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E9(R1) Statistical Principles for Clinical Trials: Addendum: Estimands and Sensitivity Analysis in Clinical Trials: Guidance for Industry

FinalCenter for Drug Evaluation and Research Center for Biologics Evaluation and Research05/11/2021
Clinical Trial DesignIntention-To-TreatRandomizationFull Analysis SetPer Protocol SetITT PrincipleEstimandSensitivity AnalysisTreatment Policy StrategyWhile-on-treatment StrategyPrincipal Stratum StrategyHypothetical StrategyComposite Variable Strategy

Description

To properly inform decision-making by pharmaceutical companies, regulators, patients, physicians, and other stakeholders, clear descriptions of the benefits and risks of a treatment (medicine) for a given medical condition should be made available. Without such clarity, there is a concern that the reported treatment effect will be misunderstood. This addendum presents a structured framework to strengthen the dialogue between disciplines involved in the formulation of clinical trial objectives, design, conduct, analysis and interpretation, as well as between sponsor and regulator regarding the treatment effect or effects of interest that a clinical trial should address.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

3
Pharmaceuticals for Human Use

ICH mission regarding safe, effective, and high-quality medicines

Drug

Defined in section 201(g) of the FD&C Act; Articles intended for use in diagnosis, cure, mitigation, treatment, or prevention of disease; Product classification based on chemical action or specific intended uses like altering pH

Vaccination

Example used for principal stratum strategy regarding infection severity

Stakeholders

2
Sponsor

Entity responsible for submitting applications under section 524B

Regulator

Initial sender type flagged in C.1.8.2

Regulatory Context

Regulatory Activities

2
Confirmatory Clinical Trials

Trials where regulatory interest in the application of these principles will be greater.

Regulatory Decision-making

The process by which agencies approve or evaluate products based on trial results

Document Types

3
Trial Protocol

Specifies DHT use and data collection methods

Clinical Trial Report

Report where the quality management approach is described.; Post-unblinding data changes and deviations from the planned statistical analyses should be reported in the clinical trial report; Document where deviations from the statistical analysis plan are described

Product Information

Labeling where results of sensitivity analysis may be included

Attributes

4
Estimand Attributes

Attributes used for constructing an estimand

Missing Data

Data that would be meaningful for the analysis of a given estimand but were not collected.

Robustness

Evaluation of robustness and parameter ranges of analytical procedures; Development of a robust multivariate analytical procedure includes scientifically justified sample selection; Capacity of an analytical procedure to meet performance criteria during normal use.; Assessed using retention time models; Performance characteristic to be validated

Population-level summary

An attribute used to provide a basis for comparison between treatment conditions

Technical Details

Substances

1
Concomitant Medication

Additional treatments that may be considered intercurrent events

Testing Methods

8
Tipping Point Analysis

A specific type of sensitivity analysis to investigate departures from assumptions

Principal Stratification

Classification of subjects according to the potential occurrence of an intercurrent event on all treatments.

Estimator

A method of analysis to compute an estimate of the estimand using clinical trial data.

Sample Size Calculations

Determining the number of subjects required for a trial based on the estimand

Sensitivity Analysis

Performed to identify uncertainties that could affect HCEI conclusions.

Main Estimation

Statistical analysis aligned to the estimand

Supplementary Analysis

Statistical analysis section of the protocol

Main Estimator

The primary method of analysis aligned to a given estimand

Processes

2
Randomization

Process of assigning trial participants to treatment or control groups using an element of chance; Process of assigning participants to treatment groups.; Process of assigning participants to groups using chance to reduce bias.

Blinding

Manufacturing and handling should maintain blinding

Clinical Concepts

5
Intercurrent Events

Events requiring handling strategies within the estimand rationale.; Events occurring after treatment initiation that affect the interpretation of the outcomes.

Treatment Effect

description of the treatment effect of interest using natural, non-technical language; The effect being measured and understood through supplementary and sensitivity analyses.

Missing Data

The Prevention and Treatment of Missing Data in Clinical Trials

Adverse Events

Reporting adverse events when engaging with patients.; changes may be related to benefits, tolerability, and/or unintended effects

Terminal Event

Events such as death that prevent further measurement of a variable

Identified Hazards

Hazards

1
Adverse Drug Reaction

A safety concern that may lead to treatment discontinuation

Standards & References

Specifications

2
Full Analysis Set

ICH E9 indicates that it is usually appropriate to plan for analyses based on both the FAS

Per Protocol Set

Consistent results from analyses based on the FAS and the PPS is indicated as increasing confidence

ICH References (2)

ICH E9(R1)

Statistical Principles for Clinical Trials: Addendum: Estimands and Sensitivity Analysis in Clinical Trials

ICH E9

Statistical Principles for Clinical Trials; Discourages deterministic procedures due to high risk of bias; Notes that the use of Bayesian methods in clinical trials may be considered.

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)

E9(R1) Statistical Principles for Clinical Trials: Addendum: Estimands and Sensitivity Analysis in Clinical Trials: Guidance for Industry | Guideline Explorer | BioRegHub