Regulatory Strategies in Real-life Product Development
Statistical significance does not always mean clinical significance; clinical significance does not always mean significance for medical practice.
–Bert Spilker
One of the tests of leadership is the ability to recognize a problem before it becomes an emergency.
–Arnold H. Glasgow, author.
HOW DOES A COMPANY REFER TO EACH PRODUCT IT IS DEVELOPING?
At the simplest level, most readers would answer that they are developing a drug, medical device, biological, or diagnostic product. While these designations are literally correct, the premise of this chapter is that they are often not the best way to refer to an investigational (or even marketed) product. In paying more careful attention to what you call the type of product you are working on, a greater sense of the product’s value may be created, potentially yielding great commercial dividends. The author stresses that this chapter is not referring to the trade name or generic name you choose subject to negotiation with the relevant agencies for a product, but rather to the function of the product.
To illustrate this point, here are examples of terms other than “drug” that could be used to describe your product. Obviously, the terms that could be chosen for a specific product will depend on its function and properties.
Enzyme replacement (note that an enzyme replacement does not have to be an enzyme)
Hormone or hormone replacement (currently this has a negative connotation)
Essential nutrient or essential mineral
Physiological replacement
Part of a preparative regimen
Diluent
Antidote
Immunological stimulant
Natural metabolite or antimetabolite
Natural substance (i.e., something that is found in the body or in nature)
Wound dressing
Enzyme inhibitor
Naturally occurring protein
Monoclonal antibody
Adjunct
There are several reasons why this approach often makes sense. First, ask yourself if you, as a patient, physician, regulatory agency, reimbursement agency, or pharmaceutical marketing department, would rather use, prescribe, approve, pay for, or market a drug or a product that is described both functionally and accurately as previously listed. Functional descriptors give a more positive feeling about the need and value of the product than does the bare term drug. Even the term medicine has much better connotations than “drug,” given the widespread use of the term drug, referring to illegal use and abuse. It is rather surprising that the term medicine is not more widely used.
If you worked in a regulatory agency, wouldn’t you expect to want to facilitate the development and approval of an enzyme replacement more than a “drug” to treat the same disease? The term replacement suggests physiological dosing to replace what is missing, and the author thinks that most of us would tend to accept a smaller dossier for that type of product compared with a “drug” to treat the same problem.
When a marketing department promotes a product through medical literature, advertisements, or exhibits at a professional meeting, they usually describe the product in terms of its functions (i.e., reduces X or improves Y). The marketing message to healthcare professionals would be enhanced if it included such phrases as “X (brand name) acts as an enzyme replacement,” or “X is an essential nutrient,” or “X is part of the chemopreparative regimen.” Of course, some drugs are approved with those terms, but many more could be, and this would both improve the image of the product and possibly lead to increased revenue.
Interactions with regulatory authorities are also likely to be facilitated if the medical value of a product is established early in development and the company refers to its product with one of the functional terms rather than as a drug. In addition, it is useful to refer to the product by its functional term each time it is mentioned in communications between the agency and company. In these ways, by using the specific functional name, it is possible that the connotations of the functional name may facilitate interactions with the agency, which is always a highly desirable goal.
LEAN REGULATORY SUBMISSIONS ARE BETTER THAN FAT ONES: BUT NOT TOO LEAN
A company mantra one often hears is “We are creating a lean-and-mean development plan to get this product to the market as soon as possible.” In other words, the company seeks to have its regulatory submission completed as rapidly as possible by submitting the absolute minimum quantity of data.
Unfortunately, that approach often fails, particularly if the magnitude of the development plan has not been agreed to by the regulatory agency. One would think that senior company executives would not make unilateral decisions to bypass the critical step of seeking regulatory endorsement of a lean plan, but that is exactly what often happens. This may result from executive naiveté or ego, or it may reflect pressures from more senior staff or boards of directors to push an ill-conceived and unrealistic plan.
The author has seen cases where a company, having had their “lean-and-mean” New Drug Application (NDA) plan rejected at a pre-NDA meeting, immediately adopted the opposite strategy for developing the next drug. In the latter plan, the company tried to collect enough data to address almost any question that a regulatory agency could possibly throw at them. This “fat” NDA approach is also fraught with many problems. First, there are many opportunities to uncover issues that may not be real but that must then be examined in additional clinical trials. This leads to long delays in the program on top of the delays caused by conducting a program that contains unnecessary studies in the first place. In addition, the mountain of data collected must be entered into computers, analyzed, interpreted, and then written up as final study reports, adding further delays to development.
