ePRO Evolution and Emerging Best Practice Adam Wood PDSM PRO Workshop 2010 Content • • • • Defining PROs Where are we now? Why ePRO? Obstacles – Emerging Best Practice • What about….? • For reference 13 April 2015 confidential Page 2 Defining PROs Defining PROs • “A PRO is a measurement of any aspect of a patient’s health status that comes directly from the patient” - FDA – Patient diaries – Questionnaires – Disease specific measures • ePRO is any electronic implementation – IVRS – Hardware device (e.g. PDA, tablet) – Digital pen 13 April 2015 confidential Page 4 Where Are We Now? PROs are all round us • CenterWatch estimate they are used in 75% of trials – Visit based measures more common that remote reported diaries • Some PROs are more important than others • Growing need for Health Economic data – Proving efficacy is one thing, persuading payers to fund your treatment can be quite another – Increasing trend to integrate Health Economics data alongside efficacy data in Ph II/III 13 April 2015 confidential Page 6 ePRO is Mainstream • A number of proven vendors with strong track records • Best practice is well established – Success is vastly more likely than failure • Regulators are positive about PROs – “Some treatment effects are known only to the patient”* • ePRO is an integral part of PROs – Not a separate, special case – And it’s not EDC * FDA PRO Guidance. 13 April 2015 confidential Page 7 ePRO and Regulators • Regulators in Europe and the US are keenly supportive of electronic PROs – invivodata regularly interacts with EMA and FDA • Drugs approved based on ePRO data worldwide – Japan (at least one) – Europe (multiple) – US (multiple) • invivodata inspected by regulators in all 3 13 April 2015 confidential Page 8 FDA PRO Guidance • Finalised in 2009; drafted in 2006 – Defines new “rules of engagement” for use of PROs • Questions it triggers – – – – – Conceptual framework Application of scale to patient population Patient input into PRO design Reliability, validity, ability to detect change Translations – And, oh yes….mode of administration (p or e) 13 April 2015 confidential Page 9 FDA “Spoke and Wheel”* i. Hypothesize Conceptual Framework • • • Outline hypothesized concepts & potential claims Determine intended population Determine intended application\characteristics (types of scores, mode and frequency of administration) Perform literature/expert review Develop hypothesized conceptual framework Place PROs within preliminary endpoint model Document preliminary instrument development • • • • v. Modify Instrument • • • • ii. Adjust Conceptual Framework & Draft Instrument Change wording of items, populations, response options, recall period, or mode of administration/ data collection Translate & culturally adapt to other languages Evaluate as appropriate Document all changes PRO ↕ Claim • • • Prepare protocol & statistical analysis plan (final endpoint & responder definition) Collect & analyze data Evaluate treatment response using cumulative distribution of response & responder definition Document interpretation of treatment benefit in relation to claim • • • • iv. Collect, Analyze, & Interpret Data • • • • Generate new items Create instrument Select recall period, response options, & format Select mode of administration / data collection Conduct cognitive debriefing Pilot test draft instrument Document content validity iii. Confirm Conceptual Framework & Assess Other Measurement Properties • • • • Confirm conceptual framework with scoring rule Assess score reliability, construct validity, & ability to detect change Finalize instrument content, format, scoring, procedures & training materials Document measurement development * Figure from: Patrick DL, Burke LB, Powers JH, Scott JA, Rock EP, Dawisha S, et al. FDA Paper Draft: Patient-Reported Outcomes to Support Medical Product Labeling Claims. Value in Health 2007 13 April 2015 confidential Page 10 FDA on Patient Compliance (Federal Register, Vol. 71, No. 23; Feb. 3, 2006) “If a patient diary or some other form of unsupervised data entry is used, the FDA plans to review the protocol to determine what measures are taken to ensure that patients make entries according to the study design and not, for example, just before a clinic visit when their reports will be collected." (Pg. 10; 334-337 – emphasis added) 13 April 2015 confidential Page 11 Why ePRO? Is This Familiar? Missing data Ambiguous data Conflicting data Extraneous data From: “Technology Solutions for the collection of patient reported outcomes data”. Bill Byrom. European Pharmaceutical Contractor, 2004. 13 April 2015 confidential Page 13 Benefits of ePRO • Who hasn’t had a paper diary nightmare? • Process benefits on the theme of cleaner data quicker – – – – – More complete – high compliance Improved integrity – date:time stamps Increased consistency – logic checks No free or extraneous text Automatically coded • Don’t forget better science - far greater compliance with protocol – Who’d want to defend paper diary data to a regulator? 