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FDA’s Project Optimus: Redefining Oncology Drug Dosage for Better Patient Outcomes

Until the late 1990s, most oncology therapies were non-specific, killing fast-dividing cancer cells, as well as normal fast-dividing cells, such as skin cells, myeloid cells (erythrocytes, neutrophils), and lymphocytes. Due to the non-specific nature of how these early drugs worked, the doses of these agents needed to be as high as the patient could tolerate to maximize their effectiveness. This often resulted in the maximum tolerated dose (MTD) being selected as the clinical dose since the goal of these agents was to kill as many cancer cells as possible. Under this paradigm, it made little sense to study doses lower than the MTD since they would almost certainly be less effective.

Advances in our understanding of the biochemistry of cancer, as well as the complex array of signaling pathways that regulate cell growth, have led to targeted oncology agents, which may block signaling proteins that regulate cell growth, angiogenesis, or apoptosis, as well as therapies that may activate the immune system toward tumor cells.[1] Because these agents are so specific, the difference between an effective dose and a toxic one is often much wider than with non-specific therapies. Choosing the MTD as the clinical dose for targeted therapies will usually result in a dose that is too high, as the MTD will likely be well beyond the plateau for the drug’s beneficial effects. In fact, a number of targeted oncology agents have had their doses lowered post-approval, with significant improvements in their safety profile and with no decrease in efficacy.[2]

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Understanding Master Protocol Designs: Platform and Basket Trials

A clinical trial usually seeks to evaluate the effects of a candidate drug in a carefully pre-specified patient population. Every detail of the trial must be outlined in the Clinical Study Protocol (CSP), including the exact inclusion and exclusion criteria for patients, the exact variables to be measured, and the statistical hypotheses to be tested.

Platform trials and basket trials, however, are innovative study designs that allow researchers to explore multiple treatments or target multiple patient populations simultaneously under a single overarching CSP, called a master protocol. Such approaches are elegant in that sponsors may start a new study arm to investigate an additional indication, dose, or inclusion criterion in parallel with the ongoing clinical trial, without needing to write a new CSP for each new study arm (which would also need to be applied for and approved by authorities). On the other hand, the planning and writing of the CSP for platform and basket trials up front requires a lot more effort than that of a traditional study.

Here, I outline benefits and challenges of these groundbreaking methodologies.

Platform trials make it possible to add study arms

Based on a particular disease, a platform trial investigates different treatments, doses, or subgroups of patients, all in different study arms. In particular, it is possible to add study arms that were not predefined in the study protocol: It is possible to start a trial, keep it running over years, and introduce new potential treatments as they appear and after evaluation of the older treatment arms. Platform trials are adaptive, as new parts of the trial may be chosen based on knowledge gained from previously evaluated parts of the trial. Allocation rates between ongoing treatment arms may also be adapted to optimize patient recruitment.

However, platform trials may come with administrative challenges

Platform trials can be notoriously difficult to administer. The CSP (i.e., the master protocol) needs to consider precise instructions for how future decisions will be made regarding the number of interventions active at the same time, the allocation of new patients between interventions and control groups, the frequency of interim evaluations, and the rules for stopping and starting interventions at interim evaluations.

Yet platform trials are helpful in collaborative projects

Despite the administrative challenges, a platform trial may be very beneficial in, for example, collaborative projects between multiple clinics or academic groups worldwide. Multiple groups of researchers may contribute to the larger project, enabling the comparison of different treatment strategies through the streamlined study arms detailed by the master protocol. Research groups may be able to share control groups and quickly adapt to new or evolving therapeutic landscapes. The STAMPEDE prostate cancer study is an example in which 12,000 patients were enrolled between 2005 and 2023.1 Another example is the I-SPY platform trial, in which 28 active interventions against breast cancer have been tested so far since the start of recruitment in 2010.2

 

Basket trials allow for multiple indications

Unlike platform designs, basket designs do not permit adding new treatments during the trial. Instead, while the trial targets a specific therapy, it allows sponsors to test multiple indications. Think of each basket coming with a new set of patients, with their own inclusion and exclusion criteria, to a trial. Each basket will be randomized to its own study arms (usually active and control treatment arms), but the outcome of the study may be a combination of the results from all the different study arms. This way, a proof of concept may be approached early and jointly between, say, different cancer indications that may be candidates for the same drug. The assessment of each indication may be derived given the results of the other indications, for example, using a Bayesian method.

