The PROTECT project An Innovative Public-Private Partnership for New Methodologies in Pharmacovigilance and Pharmacoepidemiology Progress Status: November 2011 PROTECT is receiving funding from the European Community's Seventh Framework Programme (FP7/2007-2013) for the Innovative Medicine Initiative (www.imi.europa.eu). 2 PROTECT Goal To strengthen the monitoring of benefit-risk of medicines in Europe by developing innovative methods to enhance early detection and assessment of adverse drug reactions from different data sources (clinical trials, spontaneous reporting and observational studies) to enable the integration and presentation of data on benefits and risks These methods will be tested in real-life situations. 3 Data collection from consumers – WP4 Clinical trials Observational studies Benefits Electronic health records Spontaneous ADR reports Risks Signal detection WP3 Benefit-risk integration and representation – WP5 Signal evaluation WP2 Validation studies WP6 Training and education WP7 4 Partners Public Private Regulators: EMA (Co-ordinator) DKMA (DK) EFPIA companies: AEMPS (ES) MHRA (UK) Sanofi- Aventis GSK (Deputy Coordinator) Roche Novartis Academic Institutions: University of Munich FICF (Barcelona) Pfizer Amgen Genzyme INSERM (Paris) Mario Negri Institute (Milan) Poznan University of Medical Sciences University of Groningen Others: WHO UMC GPRD IAPO University of Utrecht Imperial College London University of Newcastle CEIFE Merck Serono Bayer Astra Zeneca Lundbeck NovoNordisk Takeda SMEs: Outcome Europe PGRx 5 WP 1: Project Management and Administration Objectives: To create and maintain the conditions needed to achieve the objectives and deliverables of the PROTECT project. Scientific steer towards the overall project objectives and strategy Quality control and assurance measures Knowledge management tools and strategies Administrative, Track of work organisational progress in line with the work and financial programme support Financial monitoring and accountancy 6 WP 2: Framework for pharmacoepidemiological studies Objectives: To: • develop • test • disseminate methodological standards for the: • design • conduct • analysis of pharmacoepidemiological studies applicable to: • different safety issues • using different data sources 7 Art is made to disturb. Science reassures. Georges Braque Is it always true ? 8 Two studies on the use of statins and the risk of fracture done in GPRD around the same period by two different groups. 9 Why such a difference ? • Different patients (source population, study period, exclusion criteria) • Study design (e.g. matching criteria for age) • Definition of current statin use (last 6 months vs. last 30 days) • Possibly different outcomes (mapping) • Possibly uncontrolled/residual confounding 10 Work Package 2 Work plan • Three Working Groups (WG1-WG3) • Databases • Confounding • Drug Utilisation 11 Work Package 2 – WG1: Databases Work Plan • Conduct of adverse event - drug pair studies in different EU databases • Selection of 5 key adverse event - drug pairs • Development of study protocols for all pairs • Compare results of studies • Identify sources of discrepancies Databases • Danish national registries • British THIN databases • Dutch Mondriaan database • Spanish BIFAP project • British GPRD database • German Bavarian claims database 12 Work Package 2 – WG1: Databases Progress status (1/3) Selection of key adverse events and drugs • Selection criteria: • Adverse events that caused regulatory decisions • Public health impact (seriousness of the event, prevalence of drug exposure, etiologic fraction) • Feasibility • Range of relevant methodological issues 13 Work Package 2 – WG1: Databases Progress status (2/3) Selection of 5 key adverse events and drugs • Initial list of 55 events and >55 drugs • Finalisation based on literature review and consensus meeting Antidepressants (incl. Benzodiazepines) - Hip Fracture Antibiotics - Acute liver injury Beta2 Agonists - Myocardial infarction Antiepileptics - Suicide Calcium Channel Blockers - Cancer 14 Work Package 2 – WG1: Databases Progress status (3/3) Development of study protocols • Descriptive studies for the Drug AE pairs in all databases • 5 different study designs in selected databases • Cohort design • Case crossover • Nested case control design • Self controlled case series • Population based case control • Harmonised approach across the 5 drug-event pairs (common standards, processes and template) • Blinding of results procedure 6 Final protocols in Nov 2011 (separate protocols for antidepressants and benzodiazepines versus hip fracture) 15 Work Package 2 – WG1: Databases Next steps • Data request and approval by scientific committee (i.e ISAC for GPRD studies) • Priorities for conducting PE studies agreed: • Descriptive and cohort studies: • Mar 2012: preliminary results • Jun 2012: first publications • Other designs: • Oct 2012: preliminary results • Feb 2013: first publication 16 Work Package 2 – WG2: Confounding Work Plan • Objective • To evaluate and improve innovative methods to control confounding • Method • Creation of simulated cohorts • Use of methods to adjust for observed and unobserved confounding e.g. time-dependent exposure, propensity scores, instrumental variables, prior event rate ratio (PERR) adjustment, evaluation of measures of balance in real-life study 17 Work Package 2 – WG2: Confounding Progress status • 2010: Final protocol to conduct simulation studies • Propensity score methods • Instrumental variable methods • Time-dependent confounding • First results on propensity scores (PS)/balance measures • Usefulness of measures for balance for reporting of the amount of balance reached in PS analysis and selecting the final PS model • Recommendation of methods to quantify balance of confounder distributions when applying PS methods: • standardised difference • Kolmogorov-Smirnov distance, or • overlapping coefficient 18 Work Package 2 – WG2: Confounding Next steps • Multi-database studies • Evaluate the impact of different left and right censoring mechanisms on estimates of exposure effects when pooling the data. • March 2012: First results expected • Analysis of instrumental variables (IV) in Drug AE pairs • Evaluate the potential for IV analysis on the selected Drug AE pairs in the databases that are available within PROTECT • Feb 2012: Identify potential IV for each of the 5 Drug AE pair and in each WG1 database • Aug 2013: Results of IV studies in databases (if an appropriate IV can be identified & measured) 19 Work Package 2- WG3: Drug Utilisation Work Plan • Use of national drug utilisation data (incl IMS) • Inventory of data sources on drug utilisation data for several European countries • Evaluation and dissemination of methodologies for drug utilisation studies in order to estimate the potential public health impact of adverse drug reactions • Collaboration with EuroDURG agreed 20 Work Package 2- WG3: Drug Utilisation Progress Status Inventory on Drug Use data “Drug consumption databases in Europe” (last version August 2011: http://www.imi-protect.eu/results.html) • 11 research working groups across Europe identified • Databases heterogeneous, administrative focus and influenced by the national health system structure • Collecting DU data (in/out hospital) • from public databases (for 6 selected drugs) • from IMS (Antibiotics, Antidepressants and Benzodiazepines. Explored for other drugs) 21 Work Package 2- WG3: Drug Utilisation Next steps • Literature Search on Randomized Controlled Trials (RCT) • Search for existing meta-analyses or syntheses available in the literature (avoid duplication of work already done). • Dec 2011: Development of specific protocols for literature search Jan 2012: Start of literature search starts. • Dec 2012: Results of the literature search on RCTs expected. • Public health impact of selected Drug AE pairs • Evaluate validity of drug use data • Estimate the exposed population to drugs and calculate population attributable risk 22 Work Package 3: Signal Detection Objective: To improve early and proactive signal detection from spontaneous reports, electronic health records, and clinical trials. 23 Work Package 3: Signal Detection Scope • Develop new methods for signal detection in Individual Case Safety Reports. • Develop Guidelines for signal detection and strengthening in Electronic Health Records. • Implement and evaluate concept-based Adverse Drug Reaction terminologies as a tool for improved signal detection and strengthening. • Evaluate different methods for signal detection from clinical trials. • Recommendations for good signal detection practices. 