Modern Non-inferiority Trial Designs in Antibiotic Development

 
Rex JH, Talbot GH, Goldberger MJ, Eisenstein BI,
Echols RM, Tomayko JF, Dudley MN, Dane A
Progress in the fight against multidrug-resistant bacteria 2005-2016:
Modern non-inferiority trial designs enable antibiotic development in
advance of epidemic bacterial resistance.
Clinical Infectious Diseases, 2017. 
https://doi.org/10.1093/cid/cix246
 
Three intertwined key ideas: UDR,
superiority vs. non-inferiority, and the
public health consequences of only using
superiority designs
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
1
 
1. 
Nomenclature: UDR vs. MDR/XDR
 
Useful categories of bacteria:
WT: Wild-type. 
May well now be pretty rare
UDR: Usual Drug Resistance
1
MDR: Multi-drug resistance
XDR: Extensive multi-drug resistance
This is a continuum with implications for trial design
UDR: Many easy choices. 
Easy to choose a blinded comparator.
MDR: Harder – may need 2nd-line drug.
2
 
Single comparator is harder
XDR: Needs a difficult or unusual drug.
2
 
Comparator must be ad hoc.
Today’s UDR pathogen can be tomorrow’s MDR (& vice versa)
Consider 
S. aureus
: It’s been UDR, then MDR.
3
 MRSA is now UDR
If an organism is S(usceptible) to the novel test agent…
Response is independent of being UDR, MDR, or XDR 
to other drugs
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
2
1
This may or may not be the same thing as wild-type. See McDonnell, Rex, et al, Efficient Delivery of Investigational
Antibacterial Agents via Sustainable Clinical Trial Networks, Clin Infect Dis (in press), 2016. 
2
Or combination of drugs.
3
When MRSA emerged after the introduction of penicillin, it was the nightmare MDR bug. Vancomycin made it UDR.
 
Or, perhaps
RDR (rare DR)?
 
PK-PD
1
: UDR vs. MDR/XDR is irrelevant
Resistance to OTHER drugs should not matter
It’s all about the activity of the NEW drug
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
3
Common
Rare
 
Activity of NEW
DRUG is
independent of
being UDR, MDR,
or XDR 
to other
drugs
.
W
i
t
h
 
a
d
e
q
u
a
t
e
 
P
K
,
efficacy vs. UDR
predicts efficacy
2
 in
MDR or XDR.
Easy
Hard
 
F
r
e
q
u
e
n
c
y
 
S
t
a
n
d
a
r
d
 
c
o
m
p
a
r
a
t
o
r
1
PK-PD: Pharmacokinetic-Pharmacodynamic correlations. 
2
Efficacy against the infection, that is … the
antibiotic can’t reverse the underlying disease that may have put the patient at risk for the infection.
 
UDR
UDR
 
XDR
XDR
 
Why does this matter?
 
In addition to the problem with selecting a
comparator, it’s 
much
 harder to do prospective,
randomized, registration-quality studies of infections
due to MDR/XDR isolates than due to UDR isolates
At least twice as slow and twice as costly
Patients must present at a study site as referral is hard
Sites work hard to make MDR and XDR rare!
No site wants to be a Center of MDR/XDR Excellence!
Chasing MDR/XDR is very frustrating: Lasagna’s Law
1
 in action
Achaogen: Pivotal trial in CRE was not possible
(R)are DR: And, we 
want
 MDR/XDR rates to be low!!
If it’s easy to recruit MDR/XDR, something is very wrong
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
4
1
Louis Lasagna: “The incidence of patient availability sharply decreases when a clinical trial begins and returns to its
original level as soon as the trial is completed.” http://www.pmean.com/11/lasagna.html
 
2.
 Superiority vs. Noninferiority
 
Trial design 101: There are 2 types of trials
Superiority: Show that A is better than B
Noninferiority (NI): Show that A ≈ B
Superiority studies are preferred
Very clear result, fewer quality issues
But, new antibiotics are usually studied using NI
comparisons vs. existing agents in the UDR setting
Typical registration program: 2-4 NI studies
Why?
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
5
 
