CLINICAL REVIEW

 

 

                Application Type    NDA #20-838

            Submission Number    S-025

                 Submission Code   

 

 

 

 

 

 

 

 

 

 

                  Reviewer Name    Mehul Desai, M.D.

    Review Completion Date    3-Jan-2005

 

 

               Established Name    Candesartan Cilexitil

      (Proposed) Trade Name    Atacandâ

               Therapeutic Class    angiotensin receptor antagonist

                            Applicant    AstraZeneca

 

            Priority Designation    Standard

 

 

                         Formulation    oral

                  Dosing Regimen    initial dose of 4 mg qd up titrated to 32 mg qd

                            Indication    heart failure

            Intended Population    “preserved EF (> 40%)”


Table of Contents

1      Executive Summary.. 1

1.1        Recommendation on Regulatory Action.. 1

1.2        Recommendation on Postmarketing Actions. 2

1.3        Summary of Clinical Findings. 2

1.3.1      Brief Overview of Clinical Program.. 2

1.3.2      Efficacy. 3

1.3.3      Safety. 3

1.3.4      Dosing Regimen and Administration. 3

1.3.5      Drug-Drug Interactions. 3

1.3.6      Special Populations. 4

2      Introduction and Background.. 4

2.1        Product Information.. 4

2.2        Currently Available Treatment for Indications. 4

2.3        Availability of Proposed Active Ingredient in the United States. 4

2.4        Important Issues With Pharmacologically Related Products. 5

2.5        Presubmission Regulatory Activity.. 5

3      Significant Findings from Other Review Disciplines.. 5

3.1        CMC (and Product Microbiology, if Applicable) 5

3.2        Animal Pharmacology/Toxicology.. 5

4      Data Sources, Review Strategy, and Data Integrity.. 5

4.1        Sources of Clinical Data.. 5

4.2        Tables of Clinical Studies. 5

4.3        Review Strategy.. 6

4.4        Data Quality and Integrity.. 6

4.5        Compliance with Good Clinical Practices. 6

4.6        Financial Disclosures. 6

5      Clinical Pharmacology.. 6

5.1        Pharmacokinetics. 6

5.2        Pharmacodynamics. 7

6      Integrated Review of Efficacy.. 7

6.1        Indication: Preserved EF. 7

6.1.1      Methods. 7

6.1.2      General Discussion of Endpoints. 7

6.1.3      Study Design. 9

6.1.4      Efficacy Findings. 10

6.1.5      Efficacy Conclusions. 12

7      Integrated Review of Safety.. 13

7.1        Methods and Findings. 13

7.1.1      Deaths. 13

7.1.2      Other Serious Adverse Events. 14

7.1.3      Dropouts and Other Significant Adverse Events. 16

7.1.4      Common Adverse Events. 17

7.1.5      Laboratory Findings. 19

7.1.6      Vital Signs. 21

7.2        Adequacy of Patient Exposure and Safety Assessments. 24

7.2.1      Description of Primary Clinical Data Sources (Populations Exposed and Extent of Exposure) Used to Evaluate Safety  24

7.3        Summary of Selected Drug-Related Adverse Events, Important Limitations of Data, and Conclusions. 25

8      Additional Clinical Issues.. 25

8.1        Dosing Regimen and Administration.. 25

8.2        Drug-Drug Interactions. 25

8.3        Special Populations. 26

8.4        Pediatrics. 26

8.5        Advisory Committee Meeting.. 26

8.6        Literature Review... 27

9      Overall Assessment.. 27

9.1        Conclusions. 27

9.2        Recommendation on Regulatory Action.. 28

9.3        Recommendation on Postmarketing Actions. 28

9.4        Labeling Review... 28

My labeling recommendations are as follows: 28

10     Appendices.. 29

10.1       Review of Individual Study Reports. 29

10.1.1         CHARM Preserved. 29

10.2       Line-by-Line Labeling Review... 38

References.. 39



List of Tables

Table 1: Presubmission Regulatory highlights. 5

Table 2: Table of Clinical Studies in CHARM Preserved. 6

Table 3: Efficacy results of primary variable. 11

Table 4: Comparative event rates in the components of the CHARM Program.. 12

Table 5: Components of Primary endpoint 12

Table 6: Primary endpoint (CV death, CHF hospitalizations) by baseline EF. 12

Table 7: Summary of AE’s, SAE’s, and Discontinuations/dose reductions of study. 13

Table 8: AE’s leading to death in CHARM preserved (cutoff > 0.3%) 14

Table 9: Serious Adverse Events other than Death (Frequency > 1% on candesartan) 15

Table 10: Summary of discontinuations due to AE’s in CHARMED preserved (cutoff > 0.5%) 16

Table 11: Summary of dose reductions due to AE’s in CHARMED preserved (cutoff > 0.3%) 17

Table 12: Common AE’s occurring in CHARM Preserved. 17

Table 13: Change from baseline in serum potassium (last value carried forward) 19

Table 14: Number (%) of patients with serum K+ > 6 mmol/L any time after randomization. 20

Table 15a: Listing of patient outliers with respect to serum K+. 20

Table 16: Number (%) of patients with serum creatinine > 2x baseline value during study. 21

Table 17: Change from baseline in hematocrit (%)(last value carried forward) 21

Table 18: Listing of patient outliers with respect to serum hemoglobin. 21

Table 19: Summary of SBP and DBP outliers. 23

Table 20: Summary of Exposure in CHARM preserved. 24

Table 21: % of patients and investigational drug dose by visit and treatment 24

Table 22:  CV death and CHF hospitalization by ethnicity in CHARM Preserved. 26

Table 23: CV death and CHF hospitalization by ethnicity in overall CHARM Program.. 26

