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Indirect comparisons in the comparative efficacy and non-inferiority settings
1Amgen Inc., One Amgen Center Drive 24-2-C, Thousand Oaks, CA 91320, USA. ssnapinn@amgen.com
Indirect comparisons in clinical trials, often used for non-inferiority and comparative efficacy, require larger sample sizes. Regulatory guidance for approving experimental treatments via indirect comparison may be logically inconsistent with preference criteria.
Area of Science:
- Clinical trial design
- Regulatory science
- Biostatistics
Background:
- International Conference on Harmonization E10 guidelines address non-inferiority trials and comparative efficacy assessments.
- Indirect comparisons are frequently employed in both settings, analyzing relationships between treatments not directly tested against each other.
Purpose of the Study:
- To analyze the sample size requirements for indirect versus direct comparisons in clinical trials.
- To investigate the logical consistency between preference criteria for experimental treatments and current regulatory approval pathways based on indirect comparisons.
Main Methods:
- Comparative analysis of sample size calculations for direct and indirect superiority trials.
- Introduction of the "preservation of effect" concept to equate hypotheses in different trial settings.
- Logical assessment of existing regulatory approval criteria against a proposed preference criterion.
Main Results:
- Trials demonstrating superiority via indirect comparison necessitate larger sample sizes than direct comparisons.
- The hypothesis tested in both non-inferiority and comparative efficacy settings using indirect comparisons is fundamentally the same.
- A logical inconsistency exists where a preferred experimental treatment may not meet current regulatory approval criteria due to the burden of standard treatment uncertainty.
Conclusions:
- Current regulatory guidance for experimental treatment approval via indirect comparison may not align with reasonable preference criteria.
- The experimental treatment must overcome the uncertainty associated with the standard treatment's effect, creating potential approval discrepancies.
- An alternative approval criterion is proposed to resolve the identified logical inconsistency.
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