Common criticism of basket trial designs

Basket designs do get criticized for enabling a positive study outcome even in situations where no indication shows sufficient efficacy on its own. This is a justified comment. As you go into a follow-up study to recruit a larger number of patients with a single indication, your amount of evidence from a positive basket trial may be very light for the specific indication. This means the follow-up study has a larger element of gambling than it would have had were the first efficacy study based on that same single indication. We cannot be sure that there really is a treatment effect in one particular indication.

When are basket designs useful?

For the reason mentioned, a basket design makes the most sense when there is clinical reason that all the indications can be improved by the same molecular drug mechanism. Perhaps because the indications were all caused by the same mechanism. In such cases, coherent results in different patient populations do strengthen each other. The BRAF V600 Vemurafenib is an example basket trial in which patients had the same mutation (BRAF V600) but different diagnoses.3 It included 122 patients from 5 indications (NSCLC, Colorectal, Cholangiocarcinoma, ECD or LCH, and Thyroid) plus one “other” basket.

 

Interested in learning more? Download our complimentary ebook, Adaptive Trial Design, which outlines common adaptive trial designs, benefits of adaptive trials, how to optimize your adaptive trial, and a ten-point framework to determine if your trial should be adaptive.

Behind the Oncology Research: An Interview Between Robert Szulkin and Jana de Boniface

Welcome to our interview with Dr. Jana de Boniface, a renowned surgeon and researcher specializing in breast cancer. In this conversation, we delve into her inspiring journey, groundbreaking research, and collaborative efforts that have led to significant advancements in breast cancer treatment.

 

Robert Szulkin (RS):  Jana, you’ve just published a paper on “Omitting Axillary Dissection in Breast Cancer with Sentinel-Node Metastases” in the New England Journal of Medicine (NEJM) [1]. Congratulations! This project was completed in cooperation with Cytel’s Real-World Evidence team, and we’d love to discuss the process that made this project a reality. But first, a brief introduction. You are a surgeon specializing in oncoplastic breast surgery as well as a Professor in the Department of Medical Epidemiology and Biostatistics at the Karolinska Institute in Sweden. I’d like to ask a bit about your background.
What inspired you to become a scientist and a surgeon?

 

Jana de Boniface (JdB): I began my journey as a scientist during my university years in Berlin, and that was just a completely different topic, it was psycho-oncology. When I moved to Sweden to train as a surgeon, I didn’t have a specific moment of inspiration. However, a fantastic senior colleague, Leif, approached me early in my training and encouraged me to pursue research. He must have seen something in me—perhaps my curiosity and perseverance. Since then, what drives me to continue with research is the patients and seeing them in situations where I cannot say why I am doing what I am doing. I need to have evidence for the treatments I recommend. For instance, if I tell a patient they need a mastectomy or need lymph nodes removed and I know it’s going to hurt the patient in the long term, I want to be certain that these actions are necessary. It’s basically this unhappy feeling in the clinic when I just don’t know if I’m doing the right thing.

About how I became a surgeon, I was going to become a psychosomatic doctor, which is a combination of internal medicine, psychology, and psychotherapy in Berlin. Everything was planned: exams, research, post-doc work. Then, during my final obligatory year as a student, I decided to go to Sweden for my mandatory surgical training, as my best friend Michaela had moved there. During these three or four months at the clinic, I just felt like I was home. The hands-on nature of surgery, the immediate impact of the work, and the ability to cure people felt incredibly appealing. My mother, a psychologist, once told me, ‘ You can’t cure people with a knife’ but I believe you can!

