Other Points
Considered
Is this related to the eligibility criteria, the target
product profile or the analysis population?
The target population in clinical trials is a key
concept, often tied to the study’s eligibility criteria, the target
product profile, and the analysis population. According to regulatory
guidelines such as the ICH E9 addendum, the target population is
generally described as the study population. However, defining the
target population for an estimand based solely on
eligibility criteria can sometimes present difficulties.
For example, in this case study, the target population is defined as
patients with the condition of interest (an endocrine disorder) along
with associated health issues (uncontrolled hypertension or uncontrolled
blood sugar). In some cases, it might be important to include additional
details, such as belonging to a specific subgroup that would be relevant
to the analysis and to which the study results would directly apply.
It’s important to note that the target population
should not be defined in terms of the analysis population. Instead, the
analysis population should be defined based on the target population,
and the estimands should be established accordingly.
Handling Participants Who Were Randomized but Did Not Meet
Eligibility Criteria:
Regulators typically expect that participants who were randomized,
even if they did not meet all eligibility criteria, be included in the
analysis population. This inclusion is particularly
important when the study uses a treatment policy
strategy, which implies that the effects of the treatment
should be evaluated across all patients randomized, regardless of
deviations from protocol or treatment adherence. This strategy assumes
that all randomized participants at least met the basic condition
requirements, such as having the endocrine disorder and either
uncontrolled hypertension or uncontrolled blood sugar.
In certain circumstances, exclusion of ineligible participants from
the analysis population may be warranted based on specific scientific
questions. However, such exclusions must be clearly justified, and
regulatory authorities should be consulted for agreement on the
approach. For this specific case study, there is an additional risk of
randomization errors since the trial involves two
patient groups that may overlap. This overlap should be considered
during the protocol’s risk assessment, and appropriate mitigation steps
should be planned to handle potential issues.
Handling Participants Who Did Not Receive Study
Treatment
Similarly, regulators generally expect that participants who were
randomized but did not receive study treatment are still included in the
analysis population, particularly when the treatment
policy strategy is applied. The treatment policy strategy considers the
treatment effect for all randomized participants, regardless of whether
they completed the intervention according to protocol. In cases where
excluding such participants is scientifically necessary, the
justification should be clearly stated, and agreement sought with the
regulators.
In summary, the target population is critical for defining the scope
and relevance of a clinical study. It is important to align the analysis
population with the estimand definition based on the study’s goals and
regulatory expectations. Both the inclusion of ineligible or untreated
participants in the analysis population and any deviations from this
general rule need to be justified within the study’s framework and
properly discussed with regulatory authorities.
Data Collection to Align with Intercurrent Event (ICE)
Strategy
In clinical trials, it is crucial to collect adequate and accurate
data regarding Intercurrent Events (ICEs) to properly
implement the predefined strategies for handling such events. These
events, which occur after treatment initiation and may influence the
interpretation of treatment effects, need to be well-documented so that
they can be incorporated into the analysis according to the chosen
strategy (e.g., treatment policy strategy). Below are the key aspects to
consider:
What data do we need to collect regarding the
ICE?
To align data collection with the ICE strategy, the following
information is essential:
- Identification of ICE:
- Clearly document whether an ICE has occurred, based on the protocol
definition. ICEs may include treatment discontinuation due to lack of
efficacy, adverse events, or the use of rescue medication.
- Investigators should have a comprehensive list of potential ICEs
that could occur during the trial and precise criteria for identifying
these events.
- Detailed Documentation:
- Record the specific type of ICE (e.g., treatment discontinuation due
to lack of efficacy, safety concerns, or the use of rescue
medication).
- Collect the date and time of the ICE occurrence to determine when
the event took place in relation to the study timeline.
- Document the reason for the ICE, including whether it was due to
clinical judgment, participant choice, or another cause.
- Contextual Information:
- Gather information about the participant’s status at the time of the
ICE (e.g., clinical signs, symptoms, or any ongoing adverse
events).
- If relevant, capture information on any actions taken as a result of
the ICE (e.g., whether rescue medication was administered or alternative
treatments were introduced).
Can Lack of Efficacy Be Determined?
