Development of Quantitative Comparative Approaches to Support Complex Generic Drug Development.

On October 27-28, 2022, the US Food and Drug Administration (FDA) and the Center for Research on Complex Generics (CRCG) hosted a virtual public workshop titled "Best Practices for Utilizing Modeling Approaches to Support Generic Product Development." This report summarizes the presentations and panel discussions for a session titled "Development of Quantitative Comparative Approaches to Support Complex Generic Drug Development." This session featured speakers and panelists from both the generic industry and the FDA who described applications of advanced quantitative approaches for generic drug development and regulatory assessment within three main topics of interest: (1) API sameness assessment for complex generics, (2) particle size distribution assessment, and (3) dissolution profile similarity comparison.

Statistical Considerations in Assessing In Vivo Adhesion with Transdermal and Topical Delivery Systems for New Drug Applications.

Proper adhesion plays a critical role in maintaining a consistent, efficacious, and safe drug delivery profile for transdermal and topical delivery systems (TDS). As such, in vivo skin adhesion studies are recommended by regulatory agencies to support the approval of TDS in new drug applications (NDAs). A draft guidance for industry by the US Food and Drug Administration outlines a non-inferiority comparison between a test product and its reference product for generic TDS in abbreviated new drug applications (ANDAs).

Baseline selection in concentration-QTc modeling: impact on assay sensitivity.

The baseline selection in concentration-QTc (C-QTc) modeling is not well studied in the literature. Time-matched baseline and pre-dose baseline have been commonly used as a covariate in C-QTc modeling for parallel and crossover study, respectively. It has been showed that the C-QTc model using time-matched baseline has a low chance of showing assay sensitivity in parallel study.

Non-inferiority tests for binary endpoints with variable margins.

Non-inferiority comparison between binary response rates of test and reference treatments is often performed in clinical studies. The most common approach to assess non-inferiority is to compare the difference between the estimated response rates with some margin. Previous methods use a variety of margins, including fixed margin, step-wise constant margin, and piece-wise smooth margin, where the latter two are functions of the reference response rate.

Methods and applications of percentile estimation.

Percentile is ubiquitous in statistics and plays a significant role in the day-to-day statistical application. FDA Guidance for Industry: Assay Development for Immunogenicity Testing of Therapeutic Protein Products (2016) recommends the use of a lower confidence limit of the percentile of the negative subject population as the cut point to guarantee a pre-specified false-positive rate with high confidence. Shen proposed and compared an exact t approach with some approximated approaches.

A modified Wald test for reference scaled assessment of analytical equivalence.

For the reference scaled equivalence hypothesis to reduce the deficiency of the current practice in analytical equivalence assessment, the Wald test with Constrained Maximum Likelihood Estimate (CMLE) of the standard error was proposed to improve the efficiency when the sample sizes of test and reference product lots are small, and variances are unequal. However, by using the Wald test with CMLE standard error, simulations show that the type I error rate is below the nominal significance level. We proposed the Modified Wald test with CMLE standard error by replacing the maximum likelihood estimate of reference standard deviation with the sample estimate (MWCMLE), resulting in further improvement of type I error rate and power over the Wald test with CMLE standard error.

Assay sensitivity in "Hybrid thorough QT/QTc (TQT)" study.

A concurrent positive control should be included in a thorough QTc clinical trial to validate the study according to ICH E14 guidance. Some pharmaceutical companies have started to use "hybrid TQT" study to meet ICH E14 regulatory requirements since the release of ICH E14 Q&A (R3). The "hybrid TQT" study includes the same treatment arms (therapeutic and/or supratherapeutic dose of investigational drug, placebo, and positive control) with sample size less than traditional TQT studies, but use concentration-QTc (C-QTc) analysis as primary analysis and assay sensitivity analysis.

Evaluation of dependent variable, time effect, covariates, and covariation structure in concentration-QTc modeling: A simulation study.

The revised ICH E14 Question and Answer (R3) document issued in December 2015 enables pharmaceutical companies to use concentration-QTc (C-QTc) modeling as the primary analysis for assessing QTc prolongation risk of new drugs. A new approach by including the time effect into the current C-QTc model is introduced. Through a simulation study, we evaluated performances of different C-QTc modeling with different dependent variables, covariates, and covariance structures.

Adjustment for unbalanced sample size for analytical biosimilar equivalence assessment.

Large sample size imbalance is not uncommon in the biosimilar development. At the beginning of a product development, sample sizes of a biosimilar and a reference product may be limited. Thus, a sample size calculation may not be feasible.

Exact test-based approach for equivalence test with parameter margin.

The equivalence test has a wide range of applications in pharmaceutical statistics which we need to test for the similarity between two groups. In recent years, the equivalence test has been used in assessing the analytical similarity between a proposed biosimilar product and a reference product. More specifically, the mean values of the two products for a given quality attribute are compared against an equivalence margin in the form of ±f × σ, where ± f × σ R is a function of the reference variability.

Development of statistical methods for analytical similarity assessment.

To evaluate the analytical similarity between the proposed biosimilar product and the US-licensed reference product, a working group at Food and Drug Administration (FDA) developed a tiered approach. This proposed tiered approach starts with a criticality determination of quality attributes (QAs) based on risk ranking of their potential impact on product quality and the clinical outcomes. Those QAs characterize biological products in terms of structural, physicochemical, and functional properties.

