06/02/04DRAFT1. 06/02/04DRAFT2 QUESTIONS FOR PANEL Trial Design 1.The sponsor makes outcome comparisons between the selected subgroups of LVAS and control.

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Presentation transcript:

06/02/04DRAFT1

06/02/04DRAFT2 QUESTIONS FOR PANEL Trial Design 1.The sponsor makes outcome comparisons between the selected subgroups of LVAS and control patients, yet significant covariates of the two groups are not matched. Are such comparisons between groups with unmatched covariates valid?

06/02/04DRAFT3 QUESTIONS FOR PANEL Trial Design 2.Seven variables, with particular thresholds, were chosen as “relative contraindications” to heart transplant. Comparisons were made between transplant eligible LVAS and control patients meeting the chosen criteria. a.All of the selected patients were transplant eligible and were listed for transplant; the majority were transplanted. Are these patients comparable to to patients with these “relative contraindications” who are not transplant eligible and would not be listed or transplanted?

06/02/04DRAFT4 QUESTIONS FOR PANEL Trial Design 2.Seven variables, with particular thresholds, were chosen as “relative contraindications” to heart transplant. Comparisons were made between transplant eligible LVAS and control patients meeting the chosen criteria. b.Is there a sound scientific or clinical rationale for choosing the particular 7 “relative contraindications” selected and not including others (e.g., high PRAs, history of cancer, etc.)?

06/02/04DRAFT5 QUESTIONS FOR PANEL Trial Design 2.Seven variables, with particular thresholds, were chosen as “relative contraindications” to heart transplant. Comparisons were made between transplant eligible LVAS and control patients meeting the chosen criteria. c.Is there a sound scientific or clinical rationale for choosing the threshold values of the 7 selected variables such that the values, singly or in combination, are “relative contraindications” to transplant?

06/02/04DRAFT6 QUESTIONS FOR PANEL Trial Design 2.Seven variables, with particular thresholds, were chosen as “relative contraindications” to heart transplant. Comparisons were made between transplant eligible LVAS and control patients meeting the chosen criteria. d.Is the data sufficient to demonstrate the effect of the LVAS to “normalize” these 7 variables to justify expanding the label to include patients “… who are expected to become transplant candidates with mechanical circulatory support …”?

06/02/04DRAFT7 QUESTIONS FOR PANEL Effectiveness 3.Does the retrospective subgroup analysis of transplant eligible patients provide sufficient evidence of safety and of effectiveness to expand the labeling to include patients not eligible for transplantation?

06/02/04DRAFT8 QUESTIONS FOR PANEL Effectiveness 4.The sponsor wishes to add language indicating “.. short or long term …” use of the LVAS. Of 190 LVAS patients from the BTT trial 30 were on device ≥ 6 months; of those, 15 were on device ≥ 1 year; of those 4 were on device ≥ 2 years. Is that sufficient support to expand the labeling to include “long term” use?

06/02/04DRAFT9 QUESTIONS FOR PANEL Safety 5.Does the retrospective subgroup analysis of transplant eligible LVAS patients provide sufficient data to judge whether expanding the label to include patients not eligible for transplant is safe?

06/02/04DRAFT10 QUESTIONS FOR PANEL Labeling 6.Pre-market review of an expanded Indication for Use for an approved product includes review of the modified labeling. The labeling must include a description of the patients for whom the expanded use is intended and an explanation of how the product is to be used in those1010 patients to maximize clinical benefit while minimizing adverse events. Does the proposed expanded Indication for Use meet this requirement?