new pathways for evaluating potential acute stroke therapies
TRANSCRIPT
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View point
New pathways for evaluating potential acutestroke therapies
Marc Fisher�1, Kenneth Cheung2, George Howard3, and Steven Warach4
Abstract Pharmacological therapy for acute ischemic stroke
remains limited to one successful, approved treatment: tissue
plasminogen activator within 3 h of stroke onset. Many
neuroprotective drugs and a few other thrombolytics were
evaluated in clinical trials, but none demonstrated unequi-
vocal success and were approved by regulatory agencies. The
development paradigm for such therapies needs to provide
convincing evidence of efficacy and safety to obtain approval
by the Food and Drug Administration (FDA). The FDA moder-
nization act of 1997 stated that such evidence could be
derived from one large phase III trial with a clinical endpoint
and supportive evidence. Drugs being developed for acute
ischemic stroke can potentially be approved under this act by
coupling a major phase III trial with supportive evidence
provided by a phase IIB trial demonstrating an effect on a
relevant biomarker such as magnetic resonance imaging or
computed tomography assessment of ischemic lesion
growth. Statistical approaches have been developed to opti-
mize the design of such an imaging-based phase IIB study, for
example approaches that modify randomization probabilities
to assign larger proportions of patients to the ‘winning’
strategy (i.e. ‘pick the winner’ strategies) with an interim
assessment to reduce the sample size requirement. Demon-
strating a treatment effect on a relevant imaging-based
biomarker should provide supportive evidence for a new
drug application, if a subsequent phase III trial with a clinical
outcome demonstrates a significant treatment effect.
Introduction
Currently, the only therapy for acute ischemic stroke with
proven efficacy and regulatory approval is tissue plasminogen
activator (t-PA) initiated within 3 h after stroke onset (1). A
recent combined analysis of several t-PA trials demonstrated
that the greatest efficacy of this treatment occurred within
90 min of stroke onset and beneficial effect that likely persists
until 4�5 h after stroke onset (2). The lack of additional
approved therapies is not for lack of effort, as many other
potential pharmacological stroke therapies were evaluated in
clinical trials (3). The only other acute stroke therapies to
demonstrate a statistically significant treatment effect in phase
III trials were the defibrinogenating agent, Ancrod, in a 3-h
window enrollment trial and the thrombolytic, ProUrokinase,
in a 6-h window trial (4, 5). Neither of these therapies is
currently approved by regulatory agencies because additional
confirmatory evidence of efficacy is lacking. Many other
pivotal, efficacy trials assessing thrombolytic and neuroprotec-
tive agents in acute stroke patients were either terminated for
futility or failed to achieve evidence of a statistically significant
treatment effect (6). These many acute stroke therapy trials
failed to achieve significance for a variety of reasons, as outlined
in Table 1, but provided valuable lessons for the future.
The performance of phase III acute stroke therapy trials is
predicated on the concept of demonstrating that the therapy
will show a statistically significant, clinically meaningful
treatment effect in an appropriate group of patients (7). The
design and performance of such trials must also conform with
regulatory requirements to allow for drug approval. Therefore,
trial designers and sponsors must be aware of changing trial
design concepts and the regulatory environment that will
decide whether adequate proof of treatment efficacy was
demonstrated. State-of-the-art design for acute stroke therapy
trials and regulatory requirements are both evolving, as the
lessons from prior trials are digested and interpreted and newer
statistical and patient assessment methodologies become
available (8).
Correspondence: Dr Marc Fisher�, UMASS/Memorial Healthcare,
119 Belmont St., Worcester, MA 01605, USA. Tel: 144 508 334 6641;
Fax: 144 508 334 6695; email: [email protected] of Neurology, University of Massachusetts Medical School,
Worcester, MA, USA2Department of Biostatistics, Columbia University Mailman School of
Public Health, New York, NY, USA3UAB School of Public Health, Birmingham. AL, USA4National Institute of Neurological Disorders and Stroke, Bethesda, MD,
USA
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Development process for acute strokepharmacological therapies
The development of acute stroke therapies is primarily based
upon the hypothesis that reducing ultimate infarct size will
translate into improved clinical outcome months and years
later (9). The basic concept is that if the extent of infarction is
on average reduced by a pharmacological intervention then
stroke patients should demonstrate improved function and in
the National Institute for Neurological Disorders and Stroke
(NINDS) t-PA trial the treated patients had an improved
outcome and also demonstrated a reduction in computed
tomography (CT)-confirmed infarct volume (10).
