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PHARMAC responds on Herceptin assumptions and
decisions
We welcome the comments of Drs Richard Isaacs, Chris
Frampton, and Marion Kuper-Hommel about the funding in New Zealand of adjuvant
trastuzumab (Herceptin) for HER2-positive early breast
cancer.1 PHARMAC considers that, in terms of
its decision criteria, the available evidence for 9-weeks therapy, given
concurrently with taxanes, offers sufficient clinical benefits to justify its
funding, relative to other choices.
PHARMAC has weighed up the available evidence, together with
the wider and longer-term health care costs, in a logical, systematic, and
transparent 2,3
fashion. This has included accounting for the results of the larger trials,
fully and in their entirety, with aspects of study quality beyond
size 4 and missing
data. 5
FinHer 6
was a good trial giving adequate information to inform a concurrent 9-week
funding decision. The evidence for longer duration regimens from the larger
trials is hampered by good evidence of significant and appreciable
waning 7 (suggesting
poor durability 2) and the non-publication of
ostensibly good and highly relevant trial data from nearly 1000
participants. 2,5 These missing data may confirm
that sequential 12-month treatment is much less efficacious than concurrent and
than previously thought, as was seen in their interim
presentation, 5 and either way the data are
important and need to be published.
Responses to the correspondents’ specific points are
in Table 1 below. Much of their arguments were already discussed in detail in
the appendices (see links below) to the PHARMAC article itself, which inter
alia described in some depth the survival with HER2-positive early breast
cancer, epidemiology, and ethnic/regional disparities, and clinical
effectiveness including publication bias.
The emerging evidence2 will
feed into debates internationally about the optimal use of trastuzumab. The
optimal ‘standard of care’ is uncertain. Uncertainty around
sequencing and duration is a real issue and urgently needs to be addressed.
There needs to be full publication of all trial data around sequential
treatment, formal analysis of its durability, and proper trial evidence to
confirm optimal duration of treatment.
PHARMAC is supporting the SOLD trial internationally to help
resolve the duration question. Whilst awaiting these comparative data, PHARMAC
has taken the proactive pragmatic approach of funding the concurrent 9-week
regimen that is considered
cost-effective8—rather than funding
nothing, as currently the sequential 12-month regimen is not considered
cost-effective8 and is unjustifiable under
PHARMAC’s nine decision criteria.9
Once again, we appreciate the open debate of the issues in
the peer-reviewed setting,10 as discussion of
all of the evidence and its analysis is critical to understanding the quality of
PHARMAC’s decisions.
Conflict of interest: PHARMAC is
currently the subject of a Judicial Review of its decisions to fund a concurrent
9-week regimen of trastuzumab as adjunctive treatment of HER2-positive early
breast cancer and not to fund a sequential 12-month regimen at this stage.
Scott Metcalfe Chief Advisor Population Medicine
Jackie Evans Therapeutic Group Manager
PHARMAC, Wellington
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Topic
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PHARMAC
response
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Large patient numbers in trials
of longer duration treatment, vs. two small studies for shorter duration
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As covered in PHARMAC’s
article, major doubts persist as to optimal treatment sequencing and duration.
It is incorrect to combine all of the 12-month studies together, especially
given head-to-head RCT evidence of significant differences in efficacy and side
effects according to sequence5; given such
logic, it would be equally appropriate to compare all concurrent treatments,
including the FinHer regimen6, against
sequential regimens.5,7
Trials of the 12-month
sequential regimen, the regimen for which funding was sought, covered 5,365
patients, demonstrating a 30% relative reduction in disease events (HR 0.70, 95%
CI 0.61-0.81). These patients comprised 3,401 women in the 12-month trastuzumab
and standard care arms of HERA7 and 1,964 women
(2/3rds as many) in the 12-month sequential trastuzumab and standard care arms
of trial NCCTG-N98315—a comparison whose
publication is still awaited.
