The company said that it chose a semi-Markov model, rather than a partitioned survival model (PSM). In state-transition models such as a semi-Markov model, health-state occupancy is estimated by applying a set of transition probabilities. These inform the movement of people between health states within each set time period. A PSM directly uses PFS and OS curves to estimate health-state occupancy. The company said it chose a semi-Markov model because it allowed the assumption that the risk of death after disease progression is constant and is the same in the tisotumab vedotin and chemotherapy treatment arms. Specifically, the company assumed an exponential hazard for post-progression survival, with the same hazard applied in both treatment arms. It estimated this rate using individual-level patient data on post-progression survival, pooled from the tisotumab vedotin and chemotherapy arms of InnovaTV 301. It explained that it had explored a PSM but this overestimated survival in the chemotherapy arm. For example, at 2 years, the PSM predicted survival of 16% to 20% for chemotherapy compared with 10% to 13% from clinical expert advice and evidence from McLachlan et al. (2017). The company noted that, in the PSM, there was an extended tail in the OS chemotherapy arm and overlap in the OS curves between arms. This meant that some people having chemotherapy remained alive for a long time after the data cutoff timepoint. It also meant that there was a higher proportion of people alive in the chemotherapy arm than in the tisotumab vedotin arm at certain timepoints. It said that this was likely caused by random variation rather than a genuine survival benefit for chemotherapy, because few people remained at risk.
The EAG had concerns about the company's use of a semi-Markov model because it did not think that the InnovaTV 301 data supported the assumptions of a constant post-progression mortality rate. It noted that the hazard plot for post-progression survival pooled across treatment arms showed a time-varying hazard function (rather than a constant hazard). Also, the goodness-of-fit statistics (Akaike information criterion and Bayesian information criterion values) for the standard parametric distributions fitted to post-progression survival data from InnovaTV 301 showed that other distributions provided a better fit than the exponential distribution. The EAG noted that assuming the same post-progression survival hazard for tisotumab vedotin and chemotherapy may underestimate or overestimate OS if post-progression mortality risk differs between treatment arms. But the EAG could not override the assumption of a constant post-progression mortality risk in the company's model. This was because the model did not include 'tunnel states', which would retain information about the time of progression.
The committee agreed that the hazard plot did not support the assumption of a constant post-progression mortality. It also agreed that other distributions showed better statistical fit compared with the exponential distribution. It also noted that the semi-Markov model was restricted to using the exponential distribution to estimate post-progression survival because of the absence of tunnel states. It thought that this was a limitation in the company's model structure. But it acknowledged that adding tunnel states to the model would add complexity. It noted that this limitation could be overcome by using a PSM. It also noted that the extrapolations in the PSM were based on InnovaTV 301. So, if the chemotherapy arm in a PSM had higher OS than would be expected in clinical practice, the same might also apply to tisotumab vedotin. The company agreed that this may be the case. It said that, compared with the InnovaTV 301 data and estimates generated using a PSM, its modelling approach led to more conservative OS estimates for both chemotherapy and tisotumab vedotin. The committee acknowledged this but thought this limitation could be addressed by using appropriate parametric curves in a PSM.
In response to the draft guidance consultation, the company stated that all PSM scenarios overestimated chemotherapy OS (see section 3.7). So, it retained the use of a semi-Markov model in its base case. The EAG reiterated that the available evidence did not support the assumptions needed for the company's semi-Markov modelling approach. Specifically, the assumption of the same, constant OS hazard after disease progression in both treatment arms was not supported. It thought that the fitted parametric curves showed an acceptable fit to the InnovaTV 301 trial data and preferred to use a PSM structure. The committee thought that there were some curve choices in the PSM that provided reasonable estimates of chemotherapy OS. But it acknowledged that all the parametric distributions for chemotherapy overestimated OS compared with clinical practice, so were associated with uncertainty. It also recalled that the semi-Markov model structure was associated with uncertainty. This was especially because of the assumption that the risk of death after disease progression was constant and the same in the tisotumab vedotin and chemotherapy treatment arms. Overall, it thought that the PSM structure produced more reliable estimates of the relative treatment effect between tisotumab vedotin and chemotherapy, and acceptable estimates of the absolute treatment effect. The committee concluded that it preferred a PSM structure.