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483
19 Regulatory Considerations in Product Development for Back of the Eye
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should not be used during pregnancy unless the potential benefit justifies the potential risk to the fetus.
The BLA application for LUCENTIS™ contained clinical data from seven trials that investigated the pharmacokinetics and pharmacodynamics of ranibizumab in humans at doses ranging from 0.05 to 2 mg. All clinical trials were conducted using a bolus Intravitreal injection of the drug product in patients with neovascular ARMD. The primary endpoint was proportion of subjects losing < 15 letters of visual acuity and the secondary endpoints were the proportion of subjects gaining ³ 15 letters of visual acuity at 12 months, the mean change from baseline over time in visual acuity score, and the proportion of subjects with a Snellen equivalent visual acuity of 20/200 or worse. Clinically meaningful and statistically significant benefits were seen in the pri­mary endpoint at both 0.3
and 0.5 mg doses administered intravitreal over 12 months. Both doses were equally effective and showed a substantial benefit compared to control with the 0.5 mg dose providing a slightly better outcome in the proportion of subject gaining ³ 15 letters and the mean change in visual acuity score from baseline at 12 months. The ocular safety profile was favorable and key serious ocular adverse events appeared to be related largely to conjunctival anesthetic and intravitreal injection pro­cedures. Following the BLA application, LUCENTIS™ was approved in June 2006.
19.7 Summary
To date, regulatory guidance specifically geared towards the development of poste­rior segment therapies has not been issued. However, a good understanding of the standard drug product approval process, the various regulatory guidelines, and spe­cific ocular nonclinical and clinical programs provides a blueprint for success. Furthermore, a review of the summary basis of approvals (SBAs) for products that have been evaluated and approved by the FDA and/or other health agencies around the world is also helpful in comprehending the nature of these drug development programs. In addition, it is crucial that the sponsor interacts with the health authori­ties throughout the course of the drug development program to ensure that the pro­gram is on the right track for success. As we develop new and improved drug candidates for the treatment of various posterior ocular segment diseases with the help of cutting edge science, it is of utmost importance that we do so within the confines of each country’s ethics and regulation, and with the ultimate goal of improving patient health and quality of life, in sight.
References
Clark AF, Yorio T (2003) Ophthalmic drug discovery. Nat Rev Drug Discov 2(6):448–459 Draft FDA Guidance for Industry: Adaptive design clinical trials for drugs and biologics. Feb 2010
(http://www.fda.gov/downloads/Drugs/guidancecomplianceregulatoryinformation/guidances/
ucm201790.pdf)
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Draft FDA Guidance for Industry: Applications covered by Section
505(b)(2). Oct 1999 (http:// www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ ucm079345.pdf)
Drug Approval Package: LUCENTIS™ (Ranibizumab) Injection. Approval Date – 06/30/2006 Drug Approval Package: OZURDEX™ (Dexamethasone Intravitreal Implant). Approval Date
– 06/17/2009
Drugs @ FDA available on the FDA Website at
http://www.accessdata.fda.gov/scripts/cder/
drugsatfda/index.cfm
Edelman JL, Lutz D, Castro MR (2005) Corticosteroids inhibit VEGF-induced vascular leakage in
a rabbit model of blood-retinal and blood-aqueous barrier breakdown. Exp Eye Res 80(2):249–258
FDA Guidance for Industry, Content and Format of Investigational New Drug Applications (INDs)
for Phase 1 Studies of Drugs, Including Well-Characterized, Therapeutic, Biotechnology­derived Products, November 1995 (http://www.fda.gov/downloads/Drugs/Guidance­ComplianceRegulatoryInformation/Guidances/ucm071597.pdf)
FDA Guidance for Industry: Formal Meetings with Sponsors and Applicants for PDUFA Products.
Feb 2000 (http://www.fda.gov/cder/guidance/index.htm).
