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Effect of Crossover in Oncology Clinical Trials on Evidence Levels in Early Benefit Assessment in Germany

Open ArchivePublished:November 07, 2017DOI:https://doi.org/10.1016/j.jval.2017.09.010

      Abstract

      Background

      In oncology clinical trials, crossover is used frequently but may lead to uncertainties regarding treatment effects.

      Objective

      To investigate the handling of evidence from crossover trials by the European Medicines Agency (EMA) and the German Federal Joint Committee (G-BA).

      Methods

      For oncology medicines with early benefit assessments before January 2015, presence of crossover, clinical data, EMA requests for additional data, and G-BA benefit ratings/evidence levels were analyzed from manufacturers’ dossiers, G-BA appraisals, European Public Assessment Reports, and original publications.

      Results

      Eleven of 21 benefit assessments included crossover trials. Significant intergroup differences (P < 0.05) in overall survival (OS) were noted in 7 of 11 trials with and 7 of 10 without crossover. For 6 of 11 medicines with crossover, these were demonstrated before crossover. Treatment effects generally worsened with increasing proportions of crossover. The EMA requested additional data more frequently if crossover was performed, particularly if no OS data were available before crossover. The G-BA granted a considerable benefit to 73% of medicines with crossover and 40% of those without. Evidence levels were intermediate for 50% and 75%, respectively. None of the medicines received the highest evidence level.

      Conclusions

      In G-BA appraisals, oncology medicines with crossover received better additional benefit ratings, but were assigned lower evidence levels, than those without. The five medicines with crossover after progression were assigned lower evidence levels than the six medicines with crossover after demonstration of superior OS, indicating that the way in which crossover is implemented may be one factor influencing the assignment of evidence levels by the G-BA.

      Keywords

      Introduction

      In oncology clinical trials, “crossover” usually describes trial designs that allow patients from the control group to switch to the intervention arm and receive the investigational product after a predefined study event, for example, either after disease progression or after demonstration of clinical superiority of the investigational medicine [
      • Ishak K.J.
      • Proskorovsky I.
      • Korytowsky B.
      • et al.
      Methods for adjusting for bias due to crossover in oncology trials.
      ]. Such designs are used frequently to maximize the number of patients who have access to the investigational drug in the study [
      • Latimer N.R.
      • Abrams K.R.
      • Lambert P.C.
      • et al.
      Adjusting survival time estimates to account for treatment switching in randomized controlled trials--an economic evaluation context: methods, limitations, and recommendations.
      ,
      • Prasad V.
      • Grady C.
      The misguided ethics of crossover trials.
      ]. Moreover, they facilitate recruitment by increasing the trial’s attractiveness to candidate patients [
      • Latimer N.R.
      • Abrams K.R.
      • Lambert P.C.
      • et al.
      Adjusting survival time estimates to account for treatment switching in randomized controlled trials--an economic evaluation context: methods, limitations, and recommendations.
      ,
      • Prasad V.
      • Grady C.
      The misguided ethics of crossover trials.
      ] because patients may be more willing to enroll in a trial in which they are guaranteed to receive a given experimental treatment at some point. This is particularly true when early-phase data suggest a substantial treatment effect of the investigational agent. However, implementing crossover in a trial will reduce the treatment differences between the randomized arms for long-term trial end points, such as overall survival (OS) [
      • Ishak K.J.
      • Proskorovsky I.
      • Korytowsky B.
      • et al.
      Methods for adjusting for bias due to crossover in oncology trials.
      ,
      • Latimer N.R.
      • Abrams K.R.
      • Lambert P.C.
      • et al.
      Adjusting survival time estimates to account for treatment switching in randomized controlled trials--an economic evaluation context: methods, limitations, and recommendations.
      ,

      European Medicines Agency. Guideline on the evaluation of anticancer medicinal products in man. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/01/WC500137128.pdf. [Accessed January 14, 2016].

      ] and thus can influence a study’s ability to answer a clinical question [
      • Prasad V.
      Use of the word “cure” in the oncology literature.
      ]. Results from a simulation study indicate that a crossover rate of more than 50% dramatically decreases the probability of detecting differences in OS by up to 90% [
      • Zhang L.
      • Ko C.-W.
      • Tang S.
      • et al.
      Relationship between progression-free survival and overall survival benefit—a simulation study.
      ].
      Favorable effects on OS are still considered the most persuasive outcomes of a clinical trial in oncology [

      European Medicines Agency. Guideline on the evaluation of anticancer medicinal products in man. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/01/WC500137128.pdf. [Accessed January 14, 2016].

      ]. The European Medicines Agency (EMA) recommends that crossover after disease progression should generally be avoided and be used only if there is confidence that the objectives of the trial can be met and adequate conclusions can be drawn [

      European Medicines Agency. Guideline on the evaluation of anticancer medicinal products in man. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/01/WC500137128.pdf. [Accessed January 14, 2016].

      ,

      European Medicines Agency. Appendix 1 to the guideline on the evaluation of anticancer medicinal products in man—methodological consideration for using progression-free survival (PFS) or disease-free survival (DFS) in confirmatory trials. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/01/WC500137126.pdf. [Accessed January 14, 2016].

      ].
      Given the challenges in determining OS, particularly in the presence of crossover, additional efficacy end points, such as progression-free survival (PFS), are frequently used in clinical trials in oncology. There is an ongoing debate whether PFS is a useful surrogate for OS in oncology [
      • Lakdawalla D.N.
      • Chou J.W.
      • Linthicum M.T.
      • et al.
      Evaluating expected costs and benefits of granting access to new treatments on the basis of progression-free survival in non-small-cell lung cancer.
      ,
      • Prasad V.
      • Kim C.
      • Burotto M.
      • et al.
      The strength of association between surrogate end points and survival in oncology: a systematic review of trial-level meta-analyses.
      ]. Although PFS may be accepted as a primary end point in oncology trials by regulatory agencies in certain settings and under certain conditions [

      European Medicines Agency. Appendix 1 to the guideline on the evaluation of anticancer medicinal products in man—methodological consideration for using progression-free survival (PFS) or disease-free survival (DFS) in confirmatory trials. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/01/WC500137126.pdf. [Accessed January 14, 2016].

      ], reliable and unbiased OS estimates are still likely to be required for health technology assessments [
      • Watkins C.
      • Huang X.
      • Latimer N.
      • et al.
      Adjusting overall survival for treatment switches: commonly used methods and practical application.
      ].
      In Germany, an early benefit assessment against the appropriate comparator therapy has been mandatory for new medicines since January 2011 [

      Bundesministerium für Gesundheit. [AM-NutzenV]. Available from: http://www.gesetze-im-internet.de/bundesrecht/am-nutzenv/gesamt.pdf. [Accessed January 14, 2016].