The reduction of injury approach for developing acute
stroke therapies serves as the primary basis for animal studies
to assess novel pharmacological therapies. Thrombolytic or
neuroprotective drugs targeted at appropriate aspects of the
ischemic cascade are initially assessed in animal stroke models
(typically in rats), with the primary measure of efficacy being a
significant reduction in infarct volume in placebo-controlled,
blinded, randomized experiments with careful control of
physiological variables (11). Dose-ranging, delayed treatment
effect, and extensive toxicology studies are also necessary
before filing for an Investigational New Drug (IND) license.
Some experts also advocate additional preclinical experiments
in gyrencephalic species such as cats or primates, and many
pharmaceutical companies are now heeding this recommen-
dation (11, 12).
Drugs showing promise with preclinical testing and ap-
proved for an IND can then be tested in humans. The initial
human studies, phase I and phase IIA, are directed at establish-
ing safety. Phase IIA studies focus on demonstrating safety in
acute stroke patients with the general characteristics of the
overall stroke population (13). Exclusion criteria for this phase
will reflect particular concerns for the drug being evaluated.
Typically, phase IIA studies are performed in a dose-escalation
fashion with a 2:1 or 3:1 randomization paradigm of active
drug to placebo in relatively small patient numbers. Safety is
assessed by an independent Data and Safety Monitoring Board,
as each dose nears or is completed. The phase IIA study
continues until the maximally tolerated dose (MTD) is
identified or a dose producing a plasma concentration well
above that shown to be effective in animals is achieved without
serious side effects.
Promising drugs showing a reasonable initial safety profile
are advanced to phase IIB studies, focusing on acquiring
additional safety data and potentially demonstrating hints of
therapeutic efficacy. In stroke drug development, demonstrat-
ing possible efficacy in phase IIB studies has been difficult. In
some studies, such as the recently completed phase IIB
abciximab study, a signal of apparent efficacy on clinical
outcome measures was detected (14), but this is rare. This is
expected, as studies designed to provide adequate power to
show an association with clinical outcome measures are by
definition phase III trials. However, sponsors would like to
observe some signal of efficacy at this stage before making the
large commitment of financial and personnel resources needed
to perform phase III studies. In other therapeutic areas, such as
multiple sclerosis, detecting an efficacy signal in a modest
sample size is easier in phase IIB with a relevant biomarker
(15). Finding relevant biomarkers for acute ischemic stroke
drug development and using them in phase IIB studies could
dramatically impact upon the drug development process by
enhancing development of promising drugs, by stopping
development of unpromising drugs, and by providing the
confirmatory evidence required for FDA approval.
Regulatory process and stroke drugdevelopment
In the United States, the marketing of drugs by pharmaceutical
companies requires that the relevant division of the FDA grant
approval. The drug seeking approval must show evidence of
both safety and efficacy (16). The evidence of safety and
effectiveness is derived from ‘adequate and well-controlled
investigations, including clinical investigations, by experts
qualified by scientific training and experience to evaluate the
effectiveness of the drug involved, on the basis of which it could
be fairly and responsibly concluded by such experts that the
drug will have the effect it purports or is represented to have
under conditions of use prescribed, recommended or sug-
gested in the labeling or proposed labeling thereof ’ (16). In the
past, the FDA has typically required two phase III clinical trials
with clear objectives, methods, controls, and protocols for a
drug to be approved. Two phase III trials were required to
provide independent confirmation of treatment efficacy and to
avoid a type I error of presuming efficacy when it may have
occurred by chance.