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FinHer’s power and
efficacy
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Our stance on the statistical
power of the FinHer trial remains unchanged, described on pages 28-30 of
Appendix 4 ( http://www.nzma.org.nz/journal/120-1256/2593/Afour.pdf).
This includes (but is not restricted to) FinHer’s results being
statistically significant despite its smaller size. As few as 145
patients would have been needed for the results to still be statistically
significant.
Large treatment
effects—likely to be more clinically worthwhile—but with wider
confidence intervals (greater imprecision) should not be ignored essentially
because of less power. Such concerns are analogous to post-hoc power
calculations—where in fact once results are available, a trial yields a
treatment effect and confidence interval for the results, and the power of the
trial is expressed in that confidence interval; hence ‘power’ is no
longer a meaningful
concern. 11
Although patently the results of
FinHer are numerically less precise than those of HERA or the other large
studies, the DFS results were statistically significant at the p=0.01 level, in
other words the odds are 99 times out of 100 that improvement in DFS in FinHer
would not be attributable to chance alone, and many treatments are funded with a
lesser degree of certainty.12 RCT data from 208
patients (TAnDEM) were sufficient for the EMEA to license the use of trastuzumab
with aromatase inhibitors in metastatic
disease.13
Compared with sequential
12-month treatment (updated HERA data7 and the
sequential arm of trial N98315), at the very
worst—i.e. the minimum extent that disease recurrence can confidently be
expected to reduce, using upper confidence limits for hazard ratios—the
FinHer results were as effective as sequential regimens (17% and 19% minimum
relative hazard reductions respectively), even with its smaller number of
patients.
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Only 54 FinHer patients used
trastuzumab and docetaxel
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Interestingly, the 54 patients
in FinHer using trastuzumab with docetaxel still showed significant improvements
in disease free survival (DFS) compared with those using docetaxel alone,
despite low numbers. Such comparison is duly caveated in Appendix 4; these
caveats however extend to the correspondents’ restricting analysis to
docetaxel patients alone. Using the correspondents’ logic would require
restricting HERA data analysis interpretation to its 889 patients who received
‘standard of care’ anthracycline and taxanes, where DFS effects were
reduced and not statistically significant (HR 0.80 (0.59-1.10)). We are not
seriously advocating this post-hoc approach, but neither should the FinHer data
be so separated.
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Standard regimens in the
trials
Receipt of protocol chemotherapy
in FinHer
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Chemotherapy regimens in FinHer
were no less standard than the regimens in other trials. A similar docetaxel
regimen to FinHer was also used in BCIRG 006; the NSABP B31 and NCCTG N9831
trials (Romond 200514) used paclitaxel.
Other trials (the basis for
continuing calls for longer duration treatment) had similar issues with patients
not receiving full-dose or protocol-specified therapy. In the HERA trial
chemotherapy was not specified, therefore there was large variation in the
regimens and doses used, and only 26% of patient received taxanes and 6%
received no anthracyclines at all; doses of docetaxel in HERA (11%) were not
described.7
The other studies have yet to
describe rates of patients reducing their docetaxel doses (or indeed other
chemotherapy drugs) as a result of adverse effects.
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Methodological flaws in longer
duration trials, and the balance of the FinHer trial arms
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FinHer was a properly randomised
trial with adequate reporting and concealment of allocation. Randomisation is
designed to eliminate confounding bias, both known and unknown; randomisation
balances out groups, including unknown factors, and groups will be by definition
balanced, occurring as a matter of course. The baseline
characteristics/prognostic indicators of the treatment groups were generally
well balanced, and less favourable axillary nodal metastases and
progesterone-negative tumours tended to be more frequent in the trastuzumab
group. Such factors tend to cancel each other out—the whole point of
appropriate randomisation. The impact on the overall outcome is therefore
considered to be minimal.
FinHer was the only trial of the
five that adequately reported its methods for concealing allocation—where
inadequate or unclear allocation concealment has been associated with 30-40%
larger estimates of treatment effects,11
conceivably overstating other regimens’ effects.