To determine lack of efficacy, investigators must
collect data that reflects treatment outcomes in relation to the primary
endpoints (e.g., blood pressure or HbA1c levels). The key elements to
capture include:
- Treatment Response Data: Track whether the patient
is responding to the treatment as expected over time. This includes
regular measurements of the primary endpoints (e.g., blood pressure and
glycemic control).
- Follow-up Assessments: Continue collecting endpoint
data even after an ICE, especially if the treatment policy strategy is
in place, to assess whether lack of efficacy might be contributing to
the event.
- Clinical Judgment: Ensure that investigators record
any clinical decisions or observations that indicate lack of efficacy
(e.g., worsening of the condition, or failure to achieve desired
treatment thresholds).
Operational and Data Collection Issues for the Treatment
Policy Strategy
When applying the treatment policy strategy, there
are several operational and data collection challenges to consider:
- Continued Data Collection After ICE:
- Protocol Clarity: It should be explicitly stated in
the protocol that data collection must continue even after an ICE
occurs. This is crucial for trials using the treatment policy strategy,
which evaluates treatment effects regardless of intercurrent
events.
- Investigator Awareness: Investigators need to
understand that post-ICE data collection is necessary and that stopping
data collection after an ICE would violate the treatment policy
strategy’s intent.
- Data Collection Burden:
- Ensure that post-ICE follow-up assessments are practical for both
investigators and participants. There may be logistical issues if
participants discontinue the trial drug or shift to other
treatments.
- Systems should be in place to ensure that participants remain
engaged and continue to provide outcome data, even if they are no longer
receiving the study treatment.
- Maintaining Data Integrity:
- Consistency: Data collection tools should be
designed to ensure consistency in how ICEs and subsequent events are
recorded.
- Data Completeness: Investigators should be
encouraged to collect complete data sets following an ICE, including all
relevant outcomes, adverse events, and clinical interventions.
- Adjusting Analysis Plans:
- ICEs introduce complexities in data analysis, particularly in
treatment policy strategies. Proper documentation will allow the correct
handling of such events during statistical analysis, ensuring that the
estimands reflect the treatment effect despite the ICE.
ICE of Death
When considering death as an Intercurrent Event
(ICE), even in studies where the number of deaths is
anticipated to be small, it is essential to determine how these cases
will be handled both in the study protocol and in the statistical
analysis. Death, in many studies, impacts outcome availability and thus
must often be treated as an ICE. However, when deaths are expected to be
very rare or unimportant to the primary objectives of the study, there
can be a decision not to treat death as an ICE, but this requires
careful planning.
Is it Necessary to Consider Death as an ICE?
While death is always a potential occurrence in any study, whether or
not to explicitly include it as an ICE depends on the study’s context
and design. For indications where only a small number of deaths are
anticipated, sponsors may opt not to treat death as an ICE, especially
if the focus of the trial is on treatment efficacy rather than survival
or safety. However, in these cases, it’s important to establish clear
guidelines for how such participants are handled in the analysis. Simply
ignoring deaths can lead to biased results if not addressed
appropriately.
If death is not considered an ICE, it still impacts
data availability (since no further outcome data can be collected for
the deceased participants). Therefore, even in situations where death is
infrequent, strategies for handling deaths in the analysis must be well
thought out.
What Strategies Can Be Considered for Death as an
ICE?
Treatment Policy Strategy (Not Applicable): The
treatment policy strategy generally assumes that data is collected and
considered regardless of intercurrent events. However, in the case of
death, this strategy becomes impractical because data cannot be
collected post-mortem. As a result, applying the treatment policy
strategy is not feasible for handling death as an ICE.
Hypothetical Strategy (Not Recommended): The
hypothetical strategy involves asking “what would have happened if the
ICE had not occurred?” While this approach can be useful for some types
of intercurrent events, it is generally considered
irrelevant and not useful for death.
In most cases, simulating a hypothetical scenario in which a deceased
participant survives does not provide meaningful or practical insights
for a clinical study, especially when the death is related to factors
beyond the study’s primary objectives.
Composite Endpoint Strategy (Problematic for Continuous
Endpoints): In some cases, death is combined with other
outcomes in a composite endpoint, where death and other
serious events are considered together in one combined metric. However,
this approach is problematic for continuous endpoints,
such as blood pressure or glycemic control, because it is not feasible
to incorporate death into the measurement of these types of outcomes.