      ,

      Deutscher Bundestag. [Sozialgesetzbuch (SGB) Fünftes Buch (V) - Gesetzliche Krankenversicherung - (Artikel 1 des Gesetzes v. 20. Dezember 1988, BGBl. I S. 2477, letzte Änderung durch Artikel 3 des Gesetzes vom 20. Dezember 2012 (BGBI. I S. 2781))]. Available from: http://www.gesetze-im-internet.de/bundesrecht/sgb_5/gesamt.pdf. [Accessed January 14, 2016].

      ,
      • Ruof J.
      • Schwartz F.W.
      • Schulenburg J.M.
      • et al.
      Early benefit assessment (EBA) in Germany: analysing decisions 18 months after introducing the new AMNOG legislation.
      ]. The German Federal Joint Committee (Gemeinsamer Bundesausschuss [G-BA]) as the decision body and the Institute for Quality and Efficiency in Health Care (Institut für Qualität und Wirtschaftlichkeit im Gesundheitswesen [IQWiG]) as the scientific assessment body are charged with evaluating a medicine’s additional benefit. This evaluation is based on a dossier submitted by the manufacturer and is conducted according to the principles of evidence-based medicine [

      Bundesministerium für Gesundheit. [AM-NutzenV]. Available from: http://www.gesetze-im-internet.de/bundesrecht/am-nutzenv/gesamt.pdf. [Accessed January 14, 2016].

      ,

      G-BA. Chapter 5: assessment of the benefits of pharmaceuticals according to §35a SGB V. Available from: http://www.english.g-ba.de/downloads/17-98-3042/2011-05-18_5%20Kapitel%20VerfO%20Englisch.pdf. [Accessed January 14, 2016].

      ,

      Institut für Qualität und Wirtschaftlichkeit im Gesundheitswesen. Allgemeine Methoden 4.2. Available from: https://www.iqwig.de/download/IQWiG_Methoden_Version_4-2.pdf. [Accessed January 14, 2016].

      ]. In addition to the extent of additional benefit versus the appropriate comparator therapy—major, considerable, minor, not quantifiable, or no additional benefit (or less benefit) [
      • Ruof J.
      • Schwartz F.W.
      • Schulenburg J.M.
      • et al.
      Early benefit assessment (EBA) in Germany: analysing decisions 18 months after introducing the new AMNOG legislation.
      ,

      G-BA. Chapter 5: assessment of the benefits of pharmaceuticals according to §35a SGB V. Available from: http://www.english.g-ba.de/downloads/17-98-3042/2011-05-18_5%20Kapitel%20VerfO%20Englisch.pdf. [Accessed January 14, 2016].

      ]—the quality of the evidence base is evaluated. The evidence level is rated as proof (A), indication (B), or hint (C) on the basis of the number and characteristics of the submitted studies, the certainty of the results, and the consistency of the observed treatment effects [

      Institut für Qualität und Wirtschaftlichkeit im Gesundheitswesen. Allgemeine Methoden 4.2. Available from: https://www.iqwig.de/download/IQWiG_Methoden_Version_4-2.pdf. [Accessed January 14, 2016].

      ]. The highest evidence level (A) requires a statistically significant effect in a meta-analysis or at least two independent randomized controlled trials showing statistically significant treatment effects in the same direction. Lower evidence levels are assigned when the presented evidence is based on only one randomized controlled trial or is considered to have a higher potential for bias [

      Institut für Qualität und Wirtschaftlichkeit im Gesundheitswesen. Allgemeine Methoden 4.2. Available from: https://www.iqwig.de/download/IQWiG_Methoden_Version_4-2.pdf. [Accessed January 14, 2016].

      ]. Both the extent of additional benefit and the evidence level, together with other parameters, are considered by the National Association of Statutory Health Insurance Funds (Spitzenverband Bund der Krankenkassen) during the subsequent price negotiations with the manufacturer [

      GKV Spitzenverband. [AMNOG-Informationen - Thema: Zuzsatznutzen und Erstattungsbetrag]. Available from: https://www.gkv-spitzenverband.de/media/dokumente/krankenversicherung_1/arzneimittel/amnog_aktuell/20160114_AMNOG_Informationen_4_Zusammenhang_Zusatznutzen_und_EB_korr.pdf. [Accessed January 14, 2016].

      ].
      Currently, limited experience exists regarding the view of health technology assessment agencies on crossover trial design (e.g., the impact of crossover on the perceived evidence quality) [
      • Jönsson L.
      • Sandin R.
      • Ekman M.
      • et al.
      Analyzing overall survival in randomized controlled trials with crossover and implications for economic evaluation.
      ]. We investigated the impact of crossover trials on the evaluations by the EMA and by the G-BA. Specifically, we determined whether the G-BA considered the way crossover was used in its appraisal and whether crossover impacted the evidence levels granted.

      Methods

      Oncology medicines with benefit assessments completed before January 1, 2015, were evaluated [

      G-BA. Overview of products [Übersicht der Wirkstoffe]. Available from: http://www.g-ba.de/informationen/nutzenbewertung/. [Accessed January 14, 2016].

      ]. Orphan drugs were excluded from the analysis because an additional benefit is granted to such drugs by law [

      Deutscher Bundestag. [Sozialgesetzbuch (SGB) Fünftes Buch (V) - Gesetzliche Krankenversicherung - (Artikel 1 des Gesetzes v. 20. Dezember 1988, BGBl. I S. 2477, letzte Änderung durch Artikel 3 des Gesetzes vom 20. Dezember 2012 (BGBI. I S. 2781))]. Available from: http://www.gesetze-im-internet.de/bundesrecht/sgb_5/gesamt.pdf. [Accessed January 14, 2016].

      ]. Medicines for which no dossier was submitted were excluded because the basis for their assessment was missing.
      For all medicines included in the analysis, the assessed indication was recorded. Where a re-assessment of the same medicine for the same indication had been performed, only the most recent assessment was analyzed.
      Trials considered in G-BA appraisals were regarded as relevant for the analyses. Manufacturers’ dossiers and G-BA appraisals, both obtained from the G-BA Web site [

      G-BA. Overview of products [Übersicht der Wirkstoffe]. Available from: http://www.g-ba.de/informationen/nutzenbewertung/. [Accessed January 14, 2016].

      ], European Public Assessment Reports [

      European Medicines Agency. European public assessment reports. Available from: http://www.ema.europa.eu/ema/index.jsp?curl=pages/medicines/landing/epar_search.jsp&mid=WC0b01ac058001d124. [Accessed January 14, 2016].

      ], and original trial publications were used as source documents. The analyses of the selected medicines encompassed the following points:
      • 1.
        Presence of crossover trials
      • 2.
        Clinical data
      • 3.
        EMA’s assessment
      • 4.
        Benefit ratings and evidence levels granted by the G-BA

      Presence of Crossover Trials

      For this analysis, crossover was defined as a switch from a treatment specified for one group to a treatment specified for another group or to another treatment not included in the trial protocol that could occur either after disease progression or after reaching a predefined efficacy threshold. Medicines included in this analysis were divided into medicines with and without crossover studies.