24 Work Package 3: Sub-projects 1. Merits of disproportionality analysis 2. Concordance with risk estimates 3. Structured database of known ADRs 4. Signal detection recommendations 5. Better use of existing ADR terminologies 6. Novel tools for grouping ADRs 7. Other information to enhance signal detection 8. Subgroups and risk factors 9. Signal detection based on integrated clinical trial data analysis 10.Signal detection in Electronic Health Records 11. Drug-drug interaction detection 12. Duplicate detection 25 Work Package 3 – SP 3.1 Properties of disproportionality analysis • Scope Directly compare different statistical signal detection algorithms: • Within different databases • Between databases on same products • Current status • All methods coded in SAS • Implementations validated 26 Work Package 3 – SP 3.2 Concordance with risk estimates • Scope Investigate relationship between disproportionality statistics and conventional measures of association from interventional and observational studies. • Current status • Protocol • Review of well-characterised ADRs for study dataset • Innovation – Use of newly established EPITT database as source of research data. 27 Work Package 3 – SP 3.3 Structured database of SPC 4.8 • Objective Making available, in a structured format, already known ADRs to allow for • Triaging out known ADRs • Automatic reduction of masking effects • Current status • All coding for SPCs for CAPs completed • Application of fuzzy text matching at UMC has increased process efficiency. • Matching of SPC to MedDRA terms- if not possible through automatic text matching- was done by expert medical evaluation at EMA and Bayer. 28 Work Package 3 – SP 3.3 Structured database of SPC 4.8 • Fuzzy text matching (automatic algorithm) to match MedDRA terms from manual extracted ADRs from the SPCs • Stemming, Stop words, Permutations, Synonyms and Spelling variations Sensitivity of verbatim matching increased from 72% 98% Drug SPC Term Aclasta FLU-LIKE SYMPTOMS Verbatim match Fuzzy matching algorithm Flu symptoms Advagraf OTHER ELECTROLYTE ABNORMALITIES - Advagraf PAIN AND DISCOMFORT - Electrolyte abnormality Pain and discomfort NEC Advagraf PRIMARY GRAFT DYSFUNCTION - Primary graft dysfunction* Advagraf PRURITUS PRURITUS Pruritus* Advagraf PSYCHOTIC DISORDER PSYCHOTIC DISORDER Psychotic disorder* Advagraf PULSE INVESTIGATIONS ABNORMAL - Investigation abnormal Advagraf RASH RASH Rash* Advagraf RED BLOOD CELL ANALYSES ABNORMAL - Red blood cell analyses* Advagraf RENAL FAILURE RENAL FAILURE Renal failure* Advagraf RENAL FAILURE ACUTE RENAL FAILURE ACUTE Acute renal failure, Renal failure acute* Advagraf RENAL IMPAIRMENT RENAL IMPAIRMENT Renal impairment* Advagraf RENAL TUBULAR NECROSIS RENAL TUBULAR NECROSIS Renal tubular necrosis* Advagraf RESPIRATORY FAILURES - Respiratory failure, Failure respiratory Advagraf RESPIRATORY TRACT DISORDERS - Respiratory tract disorders NEC Advagraf SEIZURES - Seizure, Seizures* Advagraf SHOCK SHOCK Shock* Better option: Red blood cell abnormal 29 Work Package 3 – SP 3.4 SD recommendations: Database survey • Scope • EudraVigilance (EMA), VigiBase (UMC) • National data sets: AEMPS, DKMA, MHRA • Company data sets: AZ, Bayer, GSK • Focus • # reports, # drugs and # ADR terms • Types of reports (AEs or ADRs, Vaccines, Seriousness, ...) • Additional information (presence of data elements available for stratification and sub-setting, e.g. demographics) • Supporting systems (analytical methods, medical triages) • Progress • Survey deployed and completed by most organisations 30 Work Package 3 – SP 3.4 Overview of Databases EBGM implementations via external vendor systems Lack of comparability 31 Work Package 3 – SP 3.4 Data elements – demography SD (% data available in all case reports) DKMA (unk) (100%) O Country of case (100%) UMC (77%) (94%) (11%) (100%) (>0%) EMA O O MHRA (80%) (97%) O (100%) (57%) AEMPS (96%) (99%) O (100%) O BSP (74%) (97%) (58%) (100%) (83%) AZ (73%) (92%) (26%) (100%) (unk) GSK (79%) (86%) (10%) (96%) (59%) db holder Receipt Date Age/DoB Gender Ethnicity Subject ID (unk) High population of some common data elements, e.g. age, gender, country of case Interim results 2011 32 Work Package 3 – SP 3.4 Database size (no of spontaneous reports) UMC EMA GSK BSP Serious Non-serious AZ Unknown MHRA AEMPS DKMA 0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000 Interim