Continuous endpoints measure a change over time, which cannot be
extended beyond the point of death. Defining a composite endpoint in
this case is not practical and may lead to statistical
complications.
While Alive Strategy (Suggested Approach): The
most appropriate strategy when dealing with death as an ICE for
continuous endpoints is the while alive strategy. This
approach excludes participants from the analysis set following their
death, as it is no longer possible to measure their outcomes beyond that
point.
The “while alive” strategy essentially censors data after death,
ensuring that only data collected while the participant was alive is
considered. This strategy avoids the pitfalls of trying to analyze data
beyond the point of death and allows for a realistic assessment of the
treatment’s effect up to that point.
- Key Considerations for the While Alive Strategy:
- Exclude participants from analysis following their death while
keeping their data prior to death.
- Ensure proper documentation and explanation in the statistical
analysis plan to avoid bias and misinterpretation of the results.
- Provide transparent reporting on the number of deaths and how they
were handled in the analysis to maintain the study’s credibility.
Study Withdrawal
In clinical trials, study withdrawal refers to
situations where a participant withdraws from the study entirely, either
due to personal choice, administrative reasons, or other
non-treatment-related circumstances. According to the ICH E9 addendum,
study withdrawal is not considered an
Intercurrent Event (ICE). The addendum makes a clear
distinction between intercurrent events, which affect the interpretation
of the treatment effect, and other events, such as study withdrawal,
which result in missing data.
Study Withdrawal vs. Intercurrent Events (ICE)
The ICH E9 addendum emphasizes that intercurrent events are to be
handled by defining the estimand in a way that reflects
the precise trial objective. These events are closely related to the
treatment or study context, such as discontinuation due to lack of
efficacy, adverse events, or the use of rescue medication. In contrast,
study withdrawal results in missing data but does not
directly impact the interpretation of the treatment’s effect because it
is not linked to the treatment assigned.
When a participant withdraws from the study: - The outcome of
interest remains relevant, but it becomes unobserved
due to the participant no longer being part of the study. - The
withdrawal is not related to the efficacy or safety of the treatment, so
it does not affect the estimand. - Instead, study
withdrawal introduces missing data, which should be
managed during the statistical analysis, typically
using methods for handling missing data such as imputation, last
observation carried forward (LOCF), or other appropriate techniques
based on the nature of the missing data.
Handling Study Withdrawal in the Analysis
Since study withdrawal leads to missing data, it should be addressed
using appropriate statistical techniques. The ICH E9 addendum suggests
that while a participant may withdraw from the study, the
outcome of interest still exists in principle, even
though it is not observed. Thus, the trial should handle this missing
data in a way that preserves the integrity of the analysis without
introducing bias. Strategies for addressing missing data include: -
Multiple Imputation: Estimating the missing outcomes
based on observed data to create a complete dataset for analysis. -
Mixed Models: Incorporating available data up to the
point of withdrawal and accounting for the fact that some data is
missing. - Sensitivity Analyses: Testing how different
assumptions about the missing data (e.g., assuming the data is missing
at random vs. not at random) may influence the study’s conclusions.
Keeping Participants in the Study Despite Treatment
Discontinuation
The ICH E9 addendum also stresses that discontinuing study
treatment should not result in study
withdrawal. Participants who stop the treatment due to personal
reasons, adverse effects, or lack of efficacy should continue to be
followed and remain in the study. Their data should still be collected
and used in the analysis. This is critical for maintaining the integrity
of the study and ensuring that the treatment’s effect is accurately
assessed, even in those who discontinue treatment.
In cases where study withdrawal is unavoidable, the focus shifts to
managing the resulting missing data rather than interpreting it as an
ICE that alters the treatment effect.
Statistical
Analysis
Analysis
Populations
The analysis populations for the co-primary
endpoints are crucial to ensure that the study’s findings are both valid
and relevant to the research objectives. For this study, two co-primary
endpoints are being assessed: change in average systolic blood
pressure (SBP) and change in HbA1c. The
analysis populations for these endpoints are defined as follows:
- Change from Baseline in Average SBP:
- The Intent to Treat SBP (ITTSBP) analysis set will
be used. This analysis set includes all randomized participants
who had uncontrolled blood pressure at the time of study
screening, ensuring that all relevant subjects are included in
the analysis.
