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Reference - controlled observational studies - a new tool for post marketing studies and for evaluation of preventive measures
Several limitations of controlled clinical trials in phase-III drug research (e.g., highly selected patients, limited size of trials) make it mandatory to perform extensive research also in the post marketing phase. It is proposed to enhance the achievable evidence on therapeutic effects from large observational studies by designing small nested randomized trials. In contrast to the "comprehensive cohort studies" which have been discussed several years ago [25, 26], this combination of observational and experimental studies is planned in advance and does not result from patients compliance with the idea of randomization. One important feature of the proposed approach is an identical core documentation of relevant variables in the observational study and in the nested trial. The evaluation of the combined studies can partly be based on methods which have been developed for the analysis of epidemiological studies (validation studies, correction of measurement errors, nested designs). The evaluation includes
For comparisons of efficacy within and between the studies the aspect of equivalence is of special importance. Strengths and limitations of the proposed approach which e. g. cannot replace randomized "mega trials" are discussed. |
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| Introduction Randomized clinical trials (RCT) are indispensable in phase-III-drug research in order to obtain solid information on efficacy and safety before a new drug may be marketed. For good reasons (e. g. safety, good observability of effects, self determination of patients) mostly only highly selected patients are enrolled in RCTs. This fact constitutes an essential need for phase-IV drug research. [1-4] One element of phase-IV research is the conduct of large observational cohort studies (OCS) which are called in Germany "Anwendungsbeobachtungen". These studies are performed in order to observe efficacy and potential side effects of new drugs under everyday conditions and with a minimum of intervention. In contrast to RCT, OCS typically include patients from more extreme age groups, patients with comorbidity or other risk factors. In order to cover a wide spectrum of patients and to observe rare events with sufficiently high probability, OCS enroll a large number of patients, typically several thousands. Due to the size of an OCS and due to its non-interventional character, it is often necessary to observe the therapeutic effect by using a cheap and preferably non invasive method which may provide less valid results than an optimal available method ("gold standard"). It is the aim of this paper to discuss an approach which may be suited to enhance the achievable evidence from OCS. This goal can be reached by integrating a RCT into an OCS - thus constituting a reference-controlled observational cohort study (RCOCS). The nested RCT allows investigators to
The validation approach may also be used for the assessment of observed effects
obtained by using surrogate markers in an OCS on the efficacy of preventive measures. Design and conduct of a reference-controlled observational study (RCOCS) It is proposed to integrate a standard RCT (sample size about 100 to 200 patients per treatment group) into a large OCS (usually several thousand patients). If the OCS is treatment oriented, i. e., it aims to collect observations on a single drug, the nested RCT would be placebo-controlled if this is ethically justified. If the OCS is indication oriented, i. e., if it aims to compare observed effects of several drugs, randomizing in the nested RCT would relate to these drugs. It is an important feature of the RCOCS that for the OCS and for the nested RCT an identical documentation of core information is performed. The core documentation has to be kept as small as possible and usually includes the following items:
If necessary for a validation study, additional items may be documented in the nested RCT, e. g. results of advanced or invasive diagnostic procedures. These additional items may be needed for the observation and assessment of outcome criteria and/or relevant covariables (e. g. baseline variables, confounders, effect modifiers). Dose regimens for the drugs of interest and the sequence of examinations during the course of the study should be identical for the nested RCT and the OCS. Medical inclusion criteria for patients enrolled into the nested RCT may be less restrictive than in phase-III studies and should, therefore, generally be comparable to the patients observed in the OCS. However, the spectrum of indications and relevant covariables may still be wider in the OCS than in the nested RCT. Therefore, a careful and identical documentation of the corresponding items is needed in order to perform an adequate evaluation (see next section). For reasons of observational comparability it would be desirable that the same physicians treat patients within the OCS and the nested RCT. However, for practical reasons (see discussion) this is presently not suggested. Conventional separate analysis of the OCS and the nested RCT In a first step of evaluating the results from a RCOCS, standard analyses of the OCS and of the nested RCT are performed. In addition, within the OCS a subgroup of patients should be identified who are - by means of baseline values - well comparable with the patients enrolled in the nested RCT. This identification may be achieved by a n:m matching on relevant variables. A separate evaluation of the observations from the above defined subgroup should be compared with the evaluation of the remainder of the OCS. If the result of the nested RCT is negative, e. g., if a statistically significant or medically relevant treatment efficacy cannot be demonstrated, it has to be decided whether it is useful to carry on with further analyses. This will depend on careful comparisons with results from the preceding successful RCT in phase III. Validation study If outcome measures or determination of relevant covariates are obtained by additional, more valid techniques in the RCT, a validation study has to be performed. The basic idea of this approach is to correct imprecise observations in the OCS by using information which is gained from parallel measurements /observations within the nested RCT. The corresponding statistical techniques are well known - although, unfortunately, less frequently applied! - in the epidemiological literature. Adequate methods have been proposed for qualitative and quantitative variables, for the correction of outcome measures and confounders, for univariate and multivariate situations. For further details see e. g. [5] to [23]. Therefore, there is a wide spectrum of methods which can be applied to the clinical studies. If an outcome measure in the OCS is effected by nondifferential misclassification, the observed effects in the OCS will increase by the use of correction terms, however, the