Table 24: CV death, CHF hospitalizations, and All cause mortality in Orientals in overall CHARM Program   26

Table 25: Summary of clinical trials of ARB use in heart failure patients. 27

Table 26: Chronology of the CHARM Program highlights. 29

Table 27: Summary of Protocol Amendments in the CHARM program.. 32

Table 28: CHARM Preserved patient baseline characteristics. 36

Table 29: CHARM preserved patient baseline characteristics. 36

Table 30: Patients (%) using the listed class of drug at the time of study entry. 37

Table 31: Subgroup analysis of CV death or CHF hospitalization. 38


Abbreviations

AE = adverse event

ARB = angiotensin receptor blocker

CHF = congestive heart failure

CRF = case report form

CSR = clinical study report

CTD = common technical document

CV = cardiovascular

DBP = diastolic blood pressure

EF = ejection fraction

MI = myocardial infarction

NDA = new drug application

NYHA = New York Heart Association

SAE(’s) = serious adverse event

SBP = systolic blood pressure

 


1          Executive Summary

1.1        Recommendation on Regulatory Action

The CHARM Program was a prospective, randomized clinical trial of the use of candesartan, a selective angiotensin II receptor blocker, in patients with congestive heart failure to decrease cardiovascular morbidity and mortality.  The 3 sub studies within the CHARM Program were: CHARM Alternative, CHARM Added, and CHARM Preserved.  The focus of this review is CHARM Preserved.  Please refer to the review by Dr. Khin U for details on CHARM Alternative and CHARM Added.    

CHARM Preserved was a prospective, randomized, double-blind, placebo controlled study to evaluate the effectiveness of candesartan in reducing cardiovascular mortality and/or morbidity in congestive heart failure patients (NYHA Class II through IV) with a preserved ejection fraction (EF > 40%).  It is important to note that the choice of an EF > 40% to define a subset of the heart failure population as having “preserved EF” is arbitrary but very relevant to this review.  It is possible for patients with an EF around 40% (e.g. 41% to 45% or possibly even higher) to have some degree of systolic dysfunction making them similar to patients in either the CHARM Alternative or CHARM Added study.    

In CHARM preserved, an EF > 40% was used as a surrogate to describe heart failure patients as having “diastolic dysfunction.”  However, a purist would require evidence of an upward shift in the end-diastolic pressure-volume relation (EDPVR)1,2 to describe such a population.  The characterization of the EDPVR is complicated and is not routinely done in clinical practice.  The medical literature suggests that CHF patients with an EF > 40% comprise between 20% to 50% of all patients with CHF3.  It seems to be widely accepted that patients with diastolic heart failure have a better prognosis compared to patients with systolic heart failure, although recent reports seem to refute this notion4. 

The vast majority of research in CHF patients has focused on those with an EF < 40% while the optimal medical management of patients with EF > 40% has yet to be defined.  CHARM Preserved represents one of the first attempts to study the effects of a renin angiotensin system blocker in patients with a preserved EF in a prospective, controlled clinical trial.

The CHARM Preserved study was the sole study submitted by the sponsor to support approval in patients with a preserved EF.  There were no supportive studies for this indication.  More than 3000 patients with predominantly NYHA Class II and III heart failure were randomly assigned to placebo or candesartan and followed up for 2 to 4 years.  This was a multi-national study enrolling patients from Europe, Asia, Africa, and North America.  Patients were started on candesartan once daily doses of 4 to 8 mg and titrated every two weeks to a maximum dosage of 32 mg once daily as tolerated.  The primary endpoint was CV death or CHF hospitalization.  In terms of relevant demographics, the mean age of patients enrolled was 67 years, 40 % were female, and more than 4% were Black.  The most prevalent background therapy in this patient population was diuretics.  The primary endpoint was reached in 333 patients in the candesartan arm and 366 patients in the placebo arm: hazard ratio 0.89 (0.77, 1.03), p-value 0.12.  CHARM Preserved did not achieve its primary pre-specified endpoint.  The observed trend appears to be driven by patients with an EF between 40 and 50%.  By arbitrarily defining patients with an EF > 40% as having a “preserved EF”, the study likely included patients with systolic dysfunction into CHARM Preserved.  Based on the CHARM Added and CHARM Preserved components reviewed by Dr. U, it is evident that patients with systolic dysfunction will benefit from candesartan in terms of CV mortality and morbidity.  Another possibility for the observed trend is that patients with an EF > 40% represent a unique heart failure sub-population that could respond to candesartan but that CHARM Preserved was simply underpowered to detect a significant difference.  Differentiating these two possibilities would require further studies by the sponsor.           

Candesartan has been approved for the treatment of hypertension since 1997 and thus has a large post marketing safety experience.  Patients in the CHARM Preserved study were followed for a minimum duration of 24 months and a mean duration of 35 months.  Study drug discontinuations were higher in the candesartan arm (18%) versus the placebo arm (13%).  Three common adverse events of special interest that led to discontinuation of study drug were hyperkalemia, hypotension, and abnormal renal function.  Other common AE’s that led to study drug discontinuation were dizziness/vertigo and diarrhea.  The frequencies of the adverse events leading to study drug discontinuation were higher on candesartan compared to placebo and were consistent across the entire CHARM Program.   Other commonly occurring adverse events that occurred with a greater frequency on candesartan compared to placebo were anemia, dehydration, and fatigue and were consistent across the CHARM Program.

