapeutic Use Trials
Therapeutic use trials are conducted once a drug is on the market. They may be optional studies or studies required by a regulatory agency as a condition of approving the drug for marketing. In the former case, the biopharmaceutical company sponsoring a trial may wish to know more about the drug’s performance in individuals who were not well represented in preapproval trials, e.g., those with compromised liver function and/or taking several concomitant medications. Other sponsors, such as an institute within the National Institutes of Health, may wish to explore a drug’s place in future treatment guidelines, and hence conduct trials comparing its safety and/or effectiveness with other treatment options. Therapeutic use trials can be experimental or nonexperimental, nomenclature that is explained in the respective following sections.
14.3.1 Experimental Therapeutic Use Trials
The term experimental means that researchers are systematically facilitating the administration of the drug of interest to some individuals and a control drug to others: the preapproval therapeutic exploratory and therapeutic confirmatory trials discussed in previous chapters were experimental in nature.
Consider here three examples of therapeutic trials from the domain of antihypertensive medications: the Systolic Hypertension in the Elderly Program (SHEP) trial (The Systolic Hypertension in the Elderly Program (SHEP) Cooperative Research Group 1988; SHEP Cooperative Research Group 1991), the Antihypertensive and Lipid-Lowering Treatment to Prevent Heart Attack Trial (ALLHAT) (ALLHAT Collaborative Research Group 2000), and the Avoiding Cardiovascular Events through Combination Therapy in Patients Living with Systolic Hypertension (ACCOMPLISH) trial (Jamerson et al. 2008).
While each of these was a therapeutic use randomized clinical trial, the designs of the trials differed such that the most appropriate control treatment was employed in each case to best answer the research question of interest (Turner and Hoofwijk 2013). SHEP was a multicenter, randomized, double-blind, placebo-controlled trial of chlorthalidone for isolated systolic hypertension. ALLHAT employed a multicenter, randomized, double-blind, active-controlled design to compare chlorthalidone with each of three alternative antihypertensive treatments with regard to the incidence of nonfatal myocardial infarction and fatal coronary heart disease in hypertensive patients with at least one other risk factor for coronary heart disease. ACCOMPLISH was also a multicenter, randomized, double-blind, active-controlled clinical trial, but one that differed from ALLHAT in that a combination therapy comprising benazepril plus amlodipine was compared with benazepril plus hydrochlorothiazide with regard to reduction of cardiovascular events in high-risk hypertensive patients (Turner and Hoofwijk 2013).
14.3.2 Nonexperimental Therapeutic Use Trials
The term nonexperimental simply means that researchers are not systematically facilitating the administration of the drug of interest to some individuals and a control drug to others. The inclusion of “non” in the term nonexperimental is not pejorative (Turner 2010): it simply means that, in contrast to a randomized clinical trial, the study design is not an experimental one. These studies are often called observational studies. However, that terminology is not the most descriptive or distinguishing, since observations are also made during randomized clinical trials. The term nonexperimental is arguably preferable since it simply reflects that a controlled intervention is not made by the researchers.
One example of a nonexperimental study is the cohort study. A cohort study is a nonexperimental study that collects information from an identified group of individuals in an overall population, such as those receiving the marketed drug of interest (see Gamble 2014). Other study designs include case-control studies, cross-sectional studies, and ecological studies. Case reports and case series can also be informative.
