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Development of a Consensus Document as a
Supporting Document for FDA and Other Health Regulatory Authorities on
Health-Related Quality of Life Guidances
Since ISPOR membership represents both producer and
the user of outcomes research information, the Society has a unique role in
facilitating the translation of outcomes research into practice.
ISPOR is developing a supporting a document which
can be used by the FDA and other health regulatory authorities in the
development of guidances for health-related quality of life claims for labeling
and promotion of drugs, biologicals, and devices. This ISPOR initiative is part
of an ongoing consensus development process to identify contentious outcomes
research issues, develop discussion points, points of concurrence, points of
controversy, and recommendations to these issues.
Quality of Life Regulatory Guidance
Supporting
Document Development Process:
January, 1999, ISPOR leadership (Robert Epstein MD,
MS, Bryan Luce PhD, and Marilyn Dix Smith RPh, PhD) met with the FDA (Laurie
Beth Burke RPh,MS, DDMAC staff and members of the FDA HRQL Work Group) to
identify quality of life labeling and promotional claims issues.
A paper published in Value in Health,
Vol. 2, No. 2 (March/April 1999), pp 113-127 titled
‘Recommendations for Evaluating the Validity of Quality of Life Claims for
Labeling and Promotion’ by Nancy Leidy PhD, Dennis Revicki PhD, and Bernard
Geneste, was used as a basis of discussion at meetings with the FDA and ISPOR
leadership. For a copy of this issue see:
http://www.ispor.org/valueinhealth_index.asp.
The health-related quality of life claims issues
regarding labeling and promotion of drugs, biologicals, and devices issues given
below were identified.
An ISPOR Ad Hoc Quality of Life Guidance Committee
commented on these issues. Committee members were Catherine Acquadro MD (MAPI
Research Institute, Lyon, France, representing the ERIQA Group, responders:
Professor Ingela Wiklund and Steven Fullerton, Astra Hässle Quality of Life
Research, Mönldal, Sweden), Stephen Coons PhD (The University of Arizona,
Tucson, Arizona), Pennifer Erickson PhD (O.L.G.A, State College, PA), Paul Kind
PhD (University of York, York, England), Eva Lydick PhD (SmithKline Beecham,
Collegeville, PA), and Jane Osterhaus PhD (G.D. Searle, Skokie, IL). Louis
Morris PhD (PRR INC, Melville, NY) and Robert Epstein MD, MS (Merck-Medco
Managed Care, Montvale, NJ) summarized the committee comments.
Quality of Life Promotional and Label Claim Issues for Drugs,
Biologicals, and Devices
Issue
1: Terminology
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Do we need to use the term ‘quality of life’ for labeling purposes? While it is
in the vernacular today, most measures stem from health status assessments, and
this may be a more accurate description of the measures.
Issue
2: Stand-alone claims
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Can a study that is powered solely to detect QoL be enough for
labeling/promotion when there is not enough power to detect a (secondary)
clinical endpoint?
Issue 3: Safety
Issue 3a: Should QoL be a substitute for adverse events (AE) reports?
Issue 3b: When does a question inside a QoL instrument trigger AE
reporting?
Issue 3c: Can one ‘drop’ a QoL question if it would be the type to trigger
AE reporting?
Issue 4: Domains
Issue 4a: Three domains are useful, but is there concurrence that these
three are it (i.e. physical, psychological, social)?
Issue 4b: How does satisfaction play in - or is that not a part of QoL?
Issue 5: Side-effects
Issue 5a: Are side-effects part of QoL assessment or separate?
Issue 5b: Should a QoL questionnaire ask about how drugs effect QoL - or
should this be disease-specific only?
Issue 6: Clinical trial administration
Issue 6a: Should there always be a generic and disease-specific
questionnaire used in clinical trials?
Issue 6b: How does one ensure follow-up on treatment protocol
violators/drop-outs for QoL measurement?
Issue 7: Timing / administration of measurement
Issue
7a: What is the appropriate time frame for the measures to be collected?
Should it correspond to when clinical measures are obtained - more frequently or
less - if it’s a chronic drug, is 6 weeks long enough, etc?
Issue 7b: Should the questionnaires be administered at the beginning of
clinic visits or after the patients have already had other tests done?
Issue 7c: Should the respondents see their prior answers?
Issue 8: Blinding
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Under what circumstances could results from an
unblinded evaluation ever be used for marketing or promotion?
Issue 9: Development
Issue 9a: Can an instrument be truly valid if it is comprised of a
battery of scales that an investigator put together without patient input?
Issue 9b: What could be the rationale or the validation associated with a
battery-of-scales approach?
Issue 10: Evidence of proper development and validation
Issue 10a: What is needed to be submitted with CT data to FDA?
Issue 10b: How much correlation should there be between QoL measures and
clinical measures?
Issue 11: Responsiveness
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Should responsiveness be proven prior to a
clinical trial being undertaken — or, if discovered in the trial, is this good
enough?
Issue 12: Clinical significance
Issue 12a: How is clinical significance determined?
Issue 12b: Should a trial be powered to detect clinical significance
up-front?
Issue 12c: If a difference is found to be statistically significant but it
is not ‘clinically significant’ - can a claim be filed?
Issue 13: Statistical analysis
Issue 13 a: What is the role of summary scores across domains vs domain
specific?
Issue 13b: Should QoL be analyzed with intention-to-treat and per-protocol,
like all other endpoints?
Issue 13c: Should missing data be handled the same way it is handled in
symptom scores?
Issue 13d: Is there any circumstance where a different p-value could be
used (eg.10)?
Issue 13e: How many clinical trials to support a label claim - one vs two?
Issue 13f: Why should QoL endpoints be statistically treated differently
than clinical endpoint (i.e. multiplicity)?
Issue 13g: Under what circumstances can a claim be filed for equivalence?
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