2. 
Superiority vs. Noninferiority
1
 
Untreated infections are lethal! So…
New antibiotic trials must (usually) be designed to avoid superiority
Must NOT enroll if resistance is known/likely to TEST or comparator.
Very unlikely to see superior efficacy over a fully dosed modern
comparator when pathogen is susceptible to same
Very hard (rare) to be superior on toxicity (short-term dosing)
MDR/XDR are rare, we hope!
Superiority is a high-stakes gamble for a novel agent
If your primary aim is superiority and the study fails, you cannot
retreat to a claim of noninferiority.
But if you see superiority in a NI study, you can claim that result
We can tie together Ideas #1 and #2 with a recent example…
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
6
1
Rex-Talbot et al. Progress in the fight against multidrug-resistant bacteria 2005-2016: Modern noninferiority trial
designs enable antibiotic development in advance of epidemic bacterial resistance. Clin Infect Dis, 2017.
 
3. 
The public health
consequences of only using
superiority designs to advance
new antibiotics
 
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
7
 
Example: Plazomicin and CRE
CRE = Carbapenem-resistant Enterobacteriaceae
 
Plazomicin vs. colistin-
based SOC
1
 for CRE
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
8
 
4/17
 
10/20
 
2/17
 
8/20
 
Figure adapted from slide 24 the Jan 2017 Achaogen corporate
presentation. Downloaded 24 Feb 2017 from
http://files.shareholder.com/downloads/AMDA-
2JY46Z/3956962155x0x922829/80C50E00-4B27-4F84-B13F-
55DE31AABA28/AKAO-Corporate-Deck-January-2017.pdf
28-day all-cause mortality
1
SOC = Standard of Care
 
Example: Plazomicin and CRE
CRE = Carbapenem-resistant Enterobacteriaceae
 
Plazomicin vs. colistin-
based SOC for CRE
Superiority is shown in
this very small study
because …
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
9
 
4/17
 
10/20
 
2/17
 
8/20
 
Figure adapted from slide 24 the Jan 2017 Achaogen corporate
presentation. Downloaded 24 Feb 2017 from
http://files.shareholder.com/downloads/AMDA-
2JY46Z/3956962155x0x922829/80C50E00-4B27-4F84-B13F-
55DE31AABA28/AKAO-Corporate-Deck-January-2017.pdf
28-day all-cause 
mortality
 
Example: Plazomicin and CRE
CRE = Carbapenem-resistant Enterobacteriaceae
 
Plazomicin vs. colistin-
based SOC for CRE
Superiority is shown in
this very small study
because …
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
10
 
4/17
 
10/20
 
2/17
 
8/20
 
Figure adapted from slide 24 the Jan 2017 Achaogen corporate
presentation. Downloaded 24 Feb 2017 from
http://files.shareholder.com/downloads/AMDA-
2JY46Z/3956962155x0x922829/80C50E00-4B27-4F84-B13F-
55DE31AABA28/AKAO-Corporate-Deck-January-2017.pdf
28-day all-cause 
mortality
~6 people died
on (due to) SOC
 
Example: Plazomicin and CRE
CRE = Carbapenem-resistant Enterobacteriaceae
 
Plazomicin vs. colistin-
based SOC for CRE
Superiority is shown in
this very small study
because …
We are glad to have
clarity on colistin’s
relative inefficacy 
but
this is a steep price
!
As colistin is displaced
as SOC, future drugs
should not be able to
plan on similar data
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
11
 
4/17
 
10/20
 
2/17
 
8/20
 
Figure adapted from slide 24 the Jan 2017 Achaogen corporate
presentation. Downloaded 24 Feb 2017 from
http://files.shareholder.com/downloads/AMDA-
2JY46Z/3956962155x0x922829/80C50E00-4B27-4F84-B13F-
55DE31AABA28/AKAO-Corporate-Deck-January-2017.pdf
28-day all-cause 
mortality
~6 people died
on (due to) SOC
 
Summary
 
Non-inferiority trial designs are a necessary and
essential part of antibiotic development
Modern design NI studies conducted in the UDR setting vs.
a high-quality comparator produce reliable data
Using NI studies in this way permits new agents to be
developed prior to epidemic spread of resistance
Superiority designs are a valid tool but the ability to
use them depends on existence of a public health
problem with grim implications
As new agents with activity against MDR/XDR pathogens
are introduced, superiority designs will hopefully be
difficult (or impossible to implement)
 
Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas)
 
12
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This article discusses the significance of non-inferiority designs in advancing antibiotic development to combat multidrug-resistant bacteria. It emphasizes the importance of distinguishing between UDR, MDR, and XDR bacterial categories in trial design, highlighting challenges in selecting comparators and conducting studies on MDR/XDR isolates. The article underscores the critical role of innovative trial designs in addressing antibiotic resistance and the complexities of recruiting patients for such studies.

