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Protocol F1K-MC-EVDPEfficacy and Safety of Drotrecogin Alfa (Activated) in Adult Patients with Septic
ShockPROWESS SHOCKJonathan Janes FRCP MFPMMedical Director- Acute Care
Lilly Research CentreErl Wood Manor, UK
Critical Care Canada Forum 2011 Toronto
Disclosures:
I am an employee and shareholder of Eli Lilly and Company.
Xigris Studies
• Xigris Studies (> 11,000 patients) – EVAA Phase II N= 131– PROWESS Phase III N=1690– ENHANCE Open label N= 2378– ADDRESS Lower risk of death N= 2640– RESOLVE Paediatric study N= 477– XPRESS Heparin study N= 1935– RESPOND Phase II study N= 433
• Potential role of PC as a biomarker to guide Xigris therapy
– PROWESS SHOCK N= 1696
Clinical Trial and Registries – Hospital/ ICU mortalityXigris Control, Adjusted Control,
or Predicted MortalityLilly Clinical PROWESS-Overall 29% 35%
Study PROWESS-≥3 OD 36% 44%
Observational Poland (N=302) 39% 56%
Studies Italy (GiViTI; N=668) 46% 55%
United Kingdom 1 (ICNARC; N=1292) 45% 49% – 58%*
United Kingdom 2 (N=351) 47% 60%
Belgium (N=436) 52% 64%
Global 1 (N=882) 50% 57% -61%*
Spain (N=87) 37% 57%
United States 1 (N=1576) 41% 47%
United States 2 (N=108) 35% 54%
Global 2 (N=unknown) OR: 0.71 95% CI: 0.62-0.82
France (N=1049) 47% 68%* Ranges estimated from relative risk
Xigris Approvals & EU Annual Licence Reassessments
2003 1st Annual Licence Reassessment ENHANCE update
2004 2nd Annual Licence Reassessment PROWESS Long-Term Follow-Up, ENHANCE, ADDRESS
2005 3rd Annual Licence Reassessment ADDRESS Long-Term Follow-Up, RESOLVE
2006 4th Annual Licence Reassessment XPRESS, Agreement to conduct PROWESS-Shock
2007 5-year renewal
2007 5th Annual Licence Reassessment Final PROWESS-SHOCK protocol Reviewed
2008 6th Annual Licence Reassessment SPC updates
2009 7th Annual Licence Reassessment No SPC changes
2010 8th Annual Licence Reassessment No SPC changes
2011 9th Annual Licence Reassessment PROWESS-SHOCK Results
• November 2001 Approval from FDA• August 2002 Approval from EMEA
The small difference in the 28-day mortality of the overall population (26.4% in the Xigris arm versus 24.2% in the placebo arm; n=1680 patients) is not statistically significant. The risk of severe bleeding events, which is the main risk with this product, was 1.2% in the Xigris arm and 1.0% in the placebo arm, suggesting there was no increased harm.
Why did PROWESS SHOCK Results differ from PROWESS? • PROWESS SHOCK was not designed to “re-test” PROWESS, but
rather to test a high disease severity subset reflecting both the labeled indication and how DAA was being used in clinical practice– Advances in standard of care were protocolised– The following may have been contributing factors
PROWESS PROWESS SHOCK
CV Dysfunction 1 hr hypotension or 1 hr of vasopressors (any dose)
Minimum 4 hr , minimum dose of vasopressors
Resuscitation 500 ml fluid in 30 min ≥ 30 mL/kg within +/- 4 hr of vasopressors
Other organ dysfunction 1 or more Shock + hypoperfusion
Infection Known or suspected infection
Evidence of infection receiving IV antimicrobials
Coordinating centre Reviewed sepsis histories within 24 hr
Approved every patient
Placebo mortality 35% (≥2OD, Vasopressor) 24.2%
Why did Lilly Withdraw Xigris?
• Patents enrolled in PROWESS SHOCK largely reflected what would have been considered an indicated population
• The study failed to demonstrate that Xigris improved patient survival and thus calls into question the benefit-risk profile of Xigris and its continued use
Regulatory Guidance on Acceptance of a Single Study for Efficacy
In some instances, clinical evidence consisting of a single, large-scale, adequate and well controlled study or one pivotal trial and additional clinical evidence may be deemed "substantial" [Jan 31,2003]http://www.hc-sc.gc.ca/dhp-mps/prodpharma/applic-demande/guide-ld/priorit/priordr-eng.php
http://www.ema.europa.eu/ema/index.jsp?curl=pages/regulation/general/general_content_000366.jsp&mid=WC0b01ac0580032ec4&jsenabled=true
EMA Guidance• There is no formal requirement to include two or
more pivotal studies in the phase 3 program• In most cases several studies are the most or
only feasible way to confirm usefulness• In the exceptional event of a submission with
only one pivotal study this has to be particularly compelling with regard to: – Internal and external validity– Clinical relevance– Statistical significance– Data quality– Internal consistency
www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm078749.pdf
FDA Guidance on Acceptance of a Single Study for Efficacy
• Limited to situations where a clinically meaningful effect is observed:– Mortality– Permanent morbidity– Prevention of a disease with a potentially serious
outcome• Confirmation of the results in a second trial
would be practically or ethically impossible
FDA Guidance on Acceptance of a Single Study for Efficacy
(1) Large, multicenter clinical trial– No single study site provided an unusually large
fraction of patients– No single investigator or site was responsible for
the favorable effect seen(2) Consistency across study subsets
– Positive effects should be observed across clinically meaningful subsets of patients (age, gender, race, severity of illness)
(3) Statistically very persuasive findings– “In a multicenter study, a very low p-value indicates
that the result is highly inconsistent with the null hypothesis of no treatment effect.”
FDA Guidance on Acceptance of a Single Study for Efficacy
(4) Multiple endpoints involving different events– “In some cases, a single study will include multiple
primary and secondary endpoints, each of which demonstrates a beneficial, but different, event” as with reduction in MI and reduction in need for urgent intervention.
(5) Multiple studies in a single study– A large study can be viewed as two or more studies
by subdividing it and showing that effectiveness is seen in the subdivisions.
Agennix Update on Talactoferrin: 2010
• End-of-Phase II meeting with the U.S. Food & Drug Administration (FDA) to discuss future development plans for talactoferrin in severe sepsis
• The FDA strongly recommended that Agennix conduct two adequate and well-controlled Phase III studies to support a potential Biologic License Application (BLA) submission.
http://www.agennix.com
Other questions?• If 2 trials are required in the future should these be run
in sequence or parallel?– In parallel similar to 1 large trial divided into 2 parts– In sequence, the timeline and cost of Phase 3 may be
prohibitive• What is the value of registry data?
– Suggested a beneficial effect with Xigris yet RCT negative– Suggested a harmful effect of steroids yet commonly used– Is our ability to adjust/predict mortality adequate?
• Implications for other efficacy trials as clinical practice evolves? – Are there instances where we might need to repeat clinical
trials to assure continued efficacy of an intervention?– Regulatory agencies monitor for new or worsening safety
signals, not loss of efficacy
Thank You