Determining the Optimal Size of a Development Program
The optimal size of a development program must flow from decisions on how best to design it. The eventual magnitude of a particular program will depend on the nature of the product and the indications chosen, its medical value, and the strategy adopted. For example, the size of a program will depend on whether there is a scientific and medical need in the investigational period for studies such as pharmacokinetics, safety, and efficacy in the elderly or other populations (e.g., males versus females, ethnic groups, hepatic or renal failure patients, immunocompromised), quality-of-life trials, and pharmacoeconomic trials. Many other factors are likely to play a role in influencing the magnitude of the development program, particularly issues and problems encountered during development and how they are to be handled.
Some of the important factors to consider in creating the optimal size of any development plan include:
Image and culture of the company. What is the corporate comfort zone for risk of failure? What are the reputation, experience, and image of the company at the regulatory agency?
What are the medical alternatives already available on the market, and how safe and effective are they? Once a novel drug is marketed that works via a new mechanism, a follow-up product that works via the same mechanism usually needs the same number or fewer patients to determine its efficacy. But, on the other hand, because a similar product is already marketed, a larger number of patients is often required to establish a higher standard of safety, unless of course the original drug has a serious safety issue. In a situation where the second drug does not have the same safety problem as the competitor, the number of patients required by the agency may be fewer, although it will probably take more patients to demonstrate that the second drug is in fact safer and at least as effective.
How serious is the disease, and what is the current level of morbidity and mortality?
How many patients are likely to be exposed to the drug? Is it for a rare or common disease?
How many indications and/or dosage forms need to be developed simultaneously, and which ones should be submitted first for approval?
Are there any ethnic or geographic influences on the efficacy, safety, and use of the drug?
How much off-label use is likely to occur, and what are the medical and commercial issues and potential problems with that use?
How easy is it to recruit and retain patients in the planned clinical trials? If this could be a problem (e.g., because most patients are already adequately treated), how will it be addressed (e.g., with combination products, use in patients who have failed other therapies, locate untreated patient populations in India or China)?
What is the overall medical value of the product? (This concept is discussed in several chapters of this book.)
How complex or straightforward is it to demonstrate efficacy?
For any particular drug, there is likely to be a number of additional factors (e.g., the raw materials needed to make the drug may be in short supply, and it is unlikely that any steps can be taken to resolve this issue). These factors could limit the number of patients who are able to be included in clinical trials and also the duration of those trials, as well as limit any long-term extensions and possible compassionate use trials after the initial trials are completed.
Factors Influencing the Magnitude of Clinical Development
A fat or lean development plan does not reflect solely the number of clinical trials and patients in an NDA. The number of patient visits, for example, can vary widely in most chronic treatment clinical trials lasting several months or longer. The number of tests conducted at some or all visits often varies widely, depending on (among other things) biases of the author of the protocol; in addition, there is an increasing tendency to have “procedure bloat,” when protocol writers simply add on some tests to the last protocol the company used. Also, the number of times a laboratory or vital sign test is repeated can add large amounts of information that has to be processed, as well as additional cost.
The number of sites used in a trial can readily exceed what is necessary, adding further to the amount of monitoring visits, paper work with Institutional Review Boards, and legal contracts. Some companies purposely enroll more sites because they believe (rightly) that some will not be able to meet their enrollment goals. However, this and other site-related activities (e.g., too little or too excessive monitoring, site auditing, project team meetings, preparation of detailed minutes of all meetings) all add to the weight that slows development. The time taken to review some of these activities by managers can become a drain, as does having to read unnecessary e-mails and drafts of minutes. Whether the clinical trial sites are spread among many countries in a multinational trial, versus conducting a smaller number of one-country trials, is another aspect that may easily affect the speed of a drug’s development.
One further point to note is that some data can be obtained from an add-on amendment to an ongoing trial, rather than initiating an independent trial (e.g., pharmacoeconomic, quality of life, and pharmacokinetic data can often be obtained as add-ons to other trials rather than as free-standing trials). This possibility should be reviewed in all cases before starting an independent trial to study one of those areas.
Paying careful attention to the amount of data collected can help minimize what could become a collection of unnecessary data that slows development.
TYPES AND USES OF META-ANALYSES
After one has read a number of meta-analyses in respected medical journals, it is easy to think that there is a single standard for these analyses, or at least a single gold standard. In this type of analysis, publications of clinical trials that meet certain standards and criteria are identified in the literature using standardized search methods, and then the data from those articles (along with any relevant unpublished reports or other data obtained) are combined and analyzed using standard statistical tests. Using confidence intervals as a guide to help understand statistical significance of the individual trials, it is often possible to gain insight from the combination of trials in order to address an important research question. This is the most common type of meta-analysis performed, but other types are also possible. This section focuses on some of these other types of meta-analyses and some of their regulatory uses.