Ghodes DM, Balamurugan A, Larsen BA, Maylahn C (2005) Age-related eye diseases: an emerging
challenge for public health professionals. Prev Chronic Dis 2(3):A17
Gordon DM (1959a) Dexamethasone in ophthalmology. Am J Ophthalmol 48:656–660 Gordon DM (1959b) Dexamethasone in ophthalmic disorders. Ann N Y Acad Sci 82:1008–1011 Gryziewicz JL, Whitcup SM (2006) Regulatory issues in drug delivery to the eye. In: Intraocular
drug delivery, 1st edn
Gryziewicz L (2005) Regulatory aspects of drug approval for macular degeneration. Adv Drug
Deliv Rev 57(14):2092–2098
Lee SS, Robinson MR (2009) Novel drug delivery systems for retinal diseases: a review. Opthalmic
Res 41(3):124–135
Marra M, Gukasyan HJ, Raghava S, Kompella UB (2007) 2
nd
Ophthalmic drug development and
delivery summit. Expert Opin Drug Deliv 4(1):77–85
Chapter 20
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Clinical Endpoints for Back of the Eye Diseases
Karl G. Csaky
Abstract The development of new drugs and drug delivery devices for the treatment
of posterior eye diseases is critically dependent on the potential for that drug to be approved by the United States Food and Drug Administration (FDA). This approval process is predicated on the successful achievement of endpoints in large multi­center clinical trials. This chapter will discuss the history and evolving nature of endpoints for these clinical trials. Updates on recent novel endpoints will be discussed as well as the potential for the use of readouts from various imaging tools of the retina as FDA acceptable endpoints for clinical trials.
20.1 Background
For any new drug to marketed and sold in the United States, it must undergo exten­sive testing in clinical trials and ultimately be approved by the FDA. The FDA approves drugs based on adequate information that demonstrates both the drug’s efficacy and safety. While this authority derives from the Federal Food Drug and Cosmetic Act this law allows a large amount of discretionary power to the FDA to determine what standards a drug needs to meet for adequate safety and efficacy. While the FDA has established many standards for both these outcomes, the evolu­tion of medicine requires that many of these standards be continually reviewed and potentially updated. As will be noted below as new drugs for the treatment of retinal diseases are evaluated, approved and brought into clinical practice newer guidelines for approvability of a novel therapeutic evolve as well. This point as it pertains to therapeutics for retinal diseases will be discussed in this chapter.
K.G. Csaky (*) Sybil Harrington Molecular Laboratory, Retina Foundation of the Southwest, 9900 N. Central Expressway, Suite 400, Dallas, TX 75231, USA e-mail: kcsaky@retinafoundation.org
U.B. Kompella and H.F. Edelhauser (eds.), Drug Product Development for the Back of the Eye, AAPS Advances in the Pharmaceutical Sciences Series 2, DOI 10.1007/978-1-4419-9920-7_20, © American Association of Pharmaceutical Scientists, 2011
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The rate of development over the last 10 years of multiple therapies for retinal
diseases has been enormous. In contrast until the year 2000 therapies for the vast majority of retinal diseases were limited to either retinal or cryo-destructive procedures. While the approach using two modalities of treatment appeared restric­tive, the treatments were also recommended for use based on sound clinical trial data. For example, laser therapy had been demonstrated in elegant multicenter randomized clinical trials to be beneficial for diabetic proliferative retinopathy (1979), diabetic macular edema (1985), retinal neovascularization and macular edema associated with branch retinal vein occlusion (Finkelstein 1986) and choroidal neovascularization occurring in the setting of age-related macular degeneration (1991). In addition, cryotherapy had been demonstrated to prevent long-term vision loss in premature infants developing retinopathy of prematurity (1990). Interestingly, all of the above clinical trials were supported by the National Institutes of Health and utilized an approved medical device, laser photocoagulation, or cryotherapy. As such, additional FDA approval was not required to allow laser or cryo-therapy to be used in the above diseases.
