Elsevier

Value in Health

Volume 22, Issue 2, February 2019, Pages 203-209
Value in Health

Health Policy Analysis
A Review of Patient-Reported Outcomes Labeling for Oncology Drugs Approved by the FDA and the EMA (2012-2016)

https://doi.org/10.1016/j.jval.2018.09.2842Get rights and content
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Highlights

  • In recent years, the Food and Drug Administration (FDA) has granted patient-reported outcome (PRO) labeling to very few oncology drugs.

  • The FDA and the European Medicines Agency (EMA) use different evidentiary standards to assess PRO data from oncology studies. PRO labeling by the EMA was frequently based on open-label studies, on broad concepts such as health-related quality of life, and on PRO measures that may be outdated and unsuitable for contemporary oncology clinical trials.

  • There are key differences in evidentiary standards between the FDA and the EMA. An understanding of these differences may be useful to guide PRO measurement strategies as study sponsors pursue PRO labeling. Sponsors pursuing labeling from both agencies should include in clinical trials PRO measures that assess patient-focused proximal concepts of core disease symptoms, treatment-related symptoms, and impacts on physical functioning. The addition of health-related quality-of-life assessments may also be useful for EMA reviews.

Abstract

Objectives

To compare US Food and Drug Administration (FDA) and European Medicines Agency (EMA) labeling for evidence based on patient-reported outcomes (PROs) of new oncology treatments approved by both agencies.

Methods

Oncology drugs and indications approved between 2012 and 2016 by both the FDA and the EMA were identified. PRO-related language and analysis reported in US product labels and drug approval packages and EMA summaries of product characteristics were compared for each indication.

Results

In total, 49 oncology drugs were approved for a total of 64 indications. Of the 64 indications, 45 (70.3%) included PRO data in either regulatory submission. No FDA PRO labeling was identified. PRO language was included in the summary of product characteristics for 21 (46.7%) of 45 indications. European Organisation for Research and Treatment of Cancer and Functional Assessment of Cancer Therapy measures were used frequently in submissions. FDA’s comments suggest that aspects of study design (eg, open labels) or the validity of PRO measures was the primary reason for the lack of labeling based on PRO endpoints. Both agencies identified missing PRO data as problematic for interpretation.

Conclusions

During this time period, the FDA and the EMA used different evidentiary standards to assess PRO data from oncology studies, with the EMA more likely to accept data from open-label studies and broad concepts such as health-related quality of life. An understanding of the key differences between the agencies may guide sponsor PRO strategy when pursuing labeling. Patient-focused proximal concepts are more likely than distal concepts to receive positive reviews.

Keywords

European Medicines Agency (EMA)
Food and Drug Administration (FDA)
labeling
oncology
patient-reported outcome (PRO)

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Conflicts of interest: A. Gnanasakthy, A. Barrett, E. Evans, and C. Romano are salaried employees of RTI Health Solutions. D. D'Alessio is a salaried employee of Novartis Pharmaceuticals Corporation.