13 April 2015 confidential Page 14 eDiary v Paper NCI & invivodata Diary Methods Study Stone et al. (2002): British Medical Journal invivodata eDiary† N = 40 Instrumented Paper Diary* N = 40 †Actual *Contained hidden photosensor 13 April 2015 eDiary used in 2002 Study confidential Page 15 eDiary v Paper Results: eDiary vs. Paper Diary Stone et al. (2002): British Medical Journal • Paper Compliance 100 – Reported: 90% – Actual: 11% 80 60 • eDiary Compliance 40 – Reported: 94% – Actual: 94% 20 0 Paper eDiary Reported compliance Actual compliance 13 April 2015 confidential Page 16 Obstacles Obstacles and overcoming them • Fear of change – We’ve always done it this way – Precedent not acceptable to regulators 13 April 2015 confidential Page 18 Obstacles and overcoming them • Lack of awareness of modern ePRO – No longer something like this…. – Or this…. 13 April 2015 confidential Page 19 Device ePRO examples 13 April 2015 confidential Page 20 More obstacles • Not enough time? – Not enough time for what? – Not enough time to plan for success = planning for failure • Sites won’t like it? – Where’s the evidence for this? – Who pays them? – Doesn’t stop us using EDC widely 13 April 2015 confidential Page 21 PRO Scale Migration • Consensus has emerged on best practice • Documented by ISPOR “PRO Good Research Practices Task Force” • Published in Value in Health – Coons et al, 1098-3015/08 – “Recommendations on Evidence Needed to Support Measurement Equivalence between Electronic and Paper-Based Patient-Reported Outcome (PRO) Measures: ISPOR ePRO Good Research Practices Task Force Report” 13 April 2015 confidential Page 22 Levels of Modification Level of Modification Rationale Minor The modification can be justified on the basis of logic and/or existing literature. No change in content or meaning. Moderate Based on the current empirical literature, the modification cannot be justified as minor. May change content or meaning. Substantial There is no existing empirical support for the equivalence of the modification and the modification clearly changes content or meaning Adapted from Shields et al. 13 April 2015 confidential Page 23 Examples of Modification Level of Modification Examples Minor 1) Non-substantive changes in instructions (e.g., from circling the response to touching the response on a screen). 2) Minor changes in format (e.g., one item per screen rather than multiple items on a page). Moderate 1) Changes in item wording or more significant changes in presentation that might alter interpretability. 2) Change in mode of administration involving different cognitive processes (e.g., paper [visual] to IVR [aural]). Substantial 1) Substantial changes in item response options 2) Substantial changes in item wording Adapted from Shields et al. 13 April 2015 confidential Page 24 Evidence Required Level of Modification Level of Evidence Minor Cognitive debriefing Usability testing Moderate Equivalence testing Usability testing Substantial Full psychometric testing Usability testing Adapted from Shields et al. 13 April 2015 confidential Page 25 Patients can’t use it? • Severe Parkinson’s Disease patient 13 April 2015 confidential Page 26 Living with the PRO Guidance Emerging Best Practice • PRO Strategy – PRO Dossier – PRO input into protocol – An Endpoint Development Process 13 April 2015 confidential Page 28 “Begin with the end in mind” Labeling Claims Disease/Conceptual Model Measurement Strategy Instruments/Items Conceptual Framework Endpoint Model Endpoints 13 April 2015 confidential Page 29 A Few Words on Instruments • When is a PRO instrument adequate to support labeling claims? – “The adequacy of a PRO instrument as a measure to support medical product labeling claims depends on its documented measurement properties that demonstrate the instrument is ‘fit for purpose’” (Burke, 2008). • “Fit for purpose” means that the instrument is specific to and defined by the patient population and the specified disease, treatment, and selected endpoints. – In this circumstance, “instrument is defined as a means to capture data (i.e., a questionnaire) plus all the information and documentation that supports its use” (Burke, 2008). 13 April 2015 confidential Page 30 Impact of FDA PRO Guidance • Study Endpoints and Labeling Division (SEALD) are reviewing programs where labeling claims based upon PRO • Feedback from FDA specifically cites PRO Guidance • Expectations for PRO activity and documentation being driven by Guidance • PRO Submission/dossier template • Created a need for practical resources to better understand the nature of PROs – best practices that facilitate the effective development of PRO instruments. 