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      Trial designs using real‐world data: The changing landscape of the regulatory approval process

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          Abstract

          Purpose

          There is a need to develop hybrid trial methodology combining the best parts of traditional randomized controlled trials (RCTs) and observational study designs to produce real‐world evidence (RWE) that provides adequate scientific evidence for regulatory decision‐making.

          Methods

          This review explores how hybrid study designs that include features of RCTs and studies with real‐world data (RWD) can combine the advantages of both to generate RWE that is fit for regulatory purposes.

          Results

          Some hybrid designs include randomization and use pragmatic outcomes; other designs use single‐arm trial data supplemented with external comparators derived from RWD or leverage novel data collection approaches to capture long‐term outcomes in a real‐world setting. Some of these approaches have already been successfully used in regulatory decisions, raising the possibility that studies using RWD could increasingly be used to augment or replace traditional RCTs for the demonstration of drug effectiveness in certain contexts. These changes come against a background of long reliance on RCTs for regulatory decision‐making, which are labor‐intensive, costly, and produce data that can have limited applicability in real‐world clinical practice.

          Conclusions

          While RWE from observational studies is well accepted for satisfying postapproval safety monitoring requirements, it has not commonly been used to demonstrate drug effectiveness for regulatory purposes. However, this position is changing as regulatory opinions, guidance frameworks, and RWD methodologies are evolving, with growing recognition of the value of using RWE that is acceptable for regulatory decision‐making.

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          Most cited references51

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          Axicabtagene Ciloleucel CAR T-Cell Therapy in Refractory Large B-Cell Lymphoma

          In a phase 1 trial, axicabtagene ciloleucel (axi-cel), an autologous anti-CD19 chimeric antigen receptor (CAR) T-cell therapy, showed efficacy in patients with refractory large B-cell lymphoma after the failure of conventional therapy.
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            Blinatumomab for minimal residual disease in adults with B-cell precursor acute lymphoblastic leukemia.

            Approximately 30% to 50% of adults with acute lymphoblastic leukemia (ALL) in hematologic complete remission after multiagent therapy exhibit minimal residual disease (MRD) by reverse transcriptase-polymerase chain reaction or flow cytometry. MRD is the strongest predictor of relapse in ALL. In this open-label, single-arm study, adults with B-cell precursor ALL in hematologic complete remission with MRD (≥10-3) received blinatumomab 15 µg/m2 per day by continuous IV infusion for up to 4 cycles. Patients could undergo allogeneic hematopoietic stem-cell transplantation any time after cycle 1. The primary end point was complete MRD response status after 1 cycle of blinatumomab. One hundred sixteen patients received blinatumomab. Eighty-eight (78%) of 113 evaluable patients achieved a complete MRD response. In the subgroup of 110 patients with Ph-negative ALL in hematologic remission, the Kaplan-Meier estimate of relapse-free survival (RFS) at 18 months was 54%. Median overall survival (OS) was 36.5 months. In landmark analyses, complete MRD responders had longer RFS (23.6 vs 5.7 months; P = .002) and OS (38.9 vs 12.5 months; P = .002) compared with MRD nonresponders. Adverse events were consistent with previous studies of blinatumomab. Twelve (10%) and 3 patients (3%) had grade 3 or 4 neurologic events, respectively. Four patients (3%) had cytokine release syndrome grade 1, n = 2; grade 3, n = 2), all during cycle 1. After treatment with blinatumomab in a population of patients with MRD-positive B-cell precursor ALL, a majority achieved a complete MRD response, which was associated with significantly longer RFS and OS compared with MRD nonresponders. This study is registered at www.clinicaltrials.gov as #NCT01207388.
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              Complete Hematologic and Molecular Response in Adult Patients With Relapsed/Refractory Philadelphia Chromosome–Positive B-Precursor Acute Lymphoblastic Leukemia Following Treatment With Blinatumomab: Results From a Phase II, Single-Arm, Multicenter Study

