The integrated summary of safety (ISS) and integrated summary of effectiveness (ISE) are critical documents required for regulatory submissions in the approval of new medicines/drugs or devices. These documents combine the safety and efficacy results from different clinical trials conducted for the investigational product and need to contain detailed analyses of all relevant data from the individual clinical study reports. ISS and ISE allow reviewers to compare results for individual endpoints across studies for the investigational product. Overall, ISS and ISE enable broad views of the investigational product’s overall efficacy and safety profiles.
ISS and ISE are critical for regulatory submissions when combining trial results. They will feature in New Drug Applications (NDAs) which are required for the NDA submission to the United States Food and Drug Administration (FDA)[1]. However, ISS and ISE are not a regulatory requirement for the marketing authorization application (MAA) submission to EMA in Europe or to the Ministry of Health, Labour and Welfare (MHLW) of Japan. MHLW and EMA submissions will contain elements of ISS and ISE because they are part of the common technical document (CTD) format which must be followed for these regulatory submissions[2]. The Canadian regulatory authorities, Health Canada, made the Common Technical Document (CTD) format mandatory for regulatory submissions including NDAs on 1st January 2018 and is referred to as New Drug Submissions (NDS)[3].
The ISS and ISE sections within a CTD require a comprehensive amount of data analysis at the clinical trial reporting stage, conducted by statistical programmers. This analysis and supporting information is heavily formatted by medical writers to present the results within the CTD. Although there are no corresponding regulations requiring an ISE or ISS for biologic license applications (BLAs) submissions, applicants are encouraged to provide these analyses[4].
As well as a regulatory requirement, integrated summaries allow us to:
In general, for any regulatory submission, CTD is a common globally accepted format for the dossiers that are submitted to gain approval for medicinal products. The aim of creating the CTD was to provide a uniform format for drug approval and is the required format for all marketing authorization applications/new drug applications in the US, EU and Japan, Canada, and Australia.
A CTD is comprised by 5 modules, with 4 common global modules (2-5), and module 1 being specific to the region that you are submitting your CTD to.
The summary of clinical efficacy (module 2.7.3) and summary of clinical safety (module 2.7.4) can be placed in module 2 (replacing the occurrence of integrated summaries in module 5.3.5.3) or in module 5.3.5.3 of module 5, the clinical study report (Table 1). However, it is more common for the integrated summaries to appear in module 5 as module 2.7 has a 400-page limit and unless it is a small study and comparison of studies, it is likely not to be enough space and module 5.3.5.3 would provide enough space to document the required analysis and appendices of tables, listings and figures.
Table 1: ISE- and ISS-Related Sections with Corresponding Regulations[4]
CTD Section |
US Regulation |
Remark |
2.5 Clinical Overview (~30 pages) 2.5.4 Overview of Efficacy 2.5.5 Overview of Safety |
NA |
Not a U.S. requirement, but recommended by ICH M4E |
2.7 Clinical Summary (~50 – 400 pages) 2.7.3 Summary of Clinical Efficacy 2.7.4 Summary of Clinical Safety |
21 CFR 314.50(c) (2)(viii) |
U.S. requirement for a clinical summary |
5.3 Clinical Study Reports 5.3.5.3 Reports of Analyses of Data from More than One Study (Including Any Formal Integrated Analyses, Meta- Analyses, and Bridging Analyses) |
21 CFR 314.50(d)(5)(v) 21 CFR 314.50(d)(5)(vi)
|
Integrated Summary of Effectiveness Integrated Summary of Safety |
(Source: Guidance for Industry (fda.gov) – https://www.fda.gov/media/75783/download p3.)
As a global standard, to all regulatory bodies, CTD guidance[2] is set and reviewed by the International Conference of Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH).
An integrated summary should not just be considered a summary of the details of individual study results held in the Clinical Study Reports (CSR), but rather, is a comprehensive and in-depth analysis of aggregated results used to make informed decisions. This analysis involves a synthesis of the results of individual studies, in an appropriate manner, to provide evidence of the safety and effectiveness of the drug. The integrated summary is far more than just a ‘summary’, detailing pooled analyses and discussing them in detail.