- The analysis will be conducted based on the randomized
treatment arm, meaning participants will be analyzed according
to the treatment group they were assigned to at the start of the study,
regardless of any subsequent events (such as discontinuation or
treatment changes).
- This analysis population will be used for both the primary
estimand and the supplementary estimands,
ensuring consistency across the different strategies being applied to
handle intercurrent events (ICEs).
- Change in HbA1c:
- Similarly, the analysis population for the co-primary endpoint of
change in HbA1c includes all randomized
patients with poor glycemic control at baseline. The definition
of the analysis population aligns with the endpoint being studied,
ensuring that the analysis focuses on participants with the relevant
health condition (poor glycemic control).
- Like the SBP analysis, the randomized treatment arm
will be the basis for the analysis, maintaining consistency with the
intent-to-treat principle.
Supplementary Estimands 2 and 3
For supplementary estimands 2 and 3, it is
acknowledged that data from some subjects may be
excluded from the analysis. This is primarily due to the
different ICE handling strategies applied in these estimands. For
example:
- In Supplementary Estimand 2, the focus is on
participants while they are on the study treatment.
This means that once a participant discontinues the treatment, their
data may no longer be included in the analysis beyond that point.
- In Supplementary Estimand 3, the aim is to evaluate
the practical use of the treatment, which may exclude
certain participants based on their adherence to the treatment
regimen.
However, since the ICE strategies for these supplementary estimands
are clearly defined (e.g., “while on study treatment” or “while
treated”), there is no need to define additional analysis
sets. The analysis populations remain consistent, and the
exclusion of some data based on these strategies is a natural
consequence of applying the specified handling methods for intercurrent
events.
Exploring Missing
Data
In any clinical trial, missing data can present a challenge in the
interpretation of the results. While it’s not always possible to
directly test for the underlying mechanisms causing missing data, it is
essential to explore missing data patterns as part of the
statistical analysis. Understanding these patterns
helps to interpret the results more accurately and determine the
robustness of the conclusions drawn from the study.
For this study, the exploration of missing data should be approached
systematically, and at a minimum, the following steps should be
taken:
- Exploration of the Missing Data Mechanism Using Descriptive
Approaches
The first step in understanding missing data is to explore
why data may be missing. Although we can’t definitively
test for the mechanism behind the missingness (e.g., Missing
Completely at Random (MCAR), Missing at Random
(MAR), or Missing Not at Random (MNAR)), we
can use descriptive statistics to get an idea of potential patterns.
This could include: - Summarizing the amount of missing data for each
variable, such as co-primary endpoints (e.g., SBP or
HbA1c). - Looking at the distribution of missing data
across treatment groups to determine if one group has more missing data
than the other, which could signal a pattern related to the treatment. -
Descriptive statistics like the percentage of missing data for each
visit or time point to identify trends (e.g., more missing data in later
visits).
These exploratory analyses help to hypothesize whether the data might
be missing due to participant dropout, protocol deviations, or other
reasons that could be linked to the treatment or study procedures.
- Tables of Missing Data for Primary and Key Secondary
Endpoints by Visit
Creating tables of missing data for the primary and
key secondary endpoints, broken down by visit, provides a clear
visualization of where and when the missing data occurred. These tables
should: - List the number and percentage of missing
data points for each visit. - Break down the missing data by
treatment group, as differences between groups may
point to treatment-related causes of missingness. - Show the
timing of missing data to see if it is concentrated
around certain visits (e.g., near the end of the study) or is more
random throughout the study.
These tables are a straightforward way to assess whether the pattern
of missing data is consistent with expectations or if it might be biased
toward certain visits or treatment arms.
