Patient Reported Outcome (PRO) assessment in epilepsy: a review of epilepsy-specific PROs according to the Food and Drug Administration (FDA) regulatory requirements

Abstract

Despite collection of patient reported outcome (PRO) data in clinical trials of antiepileptic drugs (AEDs), PRO results are not being routinely reported on European Medicines Agency (EMA) and Food and Drug Administration (FDA) product labels. This review aimed to evaluate epilepsy-specific PRO instruments against FDA regulatory standards for supporting label claims. Structured literature searches were conducted in Embase and Medline databases to identify epilepsy-specific PRO instruments. Only instruments that could potentially be impacted by pharmacological treatment, were completed by adults and had evidence of some validation work were selected for review. A total of 26 PROs were reviewed based on criteria developed from the FDA regulatory standards. The ability to meet these criteria was classified as either full, partial or no evidence, whereby partial reflected some evidence but not enough to comprehensively address the FDA regulatory standards. Most instruments provided partial evidence of content validity. Input from clinicians and literature was common although few involved patients in both item generation and cognitive debriefing. Construct validity was predominantly compromised by no evidence of a-priori hypotheses of expected relationships. Evidence for test-retest reliability and internal consistency was available for most PROs although few included complete results regarding all subscales and some failed to reach recommended thresholds. The ability to detect change and interpretation of change were not investigated in most instruments and no PROs had published evidence of a conceptual framework. The study concludes that none of the 26 have the full evidence required by the FDA to support a label claim, and all require further research to support their use as an endpoint. The Subjective Handicap of Epilepsy (SHE) and the Neurological Disorders Depression Inventory for Epilepsy (NDDI-E) have the fewest gaps that would need to be addressed through additional research prior to any FDA regulatory submission, although the NDDI-E was designed as a screening tool and is therefore unlikely to be suitable as an instrument for capturing change in a clinical trial and the SHE lacks the conceptual focus on signs and symptoms favoured by the FDA.

Introduction

Epilepsy is defined by the recurrence of spontaneous/unprovoked seizures and covers a range of clinical situations in terms of age of onset, type of seizures, aetiological background, resulting handicap, prognosis, and response to treatment [1]. Epilepsies are a diverse group of disorders with a complex classification, broadly categorised into localization-related, generalized, undetermined, and special syndromes [2]. Antiepileptic drugs (AEDs) are the main treatment option; approximately 60% of newly diagnosed patients are seizure-free with AED monotherapy and a further 10-20% with polytherapy [1, 3]. Surgery offers alternative treatment options for patients with medically intractable epilepsy [4].

The assessment of efficacy in clinical studies evaluating AEDs is generally focused on seizure frequency/occurrence in line with regulatory guidelines [1]. However there is growing recognition of the value of capturing wider impacts of treatments reported by patients in the form of patient reported outcomes (PROs) [5]. A PRO is defined as any report of the status of a patient’s health condition that comes directly from the patient without interpretation of the patient’s response by a clinician or anyone else [5]. PROs take the form of carefully designed questionnaires which can be used to capture and quantify the patient experience of treatment and treatment impacts. Given that epilepsy is a complex disorder, which affects patients’ psychological health, independence, emotional adjustment and employment [6] there is a strong case for evaluating the impact of AEDs on broader aspects of patient’s lives, and previous studies have identified potential areas of patient’s lives that may be enhanced if epilepsy symptoms were improved [7]. Therefore it is unsurprising that PROs have been widely incorporated into clinical trials evaluating AEDs [8–10].

In order to guide the selection of PROs for epilepsy clinical studies, there have been numerous reviews evaluating PROs, each review with a unique focus: evaluating PROs designed to measure change in seizure severity [11], overview of neuropsychological and behavioural measures used AED clinical trials [8], guiding health-related quality of life (HRQL) assessment in epilepsy [12], systematically reviewing measures designed to assess the subjective impact of epilepsy and treatment in children and adolescents [13], guiding the selection and use of quality of life (QOL) instruments in epilepsy [9], appraising the conceptual underpinnings of paediatric QOL instruments [14], exploring and reviewing PROs used to assess people with epilepsy [10], and describing QOL instruments for children and adolescents with neurodisabilities [15]. Similar reviews were also conducted prior to 2000 [16, 17].