 

RS: That’s interesting. I thought you always wanted to be a surgeon. I’ve seen you perform surgery, and it was incredibly inspiring. What was the first research question you began to investigate in your career, and how has this changed over time?

JdB: My initial research in Berlin was completely different—it was a study on the treatment of hepatitis C. However, I set that aside. My first projects involved sentinel lymph node biopsy in breast cancer, around the early 2000s. At that time, we still performed many axillary clearances, so we started implementing sentinel lymph node biopsies while still performing clearances to ensure the sentinel nodes weren’t giving false-negative results. That’s how I started. We were still discussing the performance and accuracy of sentinel lymph node biopsy in large tumors as a different project. I also delved into tumor immunology, studying the immune response in lymph nodes, which was quite exciting.

 

RS: So, you’ve been doing axillary surgery research for almost 25 years now. That’s quite impressive. I guess you know the subject very well after all this time.

JdB: Yes, I’ve been deeply involved in it for many years.

 

RS: Let’s talk about our recent publication, which is a very hot topic right now. The results have been presented worldwide. The research conducted aims to reduce the burden of surgery in breast cancer patients, such as the invasiveness of surgery and potential complications. And now this research has resulted in the first surgical paper to have been published in NEJM in the last 17 years. The SENOMAC trial started back in 2015; how did you come up with the idea to start this study?

JdB: It was of course not just my idea, but we were a team from the beginning. When we started the study, we thought it would just confirm the results of two previous studies conducted in the US and the Netherlands, which had shown similar outcomes. But, those studies faced a lot of criticism, especially the US one, due to their small sample sizes and lack of statistical power. They weren’t convincing enough. Back then, I argued against continuing axillary dissections but the Swedish National Guidelines committee deemed the data too weak to support stopping them. So, we kept performing axillary dissections, which felt frustrating. We were then a small group of people who decided we’d try to start a trial adding more data to the area and broadening the population characteristics to also embrace new questions. For me, this research was a tool to reduce the number of dissections because if guidelines don’t allow you to do less, you need to research to prove the point, and at the same time, research allows patients to get access to a more modern approach.

Before our study was complete, the Swedish guidelines changed, allowing the omission of axillary dissections for certain patients, and replacing it with radiotherapy. So, I  didn’t expect our study to have such a significant impact. While it doesn’t change the Swedish guidelines, it significantly influenced guidelines in other countries. I’ve received many inquiries about the inclusion criteria, such as whether we included patients with extra-nodal extension and if our findings apply to various patient types. And then I noticed that people have probably not just used these older trial data in their full scale, but they’ve used it for some subgroups. They still hesitate to omit axillary dissection in certain types of patients. And I think our study, because it’s so large and has full statistical power, is the first to provide definitive answers to these questions. That’s fantastic and it’s gratifying to see its impact.

 

RS: Where is this already implemented? What kind of impact will this research have?

JdB: Before the study, I believed that many countries already omitted axillary dissection. The big question was regarding mastectomy patients, those undergoing removal of the entire breast, because we lacked data on that group. The impact of our study is significant here.

Some large countries had already implemented omitting axillary clearance, but they didn’t apply it to patients where metastasis had grown outside the lymph node. After our study, they began to include these patients as well, seeing similar outcomes. Many guidelines adapted these older trials with specific limitations, and I think our study helped to remove those limitations. While I don’t know every single country’s guidelines, I believe many were already moving towards reducing axillary dissection for more subgroups.

In the US, the first trials on omitting axillary clearance in breast-conserving surgery were conducted around 2011-2012. They allowed the omission of axillary clearance in these cases but not in mastectomy patients. It appears their guidelines suggest considering it, but it wasn’t standard practice. Our study is now providing the necessary evidence to support broader implementation, including for mastectomy patients.

 

RS: How would you describe the results of your research to a non-clinician, such as a patient? What kind of impact could this research have on them?