20.2 FDA Endpoints
This background is important to understand the role that the FDA played in the development of therapies for retinal diseases. The concept of FDA approval was not part of the retinal lexicon until the advent of photodynamic therapy. However the numerous clinical trials that were undertaken prior to 2000 did set the stage for the requirements that were subsequently embraced by the FDA for drug approval for the treatment of retinal diseases. For example, the use of the binary outcome of the percentage of patients with a worsening of 15 or more letters was used as an end­point for the approval of verteporfin for neovascular age-related macular degenera­tion (1999) primarily based on the fact that 15 letters represents a doubling of the visual angle using ETDRS visual acuity testing. The ETDRS chart consisted of five­letter lines that have a geometric progression from line to line with every third line representing a doubling of the size of the letters. The ETDRS chart was developed for the Early Treatment and Diabetic Retinopathy study (Beck et al. 2007).
20.3 Endpoints for Neovascular Age-Related Macular Degeneration (Table 20.1)
The clinical trial for evaluation of the efficacy of verteporfin in neovascular AMD completed in 2000 was termed the TAP trial (Treatment of Age-Related Macular Degeneration with Verteporfin Therapy) and demonstrated that 61% of verteporfin­treated eyes compared to 46% of placebo-treated eyes had lost fewer than 15 letters
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Table 20.1 Endpoints for approved agents for neovascular age-related macular degeneration
Drug Primary endpoint Secondary endpoints Anatomic endpoints
Verteporfin 15 or more letter
loss rate
Pegaptinib 15 or more letter
loss rate
Ranibizumab 15 or more letter
loss rate
15 or more letter
gain rate
15 or more letter
gain rate
15 or more letter
gain rate; mean vision change
Growth of choroidal
neovascularization
Growth of choroidal
neovascularization
Size of choroidal
neovasularization, leakage
of visual acuity from baseline (1999). Subsequently, in 2004, the VISION trial demonstrated that the anti-VEGF agent pegaptinib reduced the rate of 15 letters of vision loss from 45% in the control group to 30% in the pegaptinib group (Gragoudas et al. 2004). And finally, in 2006, approval of ranibizumab was based on two clinical trials, the ANCHOR trial, for subjects with predominately classic choroidal neovas­cularization, and the MARINA trial, for subjects with minimally classic choroidal neovascularization. The FDA-mandated primary outcome was followed with the ANCHOR trial showing that 95% of ranibizumab-treated subjects compared with 65% of subjects in the verteporfin-treated group lost fewer than 15 letters (Brown et al. 2006). In the MARINA trial, 95% of ranibizumab-treated subjects compared with 62% of subjects in the sham-injected group lost fewer than 15 letters (Rosenfeld et al. 2006).
20.4 FDA Guidelines for Other Retinal Diseases
A vision endpoint is the most important determiner of the efficacy of a drug; how­ever, the strict guidelines imposed by the FDA for approvability while practical in diseases with the potential for rapid loss of vision such as neovascular AMD might not be easily applicable to other diseases such as retinal vein occlusion or diabetic retinopathy. Additionally once it was demonstrated that less than 5% of subjects with neovascular AMD lose 15 or more letters of vision while on ranibizumab, this endpoint became limiting for future trials in neovascular AMD attempting to improve on the efficacy of ranibizumab.
Thus in 2007, the National Eye Institute along with the FDA took part in a 2-day symposium discussing various issues related to clinical trial design and endpoints for retinal disease (Csaky et al. 2008). When considering the issue of valid end­points or clinical design issues a few terms require clarification. A biomarker, as defined by the Biomarkers Definitions Working Group, is “a characteristic that is objectively measured and evaluated as an indicator of normal biological processes, pathogenic processes, or pharmacologic responses to a therapeutic intervention.” In the discussion of valid endpoints, it is safe to say that biomarkers should be able to predict known endpoints and would then have their greatest value in serving as surrogate endpoints in clinical trials. A surrogate endpoint, then, is a biomarker that
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is “reasonably likely, based on epidemiologic, therapeutic, pathophysiologic, or other evidence to predict clinical benefit.” Therefore, the best surrogate endpoint is a biomarker that changes along with a clinical endpoint. The classic example of a valid biomarker that serves as an FDA-approved surrogate endpoint is the CD4 cell count. This biomarker, the CD4 count, has been demonstrated to change in response to an efficacious therapy for AIDS and thus serves as a surrogate endpoint. Additionally, a clinical endpoint, as defined by the Biomarkers Definitions Working Group is “a characteristic or variable that reflects how a patient feels, functions, or survives.” While a primary endpoint is defined as the main result that is measured at the end of a study to see if a given treatment works. The primary endpoint must always be chosen before a clinical trial begins. And finally, most relevant to clinical trials of the retina, is the term anatomic endpoint. This term refers to an anatomic feature that is measured at the end of a study to assess whether a given treatment works. While an anatomic endpoint might serve as the primary endpoint of a trial in retinal clinical trials, anatomic endpoints serve primarily to support the results of the primary visual clinical endpoint.
