FDA Statistical Review for NDA 210655 in the indication of Schizophrenia:
"The primary analysis was conducted on the change from baseline in the total PANSS score at Day 57 (primary time point) based on the ITT population. A mixed-effects model for repeated measures (MMRM) was used with treatment, visit, interaction of treatment and visit as fixed effects and the baseline total PANSS score as a covariate. Data from Days 15, 29, 43, and 57 were used. The unstructured covariance matrix was be used to model the within-subject variance-covariance errors."FDA BLA 761037 Kevzara (sarilumab) in Treatment of rheumatoid arthritis
"In addition to the model-based missing data approach of the MMRM model, the primary efficacy analysis was also analyzed using a pattern mixture model (PMM) and a multiple imputation approach as sensitivity analyses. "
"The continuous HAQ-DI change from baseline at Week 16 was analyzed with a mixed model for repeated measures (MMRM). The repeated-measures analysis was based on the restricted maximum likelihood method assuming an unstructured covariance structure to model the within-subject errors. The model, including treatment, region, prior biologic use, visit (all visits from week 2 to week 16), and treatment-by-visit interaction as fixed effects and baseline as a covariate, was used to test the difference between each active treatment group versus placebo in the change from baseline in HAQ-DI at Week 16. The data collected after treatment discontinuation or rescue were set to missing. Therefore, the MMRM analysis assumed a missing-at-random (MAR) mechanism for missing data due to dropout and post-rescue data."FDA NDA 203313/203314S-2 /S-3Tresiba;Ryzodeg 70/30Glycemic Control in Patients with Diabetes
The applicant used a mixed effect model for repeated measure (MMRM) to assess the efficacy of IDegAsp compared with IDet. The MMRM model included treatment, sex, region, age group and visits as factors and baseline as covariate, and interactions between visits and all factors and covariate. An unstructured covariance matrix was utilized for model fitting.SNDA for Merck's Dulera in the treatment of asthma (2019)
Multiple imputation was performed as sensitivity analysis
"Missing Data Handling and Sensitivity Analyses The primary analysis incorporated a control-based multiple imputation of missing data. Missing data for subjects who discontinued treatment early were estimated using the MF group; that is, the change from baseline AM post-dose ppFEV1 in patients who discontinued treatment and missed study visits was assumed to be similar to the change from baseline in patients who continued study visits through Week 12 in the MF treatment group. The dataset was first multiply imputed to have monotone missing patterns, then for each visit, a regression method was used to impute for missing data on both study drug arm and the control arm based on trend from the control arm. After applying the control-based multiple imputation, the cLDA analysis was performed. MF/F 100/10 mcg BID was considered superior to MF 100 mcg BID with a p-value less than 0.05. "
EMA seems to have a different opinion about missing data handling using MMRM or MI. On several occasions, we have heard that EMA prefers the MI approach in handling the missing data especially the reference-baseline multiple imputation. They are moving towards developing the reference-based multiple imputation into the new standard missing data approach.
Here is a table summarizing some comparisons between the MMRM and MI in handling the missing data.
|
MMRM |
MI |
Missing data mechanism |
MAR (missing at random) |
|
Missing data imputation |
Not imputed for individual missing values But missing data is implicitly imputed |
Individual missing values are explicitly imputed |
# of steps for calculations |
One step |
At least three steps: Imputation model to create multiple data sets with missing values
filled in Analysis model to analyze each imputed data set Using Robin’s rule to combine results for inference |
Analysis Model |
Mixed model with Maximum likelihood-based method |
Analysis of Covariance or Mixed model using maximum likelihood-based
method |
Data points used in analyses |
Utilized all observed data points from all visits |
Usually, with ANCOVA, only the data points for the corresponding
visits (with imputed values) are used. |
SAS procedure(s) |
Proc Mixed |
Imputation model: Proc MI Analysis model: Proc Mixed, Proc GLM, Proc Genmod,… Robin’s rule: Proc MIANALYZE |
Results |
The two approaches will be approximately equivalent, provided the variables used in the imputation model are the same as those included in the analysis model, and conditionals are accommodated by a single joint model. In such settings, MI essentially provides an approximation to the observed likelihood analysis. If an infinite number of imputations could be performed,
then the two approaches would be equivalent. In practice, the level of
equivalence will depend on the number of imputations due to the Monte Carlo
(simulation) sampling variability of the imputation process (described in more detail below), thus will be stronger for a larger number of imputations.
|
|
Auxiliary variables |
Can not be used |
Auxiliary variables can be used in the imputation model to improve the
accuracy of the missing data prediction |
Information observed post-randomization |
Can not be included in the MMRM model |
Can be included in the imputation model to improve the accuracy of
the missing data prediction and can’t be included in the analysis model (MI approach
allows the differences in the covariates used in the imputation model and in
analysis model |
Justification of MAR assumption |
Not available through MMRM model |
Justification of MAR assumption can be performed through the tipping point
approach or delta-based imputation |
Handling the MNAR (missing not at random) |
Not directly available through MMRM |
Can be performed through PMM (pattern mixed model), reference-based
or control-based multiple imputation |
For studies with only one post-baseline measure |
Not appropriate |
Appropriate to use MI to impute the missing data and then run
analysis of covariance model as the analysis model |
For outcome measures that are not continuous variables |
Like MMRM, there are statistical approaches that handle missing data without
employing explicit imputation. As mentioned in the EMA guideline “For categorical
responses and count data, the so-called marginal (e.g. generalized estimating
equations (GEE)) and random-effects (e.g. generalized linear mixed models
(GLMM)) approaches are in use. Likelihood-based methods (MMRM and GLMM) and
some extended GEE (i.e. weighted GEE) models are applicable under MCAR and
MAR assumptions.” |
MI approach can be easily
applied to the outcome measures that are categorical responses or count data
with missing data. The analysis model may need to be PROC Logistics; PROC GLIMMIX,
PROC NLMIXED, or PROC
GENMOD |
Preferred by regulatory agencies |
US FDA but with multiple imputation approaches as sensitivity analyses (for example, reference-based MI, PMM, tipping point) |
EMA |
REFERENCES:
- CRO et al (2020) Sensitivity analysis for clinical trials with missing continuous outcome data using controlled multiple imputation: A practical guide
- Michael Kenward (2013) The handling of missing data in clinical trials
- Lisa M. LaVange Thomas Permutt (statistics in Medicine, 2015) A regulatory perspective on missing data in the aftermath of the NRC report
- Little et al (NEJM 2012) The Prevention and Treatment of Missing Data in Clinical Trials
- Ware et al (NEJM 2012) Missing Data
- Permutt (Statistics in Medicine, 2015) Sensitivity analysis for missing data in regulatory submissions
- LaVange and Permutt (Statistics in Medicine, 2015) A regulatory perspective on missing data in the aftermath of the NRC report
- Liu and Pang (Statistics in Biopharmaceutical Research, 2017) Control-Based Imputation and Delta-Adjustment Stress Test for Missing Data Analysis in Longitudinal Clinical Trials
- Tang (Statistics in Biopharmaceutical Research, 2017) An Efficient Multiple Imputation Algorithm for Control-Based and Delta-Adjusted Pattern Mixture Models using SAS
- Berglund and Heeringa (2014) Multiple Imputation of Missing Data Using SAS Chapter 7 gives examples of missing data imputation for dichotomous outcome variable and count data.