JdB: For a patient, I would explain it like this: Normally, if we don’t see any signs that cancer has spread to the armpit, we remove something called a sentinel lymph node. This is the first lymph node in the armpit which receives lymphatic fluid from the breast, and sometimes, cancer cells if the tumor spreads. We typically remove one, two, or three of these nodes. And then, if we find signs of metastasis in these nodes, previously, we used to perform an additional operation to remove more lymph nodes from the armpit—usually more than 10. This often led to problems with the arm, such as swelling, pain, and restricted movement in the arm, which could last a long time.

Now, our research shows that removing more lymph nodes does not improve survival rates or reduce the risk of cancer recurrence. So, we can safely leave the remaining lymph nodes in place even if the disease may be present in these nodes. This makes a big difference in the patient’s recovery and quality of life.

 

RS: You participate actively in real-world evidence studies, observational studies, and clinical trials. Why do you think that is important? Can they complement each other, and what’s your view on that?

JdB: In my field, many questions will never be addressed in randomized trials. For example, deciding whether to perform a mastectomy or a lumpectomy, or whether or not to have an immediate breast reconstruction, can’t be left to a coin toss today. Patients need to be involved in the decision-making process, weighing the pros and cons to make informed choices.

For issues like breast conservation versus mastectomy, new randomized trials beyond those performed in the 70s and 80s are unlikely. Instead, we rely on high-quality, population-based databases with comprehensive and reliable data. These databases allow us to adjust for all these confounders that we know we have and provide insights that randomized trials cannot. There are many similar questions where patient choice is paramount, such as whether to undergo breast reconstruction.

Prospective cohort studies also play a crucial role. If there’s evidence suggesting a new method might be better, but the existing trials are not conclusive enough, we can implement this method in a prospective cohort study. This allows us to monitor patients closely and ensure they receive modern treatment while still being able to assess the method’s effectiveness. If the method turns out to be suboptimal, we can identify this and adjust accordingly.

 

RS: As I mentioned earlier, this project was completed in cooperation with Cytel’s Real-World Evidence team. Why did you choose to partner with us on this project?

JdB: We specifically chose to work with you because our colleague, Anna Johansson, and I discussed the idea of breast conservation versus mastectomy. When we needed someone for the hands-on statistical analysis, Anna recommended you because of the previous positive experience and partnership we have had.

Before we started our collaboration, I mostly did statistics myself. However, with increasing study sizes and the need for randomized trials, I felt the quality had to be completely watertight, and you provided that. I also quite like our collaborative discussions and your proactive ideas. You’re not just executing tasks; we have a dialogue and we brainstorm our options and come up with solutions to the problems that arise throughout the process. Our team, including Anna, shares a commitment to timelines and schedules, making us very effective. When we wrote the articles, we successfully streamlined the process and ensured everyone contributed and helped.

 

RB: I agree. Our close collaboration and communication work very well. You explain the clinical aspects clearly, and I can, most of the time, explain the statistical context of everything. Even tasks like data cleaning and checks, which could be tedious, were smooth due to our excellent communication. It’s wonderful to have a good working relationship with sponsors, and it’s been a great experience working with you and Anna.

 

Interested in learning more about Cytel’s Real-World Evidence solutions? Read more.

 

Note:

[1] Omitting Axillary Dissection in Breast Cancer with Sentinel-Node Metastases | New England Journal of Medicine (nejm.org)

 

Pediatric Development Plans: Key Considerations

Historically, many drugs have been prescribed to children even though this patient population have largely been excluded from clinical trials. Authorities worldwide have, therefore, implemented regulations to address the gap in drug research involving children and to promote efforts that can lead to increased knowledge of pediatric pharmaceutical use.

There is an obvious logic. If medicines are to be used in children, they need to be studied in pediatric populations to ensure they are safe and effective. Here, we share important considerations for your pediatric development plan, including the US pediatric study plan (PSP) and the EU pediatric investigation plan (PIP).

 

When do sponsors need to conduct pediatric studies and when are they exempt?

