March 3rd, 2010

Rosiglitazone: When Evidence Is Inconclusive Even After FDA Approval

We welcome Sanjay Kaul, MD, lead author of a recent American Heart Association/American College of Cardiology science advisory about the cardiovascular risks of thiazolidinedione drugs, to answer our questions about rosiglitazone. We encourage you to ask yours.

You and your coauthors call the evidence on the cardiovascular risks of rosiglitazone “inconclusive.” When you prescribe a thiazolidinedione, which agent do you choose and why?

For diabetic patients with known ischemic heart disease — particularly older, high-risk patients who take nitrates, ACE inhibitors, or insulin — I prefer pioglitazone over rosiglitazone. Indeed, the FDA has warned about the risk for myocardial ischemia from rosiglitazone (but not pioglitazone) in some of these high-risk patients. That said, for a diabetic patient without high-risk characteristics and with well-controlled blood sugar on rosiglitazone, I see no compelling reason to switch to pioglitazone. However, I don’t object if such a patient wants to switch to pioglitazone or any other antidiabetic drug. 
 
Notably, both rosiglitazone and pioglitazone are contraindicated in patients with NYHA class III or IV congestive heart failure (CHF). Given that the drugs are associated with weight gain and fluid retention, caution is warranted in all CHF patients and in patients with signs and symptoms of CHF.
 
What is your threshold for accepting that the cardiovascular risk is real — for example, if an estimate showed a clinically important risk increase of 20% to 30%?
 
Let me answer this important question using rosiglitazone.
 
First, we have the RECORD trial, an open-label, industry-funded study in which about 4500 patients with inadequate glucose control while taking metformin or a sulfonylurea were randomized to receive either both drugs (controls) or add-on rosiglitazone. Compared with controls, rosiglitazone recipients showed no significant difference in the primary endpoint of time to first cardiovascular hospitalization or cardiovascular death (ranging from a 15% risk reduction to a 16% risk increase) or for myocardial infarction (ranging from a 20% risk reduction to a 63% risk increase). In a prespecified subgroup of patients with preexisting ischemic heart disease, the lack of a primary-endpoint difference between rosiglitazone and the control regimen persisted, although subgroup analyses are inherently limited. Indeed, this entire trial has well-known limitations, so its findings are inconclusive.
 
Next, we have evidence from an FDA meta-analysis that focused only on diabetes trials; assessed robust outcomes of cardiovascular death, MI, or stroke; and used stringent analytical and statistical methods. With regard to the risk for CV death, MI, or stroke, rosiglitazone had a nonsignificant odds ratio of 1.15 (ranging from a 20% risk reduction to a 60% risk increase, compared with control). Thus, a 15% elevated risk is the most plausible point estimate we have.
 
If we use a probabilistic approach based on Bayes’ theorem, the likelihood of a 20% to 30% clinically important risk associated with rosiglitazone is less than 50% — lower than the “preponderance of the evidence” threshold used in civil court trials and nowhere near the 95% level of certainty that one would want. Ultimately, risk-benefit assessments are something of an art practiced by a clinician as he or she carefully considers the scientific evidence along with the clinical profile and the wishes of an individual patient.
 
What should we do when years have passed since FDA approval of a drug but we still don’t know whether it is safe?

In the face of insufficient evidence, patients, providers, and insurers often find themselves at odds with one another, frequently confused, and sometimes distrustful despite the presumed good intentions of industry sponsors, investigators, and regulators. As Jerry Avorn wrote in the NEJM in 2007, “The approval, prescribing, and safety surveillance of prescription drugs involve a complicated mix of science, regulatory law, clinical judgment, business, and politics.” I hope that the quiet, dispassionate voice of science will be allowed to render verdicts through its natural but rigorous course of refutation or confirmation. Meanwhile, the Hippocratic Oath compels us as clinicians to avoid (even potentially) harmful interventions, especially if we have alternatives.

The story of rosiglitazone, like that of ezetimibe, is a cautionary tale that highlights key shortcomings inherent in drug/device development, evaluation, and approval. The FDA approved rosiglitazone more than a decade ago, and we still lack conclusive evidence about its effects on cardiovascular outcomes. I believe that all the major stakeholders bear responsibility for this evidence vacuum: drug developers, regulators, investigators, physicians, payors, patients, and the U.S. Congress.