  • Antibiotic development
  • Non-inferiority trials
  • Multidrug-resistant bacteria
  • Trial design
  • Antibiotic resistance

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  1. Rex JH, Talbot GH, Goldberger MJ, Eisenstein BI, Echols RM, Tomayko JF, Dudley MN, Dane A Progress in the fight against multidrug-resistant bacteria 2005-2016: Modern non-inferiority trial designs enable antibiotic development in advance of epidemic bacterial resistance. Clinical Infectious Diseases, 2017. https://doi.org/10.1093/cid/cix246 Three intertwined key ideas: UDR, superiority vs. non-inferiority, and the public health consequences of only using superiority designs Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 1

  2. 1. Nomenclature: UDR vs. MDR/XDR Useful categories of bacteria: WT: Wild-type. May well now be pretty rare UDR: Usual Drug Resistance1 MDR: Multi-drug resistance XDR: Extensive multi-drug resistance This is a continuum with implications for trial design UDR: Many easy choices. Easy to choose a blinded comparator. MDR: Harder may need 2nd-line drug.2 Single comparator is harder XDR: Needs a difficult or unusual drug.2 Comparator must be ad hoc. Today s UDR pathogen can be tomorrow s MDR (& vice versa) Consider S. aureus: It s been UDR, then MDR.3 MRSA is now UDR If an organism is S(usceptible) to the novel test agent Response is independent of being UDR, MDR, or XDR to other drugs Or, perhaps RDR (rare DR)? 1This may or may not be the same thing as wild-type. See McDonnell, Rex, et al, Efficient Delivery of Investigational Antibacterial Agents via Sustainable Clinical Trial Networks, Clin Infect Dis (in press), 2016. 2Or combination of drugs. 3When MRSA emerged after the introduction of penicillin, it was the nightmare MDR bug. Vancomycin made it UDR. Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 2

  3. PK-PD1: UDR vs. MDR/XDR is irrelevant Resistance to OTHER drugs should not matter It s all about the activity of the NEW drug UDR XDR Activity of NEW DRUG is independent of being UDR, MDR, or XDR to other drugs. Frequency Common Rare Standard comparator Easy Hard NEW DRUG S S S Approved Drug #1 S S S? Approved Drug #2 S S R With adequate PK, efficacy vs. UDR predicts efficacy2 in MDR or XDR. Approved Drug #3 S S R Approved Drug #4 S R R Approved Drug #5 R R R 1PK-PD: Pharmacokinetic-Pharmacodynamic correlations. 2Efficacy against the infection, that is the antibiotic can t reverse the underlying disease that may have put the patient at risk for the infection. Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 3

  4. Why does this matter? In addition to the problem with selecting a comparator, it s much harder to do prospective, randomized, registration-quality studies of infections due to MDR/XDR isolates than due to UDR isolates At least twice as slow and twice as costly Patients must present at a study site as referral is hard Sites work hard to make MDR and XDR rare! No site wants to be a Center of MDR/XDR Excellence! Chasing MDR/XDR is very frustrating: Lasagna s Law1 in action Achaogen: Pivotal trial in CRE was not possible (R)are DR: And, we want MDR/XDR rates to be low!! If it s easy to recruit MDR/XDR, something is very wrong 1Louis Lasagna: The incidence of patient availability sharply decreases when a clinical trial begins and returns to its original level as soon as the trial is completed. http://www.pmean.com/11/lasagna.html Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 4

  5. 2. Superiority vs. Noninferiority Trial design 101: There are 2 types of trials Superiority: Show that A is better than B Noninferiority (NI): Show that A B Superiority studies are preferred Very clear result, fewer quality issues But, new antibiotics are usually studied using NI comparisons vs. existing agents in the UDR setting Typical registration program: 2-4 NI studies Why? Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 5