results 2011 33 Work Package 3 – SP 3.4 DB survey Others 21% Top 5 countries by count of reports used for signal detection EMA (% of total spontaneous reports) Germany 7% FRANCE 5% Others 20% JAPAN 8% Canada 5% USA 53% France 7% UK 5% USA 52% UMC France 4% Canada 5% Germany 6% UK 6% Japan 10% German y 12% Others 26% Others 27% AZ UK 10% BSP Brazil 9% Japan 5% Interim results 2011 USA 31% Others 34% UK 10% USA 48% GSK France 5% Canada 6% Germany USA 49% UK 10% 34 Work Package 3 – SP 3.4 DB survey Top 5 agents by count of all reports (NB % of total for top 5, not total db) Interim results 2011 Sulfamethoxaz ole/Trimethop rim Urinary tract infectious disease, 58845, 17% Clozapine Schizophrenia, 63952, 19% Etanercept Reumatoid artrite, 87385, 26% UMC Diphtheria and tetanus toxoids and pertussis Diphtheria/Teta nus (prophylaxis), 63405, 18% Rofecoxib Pain, 67956, 20% Metamiz ol pain 3488 14% Paraceta mol pain 4251 17% Omepraz ole prophyla xis 5979 23% Methotrexat e Unknown indication, 29961, 14% Prednisolone Unknown indication, 30331, 14% Aspirin Unknown indication, 71815, 34% EMA Paracetamol Unknown indication, 36880, 17% Furosemide Unknown indication, 45261, 21% AEMPS Enalapril essential hyperten sion 5072 20% Tegretol Antiepile ptica, 604, 14% Pandemri x Influenza vaccine, 625, 14% Sulfotrim Antiinfect ive, 635, 14% Acetylsal ycilic acid myocardi al ischemia 6603 26% Pondocell in Antiinfect ive, 1433, 32% DKMA Eltroxin Thyroid hormon, 1159, 26% Bupropio n Unknown indication , 9297, 16% Fluoxetin e Unknown indication , 9111, 15% Clozapine Unknown indication , 15080, 26% MHRA Paroxetin e Unknown indication , 11042, 19% Neisseria Meningiti dis Unknown indication , 14459, 24% 35 Work Package 3 – SP 3.5 Better use of existing terminologies • Scope • Investigation of established adverse event coding groups for signal detection • Proof of concept • Temozolomide • Not illustrating timeliness – VigiBase as of Feb 2009 Term Level of terminology # Reports IC Erythema Multiforme PT 13 +0.30 Stevens-Johnson Syndrome PT 19 +0.68 Toxic Epidermal Necrolysis PT 6 +0.51 Bullous Conditions HLT 42 -0.01 Severe Cutaneous Adverse Reactions SMQ 47 -0.04 WHO-ART HLT 35 +0.46 Erythema Multiforme 36 Work Package 3 – SP 3.5 Better use of existing terminologies • Groups included: • MedDRA Preferred Terms (PT, HTL, SMQ narrow or broad) • Ad hoc groupings (developed for the purpose of the study or existing proprietary groupings of one of the participating organisations) • Data sources: • Medical concepts that are often drug-induced [Trifiro et al] • EU labeling changes [Alvarez et al] • WHO ICSR database, VigiBase 37 Work Package 3 – SP 3.5 Better use of existing terminologies • Tentative findings • Groupings of PTs slightly outperform predefined groupings (HLTs, SMQs) • Little indication that terminology-defined groupings are effective for screening in signal detection • Limitations • Study has been limited largely to reasonably welldefined medical concepts • Are these results applicable to broader concepts (eg, bleeding, infection)? 38 Work Package 3 – SP 3.6 Novel tools to group ADRs • Approach • Automatic generation of groups of MedDRA terms based on semantic information • Based on a mapping of MedDRA to SNOMED CT • Groups MedDRA terms based on semantic distance • Progress • Evaluation study completed • Comparison with standard MedDRA SMQs as gold standard • Next steps: • Refinement of methods • Use in signal detection! 39 Work Package 3 – SP 3.7 Other information to enhance signal detection • Scope • Evaluation of masking • Detection of drug-drug pharmacokinetic interactions using the information on metabolic pathways • Current status • Preliminary investigation of masking in EudraVigilance under review • Next steps: • Protocol for drug-drug interactions • Extension of masking analysis to other datasets 40 Work Package 3 – SP 3.8 Subgroups and risk factors • Scope • Investigate utility of adjusting for covariates and subgroup analyses in signal detection Current status • Review document produced on current opinion and evidence regarding stratification • Ongoing discussion on product list – linked to SP3.1 • Next steps: • Review of methodology • Await completion of SP3.1 analysis 41 Work Package 3 – SP 3.9 Signal Detection from clinical trials • Overall scope • Which data should be used and which methods are