In summary, given the single study that failed to meet its primary endpoint,           

                                      of candesartan for use in a subset of heart failure patients with “preserved” EF.                                          

           

1.2        Recommendation on Postmarketing Actions

N/A

1.3        Summary of Clinical Findings

1.3.1       Brief Overview of Clinical Program

CHARM Preserved was one component of the overall CHARM program that evaluated the efficacy of candesartan to reduce cardiovascular morbidity and mortality in patients with congestive heart failure.  CHARM Preserved focused on the subset of patients with an arbitrarily defined EF of greater than 40%.  The sponsor provided results from one adequate and well controlled study to support the use of candesartan in this subset population.  There were no supportive studies in this subpopulation.

CHARM Preserved was a prospective, randomized, double-blind, placebo controlled study to evaluate the effectiveness of candesartan in reducing cardiovascular mortality and CHF hospitalizations in congestive heart failure patients (NYHA Class II through IV) with a preserved ejection fraction (EF > 40%).        

1.3.2       Efficacy

The CHARM Preserved study was the sole study submitted by the sponsor to support approval in patients with a preserved EF.  There were no supportive studies for this particular subset of heart failure patients.  More than 3000 patients with predominantly NYHA Class II and III heart failure were randomly assigned to placebo or candesartan and followed up for 2 to 4 years.  The primary endpoint was time to CV death or CHF hospitalization.  The patients in the two arms of the study were similar at baseline in terms of demographics and pre-study medications.  The mean age of patients enrolled was 67 years and the mean EF was 54%.  More than 1/3 of the patients enrolled had an EF between 40 and 50.  Approximately 75% of patients were being treated with diuretics at the time of randomization.  The primary endpoint was reached in 333 patients in the candesartan arm and 366 patients in the placebo arm: hazard ratio 0.89 (0.77, 1.03), p-value 0.12.  CHARM Preserved did not achieve its primary pre-specified endpoint.  Neither component of the primary endpoint reached a statistically significant p-value of < 0.05. 

1.3.3       Safety

Candesartan has been approved for the treatment of hypertension since 1997 and thus has a large post marketing safety experience.  There were no unexpected safety findings from CHARM Preserved.  The mean duration in study was 35 months.  Study drug discontinuations were higher on candesartan arm versus placebo.  Three common adverse events of special interest that led to discontinuation of study drug were hyperkalemia, hypotension, and abnormal renal function.  Other common AE’s that led to study drug discontinuation included dizziness/vertigo and diarrhea. 

Other commonly occurring adverse events that occurred with a greater frequency on candesartan compared to placebo were anemia, dehydration, and fatigue and were consistent across the CHARM Program.

 

 

1.3.4       Dosing Regimen and Administration

Patients randomized to the candesartan arm were started on daily doses of either 4 or 8 mg and titrated every two weeks to a maximum dose of 32 mg once daily.     

1.3.5       Drug-Drug Interactions

N/A

1.3.6       Special Populations

CHARM Preserved was not designed to evaluate the efficacy of candesartan as a function of sex or ethnicity.  The effect of candesartan appeared similar in female and male patients.  A subgroup analysis of the primary endpoint by ethnicity revealed that in Orientals, the effect of candesartan was negative.  The hazard ratio for cardiovascular mortality and CHF hospitalizations was 3.7 [95%CI (1.2, 12), p-value 0.026.].  A total of 42 Oriental patients contributed 14 primary events.  The negative effect of candesartan on the primary endpoint in the Oriental subgroup seen in CHARM Preserved was consistent when analyzing pooled data across the entire CHARM Program.  In the overall CHARM Program, 133 Oriental patients contributed 51 primary events.  There is evidence of statistical heterogeneity in this subgroup.

 

2          Introduction and Background

2.1        Product Information

Candesartan (ATACANDÒ) is a selective angiotensin II type 1 (AT1) receptor blocker that is currently approved for the treatment of hypertensive patients.  In the current supplemental NDA, the sponsor has submitted clinical data in support of the use of candesartan in patients with congestive heart failure.    

2.2        Currently Available Treatment for Indications

Nearly all of the guidelines for the management of heart failure are in patients with left ventricular systolic dysfunction (EF < 40%).  Currently there are no consensus guidelines for the treatment of heart failure patients with preserved ejection fraction (EF > 40%).  Until CHARM Preserved, there have been no studies of adequate size evaluating clinically meaningful endpoints to guide management in the subset of patients with preserved systolic function. 

 

In general terms, management of heart failure patients with preserved EF (referred to as diastolic heart failure by many) is to reverse the consequences of diastolic dysfunction (e.g. venous congestion and exercise intolerance) and secondly to eliminate or reduce factors that are responsible for diastolic dysfunction (e.g. hypertrophy, fibrosis, ischemia)5.  Diuretics are the mainstay of management for venous congestion while calcium channel blockers are used for their beneficial effects in terms of myocardial ischemia, hypertension, and/or hypertrophy.  However, neither of these two classes of drugs is labeled for use in patients with diastolic heart failure.  Other agents that may also be potentially beneficial include beta blockers or renin angiotensin system blockers.      

2.3        Availability of Proposed Active Ingredient in the United States

Candesartan was approved in 1998 for the treatment of hypertension.   

2.4        Important Issues With Pharmacologically Related Products

N/A

2.5        Presubmission Regulatory Activity

Discussed here are key regulatory highlights.  Please refer to Dr. Khin U’s review for further details.  Table 1 below summarizes major regulatory highlights for this supplemental NDA application. 

 

Table 1: Presubmission Regulatory highlights

March 1993

Patent issued for candesartan cilexetil

June 1998

Candesartan cilexetil approved for the treatment of hypertension

October 1998

EOP2 meeting regarding the heart failure program

March 1999

The sponsor submitted the CHARM Program (studies SH-AHS-0003, 0006, and 0007)

November 2003

Pre supplemental NDA teleconference between Sponsor and FDA to discuss plans for filing. 