Table 1 Potential explanations for unsuccessful pharmacological acute stroke trials
(1) The drug tested did not have robust treatment effects and underwent insufficient preclinical testing to determine the true lack of efficacy
(2) Drug toxicity precluded achieving adequate patient plasma or central nervous system levels necessary to produce a reasonable treatment effect
(3) The trial did not have sufficient power to detect a modest, but clinically meaningful treatment effect
(4) Patients were included in the trial that were unlikely to benefit from the treatment under investigation
(5) Too many mildly affected patients were included in the trial and these patients had a high placebo response rate reducing the power for detecting
treatment effects
(6) Too many patients were included at delayed time points after stroke onset when potential treatment effects were less likely to occur
(7) The outcome measure used to assess a treatment effect was insensitive
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In 1997, an amendment to the 1962 Federal Food, Drug and
Cosmetic Act was passed, known as the Food and Drug
Administration Modernization Act (FDAMA). In FDAMA,
the requirement for substantial evidence of effectiveness was
reduced to a single phase III trial and confirmatory evidence
(17). How to best approach the FDAMA requirements for
stroke drug development leading to an approvable package of
information remains contentious. Peck et al. (18) in a recent
paper suggest that a phase III clinical endpoint trial is in fact
empirical because the clinical outcome measure used as the
primary endpoint in such a trial measures the effect of
treatment on a clinically relevant measure of patient outcome.
However, such a trial is not likely to assess how the drug
induces such an effect by its pharmacological activity. Another
assessment approach is to perform a trial that provides causal
confirmation of a drug’s pharmacological activity. Demon-
strating a drug’s significant effect on relevant biomarkers
defined as ‘a laboratory measurement that reflects disease
activity’ could provide causal evidence of drug activity (19).
Although it must be acknowledged that the development of
such biomarkers can be difficult and may be associated with
problems such as measurement variability, reliability of the
measurement, overinterpretation of the significance of the
biomarker, and expense of obtaining the biomarker (20),
development of relevant biomarkers for acute ischemic stroke
that are related to its pathophysiology and evolution is critical.
Relevant biomarkers could be used to provide causal evidence
of a drug treatment effect in a trial with a reasonable sample
size and should be used along with the results from one phase
III clinical trial with an empiric but clinically relevant endpoint
for potential FDA approval based upon FDAMA. When a
relevant biomarker demonstrates that it is correlated with
improved clinical outcome, it may then serve as a surrogate
marker for clinical outcomes. No validated biomarkers or
surrogate markers are currently available for assessing pur-
ported acute stroke therapies.
The most advanced potential biomarker for acute ischemic
stroke is to assess changes in ischemic lesion volume with MRI
from a baseline, pretreatment time point to a delayed time
point 30–90 days later (21). Assessing treatment effects on
ischemic lesion growth in human stroke trials is a potentially
relevant biomarker because the target of acute stroke therapy is
salvage of the ischemic penumbra and the preclinical evalua-
tion of potential stroke therapies is primarily directed at
reducing infarct size. Diffusion-weighted MRI (DWI) can
detect regions of high-energy metabolism failure and loss of
ion homeostasis within minutes of stroke onset (22). These
ischemic regions on DWI may be partially reversible with early
intervention such as thrombolysis, but their natural history is
to proceed to infarction without treatment (23). At a delayed
30–90 days time point, standard T2-weighted MRI can be used
to determine the extent of infarcted tissue, and this volume can
be contrasted with the initial volume of ischemic tissue on
baseline DWI scans. With early DWI studies obtained within
6 h after stroke onset then compared with 30–90 days T2 scans,
natural history studies in untreated patients demonstrated a
50–100% increase in mean ischemic lesion volume and 10–
15% show no lesion growth or shrinkage (24). Preliminary
studies also suggest that a significant correlation exists between
increasing lesion volume from early to delayed MRI studies
and clinical outcome. Patients with no lesion growth or
shrinkage have a statistically significant better outcome than
patients demonstrating lesion growth (21). Apparent relevant
biomarkers for phase IIB acute stroke trials would be to
compare the percentage of patients with no ischemic lesion
growth in a treated group versus a placebo group or assessing
the treatment effect on mean ischemic lesion volume change
over time.