A potential remedy is the so-called “lifecycle evaluation” of a drug. Ideally, the FDA should grant only “provisional approval” when surrogate endpoints are used (rosiglitazone was approved on the basis of glycemic control, as other diabetes drugs have been). The conditions for full approval should be timely demonstration of efficacy and safety in large, well-designed clinical-outcomes trials that examine cardiovascular endpoints. Furthermore, Congress should empower the FDA to enforce postmarketing commitments. Only then can we hope to avoid controversies like those rosiglitazone has brought us.

3 Responses to “Rosiglitazone: When Evidence Is Inconclusive Even After FDA Approval”

  1. false positive vs false negative error

    Hi Sanjay, there is a notion that I would like to run by you. Given the fact that the meta-analyses of rosiglitazone have enrolled mainly small studies (with some large ones like DREAM mixed in), studies which used varying definitions of MI or didn’t even routinely adjudicate, standardize and collect MI data, and are highly prone to other forms of reporting bias and publication bias (whereby internal data might be suppressed and/or never published), isn’t it much more likely that these studies in aggregate in meta-analytic format would lead to a false negative result (not showing a signal of harm when one exists, even a small one) rather than a false positive result (showing a signal of harm where none exists)? It seems to me that “where there is smoke, there is fire”, as has been expressed to me by one clinician who took care of a patient with an ischemic cardiomyopathy which developed two weeks after starting rosiglitazone (of course the plural of n=1 is not data). But I think all the biases in these meta-analyses move towards false negative error rather than false positive error, and the fact that some of these meta-analyses do seem to show an increased risk is a bit of a scarey phenomenon, given these operative parameters (incomplete underpowered trials, reporting bias, publication bias, etc). What do you think?

  2. Response to thoughtful comments by Dan Hackam

    Dear Dan,

    You correctly identify biases and misclassification and ascertainment errors that might potentially shift the meta-analytic estimate towards the null (resulting in a “false-negative” result). However, we and others have previously identified biases that might shift the meta-analytic estimate away from the null, thereby increasing the likelihood of a “false-positive” result such as the exclusion of “zero-event” trials, inclusion of CHF patients where rosiglitazone is contraindicated, etc. (Diamond et al, Annals of Internal Medicine 2007). Given the “fragility” of the risk estimates, it is prudent to be frugal (conservative) with the interpretation. Moreover, as you know, meta-analyses have important limitations in that they may not always provide an accurate and reliable estimate of treatment effects as measured in clinical trials. They are best utilized as exploratory tools for generating hypotheses, not validating them. These caveats apply even more to meta-analyses of epidemiologic data. Thus, meta-analytic results, especially those that do not meet the highest methodologic standards, should be avoided for drawing clinical inferences or for driving regulatory actions. In my opinion, only randomized controlled trials that are prospectively designed for the specific purpose of assessing “hard” cardiovascular outcomes are best suited to serve these goals.

    The key question is whether the signal for increased IHD risk with rosiglitazone is sufficient to warrant pulling it off the market. The FDA recently published a “guidance for industry” document requiring new antidiabetic drugs to rule out a hazard ratio of 1.80 for the CV death, MI or stroke outcome in preapproval trials. Notwithstanding their limitations, both the FDA meta-analysis as well as the results of the RECORD trial exclude this level of harm. While the evidentiary standard for drug approval process is formalized, no explicit guidance exists for withdrawing the approval. To the best of my knowledge, the FDA is only authorized to recommend a voluntary withdrawal, not to enforce it. Perhaps, the rosiglitazone saga might be instructive to inform this debate.

  3. I agree.

    Is there any way we can get an answer prior to 2015 (end date for TIDE study) – ie, perhaps for cumulative meta-analysis in which ongoing and recently completed trials like ACCORD and APPROACH are integrated into the dataset? I admit this is not the same as having a large definitive RCT which would be ideal. As LeLorier pointed out in 1997 in NEJM, one third of MAs are subsequently refuted by large definitive RCTs.