As mentioned above novel endpoints may be necessary in design of on-going and future clinical trials studying treatments for retinal diseases. One area that has received significant attention is the design of clinical trials for diabetic retinopathy. While newer agents are already in the clinic for neovascular AMD such is not the case for diabetic retinopathy. One of the issues has been the requirement of the FDA that all diabetic retinopathy trials be continued for at least 36 months. This require­ment is based on the observation in the Diabetic Complications and Treatment Trial that early results of a treatment for diabetic retinopathy may not predict outcomes at 36 months. Indeed within that DCCT, subjects in the intensive therapy group were noted to have a worsening of their retinopathy in the first 2 years but then remained stable while subjects receiving conventional therapy for diabetes worsened at a steady rate with a crossing of the outcomes from the intensive group at 2 years and then subsequent worsening at 3 years. However, recognizing that a 36-month clinical trial may be unduly burdensome to complete, the FDA did offer the possibility that effectiveness of a drug could be demonstrated in a 24-month trial. In this endpoint scenario a two-time point comparison with consistent slopes at both time points would have to be demonstrated. In other words, the two time point comparisons would have to be numerically noninferior with clinical and statistical superior differ­ences at 24 months when compared with the original baseline (Csaky et
al. 2008). This approach would have special importance for evaluations of therapies for diabetic macular edema. Indeed, recently it was announced that two trials evaluating the ability of an injectable nonerodible polymer containing fluocinolone acetonide (Iluvein) for diabetic macular edema has demonstrated success in attaining the endpoint of the percentage of patients with improved visual acuity of 15 or more letters at month 24 (Alimera Sciences Press Release Dec 23 2009). As required by the FDA, the study will continue for an additional 12 months beyond the primary endpoint to assess further measures of both efficacy and safety.
Another point of potential endpoint adjustment by the FDA would be clinical
trials designed to evaluate therapeutic agents for proliferative retinopathy. In the
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NEI/FDA symposium the FDA raised the possibility that clinical trials for neovascular diabetic subjects may be able to utilize an anatomic endpoint, the development of retinal or disc neovascularization, as a primary endpoint. This anatomic outcome was determined as a possibility because there exists a plethora of data that has demonstrated that the onset of retinal neovascularization invariably is associated with loss of vision. As such, trials utilizing the development of neovascularization as an endpoint might be acceptable (Csaky et al. 2008). This could well enhance the ability to bring drug to the markets that target the angiogenic process in diabetic retinopathy.
20.5 Endpoint for Geographic Atrophy
Another disease for which therapeutic agents are in clinical trials is geographic atrophy secondary to age-related macular degeneration. This disease represents another example where the potential for a more attainable endpoint would allow for the evaluation of novel therapeutics for a disease. As the natural history of geo­graphic atrophy is one of slow deterioration the endpoint most accepted by the FDA, the percentage of subjects with a 15-letter vision loss, would have required trials lasting many years. However in consultation with experts, it became clear that loss of retinal tissue is always considered a bad outcome regardless of the immediate effect on vision. Therefore, the FDA is now considering the loss of retinal tissue as a primary endpoint for trials studying geographic atrophy (Csaky et al. 2008). However, determination of the proper imaging modality to best evaluate the extent of retinal tissue loss remains elusive with on-going studies determining the repro­ducibility and reliability of fundus photography, fundus autofluorescence (Fleckenstein et al. 2010), and spectral domain optical coherence tomography.
