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The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville MD 20850 *No official support or endorsement by the Food and Drug Administration of this presentation is intended or should be inferred.
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Page 1: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

The Application of Propensity Score Analysis to Non-randomized Medical

Device Clinical Studies: A Regulatory Perspective

Lilly Yue, Ph.D.*CDRH, FDA, Rockville MD 20850

*No official support or endorsement by the Food and Drug Administration of this presentation is intended or should be

inferred.

Page 2: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

2

Outline

1. Randomized clinical trials

2. Non-randomized studies and a potential problem

3. Propensity scores methods for bias reduction

4. Practical issues with the application of propensity score methodology

5. Limitations of propensity score methods

6. Conclusions

Page 3: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

3

Randomized Trials

• All patients have a specified chance of receiving each treatment.

• Treatments are concurrent.

• Data collection is concurrent, uniform, and high quality.

• Expect that all patient covariates, measured or unmeasured, e.g., age, gender, duration of disease, …, are balanced between the two treatment groups.

Page 4: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Randomized Trials

• Assumptions underlying statistical comparison tests are met.

• So, the two trt groups are comparable and observed treatment difference is an unbiased estimate of true treatment difference.

• But, the above advantages are not guaranteed for small, poorly designed or poorly conducted randomized trials.

Page 5: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

5

Nonrandomized Studies and a Potential Problem

• None of advantages provided by randomized trials is available in non-randomized studies.

• A potential problem:

Two treatment groups were not comparable before the start of treatment.

i.e., not comparable due to imbalanced covariates between two treatment groups.

• So, direct treatment comparisons are invalid.

Page 6: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

6

Adjustments for Covariates

• Three common methods of adjusting for confounding covariates:

– Matching

– Subclassification (stratification)

– Regression (Covariate) adjustment

Page 7: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Question: When there are many confounding covariates needed to adjust for, e.g., age, gender, …

– Matching based on many covariates is not practical.

– Subclassification is difficulty: As the number of covariates increases, the number of subclasses grows exponentially:

Each covariate: 2 categories 5 covariates: 32 subclasses

– Regression adjustment may not be possible: Potential problem: over-fitting

Page 8: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

8

Propensity Score Methodology

• Replace the collection of confounding covariates with one scalar function of these covariates: the propensity score.

Age Gender

Duration…….

1 composite covariate:

Propensity Score

Balancing score

Page 9: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Propensity Score Methodology (cont.)

• Propensity score (PS): conditional prob. of receiving Trt A rather than Trt B, given a collection of observed covariates.

• Purpose: simultaneously balance many covariates in the two trt groups and thus reduce the bias.

Page 10: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Propensity scores construction

– Statistical modeling of relationship between treatment membership and covariates

– Statistical methods: multiple logistic regression or others

– Outcome: event -- actual trt membership: A or B

– Predictor variables: all measured covariates, some interaction terms or squared terms, e.g.,

age, gender, duration of disease,…, age*duration,…

Page 11: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Propensity scores construction

– Clinical outcome variable, e.g., major complication event, is NOT involved in the modeling

– No concern of over-fitting

– Obtain a propensity score model: a math equation

PS = f (age, gender, …)

– Calculate estimated propensity scores for all patients

Page 12: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Properties of propensity scores

– A group of patients with the same propensity score are equally likely to have been assigned to trt A.

– Within a group of patients with the same propensity score, e.g., 0.7, some patients actually got trt A and some got trt B, just as they had been randomly allocated to whichever trt they actually received.

Page 13: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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“Randomized After the Fact”

PS=0.7

Trt A Trt B

Page 14: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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– When the propensity scores are balanced across two treatment groups, the distribution of all the covariates are balanced in expectation across the two groups.

– 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.

Page 15: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Compare treatments adjusting for propensity score

– Matching – Subclassification (stratification)– Regression (Covariate) adjustment

Page 16: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

•Matching based on propensity scores (PS)

PS Trt A vs. Trt B

• Compare treatments based on matched pairs• Problem: may exclude unmatched patients

PS1

PS2

PSm

Page 17: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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•Stratification

– All patients are sorted by propensity scores.

– Divide into equal-sized subclasses.

– Compare two trts within each subclass, as in a randomized trial; then estimate overall trt effect as weighted average.

– It is intended to use all patients.

– But, if trial size is small, some subclass may contain patients from only one treatment group.