13 April 2015 confidential Page 31 Common Pitfalls/Myths • We can go at risk and then just ask the FDA afterthe-fact • Lack of patient-interview based data – Needed to support the importance and relevance of the concepts and items in the PRO instrument • The instrument is ‘valid’ in patient population A, therefore it is OK to use in patient population B • We can wait until Ph III to address the PRO instrument issues 13 April 2015 confidential Page 32 Endpoint Development Process • A tool for meeting scientific and regulatory needs Ongoing Synthesis of Material Conceptual Model Development 13 April 2015 Concept Justification Measurement Strategy confidential Instrument Identification Conceptual Framework Endpoint Model Page 33 Endpoint Development Process Ongoing Synthesis of Material Conceptual Model Development Concept Justification Measurement Strategy Identify Program Goals & Claims Expert Input Focus of Assessment Identify Relevant Population Patient Reports Identify Relevant Drug Effects Empirical Evidence Identify Relevant PRO Concepts 13 April 2015 Conceptual Framework Endpoint Model Identify Existing Instruments Theoretical Validation Evidence/Plan Study Design Requirements Interval of Assessment Modify Existing Instruments Psychometric Validation Evidence/Plan Construction of Endpoints Recall Period Identify Alternate Measurement Strategies Timing & Schedule of Assessment Develop Novel Instruments confidential Instrument Identification Page 34 Conceptual Model: Specifying & Substantiating Concepts Signs/ Symptoms Disease Related Impact General Impact Drug Action Concept Justification Patient Population Relevant Disease Process Impact 1A • Signs • Symptoms Impact 2A Impact 1B Diagnosis 13 April 2015 confidential Page 35 Concept Justification Concept Expert input Empirical Data Patient Interviews Payor Relevance Symptom Symptom A Symptom B Symptom Impact Symptom Impact A Symptom Impact B Yes indicates that this justification criterion has been satisfied No indicates that this justification criterion has not yet been satisfied TBD indicates To Be Determined 13 April 2015 confidential Page 36 Conceptual Framework PRO Concept Label Claim PRO Concept PRO Concept Item 1 Item 2 Item 3 Item 4 Item 5 Label Claim PRO Concept 13 April 2015 confidential Item 6 Page 37 PRO Strategy Pointers • Begin thinking of PRO strategy early in development • Interact with regulators • PRO EDP provides structure for elements of PRO Strategy and Dossier • Think about preparation for trial implementation 13 April 2015 confidential Page 38 What about….? What about ePRO Design • ePRO Solution Design – Maximise value of new modalities • Don’t simply recreate the weaknesses of paper instruments – Less missing data – More precise measures – More frequent, reliable measures 13 April 2015 confidential Page 40 FDA’s view on PRO Design (Federal Register, Vol. 71, No. 23; Feb. 3, 2006) “PRO instruments that require patients to rely on memory … may threaten the accuracy of the PRO data. It is usually better to construct items that ask patients to describe their current state than to ask them to compare their current state with an earlier period or to attempt to average their experiences over a period of time.” (Pg. 11; 339-343 – emphasis added) 13 April 2015 confidential Page 41 What about…? • Psychometric validation – Luckily the FDA have written us an abridged text book on psychometrics – It’s called the FDA PRO Guidance – Applies to paper as well – Eliciting the patient perspective is a central tenet 13 April 2015 confidential Page 42 Psychometric Validation • Large proportion of the FDA PRO Guidance refers to psychometric aspects • With any PRO you need to show evidence that: – “The adequacy of a PRO instrument as a measure to support medical claims depends on its development history and demonstrated measurement properties” – Reliability – Validity – Ability to detect change – Interpretability • A specialised area that applies as much to paper as electronic 13 April 2015 confidential Page 43 What about Linguistic Validation? • Translations (to a high standard) – Full title: linguistic validation & cultural adaptation • • • • Best practice well established Plenty of vendors to choose from Timelines typically 8 – 11 weeks Applies to paper as well 13 April 2015 confidential Page 44 For Reference Scientific Improvements • Patients are answering questions at the time of clinical interest – In other words as specified in the protocol and not just before a clinic visit • Patients give more complete answer sets so improving statistical power (ref: ACT 2004) • ePRO allows more sophisticated and targeted questioning • Competing compounds are now likely to be using ePRO – Who wants to be seen using inferior methods. 13 April 2015 confidential Page 46 Regulatory Motives • EMA and FDA regularly accept ePRO data for primary and secondary endpoints. – This is not something they view with suspicion. • Recently BfArM (the German regulatory authority) explicitly directed a sponsor to use ePRO rather than paper • The FDA PRO Guidance sets out clear expectations for the use of any form of PROs (paper or electronic) – http://www.fda.gov/downloads/Drugs/GuidanceComplian ceRegulatoryInformation/Guidances/UCM193282.pdf 13 April 2015 confidential Page 47 Features of Different ePRO Types Feature (incomplete list) IVRS eDiary ePen Automated coding of data Time-stamps Time windows Alarms / reminders Branching logic Prevent question skipping Prevent extra “writing” Graphics Replace Clinician Interviews Verbal Recordings High-frequency assessments Episodic, time-based reporting Illiterate subjects 13 April 2015 confidential Page 48 Thank You Adam Wood e: awood@invivodata.com +44 78 5492 8430