      Clinical Data

      For all studies included in the analysis, the comparator therapy and the primary end point were extracted from the G-BA appraisal or the manufacturer’s dossier. For studies involving crossover, the manufacturer’s dossier was searched for a justification of the crossover design. Data on OS, PFS, and other primary end points were evaluated. OS and PFS were chosen because they are the most commonly used primary end points in oncology trials [
      • Ruof J.
      • Knoerzer D.
      • Duenne A.A.
      • et al.
      Analysis of endpoints used in marketing authorisations versus value assessments of oncology medicines in Germany.
      ]. For studies with more than one data cut, data from the cut mentioned in the G-BA appraisal or, if none was mentioned, the most recent cut, were used for evaluation. If the G-BA analyzed several patient subgroups, only data for the subgroup with the best benefit rating were considered. Statistically significant differences (P < 0.05) between intervention and control treatment were assessed.
      For medicines with crossover studies, it was determined whether data were available before crossover and whether there were statistically significant differences (P < 0.05) in OS, PFS, or other primary end points between the treatment arms before crossover.
      Medicines with crossover in at least one clinical trial that presented OS or PFS data from different data cuts and provided information on the proportions of crossover patients at these time points were identified to assess the development of treatment effects over time in crossover trials.

      EMA’s Assessment

      A conditional marketing authorization may be granted by the EMA in the absence of comprehensive clinical data to ensure immediate access to the medicine also outside of clinical trials [

      European Medicines Agency. Commission Regulation (EC) No 507/2006 of 29 March 2006 on the conditional marketing authorisation for medicinal products for human use falling within the scope of Regulation (EC) No 726/2004 of the European Parliament and of the Council. Available from: http://ec.europa.eu/health/files/eudralex/vol-1/reg_2006_507/reg_2006_507_en.pdf. [Accessed January 14, 2016].

      ]. In addition, the EMA may request postauthorization measures to obtain additional data and enable a more accurate assessment of the safety or efficacy of a new medicine [

      European Medicines Agency. Post-authorisation measures: questions and answers. Available from: http://www.ema.europa.eu/ema/index.jsp?curl=pages/regulation/q_and_a/q_and_a_detail_000037.jsp. [Accessed January 14, 2016].

      ].
      Requests for additional data by the EMA (conditional marketing authorizations or postauthorization measures concerning OS) as stated in the European Public Assessment Reports were identified.

      Benefit Ratings and Evidence Levels Granted by the G-BA

      Overall additional benefit ratings assigned to the analyzed medicines were extracted from G-BA appraisals. The additional benefit rating for mortality was analyzed separately, because mortality (i.e., OS) is the preferred benefit category in assessments of oncology medicines [
      • Ruof J.
      • Knoerzer D.
      • Duenne A.A.
      • et al.
      Analysis of endpoints used in marketing authorisations versus value assessments of oncology medicines in Germany.
      ] and because OS data can be strongly influenced by crossover [
      • Latimer N.R.
      • Abrams K.R.
      • Lambert P.C.
      • et al.
      Adjusting survival time estimates to account for treatment switching in randomized controlled trials--an economic evaluation context: methods, limitations, and recommendations.
      ,
      • Prasad V.
      • Grady C.
      The misguided ethics of crossover trials.
      ,

      European Medicines Agency. Appendix 1 to the guideline on the evaluation of anticancer medicinal products in man—methodological consideration for using progression-free survival (PFS) or disease-free survival (DFS) in confirmatory trials. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/01/WC500137126.pdf. [Accessed January 14, 2016].

      ,
      • Watkins C.
      • Huang X.
      • Latimer N.
      • et al.
      Adjusting overall survival for treatment switches: commonly used methods and practical application.
      ,
      • Jönsson L.
      • Sandin R.
      • Ekman M.
      • et al.
      Analyzing overall survival in randomized controlled trials with crossover and implications for economic evaluation.
      ]. Whether safety data had a positive, negative, or neutral effect on the overall benefit rating was also assessed. The level of evidence granted by the G-BA in its appraisals was analyzed for medicines with positive additional benefit ratings. For medicines for which the G-BA analyzed more than one patient subgroup, only the benefit rating and evidence level for the subgroup with the highest additional benefit were taken into account.
      To assess the impact of crossover on benefit assessments, a comparison of benefit ratings and evidence levels was performed for medicines with and without crossover studies.