Whether you need to include children in your clinical studies will partly depend on which disease you are targeting and what type of medicine you are studying. If you have a drug that targets a condition that does not affect children, such as Alzheimer’s disease, you will be granted a waiver. A waiver may also be given for specific age groups based on safety or lack of efficacy, the condition not occurring in the specific age group or other specific age-related reasons. Sometimes, a deferral from the requirement to study the drug in the pediatric population may be granted which means that the studies can be postponed until after you have shown that the drug is safe and effective in adults. However, outlining a PIP/PSP for your drug is mandatory, regardless of whether you expect to receive a waiver or deferral for the pediatric studies.

 

The challenge of harmonizing across national borders

Harmonizing pediatric study plans for different parts of the world is a complex task due to authorities in different regions having varying recommendations about when to initiate the development of pediatric study plans and what they should include. For example, in the EU, it’s preferred to submit a PIP early in the development process, when pharmacokinetic data are available, whereas in the US, the FDA requests a PSP after the completion of Phase II trials. These differences in timing make it challenging to coordinate pediatric studies globally.  To manage this effectively, the best practice is to set a strategy for the global pediatric plan early in the development process. Without this proactive approach, the pediatric plans could delay the entire development project.

 

The contents of a PSP or PIP

The purpose of a PIP/PSP is to gather comprehensive information about the use of a drug in pediatric populations. Below are examples of what it should contain:

  • An overview of the disease, diagnosis, and treatment, highlighting differences between children and adults.
  • An assessment of the need for the drug in children across all age groups from birth to adolescence.
  • A summary of available chemical, preclinical, and clinical data on the drug.
  • A proposed strategy for any required preclinical studies and measures to adapt the drug’s formulation for use in children.
  • A proposed plan for potential clinical studies in children, including the timing of these studies in relation to those conducted in adults.

 

Financial benefits of conducting pediatric studies

Conducting pediatric studies not only ensures the safety and efficacy of a medicine in children but may also introduce new market opportunities in the pediatric population. In addition, following your pediatric plan can yield significant financial benefits in the form of a six-month patent extension (additional protection). It may seem short, but a six-month extension provides valuable exclusivity on the market and helps developers maximize the commercial lifespan of their product.

Regulatory incentives for pediatric oncology drugs: The RACE for Children Act

The Research to Accelerate Cures and Equity (RACE) for Children Act, passed by the U.S. Congress in 2017 and implemented in August 2020, significantly reformed the landscape of pediatric oncology drug development. The Act mandates that new cancer drugs developed for adults must also be evaluated for pediatric use if the molecular target of the drug is relevant to pediatric cancers. This requirement includes drugs with orphan drug designation, previously exempt from such studies. Prior to the RACE Act, pharmaceutical companies were not obligated to conduct pediatric studies for oncology drugs developed for adult cancers, leading to a significant gap in treatment options for children.

Early findings are promising, showing a clear rise in the number of oncology drugs being studied for pediatric use. Between August 2020 and August 2022, 32 initial pediatric study plans were submitted to the FDA due to the RACE Act, indicating a promising shift towards more inclusive drug development practices. [1]

 

Key Takeaways

Integrating pediatric patients into clinical trials can help ensure the safe and effective use of medicines for children. This is emphasized by global regulatory requirements and incentivized initiatives. However, navigating diverse sets of regulatory guidelines across countries and regions presents challenges in harmonizing and coordinating pediatric development plans on a global scale. With careful planning and considerations of the key factors outlined here, sponsors can minimize delays and expedite the approval process, ensuring timely access to safe and effective drugs for both adults and children.