optimal • Explore novel uses of existing clinical data in ongoing and completed clinical trials for safety signal detection • Current status • Literature searches completed • Protocol(s) for the retrospective analysis – some development needed. • Products/safety topics identified (Bayer/MS) – GSK ongoing. • Assessment of skill set, feasibility and availability of data to do the activities (Bayer/MS) 42 Work Package 3 - SP 3.10 Signal Detection in Electronic Healthcare Records • Scope • Electronic Healthcare Records vs Individual Case Safety Reports for early signal detection • Confirmatory vs exploratory data analysis • Current status • Development of functionality to apply exploratory methods on THIN data has continued • Comparison done against previous published results using the same method but on a different dataset. • Read-groupings have been refined or created for the 23 different adverse drug events from Trifiro et al (2009). 43 Work Package 3 - SP 3.11 Drug-drug interaction detection • Scope • Investigate statistical methods of detecting DDI • Current status • Literature search completed and review underway • Reference set of known DDI and known non-DDIs under construction 44 Subpackage 3.12 - Duplicate detection • Scope • Investgate statistical methods of detecting duplicate ICSRS • Assess impact of removal of ICSRS on signal detection • Current status • The protocol has been finalised • Participants have provided descriptions of their duplicate detection methodologies. • Evaluation sheet for the national centres duplicate evaluation has been agreed, as have approaches for evaluation of the impact of duplicates on signal detection. UMC are ready to distribute initial data, and evaluation can begin shortly. 45 Work Package 4: Data collection from consumers Objectives: To assess the feasibility, efficiency and usefulness of modern methods of data collection including using web-based data collection and computerised, interactive voice responsive systems (IVRS) by telephone 46 Work Package 4 - Project Definition • Prospective, non interventional study which recruits pregnant women directly without intervention of health care professional • Collect data from them throughout pregnancy using either web based or interactive voice response systems (IVRS): – medication usage, lifestyle and risk factors for congenital malformation • Compare data with that from other sources and explore differences • Assess strengths and weaknesses of data collection and transferability to other populations 47 Work Package 4 - Issues with current methods Using health care professionals to capture data • Expensive and data capture relatively infrequent • Will miss drug exposure before comes to attention of HCP • Patients may not tell truth about “sensitive” issues 48 Work Package 4 - Issues with current methods Using EHR records • non prescription medicines, homeopathic and herbal medicines not captured – ? Women switch to “perceived safer” medicines • Medicines prescribed/dispensed may not be medicines consumed – problem with p.r.n. medicines (i.e. dosage as needed) • EHR may miss lifestyle and “sensitive” information 49 Work package 4 - Study population • 4 countries: Denmark United-Kingdom The Netherlands Poland • 1400 pregnant women per country • Self identified as pregnant • Volunteers may not be “typical” of pregnant population – can characterise 50 Work Package 4: Patient workflow overview Study subject picks up a leaflet in a pharmacy or browses specific web sites to find out about the study in one of 4 countries. Study subject enrolls for the web or phone (IVRS) method of data collection. IVRS Web n = 1200 per country Study subject completes the surveys online. n = 200 per country Study subject completes the surveys via an outbound reminder or by inbound call she initiates. Final outcome survey is completed at the end of pregnancy. 