corresponding confidence intervals will generally be enlarged. The same validation techniques may also be considered for evaluating the efficacy of a preventive measure in an OCS by means of surrogate markers if both the surrogate marker and definite endpoints are observed in a nested RCT. Assessment of efficacy If a significant therapeutic effect is observed in the nested RCT, the next step is to compare this result with the analysis in the corresponding subgroup of the OCS described before, with or without correction by a preceeding validation as described in the previous paragraph. The comparison may be performed in descriptive terms, e. g. by describing mean values or rates of observed effects and their corresponding confidence intervals. The comparison of observed effects in the RCT and the OCS can also be performed by using formal statistical tests on therapeutic equivalence [24]. However, the corresponding test results cannot be used with the same strength as within an ordinary RCT. If the observed effect in the OCS is smaller than in the RCT one may conclude that under everyday conditions the drug is not as effective as within the setting of the controlled clinical trial and one may look for possible reasons for such differences (e. g. differences in compliance). If the observed effect in the OCS is more pronounced than in the RCT, this may be attributable to a placebo effect (since all patients in the OCS are informed that they receive an effective drug) or to a too "optimistic" assessment by the treating physician. When the interpretation of the observed effect in the subcohort of the OCS is not clear, it will also be difficult to interpret the results of the complete OCS. If the effects in the RCT and the OCS are equivalent, it may be concluded that observation of effects in both studies is well comparable and one may proceed with the next step. In the next step the comparison of observed effects between OCS and the nested RCT can be extended to the remainder of the OCS. The result of this comparison may be judged in relation to the comparison within the OCS mentioned before. Once again, this comparison may be performed by using descriptive or analytical statistical techniques. If the observed effects in the remainder of the OCS are both equivalent with the ones
observed in the subcohort and in the RCT, one may conclude that the results from the RCT
may be generalized to a wider population similar in structure to the OCS. If the observed
effects differ between the different subcohorts of the OCS this may lead to additional,
confirmatory trials and/or to specific recommendations regarding the use of the drug (e.
g. if it appears to be less effective in elderly patients). At the time of marketing approval of a new drug, the clinical information is still limited. Therefore, additional research is needed in the post marketing phase (phase IV). There is both a need for additional randomized trials, sometimes for "mega trials", and also for observational studies. In order to enhance the achievable evidence from an observational study, combining it with an experimental study is proposed. In order to obtain valid information from this new type of study, it is important to provide good observational comparability of the different study populations. This can be achieved by a study design which has identical treatment regimens and identical case documentation. In order to have simple protocols for the physicians and not to complicate the recruitment of patients for the OCS and the nested RCT, it is preferable that both elements of the RCOCS are performed by different groups of physicians. In order to obtain comparable observations it is important to standardize the instructions for performing the clinical observations and the related documentation. Due to the non interventional character of the OCS this part of the RCOCS has to determine the procedures for the nested RCT. In general, it cannot be ruled out that the fundamental difference between an experimental study (one has only to think of the need to obtain informed consent) and a non-intervening observation may be associated with a difference in observable effects. However, the non experimental drug treatment is in essence the situation for which we need valid information. Therefore, it is necessary to direct scientific research to this situation. The identical core documentation of relevant variables allows investigators to check whether systematic differences between the baseline variables of patients in the OCS and the nested RCT have occurred. The proposed selection of a comparable subset of patients from the OCS should in any case provide a basis for valid comparisons. However, it has to be judged carefully, whether and how the observations from the remainder of the OCS may be generalised. This will depend on the consistency of the observed effects, sometimes also on plausible inconsistencies, e. g. different effects in different age groups. If the nested RCT is placebo-controlled, the size of the placebo effect may be smaller than in the OCS since the patients in the RCT are informed that they may receive a placebo whereas all patients in the OCS are informed that they will be treated with an effective drug. The proposed equivalence tests for comparing the observed effects in the OCS and the nested RCT may be used for descriptive purposes only. However, this kind of application which has less strength than would be obtainable from comparisons of randomized groups, may lead to useful and valid information. The RCOCS may be compared with other techniques which have been proposed for similar purposes. Olschewski et al [25,26] have described the "comprehensive cohort study" (CCS). This was a proposal to follow up patients who refused participation in a randomized trial but were treated with the same drugs as used in the corresponding trial. Although the statistical evaluation techniques described for the CCS may also be used for the RCOCS, there is a fundamental difference between the two approaches: Whereas the nested RCT in the RCOCS is defined by design, the observational part of the CCS results from the decision of the patients and thus may be influenced by more kinds of potential biases. In order to maintain this advantage of the RCOCS patients who refuse to take part in the RCT should not be enrolled for the OCS. Other proposals for phase IV research relate to the use of routine data from
doctors office computers or to the use of available databases, e.g. from an
insurance company or HMO. However, this kind of data seems to be less valid than data from
a carefully planned and designed RCOCS, since data from doctors offices lack
systematic, coherent documentation. The reference controlled observational cohort study is a new tool for phase IV drug research. It may combine positive elements of experimental and observational studies in the postmarketing phase of a drug and thus may be specially suited to enhance the achievable evidence from observational cohort studies.
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