Title: A Framework of Modeling and Simulation in Regulatory Decisions
1A Framework of Modeling and Simulation in
Regulatory Decisions
- ACPS
- Nov 16, 2000
- Peter Lee, Stella Machado, and Larry Lesko
- OCPB OB/CDER
2Terminology
- Modeling determining the mathematical equations
that appropriately describe the data (mechanism
of action or smoothness). - Simulation predict the outcomes under specified
conditions based on models. - Clinical Trial Simulation A specific type of
simulation that predict outcomes of clinical
trials.
- It is not possible to review simulation without
evaluating modeling process
3Topics for Discussion
- What is the trend of modeling and simulation
(MS) in regulatory submissions? - What are regulatory experience in decision-making
based on MS ? - What are the potential applications of clinical
trial simulation (CTS), specifically ? - What are the directions and next steps for
evaluating the applications of simulation ?
4How good is the current drug development process?
- 354/499 approved NME, 1980-1999
- 22 required a post-market dose change (79)
- 80 were dose reduction (64)
- Pre-market drug development is improvable
regarding safe dose (C. Peck, CR AC, Oct 2000) - 12 year, 350-600 million (CMR Internation, 1999)
- 30 NDAs non-approvable 15 phase III failed (S.
Arlington, April 2000)
5Pharma 2005 Vision for Simulation - at the
centre of drug development process
but can be applied more widely
6Simulation - a rapidly emerging technology
Discovery
PreClinical
Clinical
Outcomes
Not appropriate
Not currently addressed
Under Development
Products Available
7Current Environment
- Computer aided trial design (CATD) used by 17 out
of top 20 PhRMA companies, and over 1200 users. - Over 15 different software packages.
- Past experience with modeling simulation to
support regulatory decisions - Emerging submissions using simulation to support
trial designs.
8Number of CTS
- Over 100 (C. Peck, 10/12/00)
- Therapeutic areas (D. Weiner, 9/11/00)
9Past Experience in MS
- New indication with new formulation
- Single dose PK study
- Simulate multiple dose PK for the new formulation
based on single dose PK
- PK Simulation
- - Cisapride 20 mg
- - Oxaliplatin Toxicity
- BE based on PD end point (FEV)
- Single dose, 4-way crossover, nasal spray
- PD model parameter estimation
- BE test on PD model parameter
- PD Simulation
- - Albuterol BE
- Identify sub-population DDI
- Single and multiple doses
- Multiple studies
- Demographic information
- 1 structure and 10 covariate models
- Support the dose selection
- Randomized , non-blind, multi-center, dose
ranging study - 400, 600, 800, 1200 mg tid
- Simulate distribution of response as a function
of dose
- PK/PD Simulation
- - Remifentanil
- - Saquinavir Dose Selection
10New Experiencein CTS
- Physiological/Disease Models
- Alzheimers
- QTc prolongation
- Diabetic
- Clinical Trial Simulation
- Neuropharm drug
- Design phase III trial
- Based on PK phase II study
- PK and PK/PD model, covariate model, assay model,
drop-off, severity, statistics
11An Example Drug X
- Drug X showed marginal efficacy in phase II
studies - Apply CTS to optimize phase III design for
maximum success rate
12Backgrounds
- Dose Regimen
- Continuous IV infusion
- Reason for marginal results in phase II
- Drug concentration may not be optimal
- Goal
- Optimize the concentration in phase III
13Concentration-Effect Relationship
32
9
N 0
15
12
32
14Adjust Infusion Rate
15Loading Dose? Infusion
16Study Design/Conduct Factors
- Responder/Non-responder
- P450 2D6 genotype
- Patient demographic
- Number of patients
- Timing of assay
- Amount of dose adjustment
- Amount of loading dose
- Drop-off
17Three Best Designs Number of Patients
18Utilities of Simulation
- Predict PK under conditions not studied.
- Select the optimal dose.
- Study design pop PK, exposure-response.
- Evaluate change in PD due to change in
formulation, dose regimen, or dosing route. - Provide bridging information for sub-populations.
- Develop informative labeling language.
19Additional (Potential) Utilities of Simulations
- Integrate preclinical, clinical pharmacology, and
biopharmaceutics study results into late-phase
clinical trials to ensure safe and effective
study design. - Design unbiased, powered, and robust studies to
maximize the treatment benefits/risk ratio in the
patients. - Explore what if scenarios, and compare
different study designs - Combine multi-discipline expertise in reviewing
IND/NDA.
20Key Factors to Successful Simulation Projects
- Prospective planning
- Well-understood MOA
- Robust model that are not overly sensitive to
assumptions - Disease progression model
- Availability of exposure-response data
- Balanced inputs from relevant disciplines
- How far dose it extrapolate ?
21Issues
- No consistent approach for CDER reviewers to
assure quality of M/S projects. - Other FDA guidance recommend simulation technique
but not address best practice - Proper review of M/S submissions may require FDA
standard for industry
22Goals of MPCC MS WG
- Assess current state of art of M/S
- Explore potential for regulatory applications
- Determine standards to assess suitability
- Develop standards for M/S outputs
- Develop a guidance as standards for reviewing and
critiquing MS reports - Prepare a guidance for industry for reporting MS
results
23Questions To ACPS Committee
- 1. How does industry use simulation to help the
drug development process ? - 2. Are modeling and simulation appropriate for
drug development and regulatory decisions ? - 3. What are the important attributes for a
meaningful simulation practice ?
24Questions To ACPS Committee (cont.)
- 4. Do we need a FDA guidance to industry
regarding the best practice of modeling and
simulation for regulatory applications ? - 5. If yes to 4, what are the important
information should the guidance include ? - 6. If no to 4, what are the critical issues that
need to be addressed before move forward to
developing a guidance ?