51 Work Package 4 – current status Status Nov 2011: • Finalised protocol for ethical submission (approval received in PL, waiver in DK and NL, UK tbc) • Main questionnaires finalised following pilot testing • Baseline (web) • Follow up (web) • Outcome of pregnancy • Satisfaction 52 Work Package 5: Benefit-Risk Integration and Representation Objectives: • To assess and test methodologies for the benefit-risk assessment of medicines • To develop tools for the visualisation of benefits and risks of medicinal products Perspectives of patients, healthcare prescribers, regulatory agencies and drug manufacturers From pre-approval through lifecycle of products 53 Structure of WP5 – Work streams • Work stream A • Work stream B • Work stream C • Work stream D • Case studies wave 1 • Case studies wave 2 • Link with WP6 • Management group 54 Work Package 5: Work Plan 1. Review of methodologies used to model effects of medicines, elucidation of patients’ preferences and integrating effects and preferences. Review of methodologies for graphical representation and visualisation techniques. 2. Selection of case studies (waves 1 and 2) 3. Data selection/requirements for case studies 4. Identification/development of software for B/R. 5. Application of methodology, recommendations, finalisation of tools, protocols for validation studies. 55 Work Package 5: Workstream A - completed • Framework for B-R analysis: achieved through a Charter (SC approved) ‘The overall objective of WP5 is to assess the relevance of various methodologies for B-R assessment of medicinal products including the provision of usable data and information, the underpinning modelling and the presentation of the results, with a particular emphasis on visualisation methods. The overall plan to achieve this task is outlined below. Consideration will be given to: • Submission and post –approval periods, while recognising the relevance of pre - approval B-R assessment • individual and population- based decision making • the perspectives of patients, physicians, regulators and other stakeholders such as societal views needed for Health Technology Assessment (HTA) although specific cost implications will not be considered • possible interdependencies with other PROTECT Work Packages as well as other relevant external initiatives.’ 56 Work Package 5: Overview • Wave 1: has 4 case studies: Raptiva, Tysabri, Ketek and Acomplia. • Drugs which have data readily available from EPARs. • Not revisiting EMA decisions, but use to demonstrate and test methodologies. Wave 1 WS C Case studies Wave 2 WS B Methods • Review of existing methods not inventing new methods. • Emphasis on graphical representation. • Methods estimating(1) magnitude / incidence of events and (2) value elicitation of benefits and risks, from a patient and regulator perspective and how combine them into a single measure. WS D Framework / Data • PrOACT-URL framework for performing benefit-risk analysis. • Oversee working parties for extracting objective measures of magnitude / incidence of benefits and risks. 57 Work stream B Review of benefit risk methodologies • Completed and circulated for comment within WP5 in June 2011 • Useful feedback received and review is in the process of being updated to take account of this • Reviewed and classified 44 approaches • Made preliminary recommendations of 13 approaches 58 Classifications of B-R approaches 59 Work Package 5: Workstream C • Objective • Establishment of criteria and process for selection of ‘initial’, ‘development’ and ‘validation’ case-studies • Taking into account perspectives of regulators and prescribers as well as patients and HTA. • Progress • Criteria for wave 1 +2 case studies decided • Drugs for wave 1: Acomplia®, Raptiv®, Tysabri®, Ketek®; library of possible candidates for wave 2 • Wave 1 studies have commended, wave 2 more challenging (1 study started) 60 Wave 2 Criteria • Uncertainty about what the main benefits and risks are. • Uncertainty about the population who has the disease. • Different time for Benefit and for Risk (long term risks). • Individual benefit-risk, or subgroups of benefit risk. • New drugs vs. long marketed drugs. 61 Work Package 5: Workstream C • Next steps • Wave 1: Report due by Dec 2011 • Wave 2: Case studies to include aspects of visualisation and due to finish August 2012 • Discussion with other WP5 members for appropriate data identification and extraction, applicability of case studies. • Identify potential presentations and publications. 