      Results

      By January 1, 2015, 26 oncology medicines had completed 28 benefit assessments. Seven assessments (six orphan drugs and one medicine for which no dossier was submitted) were excluded from the analysis. Therefore, 21 assessments of 19 medicines form the basis of the presented analyses (Fig. 1). Table 1 presents the indication, the comparator therapy, and the primary end point used in the relevant studies.
      Fig. 1
      Fig. 1Benefit assessments for oncology medicines with and without crossover in clinical trials (analysis set). G-BA, Gemeinsamer Bundesausschuss (Federal Joint Committee).
      Table 1Indication, comparator therapy, primary end point, and reason for crossover (if applicable) in studies submitted by the manufacturer for oncology medicines with and without crossover studies
      MedicineIndicationComparator therapyPrimary end pointReason for crossover
      Oncology medicines with crossover studies
       Abiraterone acetate (second indication)Prostate cancer (after failure of androgen withdrawal)Placebo
      Both arms plus prednisone/prednisolone.
      OS and PFS
      OS and PFS were coprimary end points.
      ,
      PFS, CR/Cru, and ORR were composite primary end points.
      Primary end point reached in interim analysis
      The prespecified stopping boundary (P < 0.001) was reached only for PFS but crossover was recommended by the data safety monitoring board.
       AfatinibNSCLCCisplatin and pemetrexedPFS
      PFS, CR/Cru, and ORR were composite primary end points.
      After progression or intolerable toxicity (crossover ethically required if targeted therapies show early efficacy)
       CrizotinibNSCLCPemetrexed or docetaxelPFS
      PFS, CR/Cru, and ORR were composite primary end points.
      After progression (desire for unbiased OS assessment has to be weighed against ethical demands)
       DabrafenibMelanomaDacarbazinePFS
      PFS, CR/Cru, and ORR were composite primary end points.
      After progression (at the time of study design, phase I data suggested marked superiority of investigational product over the planned comparator)
       PertuzumabBreast cancerPlacebo
      Both arms plus trastuzumab emtansine and docetaxel.
      PFS
      PFS, CR/Cru, and ORR were composite primary end points.
      Primary end point reached in interim analysis
       Radium-223-dichlorideProstate cancerPlacebo
      Both arms plus best supportive care.
      OSPrimary end point reached in interim analysis
       RegorafenibMetastatic colorectal cancerPlacebo
      Both arms plus best supportive care.
      OSPrimary end point reached in interim analysis
       RuxolitinibChronic myeloproliferative disordersPlaceboProportion of subjects achieving ≥35% reduction in spleen volumeAfter progression (OS was not primary analysis goal; therefore, crossover permitted for ethical reasons)
       Trastuzumab emtansineBreast cancerLapatinib and capecitabineOS and PFS
      OS and PFS were coprimary end points.
      ,
      PFS, CR/Cru, and ORR were composite primary end points.
      Primary end point reached in interim analysis
       VandetanibThyroid neoplasmsPlaceboPFS
      PFS, CR/Cru, and ORR were composite primary end points.
      After progression (no other approved therapy available at the time of study)
       VemurafenibMelanomaDacarbazineOS and PFS
      OS and PFS were coprimary end points.
      ,
      PFS, CR/Cru, and ORR were composite primary end points.
      Primary end point reached in interim analysis
      Oncology medicines without crossover studies
       Abiraterone acetate (first indication)Prostate cancer (after chemotherapy)Placebo
      Both arms plus prednisone.
      OSNA
       AfliberceptColorectal cancerPlacebo
      Both arms plus irinotecan, 5-fluorouracil, and folinic acid (FOLFIRI).
      OSNA
       AxitinibRenal cell carcinomaSorafenibPFS
      PFS, CR/Cru, and ORR were composite primary end points.
      NA
       CabazitaxelProstate cancerMitoxantroneOSNA
       EnzalutamideProstate cancerPlacebo
      Both arms plus best supportive care.
      OSNA
       EribulinBreast cancerTreatment of physician’s choice (EMBRACE study) Capecitabine (study 301)OS (EMBRACE study) OS and PFS
      OS and PFS were coprimary end points.
      ,
      PFS, CR/Cru, and ORR were composite primary end points.
      (study 301)
      NA
       Ipilimumab (first indication)Melanoma (second line)Placebo
      Both arms plus best supportive care.
      OSNA
       Ipilimumab (second indication)Melanoma (first line)Various
      The manufacturer presented a pooled analysis of several studies for a head-to-historic-head comparison because no study against the appropriate comparator therapy as defined by the G-BA was available.
      Various
      The manufacturer presented a pooled analysis of several studies for a head-to-historic-head comparison because no study against the appropriate comparator therapy as defined by the G-BA was available.
      NA
       PixantroneNon-Hodgkin lymphomaMonotherapy with one of seven agents permitted per protocol (to be chosen by the physician)CR/Cru
      PFS, CR/Cru, and ORR were composite primary end points.
      NA
       VismodegibBasal cell carcinomaSingle-arm studyORR
      PFS, CR/Cru, and ORR were composite primary end points.
      NA
      CR/CRu, complete response and unconfirmed complete response; EMBRACE, Eisai Metastatic Breast Cancer Study Assessing Physician’s Choice versus E7389; NA, not applicable; NSCLC, non–small cell lung cancer; ORR, overall response rate; OS, overall survival; PFS, progression-free survival.
      low asterisk Both arms plus prednisone/prednisolone.
      OS and PFS were coprimary end points.
      PFS, CR/Cru, and ORR were composite primary end points.
      § The prespecified stopping boundary (P < 0.001) was reached only for PFS but crossover was recommended by the data safety monitoring board.
      || Both arms plus trastuzumab emtansine and docetaxel.
      Both arms plus best supportive care.
      # Both arms plus prednisone.
      low asterisklow asterisk Both arms plus irinotecan, 5-fluorouracil, and folinic acid (FOLFIRI).
      †† The manufacturer presented a pooled analysis of several studies for a head-to-historic-head comparison because no study against the appropriate comparator therapy as defined by the G-BA was available.

      Presence of Crossover Trials

      For 11 of 21 assessments (52%), at least 1 trial assessed by the G-BA included crossover (Fig. 1). Information on why a crossover design was used is presented in Table 1.