Despite almost routine collection of PRO data in clinical trials of AEDs and the wide choice of PRO instruments, PRO results are not being routinely reported on European Medicines Agency (EMA) and Food and Drug Administration (FDA) product labels. A review of the current state of PRO label claims granted for new molecular entities approved 2006–2010 [18] found two approved for the treatment of epilepsy had PRO label claims: Vimpat® indicated as adjunctive therapy for patients ≥17 years to treat partial onset seizures and Sabril® indicated for refractory complex partial seizures in adults. For both products the PRO was a measure of seizure frequency. There are two likely explanations for the lack of PRO label claims for epilepsy treatments. The first relates to the possibility that there may be a lag in the effect of AED treatment on PRO outcomes after demonstration of positive treatment effect on clinical efficacy outcomes e.g. seizure frequency/occurrence. Qualitative studies show that unpredictability of seizures is a key factor in the impact of epilepsy for patients [19–21]. Patients’ perception of the unpredictability of their seizures may not change until sometime after a reduction in seizure frequency, or even seizure freedom is achieved; 3–4 months, a common timescale for AED efficacy trials, may be too short to expect much change in PRO endpoints [11]. The second explanation, and the focus of the current review, is the possibility that existing PRO instruments do not meet regulatory requirements.

There is limited guidance from regulatory authorities on incorporating PROs into evaluations of AEDs, the recent EMA guideline on clinical investigation of medicinal products in the treatment of epileptic disorders [1] suggests that a secondary efficacy variable could be ‘scales measuring social and working capacity, if validated’. Other than this the authors could find no further guidance from either the EMA or FDA specific to the use of PROs in epilepsy clinical studies. For a PRO to be incorporated into a FDA or EMA label claim, it is necessary for it to be developed to standards required by the regulatory authorities [5, 22]. Most of the epilepsy-specific PRO reviews conducted to date were published prior to the current regulatory guidance, and none have evaluated the extent to which PROs have been developed to the standard required by regulatory authorities. In order to guide those developing clinical studies to evaluate AEDs in selecting a PRO instrument for the purpose of obtaining a PRO label claim, this review sought to evaluate existing epilepsy-specific PRO instruments against FDA regulatory standards and identify any gaps in the development process that would need to be addressed prior to regulatory review.

Methods

Literature search and PRO identification

Structured Embase and Medline searches were conducted in February 2011 to identify epilepsy studies reporting the use or development of PRO instruments in epilepsy samples. Searches were constructed by combining epilepsy and seizure subject heading search terms with a number of PRO measurement terms. Searches were limited to ‘humans’, ‘English language’ and ‘year 2000 –current’. Full search terms are shown in the Additional file 1.

Abstracts of publications identified by these searches were screened to identify PRO instruments used. Full text versions of publications were screened to identify specific instruments where abstracts referred to PRO measurement without naming a specific instrument, or where abstracts specified endpoints that may have been captured by PRO measurement. Further electronic searches were conducted for each instrument identified to retrieve a copy of the instrument and establish its relevance. Given the wide variety of PRO instruments used with epilepsy patients, the following instrument inclusion criteria were used to focus the review on broadly comparable instruments that might be used to evaluate pharmacological treatment:

• Epilepsy-specific scale. Based on the FDA’s preference for more proximal endpoints that are specifically relevant to the target population, generic PROs which make no reference to epilepsy were excluded.

• Adult patient completed. Most epilepsy-specific PROs have been developed for adult patient completion. Scales developed to assess epilepsy impacts for children are commonly designed for proxy completion (e.g. by parents or clinical assessors) in part or whole and are not directly comparable to PROs designed for adult patient completion. PROs designed for completion by adolescent as well as adult patients were included.