62 Work Package 5: Workstream D • Scope • Data Collection dependent from Framework used: • Using PrOACT-URL (generic framework for decision making), identification of data sources to be used depend on detailed description of each of the steps of the framework (see back up slide) • Lead to a draft “Guidelines for preparing a Case Study Report” • In addition to EPAR as main source of data/information, additional data sources for other drugs or for other perspectives will require • Additional data collection from existing data sets (PSURs, formal B-R reviews) • Creation of new data (e.g. questionnaires for patient preferences elicitation) • Progress • Fine-tuned the PROACT-URL generic decision making framework for regulatory decision-making 63 PrOACT of PrOACT-URL* Example: Efalizumab for psoriasis • Benefits – improvement of severe chronic plaque psoriasis • Risks – PML, cardiotoxicity, neurotoxicity, serious infections including tuberculosis Application to efalizumab example 1. Problems Could any risk minimisation measures be implemented to bring the BR balance of the drug back to positive? 2. Objectives Re-evaluation of B-R balance of efalizumab from MA pivotal trials and post-marketing safety information using known favourable effects and unfavourable effects (EPAR, SPC, PSUR, literature, etc.) 3. Alternatives • Do nothing • Restriction: limit duration, restrict indication, suspend • Do nothing: B-R balance still considered positive. • Restrictions: (i) 2 year treatment duration limitation; (ii) target population change; (iii) suspension/withdrawal - drug recall worldwide 4. Consequences (* See Hammond JS, Keeney RL, Raiffa H. Smart Choices: A Practical Guide to Making Better Decisions. Boston, MA: Harvard Business School Press; 1999) 64 PrOACT of PrOACT-URL* Example: Efalizumab for psoriasis Application to efalizumab example 5. Trade-offs B-R assessment to be reiterated using the same data but with MCDA quantitative method 6. Uncertainty •Uncertainty on the extent of off-label use in patients with less severe conditions, decreasing the benefit part of the balance. •Uncertainty on the shape of the risk function of PML (probably not linear), based on only 4 cases. •No true incidence but only reporting rate. •Same for all other post-marketing safety data which lead to SPC Variations 7. Risk tolerance •No consensus between rapporteurs at the initial MA approval •Efalizumab has only modest efficacy compared to alternatives •Psoriasis is not life-threatening but serious impact on social life •Improvement of the RMP •Patients’ value judgments are different from regulators 8. Linked decisions FDA made the same decision as EMA to withdraw efalizumab from the market 65 Work Package 5: Next steps • Develop the work in WP5 to gather more information from wider stakeholders – particularly patients and sub groups of patients • Likely techniques include exploring different perceptions of acceptable risk/benefit balance with information presented in different ways e.g. Different visualisation methods. • Potentially include web based surveys alongside qualitative based work 66 Work Package 6: Validation Objectives: • To validate and test the transferability and feasibility of methods developed in PROTECT to other data sources and population groups • To determine the added value of using other data sources as a supplement or alternative to those generally used for drug safety studies, in order to investigate specific aspects or issues. Started in September 2010 67 Work Package 6 - Inventory of data sources • Creating a comprehensive list of data sources (ongoing) • Review of European databases (electronic healthcare records, cohorts, registries) • ENCePP • EFPIA • Outcomes of other Work Packages (2-5) will be evaluated in light of the inventory of data sources (e.g. type of data, covariate information, mode of collection, type of prescription data, etc) 68 Work Package 6 – WP2 validation studies • Protocols have been developed and data sources have been identified, leading to a revised list for the Extended Audience. • The objectives of these studies are: • Objective 1: Replication study in same database • Objective 2: Replication study in different database • Objective 3: Negative control study • Objective 4: Use of alternative outcome definition • Objective 5: Validation of outcome • Objective 6: Assessment of confounders 69 Draft WP6 research plan: Study objectives, rationale and design Defined Study Objective*** Objective 1: Replication study in same database Scientific Question Investigator Database Study design* Is the study replicable when conducted independently in the same database? Using