Title: CIRCULATORY SUPPORT DEVICES PANEL Wednesday, March 17, 2004
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2CIRCULATORY SUPPORTDEVICES PANELWednesday,
March 17, 2004
- Syncardia Systems, Inc.
- CardioWest Total Artificial Heart (TAH)
- System
- PMA P030011
3FDA Review Summary
- Syncardia Systems, Inc.
- CardioWest Total Artificial Heart (TAH)
- System
- Eric Chen M.S.
- FDA/CDRH/ODE/DCD
4Overview of Presentation
- History of Clinical Study
- Pre-clinical Evaluation
- Statistical Evaluation
- Clinical Evaluation
- Panel Questions
5FDA Review Team
- M. Berman
- E. Chen
- V. Covington
- D. Fleischer
- D. Gantt
- M. Hazes
- D. Kezer
- I. Piña
- J. Rinaldi
- W. Scott
- J. Swain
- S. Turtil
- L. Yue
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7Left Ventricle
Right Ventricle
Drivelines
Driveline Exit Sites
8Proposed Indication for Use
- The CardioWest TAH is intended for use as a
bridge to transplantation in cardiac
transplant-eligible candidates at risk of
imminent death from non-reversible biventricular
failure. - The CardioWest TAH is intended for use inside the
hospital.
9U.S. Clinical Study
- IDE G920101
- Two-arm prospective and retrospective,
non-randomized, multi-center clinical trial - Initial sample size of 64 patients 32 TAH / 32
control - Based on 90 power to detect a difference in
clinical outcome between patients surviving to 30
days post-transplant - Control arm
- Historical - 22 (gathered from centers before
trial initiated) - Retrospective - 10 (gathered from centers after
trial completed) - Concurrent - 3 (eligible but declined the device)
10Class III Device
- Provide reasonable assurance of safety and
effectiveness (Federal Food, Drug, Cosmetic Act,
513(a)(1)(C)) - Relevant factors (21 CFR 860.7(b))
- Patient population
- Conditions of use
- Probable benefit vs. probable injury
- Reliability of the device
11Preclinical EvaluationDetermined To Be
Satisfactory
- Alarms
- Battery Performance
- Biocompatibility
- Electrical Safety and EMC
- Reliability
- Software
12Preclinical EvaluationRemaining data to be
examined
- Sterilization, packaging, shelf life, shipping
- Manufacturing
13Engineering Conclusion
- Results of the pre-clinical testing in
conjunction with the outcome of the reliability
results from the clinical trial demonstrate
reasonable assurance of device safety.
14Statistical Summary
- Syncardia Systems, Inc.
- CardioWest Total Artificial Heart (TAH)
- System
- Lilly Yue Ph.D.
- FDA/CDRH/OSB/DBS
15Study Design
- Two-arm, non-randomized, multi-center (5)
- 35 control patients 32 retrospective
- 3 prospective
- 81 TAH patients for effectiveness assessment
- Primary effectiveness endpoint
- Treatment success at 30-days
post-transplant - Secondary effectiveness endpoints include
- Survival to transplant
- Survival to 30-days post transplant
- Safety adverse events
16Implant Frequency
17Non-comparable Baseline Covariates in Control
vs. TAH
- Factor Control
TAH Favored - Ischemic 74.3 53.1 TAH
- Smoking History 82.9 54.3 TAH
- Anticoagulated 74.3 46.9 TAH
- Myocardial Infraction 71.4 30.9
TAH - Prior Cardiac Surgery 60.0 38.3
TAH - IABP 68.6 35.8 TAH
- CPB 0.0 18.5 control
- Cardiac Arrest 25.7 37.0 control
- Ventilated 34.3 42.0 control
18- Two treatment groups are not comparable
- Imbalance of the year of implant
- Imbalance in multiple baseline covariates
- Any direct treatment comparisons on effectiveness
endpoints are inappropriate - So, all p-values from direct treatment
comparisons are uninterpretable
19- What about treatment comparisons adjusting for
imbalanced covariates? -
- Traditional covariate analysis
- Propensity score analysis
- Example of adjustment for one covariate, e.g.,
age
20Two Methods Adjusting for Age
- 1. Matching
- Age TAH vs. Control
Pair - 2. Sub-classification
- lt30 30-39 40-49
gt50 Age - lt30 30-39 40-49
gt50 Age
x1
21Adjusting for Multiple Covariates
- Usually there are many covariates that should be
adjusted simultaneously - Replace the collection of covariates with one
single number the propensity score (PS) - Age, Gender,
Propensity - Prior cardiac surgery,
Score (PS) - PS The conditional probability of receiving the
TAH, given a patients observed baseline
covariate values, e.g., age, gender, prior
cardiac surgery,
22Propensity Score Analysis
- Propensity score methods can only adjust for
observed covariates and not for unobserved ones -
- Propensity score is seriously degraded when
important variables influencing treatment
selection have not been collected
23Propensity Score Analysis
- When the propensity scores are balanced across
the treatment and control groups, the
distribution of all the covariates are balanced
in expectation across the two groups - We can use the propensity scores as a diagnostic
tool to measure treatment group comparability - If the two treatment groups overlap well enough
in terms of the propensity scores, we compare the
two treatment groups adjusting for the PS
24Two Methods Adjusting for PS
- 1. Matching
- PS TAH vs. Control
Pair - 2. Sub-classification
- 0 S1 S2 S3 S4
S5 1 PS -
x1
25Propensity Score Analysis
- Performed multiple imputations for 19 patients
with missing baseline covariate values - Adjusted for all imbalanced and/or clinically
important baseline covariates as well as the year
of implant - The propensity score model accurately predicted
the treatment group membership - However, the two treatment groups did not overlap
enough to allow a sensible treatment comparison
26Propensity Score Distribution
27Distribution of Patients in Propensity Score
Quintiles
- Propensity Score Quintile
- 1 2 3
4 5 - Control 23 11 1
0 0 - (66) (31) (3)
(0) (0) - TAH 0 12 23
23 23 - (0) (15)
(28) (28) (28)
28How to Proceed?
