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British Journal of Clinical Pharmacology logoLink to British Journal of Clinical Pharmacology
. 2019 Feb 23;85(4):838–844. doi: 10.1111/bcp.13876

Under‐representation of elderly in clinical trials: An analysis of the initial approval documents in the Food and Drug Administration database

Rikje Ruiter 1,2, Jacobus Burggraaf 1,3,4, Robert Rissmann 1,3,4,
PMCID: PMC6422639  PMID: 30681181

Abstract

Aims

To evaluate the availability of pharmacokinetic, safety and efficacy analyses specifically targeted at elderly, prior to the authorization of drugs.

Methods

A cross‐sectional, structured review of publicly available initial approval documents of Food and Drug Administration‐approved drugs was performed. The 10 most frequently on‐label prescribed drug classes, drugs with known pharmacokinetic differences in the elderly or drugs that are relatively contraindicated in elderly (e.g. anticholinergics or benzodiazepines) were included in the analyses.

Results

In total, 1129 unique active pharmaceutical ingredients were found eligible for the analyses, of these, 506 were found in the Food and Drug Administration database (45%). The initial approval documents were available for 182 drugs. For the majority of the drugs, the initial approval documents in the database showed information on pharmacokinetics in elderly (n = 113; 62%). Furthermore, over time, the availability of information with regard to elderly increased statistically significantly from 0% in the period 1970–1979 to 76% for the period 2010–2018. Information on safety and efficacy was less frequently present, i.e. 42% and 45%, respectively and, moreover, the availability of information did not improve over time.

Conclusion

The under‐representation of elderly in clinical trials thereby challenging the external validity of benefit/risk assessments of launched drugs was confirmed. Priority should be given to a study population that is representative for the target population.

Keywords: clinical trials, efficacy, elderly, pharmacokinetics, safety


What is already known about this subject

  • Under‐representation of elderly in clinical trials has been described earlier, thereby challenging the external validity of benefit/risk assessments of launched drugs.

  • Pharmacokinetic differences in the elderly may give rise to differences in safety and efficacy. Therefore, it is pivotal include geriatric patients in clinical trials of medical substances.

What this study adds

  • This is the first cross sectional, structured research on availability of pharmacokinetic, safety and efficacy analyses of the publicly available initial approval documents of Food and Drug Administration‐approved drugs.

  • For the majority of the drugs, the initial approval documents showed information on pharmacokinetics in elderly, but information on safety and efficacy was missing.

1. INTRODUCTION

The elderly represent a fast‐growing majority of the population in the Netherlands and worldwide.1, 2 In Europe, 25% of the population is aged 60 years or over and is expected to grow to 35% in 2050.3 Importantly, the representation of older people in clinical drug trials requires special attention, as it is known that pharmacokinetics and pharmacodynamics (and hence efficacy and safety) substantially change after the age of 75 years; albeit, not all drugs are similarly affected leading to increased variability in drug levels.4 In literature, different physiological parameters are discussed to affect absorption, distribution, metabolism and excretion of drugs during aging. For example, sarcopenia and increased percentage of fat tissue results in a different distribution volume.5 With regard to metabolism, the total liver mass reduces with age and there is a lower capacity for phase 1 reactions through the cytochrome P‐450 enzymes.6, 7 In contrast, conjugation reactions are not affected by ageing.5 Also, the hepatic blood flow is lower, which results in a reduced first pass effect.8 The renal function diminishes with age: there is reduced renal blood flow, diminished glomerular filtration rate and a reduced renal tubular secretory function.5 It is generally accepted that of the pharmacokinetic parameters, absorption is least affected by age.5 Pharmacodynamic changes in the elderly are the consequence of diminished reserve capacity or diseases of organ systems and changes in receptor number and affinity.5 In addition, comorbidity associated polypharmacy is more common among elderly and consequently the risk of interactions as well as adverse drug reactions is higher.9 These age‐related differences may give rise to age‐specific risk/benefit ratios for drugs in elderly.

The elderly consume the majority of prescribed medications and carry the largest burden of chronic diseases.10 Their representation in clinical trials should reflect this. For this reason, in 1993, the International Conference on Harmonization (ICH) of technical requirements for registration of pharmaceuticals for human use issued the ICH E7 guideline for the carrying out of studies in the geriatric population, stating that the trial population should represent the population that will consume the drug and should include a minimum percentage of older participants. The ICH E7 guideline was endorsed, among others, by the Food and Drug Administration (FDA) and pharmaceutical companies.11 Nevertheless, previous reports described that elderly are generally under‐represented in clinical studies in cardiology12, 13, 14, 15, 16, 17 and oncology18, 19, 20, 21 as they are excluded due to older age, multimorbidity or polypharmacy. Descriptive studies showed that in 30–40% of the original research papers in major medical journals, elderly people were excluded without justification.22, 23 Recent investigations carried out to evaluate the adherence to the ICH E7 guideline, showed that the proportion of the elderly in clinical trials is unacceptably low (1–9% in trials involving diseases not unique to old age).24 This was confirmed by an evaluation of the clinical trial database (clinicaltrials.gov).25 However, no investigation has systematically reviewed the available information on publicly available database of health care regulators.