20.6 Endpoint for Retinal Vein Occlusion
And finally in the story of evolving endpoints comes to the development of novel therapeutics for retinal vein occlusion. As no effective treatments for central retinal vein occlusion existed, including laser, the FDA reviewed trial designs for this disease and determined that a novel endpoint, time to achieve a 15 letter or improve­ment in best-corrected visual acuity, could be used. This decision allowed for a much shorter time frame for these clinical trials to occur. As a result a novel bioerodible polymer liberating dexamethasone (Ozurdex®) was approved (Haller et al. 2010). For the evaluation and subsequent approval of ranibizumab for the treatment of retinal vein occlusion, the FDA allowed for a comparison of mean change from baseline in best-corrected visual acuity at 6 months. Indeed, in the ranibizumab trial for branch retinal vein occlusion, 61% of subjects receiving monthly ranibizumab, compared with 29% in the sham injected arm, gained 15 or
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Table 20.2 Endpoints for approved agents for retinal vein occlusion
Disease Trial Primary endpoint
Neovascular AMD ANCHOR, MARINA Rate of 15 or more letter loss rate Retinal vein occlusion BRAVO, CRUISE Mean change in visual acuity from
baseline to 6 months
Retinal vein occlusion GENEVA Time to 15 or more letter gain
more letters at 6 months (Genentech Press Release June 22 2010). In subjects with central retinal vein occlusions, 48% of subjects receiving monthly ranibizumab, compared with 17% in the sham injected arm, gained 15 or more letters at 6 months (Genentech Press Release June 22 2010) (Table 20.2).
20.7 Future Endpoints
Many new technologies (e.g., spectral domain optical coherence tomography (SD-OCT), fundus autofluorescence) are allowing retina specialists to image the retina in ways never before possible. Detailed topographic and anatomical scans can provide high-resolution images of cross-sections of the retina. In many cases, accompanying software allows for the generation of 3-D reconstructions, topo­graphic analyses, and more precise macular thickness measurements including quantitative segmentation of various layers of the retina (Oster et al. 2010). While providing clinical information to physicians, these instruments also have the poten­tial to provide data that might serve as endpoints in clinical trials (Browning et al.
2009). For example, as described earlier the degree of retinal tissue loss seen in
geographic atrophy is now being considered as a valid endpoint for trials evaluating therapies for geographic atrophy (Csaky et al. 2008). In the case of geographic atro­phy this is critical because the progressive loss of retinal tissue in geographic atrophy does not always immediately involve the fovea (Sunness et al. 2008) so there may be no initial direct effect on the visual acuity. However, the FDA appreci­ates that loss of macular retinal tissue is a bad outcome and therefore this agency would consider approving agents that slow this tissue loss without requiring that a direct effect on visual acuity be demonstrated. However, as with all new imaging technologies, the questions that are raised focus on what the imaging tool is actually demonstrating. For example, Fig. 20.1 demonstrates a fundus autofluorescence image of a patient with geographic atrophy. The central dark spot is thought to be due to loss of autofluorescence from the retinal pigment epithelium (Sunness et al.
2006). However, it has been demonstrated that in some cases of diminished retinal
autofluorescence the retinal pigment epithelium and overlying photoreceptor are viable and it is simply the loss of autofluorescent pigment with the retinal pig­ment epithelium that is responsible for the diminished autofluorescent signal (Brar et al. 2009; Schmitz-Valckenberg et al. 2010). Therefore, it may very well be that additional confirmatory imaging of the retina by SD-OCT (Fig. 20.2) will be
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Fig. 20.1 Fundus autofluorescence of a patient with extensive geographic atrophy demonstrating
a central area of decreased autofluorescence and surrounding normal pigment epithelial autoflourescence
Fig. 20.2 Spectral domain optical coherence tomography of a subject with geographic atrophy
demonstrating loss of photoreceptors (arrows) and pigment epithelium (asterisk) but maintained retinal structures in the surrounding areas (arrowheads) (IR inner retina; PR photoreceptors; IS/OS inner segment/outer segment junction; RPE retinal pigment epithelium; Chor choroid)
required to confirm loss of retinal tissue as demonstrated by standard retinal autofluorescence.