- So, any treatment comparisons adjusting for
imbalanced covariates are problematic - How to proceed?
- Since the two treatment groups are not
comparable, any judgment of the performance of
TAH has to be based on the results from the TAH
group alone
29Single Arm Study Results
- TAH Group (N 81)
- Outcome Rate
95 C.I. - Treatment
- Success 56/81 69.1 (57.9, 78.9)
- Survival to
- Transplant 64/81 79 (68.5, 87.3)
- Survival to
- 30-days Post
- Transplant 58/81 71.6 (60.5, 81.1)
-
30Single Arm Study Results
- TAH Group (N 81)
- Outcome Rate
95 C.I. - 6-m survival
- from implant 61/81 75.3 (64.5, 84.2)
- 1-y survival
- from implant 57/81 70.4 (59.2, 80)
- 1-y Conditional
- Survival from
- Transplant 55/64 85.9 (75, 93.4)
-
31- Time to transplant or death before transplant
- Mean 79 days Median 47 days
- Kaplan-Meier estimate of survival probability
prior to transplant - Event Death Censoring Transplant
- Assumption underlying K-M
- Independence of censoring and event
- Concern
- Sicker patients received transplants sooner?
- Potential Problem the K-M survival probability
estimates are biased
32Statistical Summary
- Without appropriate control, it is difficult to
perform statistical evaluation of the
effectiveness of the device - For survival prior to transplant, K-M survival
estimates are potentially seriously biased
33Clinical ReviewCardioWest TAH
- Julie Swain M.D.
- Cardiac Surgery
- Ileana Piña M.D.
- Cardiology
34FDA-APPROVED BTT LVADs
- No randomized, controlled studies for BTT devices
- No comparable control groups in previous BTT
studies - In general, slow enrollment, multi-year studies
35LVAD BTT Performance Goals(Literature Search)
- Criteria for Inclusion
- Bridge to transplant indication, LVAD
- One of the 4 approved devices was used
- Published in 1997 or after thus representing
patients mostly studied after 1993-5 - Series must have at least 20 patients, adults
only - Peer reviewed journals, no abstracts, must have
original data - English, Includes OUS data, wide geographic
distribution - Detailed enough data to determine results in
adult patients with LVAD
36LVAD BTT Performance Goals
- Criteria for Exclusion
- Duplicate papers reporting same population
- Registries, meta-analyses, and reviews
- RV support at initial implant
- Primarily cardiogenic shock patients
37LVAD BTT Performance Goal Survival to Transplant
74
74
65-70
65-70
HFSA 2002 WaiShun Wong, Mohamad El-Zaru, Joseph
Lau, Douglas Gregory, Marvin A. Konstam, David
DeNofrio Tufts - New England Medical Center,
Boston, MA
38BiVAD Survival to Transplant
- Magliato ASAIO 2003 2. McBride ATS 1999 3.
El-Banayosy TCVS 1999 4. Farrar JTCVS 1997 -
- Success survival 30 days post Tx, NYHA Class I
or II, ambulatory, not vent, not dialysis
39LVAD Implantation with RV Failure
Medical Rx (inotropes, volume load, NO)
Short-term pumps
Long-term percutaneous pumps
40CardioWest TAH
- Study approved by FDA 1993
- FDA agreed that clinical equipoise did not exist
- FDA approved the control group
41U.S. Clinical Study
- 5 U.S. centers
- 10 Year clinical study
- 95 TAH patients
- 81 patients met all inclusion/exclusion criteria
(Core group) - 14 patients treated as compassionate use off
label - Efficacy judged on 81 core patients, safety on
all 95 patients - 35 Control patients
- 32 historical data
- 3 prospective patients who refused the TAH
42CardioWest TAHSurvival to Transplant
Success survival 30 days post Tx, NYHA Class I
or II, ambulatory, not vent, not dialysis
43Adverse Events
- Difficult to develop a performance goal for AEs
- No definitions listed in some studies
- Different definitions in other studies
- Rates differ among approved devices
- Rates for same device change over time
- Clinical judgement is required
44CardioWest TAH Serious Adverse Events
Infection device related
45Areas for Discussion
- Distribution of implants among study centers
- Indications for BiVAD vs LVAD
46Distribution of Implants
UPMC 1.2
LDS 9.9
STL 1.2
Loyola 16.0
UMC 71.6
47Treatment SuccessUMC vs other 4 Institutions
69.6
69
CI
CI
Success survival 30 days post Tx, NYHA Class I
or II, ambulatory, not vent, not dialysis
48Evidence of Right Heart Failure
49Indications for BiVAD vs LVAD
- Irreversibility of procedure (no
bridge-to-recovery) - our ability to predict recovery is poor
- RV failure may only become evident after LVAD
implantation - When should this device be used?
- Should this be addressed in the post-market
period? - How can the label reflect this problem?
50Clinical Conclusions
- Efficacy Survival to transplant similar to
other devices reported in the literature - Safety Adverse event profile trends seem
similar to other devices, but a direct comparison
cannot be made due to differences in definitions