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Discussion of overall
survival
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In Appendix 4 (pages 30-31) we
discussed in some detail the issues around overall survival for the short
duration and long duration regimes. We invite wide readership of this material.
FinHer’s non-significant
overall survival (OS) results to date, well-acknowledged, probably result from
the combination of the small sample size and short follow-up at the time of
analysis; significant improvements in OS may become evident in the final 5-year
median follow-up analysis of FinHer expected later this year. This mirrors that
of the sequential 12-month treatment, where the initial lack of overall survival
benefit with the HERA study did not prevent widespread calls for its
funding—via linkage to the significant OS results for concurrent regimens.
Whilst HERA does now show significance in OS, there still remain serious
questions about the efficacy and durability of sequential trastuzumab.
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ECOG-2198
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Our article and Appendix 4 went
to some pains to note that trial ECOG-E2198 (comparing shorter-with
longer-duration trastuzumab regimens) was a pilot study and we excluded it from
further analysis. It simply supports the concept of efficacy with shorter,
concurrent, treatment.
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HERA’s waning of
effect
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The point with the waning of DFS
benefit with longer-term follow-up with the HERA
study7 is that it questions how durable
sequential treatment really is—where the implication has been,
unquestioned, that short-term benefits will last. This brings doubt on the
sequential 12-month regimen advocated, particularly when other important data
have not been published and are therefore out of
mind5—data that cast further doubt on the
extent of the effectiveness of sequential 12-month treatment. This latter point
needs to be acknowledged more widely.
As noted in the article and in
Appendix 4 (pages 16-17), contamination, being the cross-over of patients in
HERA to the control arm, seemed to have little influence—the opportunity
to cross-over occurred relatively late, and the DFS hazard ratios for both
intention-to-treat and censored analyses were identical. This concordance of
hazard ratios suggests a genuine waning of effect, not a crossover artefact as
argued by the correspondents.
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International view of the ethics
of continuing studies when controls are without 12 months treatment
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The correspondents’
claimed international view on the ethics of control groups without 12 months
trastuzumab is unreferenced and its universality needs to be verified.
We also wonder whether any such
an international view, if confirmed, will change, at least for sequential
treatment, as other countries grapple with the implications of the
non-publication to date of the NCCTG-N9831 Arm B (sequential)
data.5
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CaTSoP’s
role and recommendations
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CaTSoP is one of
12 specialist subcommittees to PTAC ( http://www.pharmac.govt.nz/sub_committee.asp),
advising PTAC which in turn gives free and frank advice to PHARMAC ( http://www.pharmac.govt.nz/ptac.asp).
The subcommittee structure provides clinical evaluations in specialist areas;
PTAC puts specific questions to subcommittees relating to actual clinical
practice and real-world issues in their specialty areas. Subcommittees are
subordinate to PTAC, providing information necessary for PTAC’s work but
that is insufficient in itself.
CaTSoP itself in
April 2006 gave the sequential 12-month treatment only a low/medium priority,
highlighting problems such as resource constraints, opportunity costs, and
long-term uncertainty. This recommendation was from oncologists for what had
been heavily promoted as an exciting and important “wonder drug”.
Based on this advice from CaTSoP and its own assessment of other information,
PTAC in August 2006 recommended the sequential 12-month sequential regimen be
declined. So in October 2006, CaTSoP was being asked to consider concurrent 9
weeks in isolation, without recourse to sequential 12-month treatment.
CaTSoP’s minute for that meeting noted the following: ‘At its 17
August 2006 meeting PTAC recommended that the application for the funding of
trastuzumab as per the HERA protocol (12-months treatment) be declined and that
the application be referred back to the Cancer Treatment Subcommittee of PTAC to
consider the clinical appropriateness of any funding regimen consistent with the
FinHer protocol (9-weeks treatment)’.
CaTSoP could
have said it was not clinically appropriate to fund concurrent 9 weeks, but did
not. The subcommittee instead recommended that, in the absence of availability
of funding for sequential 12 months treatment, concurrent 9-weeks treatment
would be reasonable and gave this recommendation a high priority. However,
CaTSoP noted, and wished to emphasise, that this recommendation was strongly
based on financial considerations since the subcommittee had more confidence in
the validity of the 12-month treatment results.