June 2004

Supplemental NDA filed

 

3          Significant Findings from Other Review Disciplines

3.1        CMC (and Product Microbiology, if Applicable)

No chemistry issues affecting approvability were identified. 

3.2        Animal Pharmacology/Toxicology

No animal pharmacology/toxicology issues affecting approvability were identified. 

4          Data Sources, Review Strategy, and Data Integrity

4.1        Sources of Clinical Data

The sponsor submitted one pivotal study (CHARM Preserved) for the use of candesartan in patients with a preserved ejection fraction.  The sponsor’s sNDA submission was in the electronic CTD format.  Case report forms (CRF’s) for death and study drug discontinuations due to AE’s, case report tabulations, and clinical study report were provided by the sponsor for patients in CHARM Preserved.    

4.2        Tables of Clinical Studies

The following table lists the one study that was submitted by the sponsor in support of the use of candesartan in heart failure patients with preserved EF.  Unlike for the other two components of the CHARM Program, there were no supportive studies conducted in this subset of patients with heart failure. 

Table 2: Table of Clinical Studies in CHARM Preserved

Study

Title

SH-AHS-0007 (CHARM Preserved)

“Clinical Study of Candesartan in Patients With Heart Failure and Preserved Left Ventricular Systolic Function”

 

4.3        Review Strategy

The focus of this review is CHARM Preserved.  The other components of the CHARM Program (CHARM Alternative and CHARM Added) have been reviewed by Dr. Khin U.  I initially read over the original CHARM protocols and subsequent protocol amendments.  I then read over the sponsor’s clinical study report for CHARM Preserved.  This review is primarily based on the sponsor’s clinical study report for CHARM Preserved.  With the help of the Statistical Reviewer Dr. Charles Le, the results of the primary efficacy variable were validated.  Case report forms for death and study drug discontinuation due to AE’s were provided.  Selected CRF’s were reviewed in depth.    

4.4        Data Quality and Integrity

DSI audits were not felt to be relevant to this efficacy supplement (Please refer to Dr. Khin U’s review of CHARM Added for a detailed rationale). 

4.5        Compliance with Good Clinical Practices

A debarment certification was signed by a representative of the sponsor. 

4.6        Financial Disclosures

Please refer to Dr. Khin U’s review of CHARM Added for further details.  His review of financial disclosures is applicable to CHARM Preserved. 

5          Clinical Pharmacology

5.1        Pharmacokinetics

Please refer to the detailed “Clinical Pharmacology and Biopharmaceutics Review” completed by Dr. Nhi Beasley. 

 

The pharmacokinetics (PK) of candesartan were studied in NYHA Class II and III heart failure over the dose range of 2 to 16 mg once daily.  The PK was linear over this dose range.  No attempt was made to examine PK differences based on low EF or preserved EF and there is no clear rationale of why such a difference should exist.  In general, the exposure (as measured by plasma concentration area under the curve) to candesartan was approximately doubled in patients with NYHA Class II and III heart failure compared to healthy, young patients.  As candesartan is not a narrow therapeutic index drug, this change in exposure is not expected to significantly alter its safety profile.       

5.2        Pharmacodynamics

Please refer to the detailed “Clinical Pharmacology and Biopharmaceutics Review” completed by Dr. Nhi Beasley.  No specific pharmacodynamic studies were conducted in patients with preserved EF.

 

6          Integrated Review of Efficacy

6.1        Indication: Preserved EF

The indication as transcribed from the sponsor’s proposed label is shown below.  Highlighted and italicized are sections in the proposed labeling specifically referring to the patient population with a preserved ejection fraction. 

 

“ATACAND is indicated for the treatment of heart failure (NYHA class II-IV). ATACAND reduces the risk of death from cardiovascular causes and improves symptoms in patients with left ventricular systolic dysfunction, and reduces hospitalizations for heart failure in patients with depressed or preserved left ventricular systolic function. These effects occur in patients receiving other heart failure treatments with or without ACE inhibitors, including patients intolerant to ACE inhibitors, and with or without beta-blockers.” 

 

In essence the claim the sponsor seeks based on CHARM Preserved is a reduction in heart failure hospitalizations in patients with a preserved EF. 

6.1.1       Methods

In support of the indication for Preserved EF stated above, there was one adequate and well controlled trial submitted to NDA 20-863, SH-AHS-0007, “Clinical Study of Candesartan in Patients With Heart Failure and Preserved Left Ventricular Systolic Function.”  There were no supportive studies (e.g. Phase 2 studies) submitted for this indication.       

6.1.2       General Discussion of Endpoints

The endpoints collected during this trial were clinically relevant and included both morbidity and mortality.  The endpoints chosen in the CHARM program were not inconsistent with endpoints utilized in other large outcome studies involving patients with heart failure.  The components of the primary and other secondary endpoints collected during the CHARM program are described below.    

 

Cardiovascular (CV) death:  All deaths were considered CV unless an unequivocal non-CV cause could be established.  This category included sudden death, death due to MI, death due to heart failure, death due to stroke, death due to a CV investigation/procedure/operation, death due to other CV causes, presumed CV deaths and deaths from unknown causes. 

 

Hospitalization for heart failure: A hospitalization was defined as any overnight stay in a hospital.  A CHF hospitalization was defined as admission to hospital necessitated by heart failure and primarily for the treatment of heart failure.  A patient admitted for this reason was to demonstrate signs and symptoms of worsening heart failure and require treatment with intravenous diuretics.

