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. 2017 Sep 23;7(9):e015110. doi: 10.1136/bmjopen-2016-015110

Table 2.

Comparison of Miller et al analysis and our reassessment of controlled trials, by drug

Drug Company Miller et al Re-assessment
Trials subject to FDAAA Timely registration (%) Timely reporting (%) FDAAA compliance (%) Trials subject to FDAAA Timely registration (%) Timely reporting (%) FDAAA compliance (%)
Elelyso *Protalix 1 100 0 0 1 100 100 100
Stivarga Bayer 1 100 0 0 1 100 100 100
Perjeta Genentech/Roche 2 50 0 0 2 50 0 0
Signifor Novartis 1 100 0 0 1 100 100 100
Erivedge Genentech/Roche 2 100 0 0 2 100 100 100
Zioptan †Merck/Santen ‡6 17 17 17 1 100 100 100
Eliquis BMS 6 83 33 33 6 83 67 50
Aubagio Sanofi 7 86 71 §57 7 86 100 86
Zaltrap Sanofi 6 100 67 67 6 100 83 83
Inlyta Pfizer 2 100 100 100 2 100 100 100
Stribild Gilead 3 100 100 100 3 100 100 100
Xeljanz Pfizer 11 100 100 100 11 100 100 100
Bosulif Pfizer 1 100 100 100 ¶2 100 100 100
MenHibrix GSK 3 100 100 100 3 100 100 100
Sirturo Janssen (J&J) 1 100 100 100 1 100 100 100
Median 2 100 67 **57 2 100 100 100
Mid-50% range (1–6) (93–100) (0–100) (0–100) (1–4.5) (100–100) (100–100) (93–100)
Overall % 85 62 58 94 90 86

*Protalix was the sponsor on ClinicalTrials.gov for all trials included in this analysis for Elelyso, and all ClinicalTrials.gov-related disclosure activities were the responsibility of Protalix. Pfizer had no responsibility for trial registration or results reporting for Elelyso.

† Miller et al included five controlled trials in their FDAAA analysis despite having collected no data regarding those trials’ completion dates. In our reassessment of the data we found that those five trials were completed prior to the enactment of FDAAA (27 September 2007) and are therefore out of the scope of the analysis. These trials were all sponsored and conducted by Santen rather than Merck.

‡ The 17%t figures were in the Miller et al paper, which suggests six controlled trials instead of the reported seven. This is also consistent with the raw data.

§ The 57% figure is consistent with the raw data in the Miller et al paper, owing to a trial having results reported on time but not registered on time. The reported figure in Miller et al was 71%.

¶ We coded an additional clinical trial as ‘controlled’ because, although it was terminated prior to the controlled portion of the trial, it was originally designed as a controlled clinical investigation. Miller et al coded this trial as non-controlled ‘interventional’.

** The 57% figure is consistent with the raw data in the Miller et al paper, owing to the FDAAA compliance rate for Aubagio being corrected from 71% to 57%. With this change, the median now becomes 57% instead of 67%.

FDAAA, Food and Drug Administration Amendments Act.