14.4 Pharmacovigilance
While various definitions can be found in the literature, Man and Andrews (2002, p. xvii) regarded pharmacovigilance to be “the study of the safety of marketed drugs under the practical conditions of clinical usage in large populations.” Shakir and Layton (2002) provided a more encompassing definition that also included preapproval monitoring, detection, and evaluation of drug safety hazards. Stephens (2004, p. 2) provided a comprehensive list of the aims of pharmacovigilance:
Identification and quantification of previously unrecognized adverse drug reactions
Identification of patient subgroups at particular risk of adverse drug reactions (e.g., the risk being related to dose, age, sex, and underlying disease)
Continued monitoring of a drug’s safety throughout the duration of its use to ensure that its risks remain acceptable when considered in conjunction with its benefits
Comparison with the adverse drug reaction profiles of drugs within the same therapeutic class
Further elucidation of a drug’s pharmacological/toxicological properties and the mechanisms of action that lead to adverse drug reactions
Detection of significant drug–drug interactions between new drugs and co-therapy with agents already on the market
Communication of appropriate information to health professionals
14.5 Pharmacoepidemiology
Strom (2005, p. 3) defined pharmacoepidemiology as “the study of the use of and the effects of drugs in large numbers of people.” Dimensions of interest include safety, effectiveness, utilization, and cost. Going back to randomized clinical trials for a moment to allow a subsequent comment to be put into context, Matthews (1999, p. i) made the following comment at the turn of the millennium:
At the time that quote was published, it is likely fair to say that the statistical methodologies available to the discipline of pharmacoepidemiology were less well developed than for randomized clinical trials. In a paper published 8 years later entitled “In defense of pharmacoepidemiology–embracing the yin and yang of drug research,” Avorn (2007) commented as follows:
Over the last two to three decades, randomised concurrently controlled clinical trials have become established as the method which investigators must use to asses new treatments if their claims are to find widespread acceptance. The methodology underpinning these trials is firmly based in statistical theory, and the success of randomised clinical trials perhaps constitutes the greatest achievement of statistics in the second half of the twentieth century.
In the last decade, tremendous advances have been made: see Consiglio et al. (2013), Hennessy and Strom (2015), and Hennessy et al. (2016).
We forget how difficult it was to establish the rules of the road for conducting randomized trials. In terms of design theory and public policy, drug-epidemiology is now where randomized trials were in the 1950s. We have much to learn about methods, transparency, and protecting the public’s interest. But that work can be done, and we often have no other way of gathering vital information.
14.6 Postmarketing Surveillance
The terms used in the previous two sections, pharmacovigilance and pharmacoepidemiology, would probably both be suitable to reflect the discussions in this section. The term postmarketing surveillance has been chosen since it makes clear that our focus here is squarely in the post-approval domain.
Postmarketing surveillance involves surveillance for occurrences that have been identified in advance as potential safety concerns and also for unanticipated events. Regulatory agencies may approve a drug based on their belief at the time of approval that the benefit–risk balance is favorable, but also make it clear to the drug’s sponsor that their assessment of the benefit–risk balance’s favorability could change if certain adverse events suggested in preapproval trials materialize to a concerning degree during postmarketing surveillance.
14.6.1 Spontaneous Reporting
In multiple countries, health-care professionals are encouraged to report adverse drug reactions spontaneously to the drug’s sponsor, the appropriate governmental health agency, or a third party. In some countries, including the USA, Canada, and the UK, patients are similarly encouraged to do so. Cobert (2007, p. 12) commented that this practice “depends on the good will and energy of nurses, pharmacists, physicians, and consumers” to report adverse drug reactions. Given that health-care professionals and patients lead busy lives, the simple reality is that other systems of information collection are also of great importance.
14.6.2 Active Postmarketing Surveillance
It has become clear that active postmarketing surveillance can provide critical drug safety information. This is “an idea whose time has come,” but it is actually over four decades since the forerunner of modern approaches was utilized. Pioneering work was done at the University of Southampton, United Kingdom. Inman (1981a, b) and Inman et al. (1986) was instrumental in founding prescription-event monitoring (PEM). PEM studies are prospective cohort studies. Inman’s goal was to recruit the first 10,000 patients who received a new drug with the goal of identifying any adverse drug reaction occurring in more than 1 in 1,000 patients.
14.7 Registries
In the previous chapter, we discussed the large cardiovascular safety outcome trials that are currently required for the prospective exclusion of unacceptable cardiovascular risk associated with new antidiabetic drugs for type 2 diabetes. There is currently considerable interest in alternative ways of exonerating a drug (see Sager et al. 2015): however, these methodologies can also be applicable in other therapeutic categories.
14.7.1 A De Novo Prospective Registry/Observational Study
This method of evaluation is one in which all patients who are prescribed the drug of interest once it has received marketing approval are enrolled in a prospective, unblinded, non-randomized, observational study. Because limited data collection is involved and data are collected via minimal patient contact, this approach provides a cost-effective mechanism to gather information on the endpoint of interest.