Signs or symptoms of worsening heart failure could include at least one of the following:

·        Increasing dyspnea on exertion

·        Orthopnea

·        Nocturnal dyspnea

·        Increasing peripheral edema

·        Increasing fatigue/decreasing exercise tolerance

·        Renal hypoperfusion/ worsening renal function

·        Elevated JVP

·        Radiologic signs of CHF       

 

All cause mortality: Death from any cause

 

Myocardial infarction (MI): A diagnosis of MI was to be made if the following conditions were met:

·        Creatinine kinase (CK) or CKMB > 2x upper limit of normal (ULN) or

·        CK > 3 x ULN immediately following PTCA or

·        Troponin I or troponin T > 2 x ULN in hospitals where CK measurement unavailable

AND

·        ECG demonstrated development of pathological Q waves and/or the development or disappearance of localized ST-elevations combined with the development of T inversion in at least two of the routine standard leads and clinical history consistent with myocardial infarction. 

 

The CHARM Program utilized a Clinical Endpoints Committee (CEC).  The Chair of the Committee was Dr. Scott Solomon.  The objectives of the Committee were to classify deaths and to adjudicate CHF hospitalizations and MI’s in a consistent and unbiased manner.  The adjudication process was identical for all three components of the CHARM Program.  The CEC adjudicated data were used in the analyses of the primary and secondary endpoints.  Adjudication was done in a blinded manner.  One member of the Committee reviewed each case that was submitted for adjudication.  If the CEC member agreed with the principal investigator’s (PI) endpoint diagnosis, the endpoint was considered adjudicated.  If the CEC member disagreed with the PI, the endpoint was given to the Chairman for review, discussion, and final adjudication.        

6.1.3       Study Design

CHARM Preserved (SH-AHS-0007) was an adequate and well controlled study submitted in support of the use of candesartan in patients with preserved systolic function (EF > 40%.) 

 

CHARM Preserved was a randomized, double-blind, placebo controlled, parallel group, multi-centered study to evaluate the influence of candesartan (4 mg once daily titrated to target dose of 32 mg once daily) on mortality and morbidity endpoints in patients with preserved left ventricular (LV) systolic function. 

 

 A pictorial of the study design is shown in Figure 1 below.  Following randomization, patients were to have study drug titrated every two weeks as tolerated to a maximum dose of 32 mg once daily. 

Figure 1: Study Design of CHARM (SH-AHS-0003, 0006, 0007)

Source: Figure 1 of SH-AHS-0007 CSR

 

In order to preserve the blind, placebo tablets were identical in appearance to the active drug.  The biostatistician of the Safety Committee was the only person that could be unblinded to the data while the CHARM program was in process. 

 

Study randomization was done centrally using an Interactive Voice Response System.  Patients were randomized in blocks of four.  Patients were randomized to candesartan or placebo in a ratio of 1:1.

 

As discussed above, the CHARM Program also consisted of a CEC, which adjudicated endpoint events in a blinded manner.  In addition, there was also a Data Safety Committee that functioned independently of all other individuals and bodies associated with the conduct of the CHARM Program (e.g. investigators, Steering Committee, and Study Sponsor).  The Safety Committee received safety data on a monthly basis and was responsible for reviewing the safety data continually during the program.          

 

A data analysis plan was formulated but not finalized until approximately 2 weeks after study closure. 

 

Placebo was the control treatment in all 3 components of the CHARM program including CHARM  Preserved.      

 

The duration of the studies the CHARM Program appeared to be adequate.  The patient recruitment period was 16 months.  The total study duration could range from 32 to 48 months depending on when a patient was randomized.  The minimum duration of patient follow-up post randomization was to be 2 years.

 

The CHARM Program enrolled patients 18 years of age or older with symptomatic heart failure (NYHA Class II – IV).  There were additional study specific inclusion criteria for each component of the CHARM Program.  Please refer to section 10.1.1.2 in the Appendix for details regarding inclusion/exclusion criteria. 

 

The current maximum approved dose of candesartan for the approved indication of hypertension is 32 mg once daily.  The CHARM Program was designed as a dose titration study utilizing maximally tolerated doses of candesartan up to 32 mg.          

 

6.1.4       Efficacy Findings

CHARM Preserved was the lone study in support of the proposed indication in patients with preserved left ventricular systolic function.  The study did not achieve its primary pre-specified endpoint of a statistically significant reduction in CV mortality or CHF hospitalizations (p-value of 0.12.) 

 

CHARM Preserved randomized a total of 3025 patients of whom 2 did not receive any study drug.  Thus, a total of 3023 patients were evaluable in the ITT population.  Three patients in the ITT population were lost to follow-up (2 on placebo, 1 on candesartan).  The mean age of study patients was 67 + 11 years.  Forty percent of the patients were female, 90% were European, and more than 98% were of Class II/III NYHA class.  The etiology of CHF was ischemic heart disease in more than 50% of patients followed by hypertension in approximately 23% of patients.  The mean ejection fraction in randomized patients was 54%.  The percentage of patients on digitalis glycosides, diuretics, beta-blockers, calcium channel blockers, vasodilators, long acting nitrates, and ACE inhibitors was 28%, 75%, 56%, 69%, 38%, 33%, and 19% respectively.      

 

The baseline characteristics of the two treatment groups were generally similar as shown in Table 28 and Table 29 in the Appendix of this review.  Shown in these tables are risk factors for congestive heart failure as well as risk factors for cardiovascular disease for the two treatment groups.  The use of various medications at baseline and at study closure are listed in Table 30 located in the Appendix. 