same design/analysis 1. Takeda , LA-SER Using different design/analysis 2.Takeda , LA-SER 3. Aarhus University 1. GPRD 2. GPRD 3. Danish Psychiatric, Somatic Hospital Discharge & Mortality Registers 1. A; Population case control 2. A; Population case control 3. E; Population case control Objective 2: Replication study in different database Do the results have external validity? Using same design/analysis 1. SARD 2. SARD 3. LA-SER Using different design/analysis 4. GSK 5. LA-SER ** 6. LA-SER 7. LA-SER 8. Utrecht University** 1. LabRx/Premier 2. LabRx/Premier 3. PGRx 1. A; Nested case control 2. C; Nested case control 3. C; Population case control 4. D; Cohort 5. D; Cohort ** 6. C; Population case control 7. E; Population case control 8. A; Descriptive study** Objective 3: Negative control study Does a study using the same protocol provide absence of evidence of an association where the exposure is such that the expected result is one of no association? 1. SARD 2. GSK 3. LA-SER 4. MarketScan and Medicare 5. E3N ** 6. PGRx 7. PGRx 8. UPOD** 1. LabRx/Premier 2. GPRD 3. PGRx 1. Nested case control (AMI) 2. Self-controlled-series (hip fracture) 3. Population case control (AMI) *Study design: A=Antibiotics and ALI; B=Antidepressants/BZD and hip/femur fractures; C=Beta2Agonists and AMI; D=Calcium channel blockers and cancer; E=Antiepileptics and suicidality ** To be confirmed. 70 *** Each study may have several objectives Draft WP6 research plan: Study objectives, rationale and design (continued) Defined Study Objective Objective 4: Use of alternative outcome definition Scientific Question Investigator Database Study design* What is the impact of different levels of certainty of the outcome (e.g. definite, probable, possible) on the effect estimate? 1. Takeda , LA-SER 2. LA-SER 3. LA-SER 4. Aarhus University 1. GPRD 2. PGRx 3. PGRx 4. Danish Psychiatric, Somatic Hospital Discharge & Mortality Registers Objective 5: Validation of outcome Has the outcome of interest been validated through clinical record review? What is the impact of validation on the effect estimate? 1. Takeda , LA-SER 2. SARD 3. Utrecht University** 4. Aarhus University 5. GSK 1. GPRD 2. LabRx/Premier 3. UPOD** 4. Danish Psychiatric, Somatic Hospital Discharge & Mortality Registers 5. GPRD 1. A; Population case control 2. C; Population case control 3. E; Population case control 4. E; Population case control 1. A; Population case control 2. A; Nested case control 3. A; Descriptive study 4. E; Population case control 5. E; Descriptive study/ Population case control Objective 6: Assessment of confounders Has confounding been adequately taken into consideration? Are there additional confounders that need to be assessed? How does better control for confounding impact the effect estimate? 1. Utrecht University** 2. LA-SER 3. LA-SER 4. Aarhus University 1. UPOD** 2. PGRx 3. PGRx 4. Danish Psychiatric, Somatic Hospital Discharge & Mortality Registers 1. A; Descriptive study** 2. C; Population case control 3. E; Population case control 4. E; Population case control *Study design: A=Antibiotics and ALI; B=Antidepressants/BZD and hip/femur fractures; C=Beta2Agonists and AMI; D=Calcium channel blockers and cancer; E=Antiepileptics and suicidality ** To be confirmed. 71 *** Each study may have several objectives Work Package 6 – WP5 validation studies • To be explored based on wave 1 studies (1st choice: Tysabri) • Scope potential areas of variability and draft a protocol 72 Work Package 7: Training & communication Objective: To identify training opportunities and support training programmes to disseminate the results achieved in PROTECT. 73 Work Package 7: Scope • Development of a Platform of Training Opportunities Launched. • Regular interaction with Eu2P Consortium Mechanism in place to ensure timely input from PROTECT WPs 2-5 into Eu2P training programmes. • Communication Plan Draft list of conferences and other international forums suitable for the presentation of the results of PROTECT. Search of communication expert initiated. 74 Work Package 7: Training Platform • Available at https://w3.icf.uab.es/trainingopp (or through link from PROTECT homepage) • Launched in July 2011 • Extended to EU2P in July 2011 • Extension to ENCePP as of Nov 2011 75 More information? Website:www.imi-protect.eu Email: Protect_Support@ema.europa.eu 76