The main section of the ISS and ISE uses text to explain the study results, within this body there are tables and figures of important endpoint analysis. Finally, details of statistical approaches and listing, should be included in an appendix, which can also contain any additional supportive tables and figures. Let’s look at what to include in the ISE and ISS in more detail:
An ISE is used to define and support the effectiveness of the investigational drug’s effectiveness in terms of the endpoints and treatment aims as specified within the trials protocol. The ISE will include all available information on this effectiveness for each target claim, indication and recommended use. Below are its key components[5]:
This list is generated from more detailed regulatory guidance on what to include in an ISE.
An ISS is offers the overall analysis and summary of the safety data of the investigational drug. Below are its core components[6]:
This list is paraphrased from Section H of more detailed original regulatory guidance on ISS.
An ISS ISE need to be designed and planned carefully in advance to ensure informed decision-making and effectiveness. A focus on the approval and whole lifecycle of the product, and not just the submission, will influence the quality and direction of the content. Traceability is key in all respects of the creation of information, from data that leads to knowledgeable decisions and the ultimate wisdom that forms the label of a product.
Approvability of a product depends, of course, on the data that is selected for collection during the planning of clinical trials. However, considerable resources, time and money can be saved by planning carefully how the summaries are structured to help make effective decisions and deliver clear messages supporting the target product claims.
The following questions need to considered when planning your integrated summary:
Analysis planning of these summaries may be started alongside the preparation of the Phase II studies to ensure appropriate endpoints, time points and patient populations are being considered.
Guidelines from agencies on the preparation of integrated summaries for regulatory submissions are often lacking in terms of providing specific direction on content. What is important to sponsors at the point of submission can vary, but it is crucial to meet the needs of the sponsor, understand the details and then allocate the appropriate time and set a budget for thorough ISS and ISE that will be certain of meeting the regulator’s expectations.
Visualization of the summaries in terms of creation of output templates is defined at this early stage. These will undergo multiple reviews and updates as the knowledge of the drug increases and as the process becomes more focused, with data becoming available from early phase studies.
Forming a well-integrated and closely-knit team, including the programmer, statistician, medical writer, and physician, is key to ensuring that reviews are performed early enough to allow for a timely setup and reporting. This close partnership, especially between the programmer and statistician, fosters a clearer understanding and enables the delivery of high-quality documents, especially when working on highly technical pieces such as the CTD, all within tight timelines.
Early planning is crucial in determining how data, information, and knowledge are stored. During a product’s lifecycle the data points collected from clinical studies can be used in endless ways for information creation and decision-making. By establishing a system for easy traceability and using effective tools to manage it, you can clearly understand the basis of data-driven decisions and effectively respond to regulatory defense queries. This careful planning and documentation of each piece of data, which form the cornerstone of your product’s label for safety, efficacy, and targeted populations, are vital. These elements, integral to your organization’s intellectual property, must be meticulously planned and documented through metadata and shared with consideration, underpinning the long-term benefits to your product's label.
It is normally a dash to the finish line when the integrated summaries are created. The wait for the data to be delivered for the final clinical study reports can get frustrating as data is being cleaned and the individual study team process the data. Hopefully, by this time your programs are ready to produce all the summary tables that were defined in the templates, and they have been tested and validated to run like a validated application that is robust enough to tackle every eventuality of data.
While there is often pressure to rush the submission process, it is important to balance this with the need for careful review. Project teams should have reviewed the output tables using blinded and unblinded data to make sure that they have all the graphs and summary tables required to best interpret the information. Depending on the company/supplier setup, coordination of the review cycle will generally be done by the clinical data service provider. Getting the input of medical writers and physicians before the unblinding of the Phase III studies is vital but difficult to achieve. Planning review meetings early in people’s calendars and making sure the relevant personnel have performed a quality review prior to the meeting to enable a productive review can be critical in saving on re-engineering of the project’s critical path.