      Clinical Data

      Table 2 summarizes the data reported for the medicines with and without crossover studies.
      Table 2Data on OS, PFS, or primary end points other than OS/PFS, EMA requests for OS data, G-BA benefit ratings, and G-BA evidence level
      Oncology medicinesOS,
      In the case of subgroup analysis for a medicine, data for the subgroup with the highest additional benefit are shown.
      absolute values
      Data are median OS/PFS (mo), unless otherwise stated.
      HR (95% CI)
      PFS or primary end points other than OS/PFS,
      In the case of subgroup analysis for a medicine, data for the subgroup with the highest additional benefit are shown.
      absolute values
      Data are median OS/PFS (mo), unless otherwise stated.
      HR (95% CI)
      EMA request for OS dataG-BA benefit rating in terms of mortality
      In the case of subgroup analysis for a medicine, data for the subgroup with the highest additional benefit are shown.
      ,
      In the case of a re-assessment, the most recent assessment is shown. Categories for the overall benefit rating: 1, major; 2, considerable; 3, minor; 4, not quantifiable; 5, no additional benefit; and 6, less benefit. Categories for the evidence level: A, proof; B, indication; C, hint.
      Impact of safety data on overall G-BA benefit rating
      In the case of subgroup analysis for a medicine, data for the subgroup with the highest additional benefit are shown.
      ,
      In the case of a re-assessment, the most recent assessment is shown. Categories for the overall benefit rating: 1, major; 2, considerable; 3, minor; 4, not quantifiable; 5, no additional benefit; and 6, less benefit. Categories for the evidence level: A, proof; B, indication; C, hint.
      Overall G-BA benefit rating
      In the case of subgroup analysis for a medicine, data for the subgroup with the highest additional benefit are shown.
      ,
      In the case of a re-assessment, the most recent assessment is shown. Categories for the overall benefit rating: 1, major; 2, considerable; 3, minor; 4, not quantifiable; 5, no additional benefit; and 6, less benefit. Categories for the evidence level: A, proof; B, indication; C, hint.
      Overall G-BA evidence level
      In the case of subgroup analysis for a medicine, data for the subgroup with the highest additional benefit are shown.
      ,
      In the case of a re-assessment, the most recent assessment is shown. Categories for the overall benefit rating: 1, major; 2, considerable; 3, minor; 4, not quantifiable; 5, no additional benefit; and 6, less benefit. Categories for the evidence level: A, proof; B, indication; C, hint.
      With crossover studies
       Abiraterone acetate
      Data available before crossover (applicable only for oncology medicines with crossover studies).
      (second indication)
      35.3 vs 30.116.5 vs 8.3NoConsiderableNeutral2B
      0.79 (0.66–0.96)0.53 (0.45–0.62)
       Afatinib31.6 vs 21.113.7 vs 5.6NoConsiderableNeutral2B
      0.55 (0.36–0.85)0.28 (0.18–0.44)
       Crizotinib20.3 vs 22.87.7 vs 3.0Conditional approval, PAM related to OSNo additional benefitNeutral2
      Because of positive treatment effects on morbidity (vandetanib, vismodegib) or morbidity and quality of life (crizotinib). ¶Indirect/head-to-historic head comparison not accepted by the G-BA.
      C
      1.02 (0.681.54)0.49 (0.37–0.64)
       Dabrafenib18.2 vs 15.65.1 vs 2.7NoNo suitable evidenceNo suitable evidence5
      0.76 (0.481.21) (indirect comparison)0.30 (0.18–0.51) (indirect comparison)
       Pertuzumab
      Data available before crossover (applicable only for oncology medicines with crossover studies).
      NRNRNoConsiderableNeutral2C
      0.57 (0.44–0.74)0.55 (0.45–0.68)
       Radium-223-dichloride
      Data available before crossover (applicable only for oncology medicines with crossover studies).
      14.9 vs 11.3NDNoConsiderableNeutral2B
      0.70 (0.58–0.83)
       Regorafenib
      Data available before crossover (applicable only for oncology medicines with crossover studies).
      6.5 vs 5.02.0 vs 1.7NoRelevant increase in OSNegative3C
      0.77 (0.64–0.94)0.49 (0.42–0.58)
       RuxolitinibDeaths (%):Spleen reduction (%):PAM related to OSAdvantage in terms of OS
      Based on additional post hoc interim analyses that were considered by the G-BA, although they were not presented in the dossier, and that showed a statistically significant difference in OS in favor of ruxolitinib.
      Neutral2C
      27.1 vs 35.141.9 vs 0.7
      P < 0.05.
      0.69 (0.461.03)
       Trastuzumab emtansine
      Data available before crossover (applicable only for oncology medicines with crossover studies).
      30.9 vs 23.79.0 vs 6.9PAM related to OSConsiderablePositive2B
      0.70 (0.53–0.85)0.69 (0.55–0.85)
       VandetanibDeaths (%):Progression (%):Conditional approvalNo additional benefitNegative3
      Because of positive treatment effects on morbidity (vandetanib, vismodegib) or morbidity and quality of life (crizotinib). ¶Indirect/head-to-historic head comparison not accepted by the G-BA.
      C
      16.7 vs 16.736.5 vs 58.3
      1.06 (0.264.38)0.47 (0.29–0.77)
        Vemurafenib
      Data available before crossover (applicable only for oncology medicines with crossover studies).
      9.2 vs 7.85.3 vs 1.6PAM related to OSConsiderableNeutral2B
      0.37 (0.26–0.55)0.26 (0.20–0.33)
      Without crossover studies
       Abiraterone acetate (first indication)14.8 vs 10.95.6 vs 3.6NoConsiderableNeutral2B
      0.65 (0.54–0.77)0.67 (0.59–0.78)
       Aflibercept13.5 vs 12.16.9 vs 4.7NoRelevant increase in OSNegative3B
      0.82 (0.71–0.94)0.76 (0.66–0.87)
       Axitinib29.4 vs 27.812.1 vs 6.5NoNo additional benefitPositive3B
      0.81 (0.551.19)0.46 (0.32–0.68)
       Cabazitaxel15.1 vs 12.72.8 vs 1.4NoConsiderableNegative3B
      0.70 (0.59–0.83)0.74 (0.64–0.86)
       Enzalutamide18.4 vs 13.68.3 vs 2.9NoConsiderablePositive2B
      0.63 (0.53–0.75)0.40 (0.35–0.47)
      < 0.0001< 0.0001
       Eribulin16.0 vs 13.5NRNoConsiderableNeutral2C
      0.81 (0.71–0.92) (meta-analysis)
       Ipilimumab (first indication)10.1 vs 6.4NDNoConsiderableNeutral2B
      0.66 (0.51–0.87)
       Ipilimumab (second indication)NRNDNoNo suitable evidenceNo suitable evidence5
      0.48 (0.37–0.64)
      (head-to-historic-head comparison)
       Pixantrone13.9 vs 7.8PFS (mo):Conditional approvalNo suitable evidence
      Comparator therapy used in the study not accepted by the G-BA.
      No suitable evidence
      Comparator therapy used in the study not accepted by the G-BA.
      5
      0.76 (0.471.24)5.8 vs 2.8
      0.50 (0.32–0.78)
      CR/CRu (%):
      28.0 vs 4.1
      P < 0.05.
       Vismodegib1-y rate of OS (%): 91.6PFS (mo): 9.5Conditional approvalNo suitable evidenceNegative3
      Because of positive treatment effects on morbidity (vandetanib, vismodegib) or morbidity and quality of life (crizotinib). ¶Indirect/head-to-historic head comparison not accepted by the G-BA.
      C
      (95% CI 83.599.7)
      Single-arm study; HR calculation not possible.
      (95% CI 7.411.9)
      Single-arm study; HR calculation not possible.
      ORR (%): 42.9
      (95% CI 30.556.0)
      Single-arm study; HR calculation not possible.
      Note: Bold denotes significant differences between treatment arms (defined as P < 0.05).
      CI, confidence interval; CR/CRu, complete response and unconfirmed complete response; EMA, European Medicines Agency; G-BA, Gemeinsamer Bundesausschuss (Federal Joint Committee); HR, hazard ratio; ND, not determined; NR, not reported; ORR, overall response rate; OS, overall survival; PAM, postauthorization measure; PFS, progression-free survival.
      low asterisk In the case of subgroup analysis for a medicine, data for the subgroup with the highest additional benefit are shown.
      Data are median OS/PFS (mo), unless otherwise stated.
      In the case of a re-assessment, the most recent assessment is shown. Categories for the overall benefit rating: 1, major; 2, considerable; 3, minor; 4, not quantifiable; 5, no additional benefit; and 6, less benefit. Categories for the evidence level: A, proof; B, indication; C, hint.
      § Data available before crossover (applicable only for oncology medicines with crossover studies).
      || Because of positive treatment effects on morbidity (vandetanib, vismodegib) or morbidity and quality of life (crizotinib). Indirect/head-to-historic head comparison not accepted by the G-BA.
      # P < 0.05.
      low asterisklow asterisk Based on additional post hoc interim analyses that were considered by the G-BA, although they were not presented in the dossier, and that showed a statistically significant difference in OS in favor of ruxolitinib.
      †† Comparator therapy used in the study not accepted by the G-BA.
      ‡‡ Single-arm study; HR calculation not possible.
      All 11 medicines with crossover studies reported OS data (median OS and/or hazard ratio). In addition, 10 medicines (91%) presented data on PFS or a primary end point other than OS/PFS. Significant differences (P < 0.05) versus the control treatment were presented for 7 of 11 medicines for OS (64%) and for all 10 medicines presenting such data for PFS or a primary end point other than OS/PFS. Six of the seven medicines with a significant difference (P < 0.05) in OS between treatment arms demonstrated a positive effect before crossover, whereas for all four medicines without significant differences in OS (P ≥ 0.05), no data were available before crossover (Table 2).
      OS data were reported in 9 of 10 benefit assessments without crossover studies (90%). The remaining assessment was based on a single-arm study and presented mortality data in terms of the 1-year rate of OS. PFS was presented in 7 of 10 assessments (70%). Two of these additionally reported data on a primary end point other than OS/PFS. Significant treatment effects (P < 0.05) on OS were demonstrated in 7 of 10 assessments (70%). Six of 10 assessments (60%) presented significant differences (P < 0.05) in PFS or primary end points other than OS/PFS.
      OS data from different data cuts with varying proportions of crossover patients were available for 5 of 11 medicines with crossover trials (Fig. 2A). Similar data for PFS were provided for 4 of 11 medicines (Fig. 2B). For three of these medicines, data before and after crossover were available. For the remaining medicines, only time points after crossover were reported. The hazard ratios for OS and PFS generally increased (i.e., the treatment effect decreased) with an increasing proportion of patients who switched treatment. For ruxolitinib, the hazard ratios for OS were almost unaffected by the proportion of crossover patients.
      Fig. 2
      Fig. 2Impact of crossover on treatment effect. Hazard ratios for (A) OS and (B) PFS are shown in relation to the proportion of patients who switched therapy. OS, overall survival; PFS, progression-free survival.