  6. 2. Superiority vs. Noninferiority1 Untreated infections are lethal! So New antibiotic trials must (usually) be designed to avoid superiority Must NOT enroll if resistance is known/likely to TEST or comparator. Very unlikely to see superior efficacy over a fully dosed modern comparator when pathogen is susceptible to same Very hard (rare) to be superior on toxicity (short-term dosing) MDR/XDR are rare, we hope! Superiority is a high-stakes gamble for a novel agent If your primary aim is superiority and the study fails, you cannot retreat to a claim of noninferiority. But if you see superiority in a NI study, you can claim that result We can tie together Ideas #1 and #2 with a recent example 1Rex-Talbot et al. Progress in the fight against multidrug-resistant bacteria 2005-2016: Modern noninferiority trial designs enable antibiotic development in advance of epidemic bacterial resistance. Clin Infect Dis, 2017. Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 6

  7. 3. The public health consequences of only using superiority designs to advance new antibiotics Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 7

  8. Example: Plazomicin and CRE CRE = Carbapenem-resistant Enterobacteriaceae Plazomicin vs. colistin- based SOC1 for CRE 28-day all-cause mortality 8/20 10/20 4/17 2/17 8/20 2/17 Figure adapted from slide 24 the Jan 2017 Achaogen corporate presentation. Downloaded 24 Feb 2017 from http://files.shareholder.com/downloads/AMDA- 2JY46Z/3956962155x0x922829/80C50E00-4B27-4F84-B13F- 55DE31AABA28/AKAO-Corporate-Deck-January-2017.pdf 1SOC = Standard of Care Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 8

  9. Example: Plazomicin and CRE CRE = Carbapenem-resistant Enterobacteriaceae Plazomicin vs. colistin- based SOC for CRE Superiority is shown in this very small study because 28-day all-cause mortality 8/20 10/20 4/17 2/17 8/20 2/17 Figure adapted from slide 24 the Jan 2017 Achaogen corporate presentation. Downloaded 24 Feb 2017 from http://files.shareholder.com/downloads/AMDA- 2JY46Z/3956962155x0x922829/80C50E00-4B27-4F84-B13F- 55DE31AABA28/AKAO-Corporate-Deck-January-2017.pdf Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 9

  10. Example: Plazomicin and CRE CRE = Carbapenem-resistant Enterobacteriaceae Plazomicin vs. colistin- based SOC for CRE Superiority is shown in this very small study because 28-day all-cause mortality 8/20 10/20 4/17 2/17 8/20 2/17 ~6 people died on (due to) SOC Figure adapted from slide 24 the Jan 2017 Achaogen corporate presentation. Downloaded 24 Feb 2017 from http://files.shareholder.com/downloads/AMDA- 2JY46Z/3956962155x0x922829/80C50E00-4B27-4F84-B13F- 55DE31AABA28/AKAO-Corporate-Deck-January-2017.pdf Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 10

  11. Example: Plazomicin and CRE CRE = Carbapenem-resistant Enterobacteriaceae Plazomicin vs. colistin- based SOC for CRE Superiority is shown in this very small study because We are glad to have clarity on colistin s relative inefficacy but this is a steep price! As colistin is displaced as SOC, future drugs should not be able to plan on similar data 28-day all-cause mortality 8/20 10/20 4/17 2/17 8/20 2/17 ~6 people died on (due to) SOC Figure adapted from slide 24 the Jan 2017 Achaogen corporate presentation. Downloaded 24 Feb 2017 from http://files.shareholder.com/downloads/AMDA- 2JY46Z/3956962155x0x922829/80C50E00-4B27-4F84-B13F- 55DE31AABA28/AKAO-Corporate-Deck-January-2017.pdf Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 11

  12. Summary Non-inferiority trial designs are a necessary and essential part of antibiotic development Modern design NI studies conducted in the UDR setting vs. a high-quality comparator produce reliable data Using NI studies in this way permits new agents to be developed prior to epidemic spread of resistance Superiority designs are a valid tool but the ability to use them depends on existence of a public health problem with grim implications As new agents with activity against MDR/XDR pathogens are introduced, superiority designs will hopefully be difficult (or impossible to implement) Rex-Talbot 2017 CID - Modern noninferiority designs (three key ideas) 12

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