Surrogate endpoints in oncology: when are they acceptable for regulatory and clinical decisions, and are they currently overused?

BackgroundSurrogate outcomes are not intrinsically beneficial to patients, but are designed to be easier and faster to measure than clinically meaningful outcomes. The use of surrogates as an endpoint in clinical trials and basis for regulatory approval is common, and frequently exceeds the guidance given by regulatory bodies.DiscussionIn this article, we demonstrate that the use of surrogates in oncology is widespread and increasing. At the same time, the strength of association between the surrogates used and clinically meaningful outcomes is often unknown or weak. Attempts to validate surrogates are rarely undertaken. When this is done, validation relies on only a fraction of available data, and often concludes that the surrogate is poor. Post-marketing studies, designed to ensure drugs have meaningful benefits, are often not performed. Alternatively, if a drug fails to improve quality of life or overall survival, market authorization is rarely revoked.We suggest this reliance on surrogates, and the imprecision surrounding their acceptable use, means that numerous drugs are now approved based on small yet statistically significant increases in surrogates of questionable reliability. In turn, this means the benefits of many approved drugs are uncertain. This is an unacceptable situation for patients and professionals, as prior experience has shown that such uncertainty can be associated with significant harm.ConclusionThe use of surrogate outcomes should be limited to situations where a surrogate has demonstrated robust ability to predict meaningful benefits, or where cases are dire, rare or with few treatment options. In both cases, surrogates must be used only when continuing studies examining hard endpoints have been fully recruited.

[1]  A. Jena,et al.  The Trade-off Between Speed and Safety in Drug Approvals. , 2017, JAMA oncology.

[2]  Robert N. Stavins,et al.  ENVIRONMENTAL REGULATION IN THE 1990 S : A RETROSPECTIVE ANALYSIS , 2003 .

[3]  Daniel J Sargent,et al.  Disease-free survival versus overall survival as a primary end point for adjuvant colon cancer studies: individual patient data from 20,898 patients on 18 randomized trials. , 2004, Journal of clinical oncology : official journal of the American Society of Clinical Oncology.

[4]  K. Miller Questioning Our APHINITY for More. , 2017, The New England journal of medicine.

[5]  E. Eisenhauer,et al.  Progression-free survival: meaningful or simply measurable? , 2012, Journal of clinical oncology : official journal of the American Society of Clinical Oncology.

[6]  C. Booth,et al.  Randomized controlled trials in the era of molecular oncology: methodology, biomarkers, and end points. , 2012, Annals of oncology : official journal of the European Society for Medical Oncology.

[7]  V. Prasad,et al.  The Strength of Association Between Surrogate End Points and Survival in Oncology: A Systematic Review of Trial-Level Meta-analyses. , 2015, JAMA internal medicine.

[8]  Gideon Blumenthal,et al.  Pathological complete response and long-term clinical benefit in breast cancer: the CTNeoBC pooled analysis , 2014, The Lancet.

[9]  Huanyu Chen,et al.  FDA approval summary: crizotinib for the treatment of metastatic non-small cell lung cancer with anaplastic lymphoma kinase rearrangements. , 2014, The oncologist.

[10]  G. Molenberghs,et al.  The validation of surrogate endpoints in meta-analyses of randomized experiments. , 2000, Biostatistics.

[11]  S. Khozin,et al.  Milestone Analyses of Immune Checkpoint Inhibitors, Targeted Therapy, and Conventional Therapy in Metastatic Non–Small Cell Lung Cancer Trials: A Meta-analysis , 2017, JAMA oncology.

[12]  V. Prasad,et al.  Modern drug development: which patients should come first? , 2014, JAMA.

[13]  P. Neven,et al.  Everolimus plus exemestane for hormone-receptor-positive, human epidermal growth factor receptor-2-negative advanced breast cancer: overall survival results from BOLERO-2†. , 2014, Annals of oncology : official journal of the European Society for Medical Oncology.

[14]  V. Prasad,et al.  Strength of Validation for Surrogate End Points Used in the US Food and Drug Administration's Approval of Oncology Drugs. , 2016, Mayo Clinic proceedings.

[15]  Vinay Prasad,et al.  Cancer Drugs Approved on the Basis of a Surrogate End Point and Subsequent Overall Survival: An Analysis of 5 Years of US Food and Drug Administration Approvals. , 2015, JAMA internal medicine.

[16]  D. Zuckerman,et al.  Quality of Life, Overall Survival, and Costs of Cancer Drugs Approved Based on Surrogate Endpoints , 2017, JAMA internal medicine.

[17]  J. Baselga,et al.  Trastuzumab emtansine for HER2-positive advanced breast cancer. , 2012, The New England journal of medicine.

[18]  Richard Pazdur,et al.  Endpoints for assessing drug activity in clinical trials. , 2008, The oncologist.

[19]  Sung-Bae Kim,et al.  Pertuzumab, trastuzumab, and docetaxel for HER2-positive metastatic breast cancer (CLEOPATRA study): overall survival results from a randomised, double-blind, placebo-controlled, phase 3 study. , 2013, The Lancet. Oncology.

[20]  A. Kesselheim,et al.  Reputation and precedent in the bevacizumab decision. , 2011, The New England journal of medicine.

[21]  Marion Procter,et al.  Adjuvant Pertuzumab and Trastuzumab in Early HER2‐Positive Breast Cancer , 2017, The New England journal of medicine.

[22]  M. Buyse,et al.  Surrogate threshold effect: an alternative measure for meta-analytic surrogate endpoint validation. , 2006, Pharmaceutical statistics.

[23]  Daniel J Sargent,et al.  Estimation of tumour regression and growth rates during treatment in patients with advanced prostate cancer: a retrospective analysis. , 2017, The Lancet. Oncology.

[24]  V. Prasad,et al.  What constitutes an "unmet medical need" in oncology? An empirical evaluation of author usage in the biomedical literature. , 2017, Seminars in oncology.

[25]  Richard Pazdur,et al.  End points and United States Food and Drug Administration approval of oncology drugs. , 2003, Journal of clinical oncology : official journal of the American Society of Clinical Oncology.

[26]  M. Piccart,et al.  Everolimus in postmenopausal hormone-receptor-positive advanced breast cancer. , 2012, The New England journal of medicine.

[27]  E. Perez,et al.  Paclitaxel plus bevacizumab versus paclitaxel alone for metastatic breast cancer. , 2007, The New England journal of medicine.

[28]  V. Prasad,et al.  The role of censoring on progression free survival: oncologist discretion advised. , 2015, European journal of cancer.

[29]  Robert Ford,et al.  iRECIST: guidelines for response criteria for use in trials testing immunotherapeutics. , 2017, The Lancet. Oncology.