      EMA’s Assessment

      Five of the 11 oncology medicines with crossover (46%) had a postauthorization measure related to OS (n = 4) and/or held a conditional marketing authorization (n = 2) (Table 2). For most of these medicines (three of five), no OS data were reported before crossover (Table 2). Only 2 of 10 medicines without crossover (20%) had a conditional marketing authorization, and none of them were subject to an OS-related postauthorization measure.

      Benefit Ratings and Evidence Levels Granted by the G-BA

      G-BA benefit ratings, in terms of both OS and overall, and evidence levels are listed in Table 2 and summarized in Figure 3. The influence of safety data on the assessment of overall benefit is presented in Table 2.
      Fig. 3
      Fig. 3Additional benefit ratings—in terms of (A) mortality and (B) overall—and evidence levels* (C) granted by the G-BA. G-BA, Gemeinsamer Bundesausschuss (Federal Joint Committee). *Medicines that granted no additional benefit were excluded from the evaluation of evidence levels (one and two benefit assessments with and without crossover, respectively).
      In terms of mortality, the G-BA granted an additional benefit to 8 of 11 (73%) medicines with crossover and to 6 of 10 (60%) medicines without crossover (Fig. 3A). Eight of 11 medicines with crossover (73%), but only 4 of 10 without crossover (40%), were granted a considerable overall additional benefit (Fig. 3B).
      Evidence levels were evaluated for 10 and 8 medicines with and without crossover that had received positive additional benefit ratings. None of the medicines were granted the highest evidence level (A). For half of the medicines with crossover (5 of 10 [50%]) and 6 of 8 medicines without crossover (75%), the evidence level was considered to be intermediate (B). In summary, benefit ratings were better for medicines with crossover studies than for those without. However, the granted evidence levels were lower.

      Discussion

      In clinical trials in oncology, particularly when OS is the primary end point, crossover trial designs that allow patients randomized to the control arm to cross over to the investigational treatment play an important role. However, the crossover design limits the robustness of the evidence generated, and finding the right balance between fulfilling scientific evidence requirements and ensuring timely patient access to a superior treatment, both in the study and outside of clinical trials, is a sensitive issue. This is especially important in light of the increasing influence of payers and their high standards regarding evidence generation. From our point of view, two types of trial designs have to be taken into consideration: 1) crossover after disease progression is permitted from study start and 2) crossover occurs after a prespecified stopping boundary has been exceeded.
      • 1.
        Crossover after disease progression from study start
        In the first scenario, the primary end point is typically PFS because no appropriate, unbiased OS data are generated before crossover. Crossover to the intervention arm is usually permitted when a patient in the control arm experiences disease progression [
        • Morden J.P.
        • Lambert P.C.
        • Latimer N.
        • et al.
        Assessing methods for dealing with treatment switching in randomised controlled trials: a simulation study.
        ]. In this case, all available OS data will be affected by crossover, and the true treatment effect will be difficult to discern. In many cases, a benefit in terms of disease progression will be observed, but there will be no convincing differences in OS. This can be observed for four of the five medicines with crossover after progression from study start in the present analysis (ruxolitinib, crizotinib, dabrafenib, and vandetanib; see Table 2). There are three possible explanations for these observations: the investigational medicine confers an OS benefit that is masked by crossover; there is a treatment effect on PFS but not on OS; or a decrease in cancer-related mortality is counterbalanced by an increase in non–cancer-related deaths [
        • Prasad V.
        • Grady C.
        The misguided ethics of crossover trials.
        ].
        For some medicines with a substantial treatment effect on OS, it may be possible to demonstrate an OS benefit even in the presence of crossover [
        • Prasad V.
        • Kim C.
        • Burotto M.
        • et al.
        The strength of association between surrogate end points and survival in oncology: a systematic review of trial-level meta-analyses.
        ]. For the fifth medicine with crossover in this analysis, afatinib, a statistically significant treatment effect on OS (P < 0.05) was demonstrated in one patient subgroup, in spite of crossover after progression throughout the study (see Table 2). However, the exact extent of the OS benefit is unknown, which will lead to uncertainty in subsequent evaluations [
        • Prasad V.
        • Grady C.
        The misguided ethics of crossover trials.
        ].
        In certain types of cancers, OS is not considered the primary analysis goal, for example, in diseases with a high cure rate or a slow chronic course that would require extensive study periods or large patient numbers to allow meaningful OS evaluations [
        • Wörmann B.
        • Freund M.
        • Overkamp F.
        • et al.
        Status of clinical trials in oncology--2013 and onwards [in German].
        ,
        • Soria J.C.
        • Massard C.
        • Le C.T.
        Should progression-free survival be the primary measure of efficacy for advanced NSCLC therapy?.
        ]. In such cases, it may be considered necessary to permit crossover after progression from study start for ethical reasons: this was done for ruxolitinib in chronic myeloproliferative disorders [

        G-BA. Overview of products [Übersicht der Wirkstoffe]. Available from: http://www.g-ba.de/informationen/nutzenbewertung/. [Accessed January 14, 2016].

        ]. However, the EMA stipulates that crossover after progression should be used only if an unfavorable effect on OS can be excluded [

        European Medicines Agency. Guideline on the evaluation of anticancer medicinal products in man. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/01/WC500137128.pdf. [Accessed January 14, 2016].

        ], which may or may not be possible on the basis of the data obtained.
        The inherent uncertainty about OS data from trials with crossover from study start is reflected in the evidence levels granted by the G-BA. Out of five medicines for which such a design was used, one was rated as having no additional benefit and thus no evidence level, one received an intermediate evidence level, and three received the lowest level. Of note, the EMA requested additional OS data for all these three medicines, further highlighting the uncertainty associated with such data. In line with the requirements stipulated in EMA guidelines [

        European Medicines Agency. Guideline on the evaluation of anticancer medicinal products in man. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/01/WC500137128.pdf. [Accessed January 14, 2016].