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PHARMAC’s budget
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PHARMAC’s role is to work
with the DHBs and determine how to allocate the funding the DHBs are supplied
between pharmaceutical spending and other spending. There are many competing
options, and in this case the levels and certainty of health benefits with the
12-month regimen were modest compared with the magnitude of funding, resource
implications and opportunity costs ( http://www.pharmac.govt.nz/pdf/030307c.pdf)
so that it did not amount to a good funding choice. Wider issues of funding and
budget setting are currently undergoing review as part of the government’s
review of its Medicines Strategy ( http://www.moh.govt.nz/moh.nsf/pagesmh/5633/$File/towards-newzealand-medicines-strategy-consult.doc).
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Adoption of expensive new
treatments
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The quality of care is not an
automatic given with the uptake of new therapies. The report cited by the
correspondents (Jönsson & Wilking 2007), paid for by
Roche15,16, has been criticised on a number of
grounds15,17, including:
- New
and expensive cancer drugs might not be any
more effective than therapies already in use. In terms of
value-for-money, one reason a drug may not be
recommended is that it isn't sufficiently better than
other drugs already available to make it cost
effective.15
- Population-based,
comparative survival studies have known
limitations18, and the ranking of countries
according to survival with cancer may be
flawed.19 Reporting biases, which will
understate cancer-ascribed mortality rates in some countries, result in other
countries such as the UK (and NZ) having over-stated high comparative mortality
rates. This is where not all countries are able to link
into national mortality statistics and
automatically be notified of cancer-related
deaths.15
- The
report relates the availability of cancer drugs in 38 countries in Europe in
2000 with the 5-year survival of patients diagnosed in those countries during
1990-94, some 6-10 years earlier. For 12 of the 38 countries involved, no such
survival data are said to actually
exist.20
- For
most cancers, higher survival is considered to result from earlier diagnosis and
a combination of expert surgery and/or radiotherapy, as well as from the use of
cancer drugs.16 ‘Huge decreases’ in
cancer mortality in the UK have been considered to be largely due to a downturn
in deaths caused by tobacco, and dramatically
improved breast cancer survival rates, mostly attributed
to the success of hormone
therapies.15
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Price and negotiation with
suppliers
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Negotiation with suppliers is a
key feature of most PHARMAC funding decisions. While price is clearly
important, PHARMAC is ultimately most interested in the value of
funding decisions (population health gains, etc, not just the price). Decisions
involve inseparable clinical and funding imperatives, and trastuzumab has been
no different.
While understanding
suppliers’ commercial drivers, PHARMAC is always, in effect through its
negotiation and other purchasing strategies, scrutinising pricing policies by
incentivising suppliers to offer attractive funding proposals. Some
commentators have also argued that suppliers should be more accountable to the
public about why some medicines are priced at the level they are. In this wider
context, Richard Peto, for example has been quoted “Patient organisations
may call for all effective treatment to be
available for free, but if this was the case it
would be exploited wholly by drug companies for
corporate profit—they would double their prices
overnight. The price rise in drugs has been
unprecedented and is made more acceptable by
reports like these. There is too much criticism
of the NHS and not enough of these companies’ pricing
policies.”15
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Appendices to Metcalfe et al NZMJ 15 June
20072:
References:
- Isaacs
RJ, Frampton CM, Kuper-Hummel MJJ. PHARMAC's funding of 9 weeks Herceptin: many
assumptions in a high-risk decision. N Z Med J. 2007;120(1259). http://www.nzma.org.nz/journal/120-1259/2676/
- Metcalfe
S, Evans J, Priest G. PHARMAC funding of 9-week concurrent trastuzumab
(Herceptin) for HER2-positive early breast cancer. N Z Med J. 2007 15
June;120(1256). http://www.nzma.org.nz/journal/120-1256/2593
- http://www.pharmac.govt.nz/herceptin.asp
- Wells
S. Summary of GATE critical appraisals of trastuzumab trials. EPIQ, University
of Auckland, May 2007. http://www.health.auckland.ac.nz/population-health/epidemiology-biostats/epiq/critical_appraisal_library/Herceptin
- Perez
EA. Further Analysis of NCCTG-N9831. Slide presentation ASCO annual meeting
2005. http://www.asco.org/ac/1,1003,_12-002511-00_18-0034-00_19-005815-00_21-001,00.asp
- Joensuu
H, Kellokumpu-Lehtinen PL, Bono P, et al. FinHer Study Investigators. Adjuvant
docetaxel or vinorelbine with or without trastuzumab for breast cancer. N Engl J
Med. 2006;354(8):809-20. http://content.nejm.org/cgi/content/full/354/8/809
- Smith
I, Procter M, Gelber RD, et al. 2 year follow up of trastuzumab after adjuvant
chemotherapy in HER2-positive breast cancer: a randomised controlled trial.