 

Have questions? Get in touch with our experts: Erika Spens, Director Regulatory, Affairs; Sofie Broberg, Senior Consultant, Regulatory Affairs; Anna Törner, VP, Strategic Regulatory Affairs; and Linda Nord, Senior Consultant Regulatory Affairs: Contact Our Strategic Consulting Team

Notes

[1] Children’s Cancer Cause. (2023, February 8). First Two Years of the RACE Act Evaluated in New GAO Report. https://www.childrenscancercause.org/blog/race-act-gao-report

Optimizing Early Clinical Development Strategy

A clinical development strategy is a comprehensive plan designed to establish the safety and efficacy of new therapeutics. Developing an effective plan requires multidisciplinary expertise and adapting to accumulating learning and changes in clinical practice and the market environment.

Effective clinical development strategy is adaptive by nature. Though it mainly focuses on achieving regulatory approval, it also needs to pave the way to reimbursement and integration of new therapeutics into clinical practice. Clinical development strategy is designed to meet the goals outlined by the TPP (Targeted Product Profile). TPP and clinical development strategy are interdependent: accumulating clinical data may lead to modifications of the TPP, and clinical development strategy needs to be adapted if the TPP evolves due to changes in the regulatory, financial, and competitive landscape.

Ideally, clinical development strategy is based on scientific, clinical, and regulatory considerations. However, clinical developers need to consider business and financial aspects, such as risks, runways, costs, and time. The trade-offs and their impact differ in early development and confirmatory settings.

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On Kappler’s ‘Graphical Comparison of Simon two-stage designs’

Clinical researchers, seeking to understand the statistical benefits of a common Phase 2 oncology design, now have a new visual aid thanks to Cytel’s Martin Kappler. Phase 2 trials in oncology often rely on single-arm designs for a variety of clinical and ethical reasons. One of the most commonly used single-arm designs is Simon two-stage, which require sponsors to specify the maximum sample size. The variety of options available to sponsors, result in different operating characteristics such as average sample size, and the probability of stopping for futility after stage 1. These design characteristics are now easier for sponsors to assess and to compare.

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Late-Stage Clinical Development Strategy: Trade-Offs and Decision-Making in the Confirmatory Setting

Despite accumulating learnings from early phases, several uncertainties remain to be addressed when designing pivotal trials. Adaptive trials can help mitigate uncertainties; however, the trade-offs and their impact differ in the confirmatory setting. Quantifying uncertainties and risks and planning for mitigating adaptations are necessary to maximize the chances of success while maintaining the required scientific rigor of pivotal trials. Quantitative strategies can help inform decisions and optimize choices. Read more »

How to conduct better time-to-event analysis with delayed treatment effects

The issue of delayed treatment effects in immuno-oncology was demonstrated during a FDA-Industry sponsored workshop over two years ago. This demonstration made it clear that traditional log-rank tests, often used for analyses of progression free survival and overall survival, would need to be replaced as essential assumptions of the test no longer held.

Cytel scientists along with colleagues at Pfizer, Merck, the Medical University of Vienna, Bath University and Harvard University, have recently proposed a new test in a study published in Biometrical Journal. The max-combo test enables analysis of PFS and OS when handling delayed treatment effects, while also adding the option for early stopping.

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Design Considerations for Early Phase Trials of Immuno-oncology Drugs

Ever since the first immune checkpoint inhibitor was approved for market nearly twelve years ago, the industry has witnessed a steady rise in the search for new immunotherapies. This has aligned with the broader curation of a number of new dose-escalation and efficacy designs for clinical development in oncology.

Hastening the search for novel treatment options therefore benefits from exploration of how these complex early and late-phase designs interact with each other, and what special design considerations can be implemented in early phases of clinical research for strategic late-phase clinical development. A nuanced understanding of these considerations enables sponsors to ask more complex questions like: Read more »

Bayesian Approach in Oncology Trials

People think in Bayesian terms all the time: we use prior information and the evidence at hand to make decisions in our day-to-day lives. And it is this adaptive thinking that can be so useful in clinical trials, for example, in oncology trials where the standard of care might evolve during the course of the trial. In his recent webinar, “Novel Methods of Trial Design” Prof. Yuan Ji, serving as Cytel’s executive advisor, discusses Bayesian methods in early-phase oncology trials. Let’s take a closer look. Read more »