MRI can also be used to choose patients more likely to
respond to interventions. Perfusion MRI (PWI) evaluates
blood flow in the brain’s microcirculation and can identify
readily hypoperfused areas (22). The combination of DWI/
PWI can provide a crude approximation of potentially salvage-
able ischemic tissue or the ischemic penumbra. A commonly
observed initial DWI and PWI pattern is that the PWI volume
is larger than the DWI volume, so-called ‘DWI/PWI mis-
match’, as seen in Fig. 1 (25). The region of PWI abnormality
without DWI abnormality may represent an approximation of
the ischemic penumbra, the presumed target of acute stroke
therapies (26). Uncontrolled intravenous t-PA studies suggest
that stroke patients with a diffusion/perfusion mismatch are
more likely to have a favorable delayed clinical outcome than
patients without a mismatch (26, 27). Currently, in selected
centers, patients are chosen for intravenous t-PA treatment
beyond 3 h after onset, if they demonstrate a clear DWI/PWI
mismatch such as that observed in Fig. 1. It is, however,
appreciated that the diffusion/perfusion mismatch concept
Fig. 1 The diffusion-weighted image (DWI) on the left demonstrates bright
areas in the left parietal region, indicative of acute ischemic injury. The mean
transit time (MTT) image on the right demonstrates a larger area of
hypoperfusion in that region. This mismatch – area of hypoperfusion that
appears normal on DWI – approximates the ischemic penumbra in acute
stroke and therefore identifies the optimal patient for enrollment in clinical
trials.
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only approximates the ischemic penumbra and further refine-
ments of penumbral characterization will occur (28). Perfu-
sion CT can also provide information about the status of brain
perfusion and qualitative measurements of cerebral blood flow
and cerebral blood volume (29). Regions with collapsed CBV
on perfusion CT likely represent irreversible ischemic injury
and a mismatch between such regions and those with reduced
CBF and normal CBV can be identified. Further quantification
and validation of these CBF and CBV values on perfusion CT is
needed. When this occurs, perfusion CT may also be a useful
biomarker.
Statistical designs for detecting signals ofefficacy in early phase trials
Phase I and IIA safety trials
For a promising therapy to move quickly to a pivotal phase III
trial, it is imperative that a potentially effective and safe dose
regimen be identified. The primary objective of phase I and
phase IIA trials is to establish safety, and identify an MTD, or
the largest dose that can be safely given (30). Traditionally, the
MTD is approached from lower doses and follows the principle
that three patients are treated at each nontoxic dose level and
up to six at each level showing toxicities. Then, the MTD is
estimated by the dose immediately below the level where safety
issues become apparent (i.e., the ‘toxic’ level). This paradigm,
first applied in cancer trials, may not be the appropriate
methodology for stroke trials. In stroke trials, the expression
of a toxic level is frequently a substantial clinical event such as a
cerebral hemorrhage. Because such events carry such a sub-
stantial morbidity and mortality, the acceptable proportion of
patients undergoing such events is quite small. For example, it
would be difficult to conceive of a ‘safe’ treatment for acute
stroke that would be associated with a symptomatic hemor-
rhage rate above 10%. This is in contrast to cancer trials where
an anticipated negative patient outcome absent dramatic and
successful therapy makes a much higher level of toxic responses
tolerable. Because the acceptable proportion of patients with
toxic responses is so small for stroke studies, it is likely that the
true safe dose will be substantially overshot by the step-up
approach with three patients in a stratum. For example,
consider a dose where the true toxic rate (i.e., true hemorrhage
rate) is 20%. The algorithm would ‘step up’ to the next higher
dose if either: (1) no toxic responses were observed in the first
three patients, or (2) one toxic response was observed in
the first three patients and three additional patients were
observed with no toxic events. The likelihood of observ-
ing no toxic responses among the first three patients would
be (1–0�20)3 5 0�512, or 51�2%. The likelihood of one toxic
event among the first three patients is (3!/(2!� 1!) (0�201)
(0�802) 5 0�384, and the probability of subsequently observing
no toxic effects is 0�512; hence, the likelihood of observing one
toxic effect and then observing three additional patients with
no toxic effects is 19�7% (0�384� 0�512 5 0�197). As such,
even when the true rate of toxic events is twice the acceptable
level (20% in comparison with 10%), there is still a 70�9%
(51�2119�7%) of assuming that the dose level is safe and
stepping up to the higher level. Using this approach, the true
hemorrhage rate for an individual patient has to be approxi-
mately 63% before there is less than a 5% chance of ‘stepping
up’ to a higher dose and assuming that the current dose is ‘safe.’