Major limitations of this type of study are the lack of a control group to estimate background cardiovascular risk and potential selection bias as it relates to which patients are prescribed the drug. The study design can therefore be greatly strengthened by incorporating a comparator group.
14.7.2 A Prospective Registry/Observational Study Built on an Existing Registry Platform
A prospective registry study adds additional but somewhat limited data collection requirements to an existing registry. For example, it might be of interest to make a request for a new data field for patient exposure to a drug of interest to the National Cardiovascular Data Registry (NCDR), a registry active among over 2,000 cardiologists and more than 2,200 hospitals and 700 practices (NCDR 2016). This database is already in use by regulators for postmarketing assessment and, at times, it is also used as a platform for clinical trials.
The addition of supplementary data collection activities is a highly cost-efficient strategy compared with conducting a cardiovascular safety outcome study. However, like all registries, the utility of this strategy is constrained by methodological concerns. Continuing with the example of the NCDR, since this registry is deployed only to cardiologists, any cardiovascular safety signals would be gathered only for those patients who are referred for cardiovascular care. Therefore, it would not provide adequate information if the registry were intended to capture the incidence of cardiovascular events for a widely prescribed noncardiovascular drug. Additionally, there may be practical constraints, including institutional review board concerns and technical aspects surrounding data access and integration.
14.7.3 A Prospective Registry/Observational Study Built on an Electronic Health Record Platform
The emergence of electronic health record (EHR) technologies, also referred to as electronic medical records, may facilitate the development of cost-effective strategies to evaluate drug safety following marketing approval. EHR platforms potentially offer the advantage of standardized, ongoing, consecutive data capture that involves clinical practice settings, more representative patient populations than those participating in preapproval trials, much greater sample sizes, and a reduced data entry burden. Additional benefits include that patients can potentially be matched with control patients using different clinical factors such as comorbidities, concurrent medications, and demographics. However, while this technology is rapidly evolving, current challenges include the lack of acceptable EHR study methodologies for cardiovascular safety assessments and practical and technical issues such as intra-operability and research process models.
14.7.4 A Retrospective Analysis Built from Data Warehouses
The emergence of “Big Data” from accountable care organizations and large-scale medical centers offers the promise of ascertainment of true incident rates predicated on the power of statistical modeling from extremely large databases. One of the best examples of this structure is the Mini-Sentinel Initiative (discussed in further detail in Sect. 14.7.6), a distributed database model that currently includes health information on approximately 125 million persons (FDA 2016a).
Data come from insurance claims and administrative databases, including outpatient dispensing codes, inpatient and outpatient diagnoses, and procedural codes. Theoretically, therefore, Mini-Sentinel should be able to provide the number of exposed lives as well as outcome information that will permit assessment of cardiovascular event incidence with high statistical fidelity in a cost-effective manner. Mini-Sentinel has active project teams for statistical method development, identification of health outcomes, and validation of health outcomes. While the distributed nature of the approach currently limits the number of searches and the ability to assess potential safety issues in a more real-time manner, the EHR approach may be able to provide similar capabilities in a non-distributed manner in the future (Sager et al. 2015).
14.7.5 Relative Strengths and Weaknesses of These Methodologies Compared with a Prospective Randomized Cardiovascular Outcome Study
As in many areas of drug development and therapeutic use, different methodologies to collect information have relative strengths and weaknesses, and when two or more are candidates for use in a certain circumstance, these characteristics must be evaluated and the better option chosen. Consider first their weaknesses. Compared with prospective, randomized cardiovascular safety outcome studies, they are less rigorously performed as they are nearly always non-blinded and non-randomized. Therefore, there can be considerable heterogeneity among different observational databases.
The strengths of these potential alternate approaches include that they may be able to provide information that likely cannot be obtained from a cardiovascular safety outcome study in certain cases, e.g., when event rates are so low that there are serious practical concerns surrounding the feasibility and/or completion of the study. These approaches are less resource intensive than cardiovascular safety outcome studies, and, therefore, they have the potential to provide both regulators and the public with information about cardiovascular safety in a rapid manner without placing an undue burden on the sponsors developing the drugs of interest (Sager et al. 2015).