        ,

        European Medicines Agency. Appendix 1 to the guideline on the evaluation of anticancer medicinal products in man—methodological consideration for using progression-free survival (PFS) or disease-free survival (DFS) in confirmatory trials. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2013/01/WC500137126.pdf. [Accessed January 14, 2016].

        ], the IQWiG recommends that trials should present at least one reliable interim analysis before crossover is introduced [
        • Vervölgyi V.
        • Beckmann L.
        Beurteilung von Treatment Switching in Bewertungen des Instituts.
        ]. Therefore, the granting of low evidence levels by the G-BA appears justified if no such data are presented.
        If no reliable OS data are available, medicines are essentially approved on the basis of improvements in surrogate end points such as PFS or overall response rate. However, experience has shown that the use of surrogate end points is not without issues [
        • Prasad V.
        • Kim C.
        • Burotto M.
        • et al.
        The strength of association between surrogate end points and survival in oncology: a systematic review of trial-level meta-analyses.
        ,

        Jena AB, Zhang J, Lakdawalla DN. The trade-off between speed and safety in drug approvals [published online ahead of print September 29, 2016]. JAMA Oncol. doi:10.1001/jamaoncol.2016.3337.

        ]. The European Network for Health Technology Assessment has suggested that the use of PFS data without supporting OS data should be confined to the adjuvant setting [

        European Network for Health Technology Assessment. Endpoints used for relative effectiveness assessment: clinical endpoints. Available from: https://eunethta.fedimbo.belgium.be/sites/5026.fedimbo.belgium.be/files/explorer/WP7-SG3-GL-clin_endpoints_amend2015.pdf. [Accessed January 14, 2016].

        ]. A recent systematic review of trial-level meta-analyses found that 52% of correlations between surrogate end points and OS were weak [
        • Prasad V.
        • Kim C.
        • Burotto M.
        • et al.
        The strength of association between surrogate end points and survival in oncology: a systematic review of trial-level meta-analyses.
        ]. It has been argued that, conversely, 48% of correlations are not perfect, but reasonably strong [

        Jena AB, Zhang J, Lakdawalla DN. The trade-off between speed and safety in drug approvals [published online ahead of print September 29, 2016]. JAMA Oncol. doi:10.1001/jamaoncol.2016.3337.

        ], and that the association between OS and PFS will never be definite, even within a given indication [

        European Network for Health Technology Assessment. Endpoints used for relative effectiveness assessment: clinical endpoints. Available from: https://eunethta.fedimbo.belgium.be/sites/5026.fedimbo.belgium.be/files/explorer/WP7-SG3-GL-clin_endpoints_amend2015.pdf. [Accessed January 14, 2016].

        ]. However, it may be challenging to establish a valid association in the first place if OS data from available trials are affected by crossover or any subsequent therapy after patients stop study treatment [
        • Diaz J.
        • Sternberg C.N.
        • Mehmud F.
        • et al.
        Overall survival endpoint in oncology clinical trials: addressing the effect of crossover--the case of pazopanib in advanced renal cell carcinoma.
        ], which can be expected to be particularly relevant to studies in the front-line setting [
        • Blumenthal G.M.
        • Karuri S.W.
        • Zhang H.
        • et al.
        Overall response rate, progression-free survival, and overall survival with targeted and standard therapies in advanced non-small-cell lung cancer: US Food and Drug Administration trial-level and patient-level analyses.
        ].
      • 2.
        Crossover after demonstration of superior efficacy in terms of OS
        The second scenario of a crossover trial design in oncology is the implementation of crossover following the demonstration that the investigational agent improves outcomes. This decision may be based on the crossing of a predefined stopping boundary in an interim analysis and/or endorsed by an independent monitoring board. In addition to the introduction of crossover, enrollment may be stopped [
        • Trotta F.
        • Apolone G.
        • Garattini S.
        • et al.
        Stopping a trial early in oncology: for patients or for industry?.
        ]. Consequently, OS data unaffected by crossover will be available up to, but not beyond, the time of the interim analysis.
        Crossover was implemented following the demonstration of superior efficacy in terms of OS for six medicines included in this analysis. For four of these (pertuzumab, radium-223-dichloride, regorafenib, and trastuzumab emtansine), crossover had been implemented only after the most recent data cut. Consequently, only the long-term follow-up for OS, but none of the OS data presented in the dossier, was impacted by crossover. For two medicines (abiraterone acetate and vemurafenib), OS data before and after crossover were available [

        G-BA. Overview of products [Übersicht der Wirkstoffe]. Available from: http://www.g-ba.de/informationen/nutzenbewertung/. [Accessed January 14, 2016].

        ].
        Especially in long-term trials, interim analyses are performed to monitor whether the available data on efficacy and/or safety indicate that the trial should be modified or stopped. This is also recognized by the EMA, which cautions that the risk of damaging the integrity of a trial must be minimized, particularly in late-stage trials [

        Committee for Medicinal Products for Human Use. Reflection paper on methodological issues in confirmatory clinical trials planned with an adaptive design. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2009/09/WC500003616.pdf. [Accessed January 14, 2016].