PS 1 2 ……. 5

Page 18: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Regression (covariate) adjustment

Treatment effect estimation model fitting:

the relationship of clinical outcome and treatment

Outcome: Clinical outcome, e.g., adverse events

Predictor variables: trt received, propensity score, a

subset of important covariates

Statistical method: e.g., regression or logistical

regression

Page 19: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Propensity Score Methods

• Summary

Fit propensity score (PS) model using all measured covariates

Estimate PS for all patientsusing PS model

Compare treatments adjusting for propensity scores

Page 20: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Practical Issues• Issues in propensity score estimation

– How to handle missing baseline covariate values– What terms of covariates should be included– Evaluation of treatment group comparability – Assessment of the resulting balance of the distributions

of covariates• Issues in treatment comparison:

– Which method: matching, stratification, regression• Issues in study design with PS analysis

– Pre-specified vs. post hoc PS analysis– Pre-specify the covariates needed to collect in the study

and then included in PS estimation– Sample size estimation adjusting for the propensity

scores

Page 21: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Example – Device A

• Non-concurrent, two-arm, multi-center study

• Control: Medical treatment without device,

N=65, hospital record collection

• Treatment: Device A, N = 130• Primary effectiveness endpoint: Treatment success

• Hypothesis testing: superiority in success rate• 20 imbalanced clinically important baseline

covariates, e.g., prior cardiac surgery• 22% patients with missing baseline covariate values

Page 22: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Enrollment Time

0

5

10

15

20

25

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002

Ctl Trt

Page 23: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Two treatment groups are not comparable

– Imbalance in multiple baseline covariates– Imbalance in the time of enrollment

• So, any direct treatment comparisons on the effectiveness endpoint are inappropriate.

• And, p-values from direct treatment comparisons are un-interpretable.

• What about treatment comparisons adjusting for the imbalanced covariates?

– Traditional covariate analysis – Propensity score analysis

Page 24: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Performed propensity score (PS) analysis

• Handed missing values – MI: generate multiple data sets for PS analysis – Generate one data set: generalized PS analysis– Others

• Included all statistically significant and/or clinically important baseline covariates in PS modeling.

• Checked comparability of two trt groups through estimated propensity score distributions.

• Found that the two trt groups did not overlap well.

Page 25: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Estimated Propensity Scores (with time)

Ctl Trt

0.0

0.2

0.4

0.6

0.8

1.0Es

timat

ed P

rope

nsity

Sco

re

Page 26: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Estimated Propensity Scores (w/o time)

Ctl Trt

0.0

0.2

0.4

0.6

0.8

1.0E

stim

ated

Pro

pens

ity S

core

Page 27: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Patients in Propensity Score Quintile 1 2 3 4 5 Total Ctl 38 18 8 1 0 65(w/time) 58% 28% 12% 2% 0%

Trt 1 21 31 38 39 130 1% 16% 24% 29% 30%

Ctl 29 24 8 4 0 65 (w/o time) 45% 37% 12% 6% 0%

Trt 10 14 32 35 39 130 8% 11% 24% 27% 30%

Page 28: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Treatment Success 1 2 3 4 5 Total

Crl S 16 8 1 0 25 N 38 18 8 1 0 65

Trt S 0 14 25 24 23 86 N 1 21 31 38 39 130

• Tried Cochran-Mantel-Haenszel test controlling for PS quintile, Logistic regression using PS as a continuous covariate

• However, the sig. p-values are un-interpretable

Page 29: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Conclusion:

– The two treatment groups did not overlap enough to allow a sensible treatment comparison.

– So, any treatment comparisons adjusting for imbalanced covariates are problematic.

Page 30: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Example: Device B

• New vs. control in a non-randomized study

• Primary endpoint: MACE incidence rate at 6-month after treatment

• Non-inferiority margin: 7%, in this study

• Sample size: new: 290, control: 560

• 14 covariates were considered.

Page 31: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Covariate balance checking before and after propensity score stratification adjustment

Mean p-value New Control Before After --------------------------------------------------------------------------------------

Mi 0.25 0.40 <.0001 0.4645

Diab 0.28 0.21 0.0421 0.8608

CCS 2.41 2.75 0.0003 0.3096

Lesleng 11.02 12.16 <.0001 0.5008

Preref 3.00 3.08 0.0202 0.2556

Presten 62.75 66.81 <.0001 0.4053

Page 32: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Model Building

• The PS is conditional Prob. that a patient would have been assigned to new device, based on his or her baseline covariates.