14.7.6 The Sentinel Initiative, the Science of Safety, and Mini-Sentinel
In May 2008 the FDA released a report entitled “The Sentinel Initiative: National Strategy for Medical Product Safety” (FDA 2016b). The report started with a message from then Commissioner Dr. Andrew von Eschenbach, the first part of which read as follows:
Imagine a national electronic safety system capable of tracking the performance of a drug or medical product, beginning with the earliest stages of clinical research through its effects on millions of Americans who use it to treat or to recover from an illness or condition.
The US Food and Drug Administration of the twenty-first century needs such an electronic system to serve as sentinel over the safety of medical products and help FDA fulfill its responsibility to protect the health and well-being of the American people. Accurate and reliable information must be obtained before products are approved and afterwards when they are being used by large and diverse populations.
The goal of the Sentinel Initiative was described as being to create a national, integrated, electronic system for monitoring medical product safety. The report also introduced the emerging science of safety, a science that combines “a growing understanding of disease and its origins with new methods of safety and signal detection” (FDA 2016b). Updates have been provided by various authors, including the following: Platt et al. (2012), Robb et al. (2012), Ball et al. (2016), and Chakravarty et al. (2016).
14.8 Evidence-Based Medicine
Evidence-based medicine was defined by Sackett and colleagues (1996) as follows:
There are two components to evidence-based medicine and two related sets of responsibilities. The first component is clinical research. Clinical research is a scientific endeavor that provides evidence concerning potential therapeutic interventions. Once clinical trials have been conducted, results are published in appropriate peer-reviewed journals. Everyone involved in clinical research has the responsibility to provide the best possible evidence in this manner (a topic discussed in the following chapter with particular attention to safety results).
Evidence-based medicine is the conscientious, explicit, and judicious use of current best evidence in making decisions about the care of individual patients. The practice of evidence based medicine means integrating individual clinical expertise with the best available external clinical evidence from systematic research. By individual clinical expertise we mean the proficiency and judgment that individual clinicians acquire through clinical experience and clinical practice. Increased expertise is reflected in many ways, but especially in more effective and efficient diagnosis and in the more thoughtful identification and compassionate use of individual patients’ predicaments, rights, and preferences in making clinical decisions about their care.
The second component of evidence-based medicine is clinical practice. Clinicians have the responsibility of providing the best possible care to each of their individual patients. One part of being able to provide this optimum care is remaining aware of pertinent evidence that is published in clinical communications (no small task given the enormous amount of publications per year). It is also incumbent on clinicians to be able to decide for themselves if the evidence presented in a clinical communication is solid evidence and if the conclusion conveyed by the publication is justified based on the results presented. As Katz (2001, p. xvi) commented:
Therefore, an appreciation of study design, experimental methodology, statistical analysis, and clinical interpretation is vital for clinicians who must decide whether the evidence presented in journal publications is adequate and reliable and therefore constitutes an appropriate basis for clinical care.
Part of the burden for the responsible cultivation of higher standards and better outcomes in medicine falls, naturally, to researchers and those who screen and publish their findings. But application is ultimately the responsibility of the clinician, who is obligated to consider not only the pertinence of particular evidence to his or her practice, but also the adequacy and reliability of the evidence itself.
14.8.1 Scientific Evidence and Clinical Judgment
In addition to remaining abreast of journal publications and evaluating the scientific validity of their results and interpretations, a clinician also has to use clinical judgment in providing clinical care. As we have noted, the evidence from a clinical trial is not perfectly generalizable to the target population with the disease or condition of interest. Therefore, a clinician is constantly faced with the task of deciding to what extent the information from a given clinical trial applies to a particular patient. As Katz (2001, pp. xi, xvii) observed:
If our patient is older than, younger than, sicker than, healthier than, ethnically different from, taller, shorter, simply different from the subjects of a study, do the results pertain? … No degree of evidence will fully chart the expanse of idiosyncrasy in human health and disease. Thus, to work skillfully with evidence is to acknowledge its limits. All of the art and all of the science of medicine depends on how artfully and scientifically we as practitioners reach our decisions. The art of clinical decision making is judgment, an even more difficult concept to grapple with than evidence.Stay updated, free articles. Join our Telegram channel
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