              Purpose Few therapeutic options are available for patients with Philadelphia chromosome–positive (Ph + ) B-precursor acute lymphoblastic leukemia (ALL) who progress after failure of tyrosine kinase inhibitor (TKI) −based therapy. Here, we evaluated the efficacy and tolerability of blinatumomab in patients with relapsed or refractory Ph + ALL. Patients and Methods This open-label phase II study enrolled adults with Ph + ALL who had relapsed after or were refractory to at least one second-generation or later TKI or were intolerant to second-generation or later TKIs and intolerant or refractory to imatinib. Blinatumomab was administered in 28-day cycles by continuous intravenous infusion. The primary end point was complete remission (CR) or CR with partial hematologic recovery (CRh) during the first two cycles. Major secondary end points included minimal residual disease response, rate of allogeneic hematopoietic stem-cell transplantation, relapse-free survival, overall survival, and adverse events (AEs). Results Of 45 patients, 16 (36%; 95% CI, 22% to 51%) achieved CR/CRh during the first two cycles, including four of 10 patients with the T315I mutation; 88% of CR/CRh responders achieved a complete minimal residual disease response. Seven responders (44%) proceeded to allogeneic hematopoietic stem-cell transplantation, including 55% (six of 11) of transplantation-naïve responders. Median relapse-free survival and overall survival were 6.7 and 7.1 months, respectively. The most frequent AEs were pyrexia (58%), febrile neutropenia (40%), and headache (31%). Three patients had cytokine release syndrome (all grade 1 or 2), and three patients had grade 3 neurologic events, one of which (aphasia) required temporary treatment interruption. There were no grade 4 or 5 neurologic events. Conclusion Single-agent blinatumomab showed antileukemia activity in high-risk patients with Ph + ALL who had relapsed or were refractory to TKIs. AEs were consistent with previous experience in Ph – ALL.
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                Author and article information

                Contributors
                elodie.baumfeldandre@pfizer.com
                Journal
                Pharmacoepidemiol Drug Saf
                Pharmacoepidemiol Drug Saf
                10.1002/(ISSN)1099-1557
                PDS
                Pharmacoepidemiology and Drug Safety
                John Wiley and Sons Inc. (Hoboken )
                1053-8569
                1099-1557
                10 December 2019
                October 2020
                : 29
                : 10 , Real Word Evidence ( doiID: 10.1002/pds.v29.10 )
                : 1201-1212
                Affiliations
                [ 1 ] Pfizer New York NY USA
                [ 2 ] Tulane University School of Public Health and Tropical Medicine New Orleans LA USA
                [ 3 ] Centre for Clinical Epidemiology Lady Davis Institute Jewish General Hospital Montreal Canada
                [ 4 ] Department of Epidemiology, Biostatistics, and Occupational Health and Gerald Bronfman Department of Oncology McGill University Montreal Canada
                [ 5 ] IQVIA Real‐World Solutions Cambridge MA USA
                [ 6 ] University of North Carolina at Chapel Hill Chapel Hill NC USA
                Author notes
                [*] [* ] Correspondence

                E. Baumfeld Andre, Pfizer, 219 East 42 Street, New York, NY 10017, USA.

                Email: elodie.baumfeldandre@ 123456pfizer.com

                Author information
                https://orcid.org/0000-0001-7169-1855
                https://orcid.org/0000-0001-5162-3556
                https://orcid.org/0000-0003-0153-8286
                Article
                PDS4932 PDS-19-0111.R2
                10.1002/pds.4932
                7687110
                31823482
                e848a2ab-53d3-42a0-8835-82ab6c19255d
                © 2019 The Authors. Pharmacoepidemiology and Drug Safety Published by John Wiley & Sons Ltd.

                This is an open access article under the terms of the http://creativecommons.org/licenses/by-nc-nd/4.0/ License, which permits use and distribution in any medium, provided the original work is properly cited, the use is non‐commercial and no modifications or adaptations are made.

                History
                : 13 March 2019
                : 17 September 2019
                : 11 November 2019
                Page count
                Figures: 0, Tables: 3, Pages: 12, Words: 3545
                Funding
                Funded by: Pfizer , open-funder-registry 10.13039/100004319;
                Categories
                Review
                Reviews
                Custom metadata
                2.0
                October 2020
                Converter:WILEY_ML3GV2_TO_JATSPMC version:5.9.4 mode:remove_FC converted:25.11.2020

                Pharmacology & Pharmaceutical medicine
                external control,long‐term follow‐up study leveraging rwd,pharmacoepidemiology,pragmatic trial,real‐world data (rwd),real‐world evidence (rwe)

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