A once-rare type of clinical trial that violates one of the sacred tenets of trial design is taking off, but is it worth the risk?
When researchers at Pfizer first began a Phase 2 trial of an acute stroke therapy in 2000, they decided to take a novel approach. The study—called the ASTIN trial—would determine the drug’s optimal dose not with three or four different dosing arms, as trials often have, but with 15. Data from the trial would be captured continuously and used to make changes in real time to how the trial was run. As new patients joined, they would be randomized to a particular arm based on those real-time results—a process which required an intensive level of relatively novel statistics.
Before the drug entered Phase 3, the data showed that it was ineffective, and the trial ended in 2001. But processing a massive...
ASTIN’s methodology, termed adaptive trial design, goes against the sacred rule of the randomized double-blind, placebo-controlled trial: In order to avoid influencing the trial’s outcome, no one should know who is getting which treatment.
But in an increasingly common approach, a trial can be altered in various ways while it’s still in progress, perhaps by tweaking the sample size, dropping ineffective dosing arms, or even changing the endpoint. Such modifications are based on a peek at interim data—which of necessity means unblinding the data before the trial’s completion.
“The reasons to do it are pretty clear,” says Janet Wittes, president of the clinical trial design firm Statistics Collaborative, Inc., in Washington, DC. Adaptive trials “hold the potential and the promise for doing trials faster and getting answers faster.” Plus, assessing assumptions you made in planning a trial as it proceeds can strengthen a trial’s scientific merit, says Scott Evans, a biostatistician at Harvard University.
According to Berry, a vocal champion of adaptive design, “the randomized trial moved us up to a very high level in terms of science,” he says. “We’re trying to preserve that level but move to even higher levels in terms of efficiency.” Clinical trials, especially late-stage ones, can cost tens to hundreds of millions of dollars; done right, an adaptive design can shave 20–50% off that sum.
In the past few years, pharmaceutical companies have adopted the approach in full force. Many—such as Wyeth, Eli Lilly, and Novartis—have dedicated divisions for adaptive trial design. For biotechs with few resources, the possibility of a faster, cheaper clinical trial may be even more of a draw.
But like all propositions that sound too good to be true, there’s a downside. Too often, critics caution, companies wrongly assume the approach is an easy fix to common clinical trial woes when, in fact, the changes can ultimately cost time and money, not save them. “There’s been a lot of overselling, overmarketing, if you will,” says Bob O’Neil, who heads adaptive design efforts for drugs and biologics at the US Food and Drug Administration (FDA). “This is not a panacea for all situations,” he stresses. “It is not standard fare.”
There’s also a bigger concern, which has both US and European regulators struggling to delineate when the approach is appropriate and when it isn’t. Trials are traditionally blinded in order to prevent investigators’ or subjects’ knowledge from influencing the outcome. “If you’re looking at trial data before it’s completed, there’s always the chance that you’re jeopardizing the trial’s integrity,” Evans says.
Adaptive design is a slippery term, and experts argue about its definition. Some adaptations are so straightforward that they raise no concerns whatsoever, Wittes explains. Stopping a trial early, for example, because the treatment works either much better or much worse than expected, is nothing new. Starting with a few concurrent dosing arms and, based on interim results, winnowing them down to the best one or two is also generally not controversial, she said, though the FDA would need to ensure that protocols were in place in such cases to prevent anyone but a data monitoring board from seeing the interim data.
Other adaptations, though, walk a finer line, and whether or not they’re okayed depends on the reasons for implementing them as much as on the adaptations themselves. Suppose, for example, that interim results show that the variance in the data is larger than you’d like. “Variance is a nuisance parameter,” says Wittes. “I don’t think anyone has any trouble” with the idea of increasing the trial’s size in this case. But say the treatment’s effect appears to be smaller than expected, contradicting the prediction for efficacy that the company filed with the FDA before commencing the trial. In that case, by increasing the trial size, she believes, “you’re really changing your hypothesis,” which is based on a prediction of how well the drug works.
Indeed, the FDA itself does not yet have a clear understanding of what this type of trial entails. “We want to put some definitions in place for what we mean as an adaptive design,” says O’Neil. To this end, the agency assembled a working group in 2004, but has yet to release its promised guidance document for companies to follow. Until then, the agency’s take on a particular company’s proposal may depend on who sits on its FDA panel. The European Medicines Evaluation Agency (EMEA) came out with a guidance document in October 2007, and is somewhat less conservative on some elements of the approach than the FDA. One example, explains Berry, is the way the two agencies treat seamless Phase 2/Phase 3 trials—while EMEA generally allows data from Phase 2 patients to be included in the Phase 3 trial, FDA is more cautious.