Sample size determination for a three-arm equivalence trial of Poisson and negative binomial responses.

Assessing equivalence or similarity has drawn much attention recently as many drug products have lost or will lose their patents in the next few years, especially certain best-selling biologics. To claim equivalence between the test treatment and the reference treatment when assay sensitivity is well established from historical data, one has to demonstrate both superiority of the test treatment over placebo and equivalence between the test treatment and the reference treatment. Thus, there is urgency for practitioners to derive a practical way to calculate sample size for a three-arm equivalence trial.

Ratio of means vs. difference of means as measures of superiority, noninferiority, and average bioequivalence.

Ratio of means (ROM) and difference of means (DOM) are often used in a superiority, noninferiority (NI), or average bioequivalence (ABE) test to evaluate whether the test mean is superior, NI, or equivalent to the reference (placebo or active control) mean. The literature provides recommendations regarding how to choose between ROM and DOM, mainly for superiority testing. In this article, we evaluated these two measures from other perspectives and cautioned the potential impact of different scoring systems/transformation for the same outcome (which is not rarely seen in practice) on the power of a ROM or DOM test for superiority, NI, or ABE.

Wald tests for variance-adjusted equivalence assessment with normal endpoints.

Equivalence tests may be tested with mean difference against a margin adjusted for variance. The justification of using variance adjusted non-inferiority or equivalence margin is for the consideration that a larger margin should be used with large measurement variability. However, under the null hypothesis, the test statistic does not follow a t-distribution or any well-known distribution even when the measurement is normally distributed.

Statistical considerations regarding correlated lots in analytical biosimilar equivalence test.

In the evaluation of the analytical similarity data, an equivalence testing approach for most critical and quantitative quality attributes, which are assigned to Tier 1 in their proposed three-tier approach, was proposed. The Food and Drug Administration (FDA) has recommended the proposed equivalence testing approach to sponsors through meeting comments for Pre-Investigational New Drug Applications (PINDs) and Investigational New Drug Applications (INDs) since 2014. The FDA has received some feedback on the statistical issues of potentially correlated reference lot values subjected to equivalence testing since independent and identical observations (lot values) from the proposed biosimilar product and the reference product are assumed.

Lessons Learned From Hundreds of Thorough QT Studies.

Background: The coherence between the relationship of QTc and drug plasma concentration (this relationship is measured through the slope) and ICH E14 findings based on hundreds of QT study reports was studied.

Results: Based on ICH E14 analysis, our findings indicate that if the slope was not positive, in most cases (86%) the corresponding QT studies were also negative. If the slope was positive, 92% of the corresponding QT studies were also positive.

Application of the modified chi-square ratio statistic in a stepwise procedure for cascade impactor equivalence testing.

Equivalence testing of aerodynamic particle size distribution (APSD) through multi-stage cascade impactors (CIs) is important for establishing bioequivalence of orally inhaled drug products. Recent work demonstrated that the median of the modified chi-square ratio statistic (MmCSRS) is a promising metric for APSD equivalence testing of test (T) and reference (R) products as it can be applied to a reduced number of CI sites that are more relevant for lung deposition. This metric is also less sensitive to the increased variability often observed for low-deposition sites.

Statistical considerations in setting product specifications.

According to ICH Q6A (1999), a specification is defined as a list of tests, references to analytical procedures, and appropriate acceptance criteria, which are numerical limits, ranges, or other criteria for the tests described. For drug products, specifications usually consist of test methods and acceptance criteria for assay, impurities, pH, dissolution, moisture, and microbial limits, depending on the dosage forms. They are usually proposed by the manufacturers and subject to the regulatory approval for use.

Quality assurance test of delivered dose uniformity of multiple-dose inhaler and dry powder inhaler drug products.

The delivered dose uniformity is one of the most critical requirements for dry powder inhaler (DPI) and metered dose inhaler products. In 1999, the Food and Drug Administration (FDA) issued a Draft Guidance entitled Nasal Spray and Inhalation Solution, Suspension, and Spray Drug Products-Chemistry, Manufacturing and Controls Documentation and recommended a two-tier acceptance sampling plan that is a modification of the United States Pharmacopeia (USP) sampling plan of dose content uniformity (USP34<601>). This sampling acceptance plan is also applied to metered dose inhaler (MDI) and DPI drug products in general.

Statistical evaluation of several methods for cut-point determination of immunogenicity screening assay.

The cut point of the immunogenicity screening assay is the level of response of the immunogenicity screening assay at or above which a sample is defined to be positive and below which it is defined to be negative. The Food and Drug Administration Guidance for Industry on Assay Development for Immunogenicity Testing of Therapeutic recommends the cut point to be an upper 95 percentile of the negative control patients. In this article, we assume that the assay data are a random sample from a normal distribution.

Using tolerance intervals for assessment of pharmaceutical quality.

In quality control of drug products, tolerance intervals are commonly used methods to assure a certain proportion of the products covered within a pre-specified acceptance interval. Depending on the nature of the quality attributes, the corresponding acceptance interval could be one-sided or two-sided. Thus, the tolerance intervals can also be one-sided or two-sided.

Statistical Properties of Large Sample Tests for Dose Content Uniformity.

The European Union (EU) test for uniformity of dosage units using large sample sizes was published in European Pharmacopoeia 7.7 in 2012. There are 2 alternative tests.