• Target a concept that could potentially be impacted by pharmacological treatment. Non-interventional studies or those evaluating non-pharmacological interventions may also use PROs to evaluate concepts that would not be impacted by pharmacological treatment. However, PROs evaluating these concepts would not need to meet FDA requirements for supporting a label claim.

Further literature searches were then conducted in Embase and Medline to identify published validation work on each PRO instrument identified. Full text versions of all published reviews of PRO instruments identified by the initial search and instrument focused literature searches were retrieved and checked for any additional instruments or validation work. Any instrument that was found to comprise single items that did not form a scale and/or for which no documentary evidence of validation could be located was excluded from further review.

Developing the review criteria

Detailed review criteria were developed from requirements laid out in the FDA guidance for PROs supporting label claims [5]. These criteria are detailed in Table 1. Development work and evidence for psychometric properties of each PRO instrument were extracted into structured individual instrument review tables before being systematically reviewed against the review criteria (Table 1).

Table 1 Review criteria based on FDA requirements for PROs to support label claims

Results

Identification of PROs

Initial Embase and Medline searches identified a total of 1854 publications (after de-duplication) from which 159 PRO instruments were identified by abstract or full-text manuscript review. Following instrument retrieval and initial review, 133 of these were excluded as they were found to be not epilepsy specific (n = 52), not for adult patient completion (n = 42), not to target a concept that could be potentially impacted by pharmacological treatment (n = 20) or instruments comprising single items that did not form a scale and/or for which no documentary evidence of validation could be located (n = 19). Many of these instruments could be excluded on more than one criterion. Numbers shown here depict the first reason for exclusion.

PRO instrument characteristics

Twenty-six (26) epilepsy-specific PRO instruments were identified and reviewed, Table 2 details the key characteristics for each of these 26 instruments. The identified PROs vary widely in their key characteristics. Conceptual coverage of the PROs include instruments designed to capture epilepsy attack experience including severity (e.g. Attack Symptom Measure, Ictal Consciousness Inventory (ICI), Liverpool Seizure Severity Scale (LSSS), Seizure Severity Questionnaire (SSQ)); issues associated with the treatment and management of epilepsy (e.g. Assessing Side Effects of AED Treatment (SIDAED), Aldenkamp-Baker Neuroassessment Schedule (ABNAS), Liverpool Adverse Events Profile (LAEP), Portland Neurotoxicity Scale (PNS), Epilepsy Self-Efficacy Scale (ESES)); instruments designed to capture the impacts of epilepsy on different aspects of patient’s lives (e.g. Epilepsy Psycho-Social Effects Scale, Impact of Epilepsy Questionnaire, Neurological Disorders Depression Inventory for Epilepsy (NDDI-E), Perceived Stigma Scale, Washington Psychosocial Seizure Inventory (WPSI)) and instruments measuring the impact of epilepsy on patients’ HRQL (e.g. Epilepsy Foundation of America (EFA) Concerns Index, Epilepsy Surgery Inventory 55 (ESI-55), EPI-QOL, Quality of Life in Epilepsy (QOLIE) instruments, Quality of Life in Newly Diagnosed Epilepsy (NEWQOL)).

Table 2 Epilepsy-specific PRO instruments

Instruments vary in terms of length, ranging from five items (Perceived Limitations Scale) to 132 items (WPSI). Nine of the PROs do not have a defined recall period (e.g. ABNAS, SIDAED), two refer to the time of an epilepsy attack (Attack Symptom Measure, ICI). Most specify a recall period varying from now (EPI-QOL) to six months (SHE), with five PROs referring to multiple recall periods within the same PRO (e.g. EPI-QOL, NEWQOL, SHE). Response options for most of the reviewed PROs employ a Likert approach with 3–5 options, for example the Epilepsy Psycho-Social Effects Scale has a five point Likert scale ranging from ‘almost always or always’ to ‘never’ and the EPI-QOL has a five point response scale ranging from ‘very frequently’ to ‘not at all’. Less common is a numerical rating scale (NRS) approach with anchors, such as the ESES which has a 11 point scale ranging from 0 (I cannot do at all) to 10 (sure I can do).