Clearly, no drug dose with a 63% chance of causing a
hemorrhage would be considered safe.
Recent statistical methods have been proposed to determine
the MTD in the case where the acceptable level of toxicity is at a
low level (e.g., 10%). At the heart of the statistical challenge is
that the step-up approach described above does not allocate
many patients at levels close to the toxic level. With either three
or six patients evaluated at the toxic level, the proportion of
patients with toxic responses are measured with crude percen-
tages that are multiples of 16�7% (i.e., 1/6th), and the widths of
the confidence limits about these estimates on small sample
sizes are disappointingly large.
Perhaps the most promising detection method to address
this challenge is the ‘continual reassessment method,’ which
addresses this concern by using a strategy using information
accrued during the trial, so that the next patient will be treated
at the most currently estimated MTD (31–33)–in essence, the
approach keeps allocating individuals at the ‘best guess’ of the
MTD. This approach then has the advantage of moving more
quickly to dose levels close to the true MTD, resulting in a
larger number of patients allocated to doses that are close to the
true MTD through avoiding processes that ‘waste’ patients by
allocating them to doses that are substantially below the MTD.
In contrast to the commonly used 313 step-up procedure, a
much greater level of precision in the estimated toxicity is
provided because a larger number of patients are assessed in
the true neighborhood of the MTD. In turn, this greater level of
precision allows reliable estimation in the neighborhood of low
levels of toxicity (i.e., 10%). This approach can be optimized by
analytic techniques and computer simulations when applied to
actual trials (34).
Dose-finding phase IIB trials
The identification of a potentially effective dose(s) should be
the primary objective of phase IIB trials. Relatively little is
known about the dose–efficacy relationship of an agent prior
to conducting a phase IIB trial. Typically, the MTD is used in
phase IIB trials, but lower doses may be safer and equally
effective. A better strategy may be to evaluate several doses and
select the ‘best’ dose for the phase III study.
Two-stage designs
To have adequate power and control of type I error rates, the
sample size required for multiple-dose comparison trials
would be infeasible if conventional one-stage, balanced ran-
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domization designs that use a clinical outcome endpoint are
used. A phase IIB trial should be efficient regarding dose
finding with a realistic sample size and the use of outcome-
adaptive methods may advance trial conduct. One of the first
approaches proposed was to adjust the allocation scheme to
assign a larger number of patients to the treatment that appears
most promising at the current time. The practicality of this
‘play-the-winner rule’ (35, 36) is limited as the outcome of
assigned treatment must be observed before establishing the
‘winner’ in order to make future assignments. At the extreme,
even having a 90-day outcome measure as the primary out-
come would limit enrollment of patients to approximately
a 3-month cycle. These limitations have led to a wide-
spread recognition of timeliness issues for sequential methods
(37, 38).
Among the responses has been the development of ‘two-
stage designs’ that provide a good balance between ethical,
economical, and timeliness considerations (39). Briefly, these
approaches use a first stage where patients are randomized to a
large number of doses in an attempt to ‘seek’ the most effective
doses. Following the first stage, the interim data can be used to
eliminate ineffective doses: additional patients will then be
randomized to potentially effective doses. Eliminating ineffec-
tive doses in the first stage again avoids ‘wasting’ patients by
assigning them to doses that are unlikely to show benefit
during the second stage. Such designs are ethically and
economically appealing because the average sample size will
be reduced while maintaining comparable statistical power
and type I error rates compared with one-stage designs. For
example, Table 2 compares a two-stage design with the
conventional one-stage, balanced randomization design in a
three-armed trial with two active doses versus the placebo. In
this example, the maximum number of patients required by
the two-stage design is 126, whereas the one-stage design needs
a total of 216 patients. In addition, since the two-stage design
will stop the trial after the first stage if neither dose is superior
to the placebo in terms of the observed number of responses,
the average number of patients will be 87 if in reality neither
dose is better than the placebo (40).