- Lists of Intercurrent Events by Visit
Since intercurrent events (ICEs) are a key factor in this study, it
is important to generate lists of ICEs by visit,
especially for cases where ICEs might lead to missing data. These lists
will: - Show the types and frequencies of ICEs (e.g.,
treatment discontinuation, use of rescue medication, death) at each
visit. - Highlight any links between ICEs and missing data, for example,
if participants who experience an ICE are more likely to miss subsequent
data collection points. - Differentiate between ICEs handled according
to the treatment policy strategy and those handled by other strategies
(e.g., hypothetical, while alive), as different strategies might affect
how missing data is treated in the analysis.
By reviewing these intercurrent events by visit, the analysis can
identify where the study’s outcomes may be influenced by external
events, helping to interpret the overall results more effectively.
Primary Efficacy
Analysis
The primary efficacy analysis for the co-primary
endpoint of change in average systolic blood pressure
(SBP) from Baseline to Week 24 will be
performed using an analysis of covariance (ANCOVA).
This statistical method is suitable for comparing the treatment effects
on blood pressure changes while controlling for baseline differences and
other covariates.
Handling of Missing Data
For missing data related to the primary endpoint caused by
intercurrent events (ICEs) such as: - Treatment
discontinuation due to lack of efficacy or safety, - Use of
rescue medication, or - Not receiving a dose of
study treatment,
the analysis will use multiple imputation with a
retrieved dropout approach, as described by
Wang and Hu. This approach aims to account for the
missing data while maintaining the validity of the statistical inference
about the treatment effects.
Wang, S., Hu, H. Impute the missing data using retrieved dropouts.
BMC Med Res Methodol 2022, 22: 82. https://doi.org/10.1186/s12874-022-01509-9
Retrieved Dropout Subgroups
Two retrieved dropout subgroups will be defined to handle missing
data:
- Discontinued Treatment Retrieved Dropout Subgroup:
- This subgroup will include all participants who have
discontinued treatment but still have observations at
the time of the endpoint (Week 24). These participants’ data will be
used to estimate the missing data following treatment
discontinuation.
- Rescue Medication Retrieved Dropout Subgroup:
- This subgroup includes all participants who have received
rescue medication and have observations at the time of
the endpoint. The data from these participants will be used to impute
missing values following the use of rescue medication.
Imputation Procedure
Imputation Frequency: Missing values will be
imputed 1,000 times using a multiple imputation
procedure. This creates multiple complete datasets that account for the
uncertainty associated with the missing data.
Separate Models for Each Treatment Group: The
imputation process will be performed separately for each treatment group
to reflect potential differences in the missing data mechanism between
the treatment arms.
Linear Model for Imputation:
- The imputation model will use a linear regression approach.
- Covariates for the imputation model will include:
- Baseline mean SBP, which controls for participants’
initial blood pressure values,
- Last on-treatment visit mean SBP, which represents
the most recent observed blood pressure before the treatment
discontinuation or rescue medication was administered.
This imputation strategy helps to preserve the study’s
statistical power by utilizing the available data from
participants who either discontinued treatment or used rescue
medication, while appropriately accounting for the missing data in a way
that minimizes bias.
Missing Data Not
Due to Intercurrent Events (ICE)
For missing data that is not due to an Intercurrent Event
(ICE), it is assumed to be Missing at Random
(MAR). This means that the probability of the data being
missing is related to observed data but not the unobserved values
themselves.
To handle this type of missing data, the study will use
Markov Chain Monte Carlo (MCMC) methods to impute both:
- Non-monotone missing data: Data where missingness
occurs at random points, without a clear pattern. - Monotone
missing data: Data where missingness occurs in a sequential
manner (e.g., if a participant misses multiple follow-up visits after
initially completing a few visits).
The MCMC approach is well-suited for multiple
imputation in these scenarios, as it models the joint
distribution of the data and generates imputations based on this model,
filling in the missing values while maintaining the relationships in the
observed data.

Sensitivity
Analyses
To assess the robustness of the analysis to different assumptions
about the missing data, several sensitivity analyses
will be conducted. These analyses provide insights into how deviations
from the missing at random assumption might affect the study
results.
- Imputation Based on the MAR Assumption (Using
MCMC)
As part of the sensitivity analyses, the study will use multiple
imputation methods based on the Missing at Random (MAR)
assumption, with MCMC to handle the imputation of
missing data. This analysis will evaluate the treatment effect under the
assumption that the missing data is related to the observed data, but
not to unobserved outcomes. This approach helps assess how much the
results depend on the MAR assumption.
