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Possible Approval Pathways for Mitral Valve Device Therapies FDA View

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Presentation on theme: "Possible Approval Pathways for Mitral Valve Device Therapies FDA View"— Presentation transcript:

1 Possible Approval Pathways for Mitral Valve Device Therapies FDA View
John Laschinger, M.D. Medical Officer Structural Heart Device Branch DCD/ODE/CDRH

2 Disclosures and Disclaimer
John C. Laschinger, M.D. I am a full time employee of the FDA. I have no financial conflicts of interest to report. The views expressed in this presentation are those of the presenter and do not represent the official policies of the FDA.

3 Mitral Regurgitation (MR) Simple Problem (valve leaks), Complex Disease
Primary (Degenerative) MR Valve complex is the Disease Annulus, Leaflet and/or Chordae Pathology e.g. Barlow’s, Marfan, Fibroelastic deficiency Surgery is gold standard Early restoration of MV competence is “curative” Device Repair/Replacement requires RCT proof of clinical equivalence MV Repair is Comparator Patients with Class I Indication Individual Surgeon skill/experience a factor Underutilized Optimal repair (MR < mild) essential Secondary(Functional) MR Primarily a disease of the ventricle Valve leaflets typically normal LV enlarged and Papillary muscle(s) displaced restricted leaflet motion Annular dilatation No Gold Standard Therapy Progressive LV Dysfunction - Is MR Cause or Effect? MR Correction - not curative - palliative?? Is MR reduction palliative, does it halt progression? Optimal comparator therapy – Uncertain Medical Therapy (GDMT) Titration and adherence MR reduction - devices MR correction Surgical Repair - Prone to recurrence Surgery and Device Replacement – higher initial risks

4 Clinical Evidence Acquisition Plan Enrollment and Data Quality Assurance
Identification of Appropriate Study Sites Patient mix* Facility resources* Track record of performance in clinical research studies (personnel, enrollment, protocol adherence, complete and accurate data, etc) Identification of appropriate patients Central Steering Committee Assurance of Appropriate Personnel Heart Team – minimum composition Skilled* Interventionalist Skilled* Surgeon Heart Failure Physician Skilled* Echocardiographer available in Cath lab/OR Adjudication of Critical Data Primary Endpoint Outcomes, Major Adverse Events Imaging Endpoints *based on disease/therapies

5 What is Control Therapy Choice of Comparator for MR trials
Dictated by Indication for Use Disease (intended use) Availability of standard of care (SOC) therapy Unmet clinical need Population of Use (conditions of use) Cause of valvular dysfunction - Primary vs. Secondary MR (ischemic or non-ischemic) Operative risk status Timing in Disease Course Severity of resulting or underlying ventricular remodeling and dysfunction Severity of symptoms Importance of Heart Failure Team Assurance of uniform treatment application & compliance Control Rx - adequacy and adherence Test Rx – Operator/interventionalist skills Appropriate utilization of GDMT (+ CRT and/or CAD-Rx) in all patients

6 What is Safety Factors to Consider
Safety Profile Differences - Balanced Primary Safety Endpoints Timing of Outcome determinations Short Term Long term Account for variable risks by therapy Drug Transcatheter Device Open Surgery Procedural AE’s Mortality - Neurological Events Bleeding - Acute Kidney Injury Cardiovascular (MI, Arrhythmias) - Access Injury/Tamponade Specific device-related technical failure issues and complications Adjudicated for Device relatedness Access – Vascular, apical, septal, open surgical Anchor points - Tissue Disruption; Device Misplacement, Malfunction, Embolism Durability – Fracture, thrombosis Damage or interaction with surrounding tissues (e.g. mitral apparatus, coronary compression) Infection Paravalvular leak Hemolysis Unplanned additional devices Need for emergent unplanned intervention or surgery

7 (MR increase > 1 Grade)
Judging Effectiveness Depends on Disease, Device, Available Rx and Timing Required: Alive , with Expected device/surgery performance for MR therapy: Correction (MR < mild) Reduction (MR decrease > 1 grade) Clinically meaningful benefit: Prevention or delay in the clinical progression of the effects of the disease: Survival Advantage Fewer Morbid Events Reduction in HF events (Hospitalization & equivalents) Reduced need for chronic medications Clinical improvement(s) of value to the patient: Symptoms (e.g. NYHA Class) Function (e.g. 6MWT) Quality of life (e.g. KCCQ) Helpful: Supportive Secondary Endpoints Favorable trends in biomarkers Improvements in Ventricular volume or function Prevention of deterioration in ventricular function or volume Durable over time Low/no MR recurrence (MR increase > 1 Grade) Hemodynamic Success