The PROs provide different levels of information depending on the scoring approach, a minority of instruments provide only a total score based on the scoring of all items in the PRO (e.g. EFA Concerns Index, NDDI-E), whilst most provide a more detailed amount of information through provision of sub-scale scores (also referred to as domain scores), with the number of sub-scale scores ranging widely, from two (e.g. ICI, PNS) to 20 (Bonner Psychsoziale Skale fur Epilepsie (BPSE)). Most instruments provide between 5–15 subscale scores.

PRO review against regulatory requirements

Table 3 provides the results of the PRO review against the regulatory requirements detailed in Table 1.

Table 3 Instrument review against regulatory requirements

Conceptual framework

The authors did not find any published conceptual framework for any of the reviewed instruments.

Content validity

Three of the PROs involved patients in concept elicitation/item generation and in the evaluation of items through a cognitive debrief methodology or similar approach: the EFA, LSSS and SHE. Of these, the LSSS and SHE also had documented evidence that literature had been used to guide the instrument development and/or clinical experts were involved. Most of the PROs (n = 14) had partially involved patients in the development of the instrument, in most cases either concept elicitation OR cognitive debrief were undertaken, but not both methodologies. All but one of these 14 instruments (LAEP) had also reviewed literature and/or involved clinical experts in the instrument development. Of the 26 instruments only five did not involve literature and/or clinical experts in the instrument development process according to published information.

Construct validity

Seven instruments had full evidence of the construct validity of the PRO by providing hypotheses of the expected relationships between the PRO under evaluation and other clinical or PRO measures, and the hypotheses being supported by reported results. Most of the PROs only had partial evidence of construct validity (n = 16), in most cases there was no evidence of hypotheses of expected relationships being developed in advance of analysis. For some instruments this was compounded by limited testing e.g. only known groups validity was evaluated or very limited comparisons were made. The Perceived Limitations Scale, Perceived Stigma Scale and SIDAED did not have any available evidence of construct validity.

Reliability

Five PROs had sufficient evidence of test-retest reliability, and four PROs had sufficient evidence of internal consistency reliability, with two PROs providing sufficient evidence of both types of reliability: LAEP and NDDI-E. Thirteen PROs had partial evidence of test-retest reliability and 14 had partial evidence of internal consistency. Most of the PROs that had only partial evidence of these measurement properties had a mix of results for sub-scales in terms of achieving the required criteria (i.e. α ≥ 0.8 for internal consistency [85, 86], r ≥ 0.7 for test-retest reliability) (e.g. PESOS, EPI-QOL) or there were no results provided for the PROs total score (e.g. Attack Symptom Measure). Eight PROs had no evidence of test-retest reliability (Attack Symptoms Measure, BPSE, ESI-55, ICI, Impact of Epilepsy scale (IES), Perceived Limitations Scale, Perceived Stigma Scale and SIDEAD) and four instruments had no evidence of internal consistency reliability (Epilepsy Psycho-Social Effects Scale, Portland Neurotoxicity Scale, SIDAED and SSQ).

Four PROs had evidence of testing for internal consistency but failed to reach the required standard of α ≥ 0.8 for all reported scales including any total score: Quality of Life in Epilepsy 10 (QOLIE 10), Perceived Stigma Scale, Perceived Limitations Scale and IES. The IES has an internal consistency of 0.65 which increases to 0.82 if one of the 8 items is removed, but later publications are based on either the eight item version or a 10-item version [42, 87] for which no published psychometric validation evidence could be found. The Perceived Limitations Scale had a notably low internal consistency (α = 0.55) with the Perceived Stigma Scale getting close to the required standard (α = 0.75) [55]. The reported alpha values for the three empirically derived factors from the QOLIE-10 (epilepsy effects, mental health scale, role function) do not meet the criterion thresholds [58]. These three subscales are not the usual scores derived from the QOLIE-10. Researchers more commonly report the same seven subscales as the QOLIE-31 (five of which have only one item in the QOLIE-10) and/or a total QOLIE-10 score [59, 88, 89] for which no evaluation of internal consistency has been published.