- Tipping Point Analysis Using the Delta Adjustment
Approach
The tipping point analysis will be used to evaluate
how sensitive the results are to deviations from the MAR assumption. The
delta adjustment approach will be employed for this
purpose: - The delta adjustment introduces a systematic shift (or
“delta”) to the imputed values to simulate Missing Not at Random
(MNAR) scenarios. This allows for the exploration of how much
deviation from the MAR assumption would be needed to change the overall
conclusions of the analysis. - By adjusting the imputed data in this
way, the tipping point analysis provides a range of potential outcomes
under different missing data scenarios. It identifies whether there is a
“tipping point” at which the study’s conclusions change as the
assumptions about the missing data deviate from MAR.
This combination of multiple imputation methods and sensitivity
analyses ensures that the treatment effect estimates are robust and
account for potential biases introduced by missing data. If the results
remain consistent across different imputation strategies, confidence in
the study’s findings is reinforced.
Supplementary
Analyses
While supplementary analyses are typically not
detailed in the Clinical Study Protocol (CSP), they are instead defined
in the Statistical Analysis Plan (SAP), which offers
more in-depth guidance on how these analyses will be conducted. The
supplementary estimands differ from the primary estimand in their
handling of intercurrent events (ICEs), reflecting different assumptions
about how ICEs, such as rescue medication use and treatment
discontinuation, influence the analysis.
Each supplementary estimand adjusts the analysis based on different
assumptions regarding the treatment effect and how intercurrent events
(particularly rescue medication use and not receiving a dose of study
treatment) should be handled. These adjustments allow for a more nuanced
understanding of how Drug X performs under various conditions:
Supplementary Estimand 1 uses a
hypothetical strategy to estimate the treatment effect
assuming no rescue medication is available, and imputes
missing data based on different approaches for the intervention and
control groups.
Supplementary Estimand 2 applies a while
on study treatment strategy, where participants are excluded
from the analysis after using rescue medication or not receiving a dose
of study treatment.
Supplementary Estimand 3 focuses specifically on
excluding participants from the analysis after they fail to receive a
dose of the study treatment, using a similar while on study
treatment approach.
These supplementary analyses provide complementary perspectives to
the primary analysis, exploring the robustness of the treatment effect
under different real-world scenarios.
Supplementary Estimand 1
This estimand differs from the primary estimand in the ICE
strategy for rescue medication. The key difference lies in the
adoption of a hypothetical approach: -
Hypothetical Strategy for Rescue Medication: This
approach assumes that rescue medication is not
available for the intervention group. As a result, the
treatment effect is estimated under the assumption that participants do
not have access to rescue medication. - Handling of Missing
Data: All data following the use of rescue medication will be
considered missing. - For the intervention
group, a reference-based multiple imputation
method will be used, which assumes that after the ICE, the trajectory of
the participant’s data will reflect that of a reference group (e.g.,
control group). - In the control group, missing data
will be imputed using the MAR (Missing at Random)
assumption. This reflects the assumption that the missing data
is related to the observed data but not to the unobserved outcomes
themselves.
Supplementary Estimand 2
This estimand differs from the primary estimand by the use of a
“while on study treatment” strategy for two ICEs:
rescue medication use and the participant not receiving a dose of the
study treatment. - While on Study Treatment for Rescue
Medication and No Dose Received: This strategy means that
participants who either received rescue medication or never received a
dose of the study treatment will be excluded from the
analysis after these events occur. - Specifically, the data
from timepoints following the ICE will not be included in the analysis
for those participants, as their experiences are considered irrelevant
to the effect of the treatment under study in this particular
estimand.
Supplementary Estimand 3
This estimand differs from the primary estimand by using the
“while on study treatment” approach for the ICE of not
receiving a dose of the study treatment. - While on Study
Treatment for No Dose of Study Treatment: In this case,
participants who did not receive a dose of the study treatment will be
excluded from the analysis for any timepoints following
the ICE. - The rationale is to assess the treatment effect only during
the period in which participants are actually receiving the treatment,
excluding any data that comes after the treatment regimen was
interrupted or never initiated.