Lancet. 2007;369:29–36. http://www.thelancet.com/journals/lancet/article/PIIS0140673607600282/fulltext
- PHARMAC.
TAR 75 Trastuzumab (Herceptin) in HER-2 positive early breast cancer with 9 week
regimen CUA. Released May 2007. http://www.pharmac.govt.nz/pdf/030307c.pdf
- Moodie
P, McNee W, Metcalfe S. PHARMAC welcomes debate. N Z Med J. 2005;118(1218). http://www.nzma.org.nz/journal/118-1218/1572/
- PHARMAC
decision criteria at http://www.pharmac.govt.nz/pharmaceutical_schedule_update.asp
- Schulz
KF. Assessing allocation concealment and blinding in randomised controlled
trials. Why bother? Evidence Based Medicine. 2000;5:36-37.
- Hind
D, Pilgrim H, Ward S. Questions about adjuvant trastuzumab still remain. Lancet.
2007; 369:3-5. http://www.thelancet.com/journals/lancet/article/PIIS014067360760004X/fulltext
- Roche
media release 3 May 2006. Herceptin approved in Europe for use in combination
with an aromatase inhibitor for the treatment of patients with HER2 and hormone
receptor-co-positive metastatic breast cancer. http://www.roche.com/med-cor-2007-05-03
- Romond,
EH, Perez EA, Bryant J, et al. Trastuzumab plus adjuvant chemotherapy for
operable HER-2 positive breast cancer. N Engl J Med 2005;353(16):1659-1672. http://content.nejm.org/cgi/content/full/353/16/1673
- Coombes
R. Cancer drugs: swallowing big pharma's line? BMJ 2007;334:1034-5. http://www.bmj.com/cgi/content/full/334/7602/1034
- Boseley
S. Concern over cancer group's link to drug firm. The Guardian, 18 October 2006.
http://society.guardian.co.uk/health/story/0,,1924747,00.html
- Day
M. Experts dispute claims of poor cancer survival in UK. BMJ 2007;334:1021-a. http://www.bmj.com/cgi/content/full/334/7602/1021-a
- Berrino
F. The EUROCARE Study: strengths, limitations and perspectives of
population-based, comparative survival studies. Ann Oncol. 2003;14 Suppl
5:v9-13. http://annonc.oxfordjournals.org/cgi/reprint/14/suppl_5/v9
- Madsen
F, Frolund L, Nørskov B. The Eurocare 2 study re-evaluated: Ranking of
countries according to survival with cancer may be flawed. BMJ website 12 June
2007. http://www.bmj.com/cgi/eletters/334/7602/1021-a
Rapid response to Day M. Experts dispute claims of poor cancer survival in UK.
BMJ 2007;334:1021-a. http://www.bmj.com/cgi/content/full/334/7602/1021-a
- Research
behind new Europe-wide cancer campaign ‘all wrong’, 19 October 2006.
http://www.lshtm.ac.uk/news/2006/cancerunited.html
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