A thorough and careful final review not only impacts the speed at which submissions are reviewed and products are introduced to the market but also affects the quality of the label that is ultimately approved. A well-prepared submission, with information that is well organized, traceable, and clearly understood, is more likely to facilitate a smoother regulatory defence, potentially reducing the number of questions from authorities and the time required for responses. The primary goal should always be the approval of the product, achieved through a high-quality submission that require only one review cycle. The ultimate measure of a quality submission lies in its efficiency in obtaining approval, characterized by fewer queries and a faster turnaround time.
It is important to pre-empt any questions that may come from regulatory authorities to improve the review time of a product and enhance the long-term reputation of your organization. While most project teams believe they have supplied every eventuality in terms of summary tables, insights can always be gained from other submitted projects. Forming a team of experts to critically review the summaries developed for your submission can be an effective strategy. This team should aim to anticipate and address potential questions that regulatory reviews potentially might have.
Effective planning of your integrated summaries should start early in the process of the approval of a product. At Phase II, you should start to plan and be prepared to adapt the plan as knowledge of the product increases. Communicate effectively with the relevant individuals in your teams and ensure close partnerships throughout between your programmers and statisticians. Using metadata, define the standards of how the data is captured, how information is derived and stored, and how knowledge is acquired and subsequently used upfront. This will pay dividends in the traceability of the crown jewels of your product in the long run. Don’t rush the end game and be ready for any questions that may come your way.
Ultimately, an optimal clinical program with great vision, design, and strategy will provide you with the expected results to support your label, but this does need to be backed-up with the right summaries to best explain and interpret your hard work. You may have the right data to strengthen your target product claims, but unless the correct information and knowledge is generated to support this, it could take you a lot longer to get to the approval stage if your planning and summaries are not thought through. The summaries must communicate the vision defined through its selective program design and expert interpretation of the quality data generated, ensuring a coherent and compelling narrative that aligns with regulatory expectations and enhances the likelihood of a successful product launch.
At Quanticate we have a wealth of experience in producing integrated summaries for our clients with our ISS ISE services. Working collaboratively across our biostatistics, programming and medical writing departments we can support you with a successful regulatory submission and product launch when you need to combine multiple studies to prove your drugs efficacy and safety. For more information contact us and speak to a member of our team.
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References
[1] FDA Center for Drug and Biologics Evaluation and Research (CDER and CBER). (April 2009). Guidance for Industry: Integrated Summaries of Effectiveness and Safety: Location Within the Common Technical Document. Retrieved from https://www.fda.gov/downloads/drugs/guidances/ucm136174.pdf
[2] (2018). CTD: M4: The Common Technical Document. [online] Retrieved from https://www.ich.org/page/ctd
[3] ca. (2018). Updated Notice – Mandatory use of the Electronic Common Technical Document (eCTD) format – Canada.ca. [online] Retrieved from https://www.canada.ca/en/health-canada/services/drugs-health-products/drug-products/announcements/notice-mandatory-requirements-using-common-electronic-submissions-gateway-technical-document-format.html
[4] FDA Guidance for Industry – Integrated Summaries of Effectiveness and Safety: Location Within the Common Technical Document. April 2009. https://www.fda.gov/media/75783/download
[5] FDA Center for Drug and Biologics Evaluation and Research (CDER and CBER). Integrated Summary of Effectiveness: Guidance for Industry. October 2015. Retrieved from https://www.fda.gov/downloads/drugs/guidances/ucm079803.pdf
[6] Food and Drug Administration. (1988). Guideline for the format and content of the clinical and statistical sections of new drug applications. FDA, US Department of Health and Human Services Rockville, MA, USA. Retrieved from https://www.fda.gov/media/71436/download / https://www.fda.gov/regulatory-information/search-fda-guidance-documents/format-and-content-clinical-and-statistical-sections-application
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