Ability to detect change

Four PROs had full evidence of ability to detect change and reported the results of analysis undertaken with the specific aim of testing within-group responsiveness for all sub-scales as well as total score (as appropriate): ESI-55, Performance, subjective evaluation and socio-demographic data (PESOS), Quality of Life in Epilepsy 31 (QOLIE-31) and Quality of Life in Epilepsy 89 (QOLIE-89). Three PROs provided partial evidence of ability to detect change: LSSS, QOLIE-10 and WPSI; for example analysis was conducted on a previous version of the PRO (LSSS) or a non-empirically derived scale structure (QOLIE-10 results based on sub-scales taken from the QOLIE-31). For most of the PROs (n = 19) this measurement property had not been investigated.

Interpretation of change

The LAEP was the only PRO that had fully documented evidence of the minimally important difference (MID) of the scale. This was evaluated in a study that was designed to assess the magnitude of change in the LAEP and other PROs in order to exclude chance or error at various levels of certainty in patients with medically refractory epilepsy through application of a Reliable Change Index analytic approach [44]. Two PROs had partial evidence of MID; the MID investigation for the QOLIE-31 provided evidence for the total score but none of the sub-scales and for the QOLIE-89 results were provided for selected sub-scales and total score. No anchor-based values for interpreting change were reported for any of the reviewed instruments, and none reported responder definitions for an epilepsy population according to the FDA’s requirements around establishing responder definitions (see Table 1).

Discussion

This review sought to evaluate epilepsy-specific PRO instruments against FDA regulatory standards and to identify gaps in the development process of the instruments that would need to be addressed prior to regulatory review. Twenty-six (26) epilepsy-specific PRO instruments were identified and reviewed.

This review identified that the SHE and NDDI-E met more of the regulatory requirements in terms of measurement properties, with both scales meeting four of the eight measurement properties evaluated. These two PROs lacked a published conceptual framework and require further evidence of ability to detect change and interpretation of change. In addition, the NDDI-E requires further evidence of patient input and the SHE requires further evidence of internal consistency reliability. Internal consistency fell below the required standard (α ≥0.8) [85] for some of the SHE’s sub-scales, further developmental work might be needed to increase the internal consistency of this scale (e.g. item removal, development of supplemental items, item re-wording, revised scale structure/conceptual framework). The SHE and NDDI-E were designed for different purposes. The SHE is a measure of patient’s subjective handicap of epilepsy based on the World Health Organisation (WHO) concept of handicap, providing six subscale scores: work and activities; social and personal; physical; self-perception; life satisfaction; and change. The lack of focus on signs and symptoms in the SHE is likely to make it unfavourable from the FDA perspective as an instrument to support a PRO label claim. The same is true of other PROs evaluated in this review. The NDDI-E is a short instrument designed to detect depression in epilepsy patients, providing a total score. Whilst the NDDI-E has been used as an outcome measure in clinical trials [90, 91], this may have been inappropriate as it was designed as a screening tool, and therefore its ability to detect change is not only unknown but potentially unlikely given that it was not designed to capture change.

The LAEP, ICI and ESI-55 all met requirements for three of the eight measurement properties. The LAEP in terms of test-retest reliability, internal consistency and interpretation of change; the ICI in terms of literature and clinician input, construct validity and internal consistency; and the ESI-55 in terms of literature and clinician input, construct validity and ability to detect change. Therefore all three instruments lack a published conceptual framework and required further evidence in terms of patient input, as well as specific gaps for each PRO.