Impact on the phase III trials and regulatory issues
There is an extensive statistical literature of outcome-adaptive
designs, but their trial application is limited due to perceived
logistical challenges to implementation. A more controversial
approach is the use of Bayesian methods that promise the
possibility of providing a flexible and unified framework for
inference (41). Bayesian analysis has the ability to incorporate
information available at the initiation of the study, and this
information holds the possibility of substantial reductions in
the sample size. This is in contrast to the standard approach
(frequentist approach) where the interpretation of each trial is
limited to only the data provided by the study.
Bayesian methods are viewed by many investigators as being
subjective because of the necessity of specifying the investiga-
tor’s belief before data collection (i.e., the ‘prior distribution’),
making the results of the study both a function of the study
results and the prior assumptions. This joint dependence on
the assumptions and the resulting study data creates the
possibility of differing interpretations of the data resulting
from the same clinical trial (42). Finally, the process of
conducting phase III trials involves the selection of promising
treatments from the phase I/II studies. A study can appear
promising both for its true effect, but also because the
estimated effect appears inappropriately large in the specific
phase I/II studies that were conducted. As such, it is possible
that the prior information is biased, and the use Bayesian
analysis will ‘carry forward’ these biases through their use in
the prior distributions (42). Conversely, advocates of Bayesian
analysis have argued that the approach is rather robust and that
the potential gains from a Bayesian approach more than offset
the potential risks. If Bayesian approaches are considered,
caution should be exercised in light of FDAMA. If a phase IIB
trial outcome is to serve as confirmatory evidence under
FDAMA, the conventional frequentist method that provides
a ‘P value’ with respect to a predefined hypothesis concerning
relevant biomarkers or may be more convincing to regulatory
agencies than Bayesian inferences. The use of novel statistical
methods and the regulatory process need to maintain a
Table 2 Comparison of a two-stage design and the conventional one-stage design in a three-armed study (two active doses and one placebo)
One-stage design Two-stage design
Description 1. Enroll 72 patients per arm 1. Enroll 22 patients per arm
2. Choose a dose if a one-sided, two-sample binomial
test between the dose and the placebo is significant
at 0�025 level according to the Bonferroni’s adjustment
2. If any dose has at least two more responses than the placebo,
then take the dose with the largest number of responses
(called the winning arm) to stage 2 with the placebo.
3. Enroll 30 patients each to the placebo arm and the winning arm.
4. Declare a dose effective if it has at least 6 responses more
than the placebo.
Type I error� 0�05 0�05
Power 80% 80%
Sample size 216 126
�The type I error is defined as the probability of selecting any ineffective.
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dynamic relationship to allow for a clinical trial program that
will demonstrate convincing proof of efficacy and lead to
regulatory approval.
Conclusions
The lessons learned from the many prior unsuccessful acute
stroke trials and the recent availability of likely relevant
imaging biomarkers of drug activity using DWI/PWI and
perfusion CT provide an opportunity to enhance trial design
for acute ischemic stroke pharmacological interventions that
should accelerate the evaluation of new, promising drugs. The
use of a relevant biomarker in phase IIB studies could provide
causal evidence of drug activity and presumably be used with
one, large phase III with an empirical, clinical outcome
measure to seek FDA approval based upon the requirements
of FDAMA. Newer statistical methodology can be used in
phase IIB trials to also provide valuable and timely information
about drug efficacy or lack thereof. The confluence of relevant
biomarkers, newer statistical methodology, and moderniza-
tion of FDA requirements for drug approval should lead to a
new era of more rapid assessment and hopefully approval of
additional acute stroke drugs.
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