• A hierarchical logistic regression model with a stepwise selection process was used to build the propensity score model.

• The final propensity score model includes all covariates as well as a quadratic term.

Page 33: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Table 2. Distribution of patients at five strata

Subclass Control New Total 1 142 28 170

2 127 43 170

3 122 48 170

4 119 51 170

5 50 120 170

Total 560 290 850

Page 34: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Estimated Propensity Scores

N(new)=560, N(control)=290

Control New

0.0

0.2

0.4

0.6

0.8

1.0

Est

imat

ed P

rop

ensi

ty S

core

Page 35: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Covariate balance checking before and after propensity score stratification adjustment

Mean p-value New Control Before After --------------------------------------------------------------------------------------

Mi 0.25 0.40 <.0001 0.4645

Diab 0.28 0.21 0.0421 0.8608

CCS 2.41 2.75 0.0003 0.3096

Lesleng 11.02 12.16 <.0001 0.5008

Preref 3.00 3.08 0.0202 0.2556

Presten 62.75 66.81 <.0001 0.4053

Page 36: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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•After adj. balance check:

Prior Mi rate:

• Overall: Group % patients with prior Mi New 25 Control 40 Diff 15

• After:

Quintile Group 1 2 3 4 5 New 70.4 32.6 25.0 17.6 15.0 Control 75.2 32.8 30.0 24.8 10.4

Page 37: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Percentage of patients with prior Mi

0

10

20

30

40

50

60

70

80

1st 2nd 3rdsubcla

4th 5th BeforeAdj

NewCtl

Page 38: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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• Adjusted Difference: Mew – Control:

• Point estimate: -1.5%

• 2-sided 95% C.I. : (-6.6%, 3.6%)

• Non-inferiority margin: 7%

• Claim: Non-inferiority w.r.t. Mace 6-month

Page 39: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Study Design

• Plan in advance

• Pre-specify clinically relevant baseline covariates: as many as possible

• Sample size estimation:– Ignore the propensity score adjustment?– Could be inappropriate

Page 40: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Limitations

• Propensity score methods can only adjust for observed confounding covariates and not for unobserved ones.

• Propensity score is seriously degraded when important variables influencing selection have not been collected.

• Propensity score may not eliminate all selection bias.

Page 41: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Limitations

• Propensity score methods work better in larger samples.

• Propensity score is not only way of adjusting for covariates. And, it may or may not be helpful in a particular comparison study.

• Randomized trials are considered the highest level of evidence for trt comparison. Propensity score methods lack the discipline and rigor of randomized trials, and not as definitive as randomized trials.

Page 42: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Conclusions

• Propensity score methods generalize technique with one confounding covariate to allow simultaneous adjustment for many covariates and thus reduce bias.

• Propensity score methodology is an addition to, not a substitute of traditional covariate adjustment methods.

• Plan ahead and carefully consider the practical issues discussed above.

• Randomized studies are still preferred and strongly encouraged whenever possible!

Page 43: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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References

• Rubin, DB, Estimating casual effects from large data sets using propensity scores. Ann Intern Med 1997; 127:757-763

• Rosenbaum, PR, Rubin DB, Reducing bias in observational studies using subclassification on the propensity score. JASA 1984; 79:516-524

• D’agostino, RB, Jr., Propensity score methods for bias reduction in the comparison of a treatment to a non-randomized control group, Statistics in medicine, 1998,17:2265-2281

Page 44: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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References

• Blackstone, EH, Comparing apples and oranges, J. Thoracic and Cardiovascular Surgery, January 2002; 1:8-15

• Grunkemeier, GL and et al, Propensity score analysis of stroke after off-pump coronary artery bypass grafting, Ann Thorac Surg 2002; 74:301-305

• Wolfgang, C. and et al, Comparing mortality of elder patients on hemodialysis versus peritoneal dialysis: A propensity score approach, J. Am Soc Nephrol 2002; 13:2353-2362

Page 45: The Application of Propensity Score Analysis to Non-randomized Medical Device Clinical Studies: A Regulatory Perspective Lilly Yue, Ph.D.* CDRH, FDA, Rockville.

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Thanks!


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