 

The results of the primary efficacy variable are shown below.    The results were confirmed independently by Dr. Charles Le, FDA statistician. 

 

Table 3: Efficacy results of primary variable

 

Candesartan

(N = 1514)

Placebo

(N = 1509)

Hazard ratio

(95% CI)

p-Value

CV death or

CHF hospitalization

333

366

0.89

(0.77, 1.03)

0.12

Note: This data in this table obtained from Table 24 of SH-AHS-0007 CSR

 

The primary endpoint is displayed graphically in a Kaplan-Meier plot in Figure 2 below.    

 

 

Figure 2: Cumulative incidence (%) of confirmed adjudicated CV death or hospitalization due to CHF over time

Source: Figure 4 of SH-AHS-0007 CSR

As seen in the table and figure above, the CHARM Preserved study did not meet its primary objective.  It is important to note that the incidence of cardiovascular mortality and morbidity was lower in CHARM Preserved compared to the other two components of the CHARM Program as shown in Table 4 below.    

 

Table 4: Comparative event rates in the components of the CHARM Program

 

Events per 1000 follow-up years

 

Placebo

Candesartan

SH-AHS-003 (“Alternative”)

182

138

SH-AHS-006 (“Added”)

166

141

SH-AHS-0007 (“Preserved”)

91

81

Note: Data in this table obtained from Table 24, Table 23, and Table 23 of SH-AHS-0003, SH-AHS-0006, and SH-AHS-0007 CSR respectively.

 

In terms of the individual components contributing to the primary endpoints, there was no statistically significant difference in terms of CV death or in terms of CHF hospitalization as shown in the table below. 

Table 5: Components of Primary endpoint

 

Candesartan

(N = 1514)

Placebo

(N = 1509)

Hazard ratio

(95% CI)

p-Value

CV death

170

170

0.989

(0.80, 1.22)

0.918

CHF hospitalization

241

276

0.853 (0.718, 1.014)

0.072

Note: The data in this table obtained from Table 30 of SH-AHS-0007 CSR

 

Various subgroup analyses (e.g. age, sex, and ethnicity) of the primary endpoint are discussed in detail in the Appendix of this review.    

 

The result of one relevant subgroup analysis is shown in Table 6 below. 

Table 6: Primary endpoint (CV death, CHF hospitalizations) by baseline EF

Variable

Group

N

Cand # of events

Placebo # of events

Hazard ratio (95% CI)

P-value

LVEF

< 0.50

1072

106

131

0.78 (0.60, 1.01)

0.055

 

> 0.50

1951

227

235

0.95 (0.79, 1.14)

0.592

 

 

The tabular results of the secondary endpoints are not displayed in this review.  The pre-specified secondary endpoint of time from randomization to all cause death and CHF hospitalization was not statistically significant between the two study groups.  Similarly the other secondary endpoint consisting of time from randomization to CV death, CHF hospitalization or non-fatal MI was not statistically significant between the two study arms. 

6.1.5       Efficacy Conclusions

The CHARM Preserved study was the sole study submitted by the sponsor to support approval in patients with a preserved EF.  There were no supportive studies for this particular subset of heart failure patients.  More than 3000 patients with predominantly NYHA Class II and III heart failure were randomly assigned to placebo or candesartan and followed up for 2 to 4 years.  The primary endpoint was CV death or CHF hospitalization.  The patients in the two arms of the study were similar at baseline in terms of demographics and pre-study medications.  The mean EF of patients enrolled was 54%.  The primary endpoint was reached in 333 patients in the candesartan arm and 366 patients in the placebo arm: hazard ratio 0.89 (0.77, 1.03), p-value 0.12.  CHARM Preserved did not achieve its primary pre-specified endpoint.

  

7          Integrated Review of Safety

7.1        Methods and Findings

The information presented in the safety section of this review was primarily obtained from the sponsor’s clinical study report.  Line listings of all patient deaths in the candesartan arm were reviewed.  Death narratives of selected cases were also reviewed with referencing of the case report forms. 

 

Table 7 below summarizes the overall AE experience in CHARM preserved.  There were nominally more deaths on the candesartan arm compared to the placebo arm during the study period (238 P vs 244 C).  The were a greater number of discontinuations due to AE’s and dose reductions due to AE’s in the candesartan arm compared to the placebo arm.  A more detailed discussion of these safety findings are provided later in this review.              

 

Table 7: Summary of AE’s, SAE’s, and Discontinuations/dose reductions of study

drug due to AE’s

 

Placebo

(n = 1509)

Candesartan

(n = 1514)

Any AE during study

1060 (70%)

1074 (71%)

Serious AE’s leading to death during study

238 (16%)

244 (16%)

Serious AE’s not leading to death during study

963 (64%)

939 (62%)

Discontinuations due to AE’s

192 (13%)

269 (18%)

Dose reductions due to AE’s

125 (8%)

192 (13%)

Note: This data in this table obtained from Table 65 of SH-AHS-0007 CSR

7.1.1       Deaths

There were a total of 482 deaths during the study of which 238 occurred in patients randomized to placebo and 244 in patients randomized to candesartan.  Table 8 shows the most common AE’s leading to death.  The etiologies of death in the two treatment arms were similar.  The most common etiologies of death were not unexpected given the patient population enrolled into the study.  The most common etiologies of death in CHARM Preserved were similar to the etiologies in the overall CHARM Program and were mainly cardiovascular in nature (e.g. sudden death, heart failure, myocardial infarction).  Line listings of all deaths, located in the sponsor’s clinical study report SH-AHS-0007, Appendix 12.2.7.2, that included the sponsors “Preferred Term” and the investigator’s terms were reviewed.  In general, the sponsor’s coding of adverse events based on the investigator’s verbatim term was acceptable.   Line listings from all deaths in the candesartan arm were reviewed.  Narratives of death from selected cases and their respective case report forms (CRF’s) were also reviewed. 