        ]. Generally, when considering stopping a trial early, obtaining the most accurate estimate for the treatment effect must be weighed against minimizing the number of trial participants who receive an inferior treatment [
        • Goodman S.N.
        Stopping trials for efficacy: an almost unbiased view.
        ]. Stopping trials early appears to have become more common in oncology [
        • Trotta F.
        • Apolone G.
        • Garattini S.
        • et al.
        Stopping a trial early in oncology: for patients or for industry?.
        ] and in general [
        • Montori V.M.
        • Devereaux P.J.
        • Adhikari N.K.
        • et al.
        Randomized trials stopped early for benefit: a systematic review.
        ]. Commercial motives have been suspected [
        • Trotta F.
        • Apolone G.
        • Garattini S.
        • et al.
        Stopping a trial early in oncology: for patients or for industry?.
        ,
        • Mueller P.S.
        • Montori V.M.
        • Bassler D.
        • et al.
        Ethical issues in stopping randomized trials early because of apparent benefit.
        ], but alternative explanations, such as the increasing use of targeted therapies and improved application of statistical principles, are also possible [
        • Bradbury P.
        • Meyer R.
        • Pater J.
        • et al.
        Stopping a trial early in oncology: for patients or for industry?.
        ]. The main concerns associated with premature study termination are the fact that the differences observed may represent only a random high or low [
        • Goodman S.N.
        Stopping trials for efficacy: an almost unbiased view.
        ,
        • Heffner A.C.
        • Milbrandt E.B.
        • Venkataraman R.
        Trials stopped early for benefit? Not so fast!.
        ,
        • Wilcox R.A.
        • Djulbegovic B.
        • Moffitt H.L.
        • et al.
        Randomized trials in oncology stopped early for benefit.
        ], and/or the large treatment effects observed in these trials, especially with low numbers of events [
        • Montori V.M.
        • Devereaux P.J.
        • Adhikari N.K.
        • et al.
        Randomized trials stopped early for benefit: a systematic review.
        ,
        • Wilcox R.A.
        • Djulbegovic B.
        • Moffitt H.L.
        • et al.
        Randomized trials in oncology stopped early for benefit.
        ]. However, such large effects can be expected when stopping rules are used, because a large outcome difference is required to generate a significance level exceeding a predefined level in an early interim analysis [
        • Pater J.L.
        • Goss P.
        • Meyer R.
        Stopping trials for benefit can (sometimes) benefit patients.
        ]. Therefore, the fact that a trial is stopped prematurely should not per se be interpreted to mean that the estimated effect size is incorrect [
        • Goodman S.N.
        Stopping trials for efficacy: an almost unbiased view.
        ]. Results from a simulation study confirmed that for trials with well-designed interim-monitoring plans, an inflation of the treatment effect is only likely for interim analyses based on 25% or less of the planned total events [
        • Freidlin B.
        • Korn E.L.
        Stopping clinical trials early for benefit: impact on estimation.
        ]. There is a general consensus that stopping a trial early may be acceptable if interim analyses are based on a sufficiently large number of events and use stopping rules associated with low P values [
        • Mueller P.S.
        • Montori V.M.
        • Bassler D.
        • et al.
        Ethical issues in stopping randomized trials early because of apparent benefit.
        ,
        • Heffner A.C.
        • Milbrandt E.B.
        • Venkataraman R.
        Trials stopped early for benefit? Not so fast!.
        ]. Confirmatory analyses, for example, comprising also those patients not yet included in the interim analysis, may lend more credibility to the results [

        Committee for Medicinal Products for Human Use. Reflection paper on methodological issues in confirmatory clinical trials planned with an adaptive design. Available from: http://www.ema.europa.eu/docs/en_GB/document_library/Scientific_guideline/2009/09/WC500003616.pdf. [Accessed January 14, 2016].

        ,
        • Mueller P.S.
        • Montori V.M.
        • Bassler D.
        • et al.
        Ethical issues in stopping randomized trials early because of apparent benefit.
        ]. Moreover, the clinical context should be considered [
        • Mueller P.S.
        • Montori V.M.
        • Bassler D.
        • et al.
        Ethical issues in stopping randomized trials early because of apparent benefit.
        ,
        • Whitehead J.
        • Cobo E.
        Stopping a trial early in oncology: for patients or for industry?.
        ].
        For the six medicines with crossover after an interim analysis, the decision to implement crossover and/or stop the trial was made following interim analyses based on approximately 40% to 70% of the planned number of total deaths (18). P values were less than 0.01 for all medicines and less than 0.001 for three medicines. According to the simulation study cited above, an inflation of the treatment effect should therefore be unlikely. Data from additional analyses before crossover are mentioned in the dossiers of two medicines (radium-223-dichloride and regorafenib) and confirm the results of the interim analyses. For the other four medicines, additional OS analyses after crossover are available either in the dossiers (abiraterone acetate and vemurafenib [

        G-BA. Overview of products [Übersicht der Wirkstoffe]. Available from: http://www.g-ba.de/informationen/nutzenbewertung/. [Accessed January 14, 2016].

        ]) or from the literature (pertuzumab [
        • Swain S.M.
        • Baselga J.
        • Kim S.B.
        • et al.
        Pertuzumab, trastuzumab, and docetaxel in HER2-positive metastatic breast cancer.
        ] and trastuzumab emtansine [
        • Diéras V.
        • Miles D.
        • Verma S.
        • et al.
        Trastuzumab emtansine versus capecitabine plus lapatinib in patients with previously treated HER2-positive advanced breast cancer (EMILIA): a descriptive analysis of final overall survival results from a randomised, open-label, phase 3 trial.
        ]) and demonstrate sustained superiority in spite of crossover. Therefore, it can be concluded that the conduct of the studies in question meets high standards in all six cases. This is supported by the observation that the EMA requested additional OS data for only two of these medicines (trastuzumab emtansine and vemurafenib) and that these requests exclusively referred to already planned evaluations of OS to be performed after approval.
        The G-BA accorded the lowest evidence level to two medicines, regorafenib and pertuzumab, because of an unclear relevance of the study to the German context and uncertainties regarding non-OS data. The other four of the six medicines, including those for which the EMA had requested additional data, received an intermediate evidence level. In two cases, this was due to data-related uncertainties. However, for the remaining two medicines (abiraterone acetate and radium-223-dichloride), the only reason why the highest evidence level was not granted was the conduct of only one study. The same argument was put forward for three of the six medicines without crossover that were granted an intermediate evidence level [

        G-BA. Overview of products [Übersicht der Wirkstoffe]. Available from: http://www.g-ba.de/informationen/nutzenbewertung/. [Accessed January 14, 2016].

        ], suggesting that the conclusiveness of trials with crossover after a meaningful interim analysis may be considered similar to that of trials without crossover.
        IQWiG guidance maintains that generally two pivotal trials are required to receive the highest evidence level [

        Institut für Qualität und Wirtschaftlichkeit im Gesundheitswesen. Allgemeine Methoden 4.2. Available from: https://www.iqwig.de/download/IQWiG_Methoden_Version_4-2.pdf. [Accessed January 14, 2016].

        ]. Especially in oncology, however, ethical considerations often make the conduct of a second trial challenging if convincing data indicating superiority of the investigational treatment, particularly with regard to OS, have been obtained in a first trial. This is due to the general perception that uncertainty regarding which of the analyzed treatments is more effective is required for a randomized trial to be ethical [
        • Kurzrock R.
        • Stewart D.J.
        Equipoise abandoned? Randomization and clinical trials.
        ].
        A limitation of this analysis is the relatively small data set, because the number of available oncology assessments is limited. More differentiated findings regarding G-BA’s view on crossover are expected to emerge in the coming years when more medicines have undergone the assessment procedure. Furthermore, this analysis is based on a conservative estimation because assessments for the best subgroup were considered in the case of subgroup analyses, irrespective of subgroup size. This is likely to have led to a positive shift in the G-BA ratings.

      Conclusions

      Oncology medicines with crossover trials were granted better additional benefit ratings by the G-BA than those without. However, the assigned evidence levels were lower. Within the group of medicines with crossover trials, the assigned evidence levels were lower for five medicines with crossover after progression from study start than for six medicines with crossover following demonstration of significant OS differences (P < 0.05). The latter were assigned evidence levels comparable to those of medicines with no crossover, indicating that the way in which crossover is implemented may be one factor influencing the evidence levels assigned by the G-BA. None of the medicines received the highest evidence level, regardless of crossover.

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