Another problem with the use of anatomic imaging tools and that changes that
are seen and measured on the above instruments are not always correlated to visual
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function. Measures of anatomic changes are already being used to support an indication of a treatment effect, but data to date suggests a poor correlation with many aspects of OCT measurements and visual acuity (Fleckenstein et al. 2010). Therefore, it is not clear how and when OCT findings will be used as a surrogate outcome for visual function. But as these new imaging modalities are further tested alternative anatomic measures, such as integrity of the inner segment/outer segment junction, may prove to be more precise predictors of visual acuity (Oster et al.
2010). The future of these more rapidly measurable endpoints portends an exciting
future for the development of treatments for retinal diseases.
References
Alimera Sciences Press Release Dec 23 (2009) Alimera Announces Positive Results from the
Two Phase 3 Fame™ Trials of Iluvien
alimerasciences.com/News/2009PressReleases/tabid/106/ItemID/48/Default.aspx
Anon (1979) Four risk factors for severe visual loss in diabetic retinopathy. The third report from
the Diabetic Retinopathy Study. The Diabetic Retinopathy Study Research Group. Arch Ophthalmol 97:654–655
Anon (1985) Photocoagulation for diabetic macular edema. Early Treatment Diabetic Retinopathy
Study report number 1. Early Treatment Diabetic Retinopathy Study research group. Arch Ophthalmol 103:1796–1806
Anon (1990) Multicenter trial of cryotherapy for retinopathy of prematurity. One-year outcome–
structure and function. Cryotherapy for Retinopathy of Prematurity Cooperative Group. Arch Ophthalmol 108:1408–1416
Anon (1991) Subfoveal neovascular lesions in age-related macular degeneration. Guidelines for
evaluation and treatment in the macular photocoagulation study. Macular Photocoagulation Study Group. Arch Ophthalmol 109:1242–1257
Anon (1999) Photodynamic therapy of subfoveal choroidal neovascularization in age-related mac-
ular degeneration with verteporfin: one-year results of 2 randomized clinical trials–TAP report. Treatment of age-related macular degeneration with photodynamic therapy (TAP) Study Group. Arch Ophthalmol 117:1329–1345
Beck RW, Maguire MG, Bressler NM, Glassman AR, Lindblad AS, Ferris FL (2007) Visual acuity
as an outcome measure in clinical trials of retinal diseases. Ophthalmology 114:1804–1809
Brar M, Kozak I, Cheng L, Bartsch DU, Yuson R, Nigam N, Oster SF, Mojana F, Freeman WR
(2009) Correlation between spectral-domain optical coherence tomography and fundus auto­fluorescence at the margins of geographic atrophy. Am J Ophthalmol 148:439–444
Brown DM, Kaiser PK, Michels M, Soubrane G, Heier JS, Kim RY, Sy JP, Schneider S (2006)
Ranibizumab versus verteporfin for neovascular age-related macular degeneration. N Engl J Med 355:1432–1444
Browning DJ, Apte RS, Bressler SB, Chalam KV, Danis RP, Davis MD, Kollman C, Qin H, Sadda S,
Scott IU (2009) Association of the extent of diabetic macular edema as assessed by optical coherence tomography with visual acuity and retinal outcome variables. Retina 29:300–305
Csaky KG, Richman EA, Ferris FL 3rd (2008) Report from the NEI/FDA Ophthalmic Clinical
Trial Design and Endpoints Symposium. Invest Ophthalmol Vis Sci 49:479–489
Finkelstein D (1986) Argon laser photocoagulation for macular edema in branch vein occlusion.
Ophthalmology 93:975–977
Fleckenstein M, Adrion C, Schmitz-Valckenberg S, Gobel AP, Bindewald-Wittich A, Scholl HP,
Mansmann U, Holz FG (2010) Concordance of disease progression in bilateral geographic atrophy due to AMD. Invest Ophthalmol Vis Sci 51:637–642
®
in Patients with Diabetic Macular Edema. http://www.