 

Table 8: AE’s leading to death in CHARM preserved (cutoff > 0.3%)

 

Placebo

Cand

Preferred term

(N=1509)

 

(N=1514)

 

 

N

(%)

N

(%)

Sudden death

68

(4.5)

68

(4.5)

Cardiac failure/cardiac

 

 

 

 

failure aggravatedb

53

(3.5)

41

(2.7)

Myocardial infarction

20

(1.3)

18

(1.2)

Pneumonia

19

(1.3)

14

(0.9)

Cerebrovascular disorder

14

(0.9)

11

(0.7)

Death

11

(0.7)

7

(0.5)

Sepsis

9

(0.6)

6

(0.4)

Respiratory insufficiency

8

(0.5)

5

(0.3)

Pulmonary oedema

6

(0.4)

6

(0.4)

Renal failure acute

6

(0.4)

5

(0.3)

Accident and/or injury

6

(0.4)

4

(0.3)

Pulmonary carcinoma

5

(0.3)

5

(0.3)

Renal failure nos

4

(0.3)

5

(0.3)

Coronary artery disorder

5

(0.3)

3

(0.2)

Note: This data in this table obtained from Table 67 of SH-AHS-0007 CSR

 

7.1.2       Other Serious Adverse Events

Table 9 below lists serious adverse events (SAE’s) other than death that occurred on treatment in CHARM preserved.  The table lists SAE’s occurring at a frequency of at least 1% based on the candesartan arm.  The 4 most common serious adverse events not leading to death on the candesartan arm were cardiac failure, angina pectoris, atrial fibrillation, and pneumonia.  In general the frequency of these SAE’s was similar or lower to that observed in the placebo arm. 

Adverse events that occurred with frequency that was nominally higher on candesartan compared to placebo included hypotension, anemia, syncope, renal failure (acute), GI hemorrhage, renal function abnormal, skin cellulitis, bradycardia, renal failure NOS, dehydration, respiratory infection, diarrhea, ventricular tachycardia/arrhythmias, atrial flutter, hyperkalemia, arteriosclerosis, AV block, hernia, and fracture.  Of these listed AE’s, three occurred with a frequency that was 2 fold higher on candesartan compared to placebo and are highlighted in the table below.  These include dehydration, hyperkalemia, and fracture.    

 

Three adverse events of special interest, hypotension, hyperkalemia, and renal dysfunction/renal failure occurred more frequently on candesartan compared to placebo.  The adverse events of hypotension and hyperkalemia were notably higher in the candesartan arm compared to the placebo arm: hypotension (4.9% vs. 3.6%), hyperkalemia (1.5% vs. 0.4%).  The adverse events of “renal failure acute”, “renal function abnormal/renal dysfunction aggravated”, and “renal failure NOS” occurred with a higher incidence on candesartan compared to placebo.    

 

Another SAE worth noting that occurred with a greater frequency on candesartan compared to placebo was anemia.  There is more discussion of this AE later in this review.    

 

Table 9: Serious Adverse Events other than Death (Frequency > 1% on candesartan)

 

Placebo on

Cand on

Preferred term

Treatment

Treatment

 

(n=1509)

(n=1514)

 

n

(%)

N

(%)

Cardiac failure/cardiac

 

 

 

 

failure aggravated

303

(20.1)

234

(15.5)

Angina pectoris/angina

 

 

 

 

pectoris aggravated

195

(12.9)

179

(11.8)

Fibrillation atrial

103

(6.8)

77

(5.1)

Pneumonia

81

(5.4)

76

(5.0)

Coronary artery disorder

85

(5.6)

69

(4.6)

Cerebrovascular disorder

83

(5.5)

65

(4.3)

Myocardial infarction

74

(4.9)

63

(4.2)

Chest pain

69

(4.6)

66

(4.4)

Tachycardia supraventricular

76

(5.0)

55

(3.6)

Arrhythmia atrial

73

(4.8)

53

(3.5)

Hypotension

54

(3.6)

74

(4.9)

Accident and/or injury

46

(3.0)

45

(3.0)

Anaemia

35

(2.3)

45

(3.0)

Syncope

32

(2.1)

43

(2.8)

Dyspnoea/dyspnea

 

 

 

 

(aggravated)

39

(2.6)

24

(1.6)

Arrhythmia ventricular

36

(2.4)

23

(1.5)

Diabetes mellitus/diabetes

 

 

 

 

mellitus aggravated

30

(2.0)

26

(1.7)

Renal failure acute

24

(1.6)

30

(2.0)

Gi haemorrhage

20

(1.3)

25

(1.7)

Bronchitis/bronchitis

 

 

 

 

aggravated

25

(1.7)

24

(1.6)

Chronic obstruct airways

 

 

 

 

Disease

27

(1.8)

23

(1.5)

Pulmonary oedema

26

(1.7)

21

(1.4)

Renal function

 

 

 

 

abnormal/renal dysfunction

 

 

 

 

aggravated

18

(1.2)

28

(1.8)

Cellulitis skin

20

(1.3)

24

(1.6)

Dizziness/vertigo

24

(1.6)

23

(1.5)

Hypertension

32

(2.1)

12

(0.8)

Bradycardia

16

(1.1)

25

(1.7)

Renal failure nos

14

(0.9)

23

(1.5)

Urinary tract infection

18

(1.2)

18

(1.2)