When considering PROs with at least partial evidence of measurement properties, a different group of PROs come to the forefront: the QOLIE-31 and QOLIE-89 met or partially met requirements for seven out of the eight measurement properties, and the LSSS met or partially met requirements for six of the measurement properties. However, of concern for the QOLIE-89 is that seizure free patients did not score significantly higher than the most severe group on nine of the sub-scales [64] and test-retest reliability was <0.7 for four of the sub-scales [64]. Of concern for the QOLIE-31 is that internal consistency was <0.8 for four sub-scales [60] (although at 0.77-0.79 they were very close to this threshold) and test-retest fell below 0.7 for one sub-scale [60]. Questions are raised over the LSSS because of gaps in the evidence for reliability and validity.

Of particular concern from a regulatory perspective are the Perceived Limitations Scale, Perceived Stigma Scale and the SIDAED, all of which failed to achieve even partial evidence for any of the eight measurement characteristics. Notably, the Perceived Limitations Scale and Perceived Stigma Scale failed to achieve required standards for internal consistency when tested (no evidence of testing for this for the SIDAED). No other psychometric properties were tested for these three PROs.

Content validity is defined by the FDA as ‘… the extent to which the instrument measures the concept of interest’, with evidence being supported through the conduct of qualitative studies to demonstrate that the items and domains of an instrument are appropriate and comprehensive relative to its intended measurement concept, population and use [5]. Importantly, whilst all the evidence criteria in this review are considered to be required by the FDA (with the exception of responder definitions which are recommended) the FDA make a clear statement that ‘It is important to establish content validity before other measurement properties are evaluated’. The FDA will review the process for evidence of content validity in terms of item generation, data collection method and instrument administration mode, recall period, response options, instrument format, instructions and training, patient understanding, scoring of items and domains, and respondent and administration burden. The evaluation of content validity in this review has been an assessment of process rather than an evaluation of the evidence for content validity, with access restricted to published information rather than the detailed qualitative results that would be required for FDA assessment of content validity. No published conceptual framework was identified for any of the instruments; however for nearly all of the reviewed PROs there is sufficient information regarding how items group into domains/concepts to be able to develop a conceptual framework. Compared to other deficiencies, this may not be hard to overcome. Providing empirical evidence in support of the conceptual framework, would be a greater challenge.

In terms of evidence gathered through psychometric testing, the review identified common pitfalls. In relation to testing for construct validity, the FDA require that a priori hypotheses are tested concerning logical relationships that should exist with measures of related concepts or scores. This was an area where most PROs failed to meet the criteria in this review. It is entirely possible that hypotheses were set in advance of analysis, but not reported in the published manuscript and it is strongly encouraged that this information is shared in publications reporting the psychometric properties of PROs. In terms of test-retest reliability and internal consistency, it is necessary to provide evidence for all domains and total scores (if applicable). Again this was a common area where PROs failed to meet the criteria in this review.

Although several PROs had evidence from clinical studies that the PRO measured change in an epilepsy population, few PROs had evidence that ability to detect change had been specifically investigated. One likely reason for this is that this measurement property is harder to evaluate in terms of study design as it means undertaking a longitudinal study of a patient group expected to improve/deteriorate. However, this is an essential measurement property, particularly when considering that the PROs are to be incorporated into clinical studies designed to test the effectiveness of a treatment for epilepsy.

Even fewer PROs had evidence for interpreting change or empirically derived responder definitions. The responder definition may vary by target population or other clinical trial design characteristics and therefore the FDA will evaluate a PROs responder definition in the context of each clinical trial. Evidence towards a PROs MID can contribute to the responder definition, and so this review sought to identify any evidence of statistically derived or anchor-based MID and/or responder definition, and found that only the LAEP was able to demonstrate empirically derived evidence of the measurement property.