Even straightforward adaptations don’t come without challenges. For an adaptive dose range such as the now-defunct Cervelo Pharmaceuticals used in testing a drug for neuropathic pain, looking at interim data and modifying the doses was “quite a logistical nightmare,” says Marc de Somer, chief medical officer. Also, interim data must be evaluated by an independent data monitoring board, made up of people uninvolved in the study or the company. “It’s a tough pill for companies to swallow, putting decisions about a trial into the hands of totally independent bodies,” notes Bruce Turnbull, a biostatistician at Cornell University.
Still, the use of adaptive trials is definitely on the rise, though different experts offer varying estimates. A survey by Cytel—a biostatistical software company in Cambridge, Mass., which pioneered adaptive trial design—of trials conducted between 2003 and last year identified 59 companies that used the approach. “When we hit 2007, there was [something] like a step change—now people were really ready to try them,” said Judith Quinlan, a biostatistician at Cytel. Today, Berry guesses that more than one in 10 trials have some sort of interim data monitoring, while Stuart Pocock, a medical statistician at University College London, says the number of truly adaptive trials is significantly less than 1 in 10. (The approach is much more common in medical device trials.) Pocock notes that “nobody has the overall picture,” since trial details are generally kept confidential until it’s time to file with a regulatory body. According to O’Neil, about 40 or 50 drug trials using the approach have so far submitted filings for FDA approval.
Regardless of the adaptation, unblinding the data for an interim peek invariably brings up two problems for regulators. The first one is statistical in nature. Because statistics measure the likelihood, based on probability, that a treatment is effective, repeating a statistical test multiple times increases the chances that one test along the way will mistakenly show an effect where there actually is none, and companies will submit that false-positive data to the FDA. “If you’re always tweaking [the trial] to get the best result possible,” says Turnbull, “then you will get the best result possible.” There are statistical maneuvers to counteract that possibility, but they are far from straightforward, he explains.
The second concern is operational: When an adaptation to a trial takes place, will investigators and patients put two and two together to deduce clues about the therapy’s efficacy? “Let’s say we’re going to increase sample size, or drop certain arms,” Evans says. “Well, that adaptation could send a message to people involved in the trial that the effect isn’t what you’d expect it to be. If that then changes people’s actions—whether it be investigators or patients—then you’ve introduced a source of bias.”
By and large, adaptations in early-stage trials are not problematic. In fact, says O’Neil, “we think they’ve been underexplored” in that context. But regulators need much more convincing in Phase 3, or in Phase 2 trials that propose to morph directly into Phase 3 without the 6–9 months of analysis between the two steps. Proposals that include such seamless Phase 2/3 trials undergo intense regulatory scrutiny, which can offset whatever time you’ve gained from the adaptation.
And at any stage, the approach requires “a lot more prospective planning, a lot more complexity in design, and perhaps even more risk, in terms of will [the trial] turn out as you had planned,” says O’Neil. Every possible eventuality in the trial that may result in an adaptation must be thought through and documented in advance—a simulation exercise requiring an enormous amount of statistical resources that small companies generally don’t have in-house. “There are a lot of amateurs running around saying we should do this without understanding the statistics behind it,” Turnbull notes.
Some say that the pressures of efficiency push some companies to misuse it. One strategy Wittes has encountered is undersizing trials in order to bait investors, she says. A company that can’t afford to run a full trial might plan an adaptive trial that stipulates an “outrageously large” effect for their treatment and contains a built-in plan to increase subject numbers if this noncredible effect size isn’t met. “Then at some planned interim they look at the data and they say, ‘Oh, the observed effect size is smaller than anticipated.’” Still, that limited data can be used to lure investors to fund the larger trial. “What I worry about is that in part [adaptive design] has caught on because of business pressures,” Evans says.
For Cervelo’s de Somer, conducting an adaptive trial meant hiring Cytel to help plan the trial and determine what, if any, adaptations were appropriate, at the cost of $200,000 for a $10 million trial. “I think it’s an investment of a few months and a few hundred thousand dollars for a trial that costs at least 50 to 100 times more,” de Somer says. “Beyond the money, it’s probably worth it from an ethical and a regulatory perspective.”
Indeed, if done right, the approach has one benefit that’s hard to deny: It forces trial organizers to plan their studies carefully, whether or not they decide to make adaptations. “I think the by-product [of attempts to implement adaptive trials] is an appreciation of much more prospective planning in trials than we had even five years ago,” says O’Neil. Quinlan agrees. “The process itself is really the benefit of adaptive design,” she says. “Whether or not you choose to have an adaptive design, if you go through the process of evaluation of comparing it with a traditional trial, you’ll end up with a better trial.”