8 Secondary Mechanistic
Transcatheter Valve Repair and Replacement Traditional Hierarchy of Importance for Effectiveness Measures Lowest Highest Secondary Mechanistic Increased survival Prevention or delay of the clinical effects of the disease – HF hospitalization Significant improvements Symptoms Daily function Quality of life Longitudinal Hemodynamic success Prevention or Delay in the progression of the anatomic effects of the disease

9 Secondary Mechanistic
Transcatheter Valve Repair and Replacement What’s important to the Patient? “Years of Life” vs. “Life in Years” Increased survival Prevention or delay of the clinical effects of the disease – HF hospitalization Longitudinal Hemodynamic success Significant improvements Symptoms Daily function Quality of life Prevention or Delay in the progression of the anatomic effects of the disease Lowest Highest Secondary Mechanistic Lowest Minimally Symptomatic Patient, “Curable” Patient Severe Symptoms, Failed Medical Rx Patient Highest

10 Patient Centered Outcomes Customized based on Device Indications for Use*
% of Patients Alive with… Timing of Measurement Relevant patient questions Technical Success …successful implant of the single intended device without additional unplanned emergency procedure/intervention At exit from Procedure (OR or Cath lab) How successful is the procedure to implant the device? Procedural Success …technical/Device Success and no major adverse events (MAE’s) At discharge (D/C) from hospital or 30 days, whichever is later What are my chances of having the device placed successfully without major complications? Device Success … the original implant in place performing structurally and functionally as intended, without device related complications or need for additional procedures All post-procedure time intervals starting at D/C or 30 days Once the device is in place, does it break or fail? Can it cause problems over time? How long does it last? Individual Patient Success …device Success and return to pre-procedure environment and meaningful clinical improvement in Symptoms, Function, or Quality of Life (QoL) All post-procedure intervals starting at 6 months If my device works, will I be able to resume my normal life and stay out of the hospital? Will this improve how I feel and function and my QoL? For how Long? *Adapted from Stone GW et al. J Am Coll Cardiol 2015;66:308–321

11 Curative or Palliative
Valve Repair and Replacement Effectiveness Measures for Symptomatic Valve Disease For Diseases where Device Therapy is proven to be clinically effective vs. the natural history of underlying disease, one or more of the following clinically meaningful changes is observed: “Traditional” Outcomes Patient Centered Outcomes Hemodynamic success Significant improvements Symptoms Daily function Quality of life Prevention or decreased incidence of the clinical effects of the disease Prevention or Delay in the anatomic progression of the effects of the disease Increased survival Early (OR to 30 days) Expected Observation Time Late (1 year to Years) Mid (6mo – 1 year) Technical Success (OR exit) Procedural Success (30 day) Device Success (all time intervals > 30 days) Durability of device Individual Patient Success (all intervals > 6 months) Durability of benefit Stability over time Curative or Palliative

12 Valve Approval Remaining Relevant Questions (2017)
Is there anything about the valve that makes it more difficult or less safe to insert Procedural Success at 30 days Is the valve structure and performance durable over time Device Success days and yearly Does correction of the underlying valve disorder result in meaningful and durable clinical benefits to the patient Individual Patient Success 6months and yearly

13 PMA Approval - Clinical Decision Accounting for Unmet Need and Patient Preference
Benefit-Risk Determination

14 Thank You! John Laschinger, MD Medical Officer, SHDB 301.796.1210

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16 Hemodynamic Performance Effectiveness
Hemodynamic Success (Valve Dependent) Mean gradient 30 day 1 year Indexed Effective Orifice Area – change over time Central Insufficiency – change over time 30 day and 1 year Device Success: Aortic < 20mmHG Mitral < 5mmHg Device Failure (both): Increase > 25% increase over post-procedure baseline 30 day and 1 year Device Success: Stenosis: Increase in EOAI > 50% over pre-procedure baseline Regurgitation: EOAI in normal range post-procedure Device Failure (both) = decrease > 10% of post-procedure baseline Device Success: Central Regurgitation < Mild PVL < mild Total Regurgitation < Mild Device Failure: Central Regurgitation > Mild PVL > mild Total Regurgitation > Mild

17 Imaging Durability Evidence of Bioprosthetic Valve Disease
Hemodynamic deterioration (mild, moderate, severe; + Symptoms) Thrombotic leaflet thickening responding to anticoagulation - HALT or HAM; + HD, + Symptoms Imaging evidence of persistent Structural Valve Deterioration (e.g. Loss of leaflet or frame structure, integrity or function; + HD – stenosis and/or insufficiency; + Symptoms) Prosthetic Valve Failure (referral for Explant, valve related death or SVD discovered at autopsy; Cause – a or c above)

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