Arthrosis

21

(1.4)

19

(1.3)

Dehydration

10

(0.7)

25

(1.7)

Respiratory infection

16

(1.1)

20

(1.3)

Diarrhoea

15

(1.0)

20

(1.3)

Tachycardia

 

 

 

 

ventricular/arrhythmia

14

(0.9)

19

(1.3)

Atrial flutter

13

(0.9)

17

(1.1)

Sick sinus syndrome

16

(1.1)

17

(1.1)

Hyperkalaemia

6

(0.4)

22

(1.5)

Arteriosclerosis

10

(0.7)

17

(1.1)

Av block

12

(0.8)

16

(1.1)

Hernia

11

(0.7)

17

(1.1)

Fracture

9

(0.6)

18

(1.2)

Taken from Table 129 of SH-AHS-0007 CSR

 

7.1.3       Dropouts and Other Significant Adverse Events

Dropouts due to AE’s and dose reductions due to AE’s were greater on the candesartan arm compared to the placebo arm in CHARM Preserved.  This pattern was observed in all 3 components of the CHARM Program.  More details are provided below.    

7.1.3.1       Adverse events associated with dropouts

As shown earlier, the study drug was permanently discontinued due to AE’s in 192 patients randomized to placebo and 269 patients randomized to candesartan.  As shown in Table 10 below, AE’s leading to study drug discontinuation that were at least twice as common on candesartan compared to placebo were abnormal renal function, hypotension, hyperkalemia, dizziness/vertigo, renal failure, diarrhea, and nausea.  The sponsor’s coding of adverse events based on the investigator’s verbatim terms were acceptable.         

 

Table 10: Summary of discontinuations due to AE’s in CHARMED preserved (cutoff > 0.5%)

Preferred term

Placebo

Cand

 

(N=1509)

 

(N=1514)

 

 

N

(%)

N

(%)

Renal function abnormal

32

(2.1)

68

(4.5)

Cardiac failure/cardiac failure aggravated

33

(2.2)

43

(2.8)

Hypotension

18

(1.2)

40

(2.6)

Hyperkalaemia

8

(0.5)

23

(1.5)

Cerebrovascular disorder

11

(0.7)

14

(0.9)

Angina pectoris

7

(0.5)

12

(0.8)

Myocardial infarction

13

(0.9)

6

(0.4)

Dizziness/vertigo

4

(0.3)

14

(0.9)

Renal failure nos

4

(0.3)

12

(0.8)

Diarrhoea

3

(0.2)

11

(0.7)

Dyspnoea/dyspnoea (aggravated)

6

(0.4)

8

(0.5)

Nausea

4

(0.3)

10

(0.7)

Pneumonia

8

(0.5)

6

(0.4)

Note: This data in this table obtained from Table 69 of SH-AHS-0007 CSR

 

Table 11 below summarizes the reductions in dosages of study drugs due to adverse events.  Several of the findings in this table are consistent with those in Table 10.  AE’s leading to a reduction in study drug dose that were at least twice as common on candesartan compared to placebo were hypotension and hyperkalemia.  The frequency of abnormal renal function was also higher in patients randomized to candesartan compared to placebo but just missed the two fold threshold.   Fatigue was also a reason for reduction in study drug dose that was twice as frequent on candesartan relative to placebo.       

Table 11: Summary of dose reductions due to AE’s in CHARMED preserved (cutoff > 0.3%)

Preferred term

Placebo

Cand

 

(N=1509)

 

(N=1514)

 

 

N

(%)

N

(%)

Hypotension

52

(3.4)

106

(7.0)

Renal function abnormal

17

(1.1)

30

(2.0)

Dizziness/vertigo

21

(1.4)

16

(1.1)

Hyperkalaemia

5

(0.3)

16

(1.1)

Fatigue

5

(0.3)

12

(0.8)

Cardiac failure aggravated

13

(0.9)

10

(0.7)

Nausea

5

(0.3)

6

(0.4)

Dyspnoea/dyspnoea (aggravated)

6

(0.4)

5

(0.3)

Asthenia

3

(0.2)

5

(0.3)

Note: This data in this table obtained from Table 70 of SH-AHS-0007 CSR

 

7.1.4       Common Adverse Events

Common AE’s causing study drug discontinuation or down-titration were recorded in the CRF.  Non-serious AE’s that did not lead to drug discontinuation or dose reduction were not recorded.  Assessments for AE’s were made during the up titration period and every 4 months until the end of the study as shown in Figure 5 in the Appendix.   

7.1.4.1       Common adverse event tables

The table below lists AE’s occurring with a frequency of > 1% in the candesartan arm on treatment and the corresponding frequency on the placebo comparator. 

Three adverse events that are worth noting and that occurred with a significantly higher frequency on candesartan compared to placebo were hypotension, abnormal renal function, and hyperkalemia.  These AE’s have also been discussed in a previous section dealing with discontinuation/dose reduction due to AE’s.  These AE’s occurred at a consistently higher frequency on candesartan compared to placebo for the entire CHARM Program.    

Other AE’s that occurred more frequently on candesartan compared to placebo and were consistent across the CHARM Program included dizziness/vertigo, syncope, diarrhea, fatigue, and anemia. 

Table 12: Common AE’s occurring in CHARM Preserved

(AE’s with a frequency > 1% in the candesartan arm)

 

Placebo on

Cand. cil. on

Preferred term

treatment

treatment

 

(N=1509)

(N=1514)

 

N

(%)

N

(%)

Cardiac failure/cardiac failure

 

 

 

 

aggravatedb

321

(21.3)

247

(16.3)

Angina pectoris/angina