One reoccurring problem found through the course of this review is that of several versions of one PRO instrument. Great care has to be taken when evaluating published evidence on the development and psychometric validation of a PRO instrument that the same version of the PRO is being referred to. By way of example, the ESES was originally developed to be a 25-item instrument, with evidence for content validity, construct validity and internal consistency [24]. However, the ESES was later updated to include an additional eight items to further assess self-efficacy associated with lifestyle issues with limited details around this update being published. In these instances, the evidence provided for earlier versions of the instrument were considered ‘partial’ evidence in Table 3 as this earlier evidence is likely to indicate how the revised instrument might perform. However, from a regulatory perspective the FDA would need to see full evidence for the developmental history and measurement properties of the revised instrument, assuming it is the revised version that is currently available for use in clinical trials.

It is vital to consider these findings in the broader context of PRO label claims in the US. The review of the current state of PRO label claims granted for new molecular entities approved 2006–2010 [18] found that of 116 products identified, 24% were granted PRO claims of which 86% were for symptoms and of these 38% were pain related. The proportion of new molecular entities and biologic license applications with PRO label claims has decreased slightly from 30% 1997–2002 to 24% 2006–2010. PRO label claims for non-primary endpoints were uncommon, with occurrence of symptoms the mostly commonly reported PRO label claim granted. The majority of accepted claims were supported by simple scales such as visual analogue scale (VAS), numeric rating scale (NRS), or symptom diaries, or on the basis of measures that have been traditionally accepted by the reviewing divisions. Within this context none of the reviewed epilepsy instruments are ‘simple scales’ i.e. VAS, NRS or symptom diaries. The reviewed PRO instruments do not appear to be measures that are ‘traditionally accepted by the reviewing divisions’ as none were identified in labels for PRO epilepsy treatments approved 2006–2010. The level of evidence required to support a desired label claim on the basis of the reviewed PRO instruments is of substantial importance as the reviewed instruments are not the typical PRO instruments being seen to support NME and BLA product approvals in the US.

It is worth considering the extent to which the evaluated PROs would be suitable to support regulatory approval of medicines in Europe through a regulatory review conducted by the EMA. The EMA has been less prescriptive in terms of their requirements for PROs, with one reflection paper published in 2005 for HRQL instruments, but nothing extended more generally to PROs. In the absence of clear guidelines from the EMA, it is difficult to determine which of the evaluated PROs would be well received by the EMA. However, whilst both the FDA and EMA require PROs supporting regulatory approvals to be validated and reliable, the EMA is more likely to accept and encourage the use of well-known, commonly used PROs than the FDA. The EMA also places less emphasis on qualitative evidence of content validity. Therefore PROs that are likely to be well received by the EMA will need to have demonstrated evidence of the psychometric properties of the PROs, particularly where this evidence is published in peer-review publication.

A limitation to this research is that the review was conducted on published information. It is frequently the case that documentation on the development process for PRO instruments is not published, particularly for older PRO instruments which were developed at a time where there were less publication options for PRO development manuscripts. It is likely that there are more details on the development of the reviewed instruments that have not been considered in this review. An important step for anyone considering the use of the PRO to support a label claim is to contact the instrument developer to see if further information can be made available to address seeming gaps in the evidence, which if available will reduce the need to conduct further research to gather evidence in support of the PRO instrument.

Conclusions

This systematic review of 26 epilepsy-specific PRO instruments, evaluated to the standards set out in the FDA guidance [5] indicates that none of the identified instruments have the full evidence required by the FDA to support the label claim, and all require further research to support their use as an endpoint. This may at least partially explain the lack of PRO label claims in support of epilepsy products. The SHE and NDDI-E have the fewest gaps that would need to be addressed through additional research prior to any FDA regulatory submission, although the NDDI-E was designed as a screening tool and is therefore unlikely to be suitable as an instrument for capturing change in a clinical trial and the SHE lacks the conceptual focus on signs and symptoms favoured by the FDA.