1. Characteristics of non-randomised studies using comparisons with external controls submitted for regulatory approval in the USA and Europe: a systematic review.
- Author
-
Goring S, Taylor A, Müller K, Li TJJ, Korol EE, Levy AR, and Freemantle N
- Subjects
- Drug Approval methods, Europe, Government Agencies, Hematologic Diseases, Hematologic Neoplasms, Humans, Metabolic Diseases, Product Surveillance, Postmarketing, Stem Cell Transplantation, United States, United States Food and Drug Administration, Drug Approval statistics & numerical data, Non-Randomized Controlled Trials as Topic
- Abstract
Objectives: Non-randomised clinical trial designs involving comparisons against external controls or specific standards can be used to support regulatory submissions for indications in diseases that are rare, with high unmet need, without approved therapies and/or where placebo is considered unethical. The objective of this review was to summarise the characteristics of non-randomised trials submitted to the European Medicines Agency (EMA) or Food and Drug Administration (FDA) for indications in haematological cancers, haematological non-malignant conditions, stem cell transplants or rare metabolic diseases., Methods: We conducted systematic searches of EMA databases of conditional approvals, exceptional circumstances, or orphan drug designations and FDA inventories of orphan drug designations, accelerated approvals, breakthrough therapy, fast-track and priority approvals. Products were included if reviewed by at least one agency between 2005 and 2017, the primary evidence base was non-randomised trial(s) and the indication was for haematological cancers, stem cell transplantation, haematological conditions or rare metabolic conditions., Results: We identified 43 eligible indication-specific products using non-randomised study designs involving comparisons with external controls, submitted to the EMA (n=34) and/or FDA (n=41). Of the 43 indication-specific products, 4 involved matching external controls to the population of a non-randomised interventional study using individual patient-level data (IPD), 12 referred to external controls without IPD and 27 did not explicitly reference external controls. The FDA approved 98% of submissions, with 56% accelerated approvals; most required postapproval confirmatory randomised controlled trials (RCT). The EMA approved 79% of submissions, with a quarter of approvals conditional on completion of a postapproval RCT or additional non-randomised trials., Conclusions: There has been a large increase in submissions to the EMA and FDA using non-randomised study designs involving comparisons with external controls in recent years. This study demonstrated that regulators may be willing to approve such submissions, although approvals are often conditional on further confirmatory evidence from postapproval studies., Competing Interests: Competing interests: AT is an employee of Takeda. EEK, TJJL and KM are employees of ICON, a CRO that was paid by Takeda to perform this study and to draft this manuscript. SG was an employee and is a consultant for ICON. ARL is a consultant for ICON. NF has received funding for research, travel or consultation from Sanofi Aventis, Takeda, Allegan, Biopharma, Ipsen, Servier, Pfizer and Novo Nordisk., (© Author(s) (or their employer(s)) 2019. Re-use permitted under CC BY-NC. No commercial re-use. See rights and permissions. Published by BMJ.)
- Published
- 2019
- Full Text
- View/download PDF