In this study, we aimed to evaluate the availability of pharmacokinetic, safety and efficacy analyses specifically targeted at the elderly, prior to the authorization of the most frequently prescribed drug classes during the past years.

2. METHODS

2.1. Design

A cross‐sectional, structured assessment of publicly available initial approval documents of FDA‐approved drugs was performed. To obtain marketing authorization for newly developed drugs, companies are required to deliver quality, safety and efficacy information about the drug.

2.2. Drugs of interest

The following initial approval documents were assessed: those of frequently on‐label prescribed drug classes, those of drugs with known pharmacokinetic differences in the elderly, or those of drugs that are relatively contraindicated in elderly (e.g. anticholinergics or benzodiazepines). The following most frequently described drug classes were selected: antihypertensive drugs, medication for pain, drugs used for mental health or nervous system disorders, antibacterial drugs, lipid regulators, glucose lowering drugs, respiratory drugs, antiulcer drugs and thyroid therapies based on IQVIA.26 Furthermore, drugs with known large or small volumes of distribution and/or high or low hepatic clearance or renal excretion were included.4 Last, drugs with relative contraindications in elderly (e.g. anticholinergics or benzodiazepines).27

2.3. Assessment of information on pharmacokinetics, safety and efficacy

For these drug classes all available medical substances were extracted in December 2017 from the World Health Organization Anatomical Therapeutical Chemical Classification (ATC) index 2018.28 All drugs selected for the analyses were included in Table S1. Subsequently, using the FDA drug database, initial approval documents were retrieved for all selected drugs29 during the period December 2017–March 2018. When initial approval documents were available, these were evaluated for availability of data on pharmacokinetics, efficacy and safety analyses. The availability of analyses in the geriatric population was assessed as sufficient or insufficient, based on thorough assessment of the complete initial approval document. Information was deemed sufficient if information on pharmacokinetics, efficacy and safety was present in adequate numbers (e.g. representative of the target population). Adequate was assessed in concordance with the ICH7 guideline: “geriatric patients should be included in the Phase 3 database (and in Phase 2, at the sponsor's option) in meaningful numbers.” With regard to pharmacokinetic studies it is stated in the ICH7 guideline that “a pilot trial of limited size conducted under steady‐state conditions to look for sizable differences between older and younger subjects or patients” can be performed and “a larger, single‐dose pharmacokinetic study of sufficient size to permit statistical comparisons between geriatric and younger subjects’ or patients' pharmacokinetic profiles is also acceptable.” A pharmacokinetic screening approach as described in the ICH7 guideline was also deemed adequate.

Furthermore, the year of initial marketing approval was extracted. One researcher (Ri.R.) performed the inclusion and assessments. In case of uncertainty, a second researcher (Ro.R.) was consulted. A random sample of 10% (n = 18) was selected and double checked by the second researcher (Ro.R.), to ensure correct assessment of adequateness. Outcomes were numbers (%) of initial approval documents that contained adequate data on pharmacokinetics, efficacy and safety analyses.

2.4. Statistical analyses

To assess whether the percentage of available initial approval documents significantly increased during a certain time frame, χ2 test statistics were used, considering P < .05 statistically significant. Analyses were performed using SPSS statistics version 23.

3. RESULTS

In the ATC database, 1129 unique active pharmaceutical ingredients were found for the analyses (Table S1). Of these, 506 medical substances were found in the FDA database (45%). The majority consisted of drugs for mental health or nervous system disorders (n = 132; 26%); followed by antibacterial drugs (n = 101; 20%) and respiratory drugs (n = 86; 17%). Seventy‐one antihypertensive drugs were found (14%) and 39 glucose‐lowering drugs (8%). All other drugs each comprised <5% of the total amount of drugs found in the FDA database (Figure 1 ).

Figure 1.

Figure 1

Flow diagram of the availability of initial approval documents in the Food and Drug Administration (FDA) database. WHO, World Health Organization

Of the 506 medical substances, 182 (36%) initial approval documents were available (Table 1). Of these, the majority were drugs for mental health or nervous system disorders (n = 51; 28%); followed by glucose‐lowering drugs (n = 32; 18%) and antibacterial drugs (n = 22; 12%). Twenty‐one antihypertensive drugs were found (12%), 16 lipid‐lowering drugs (9%) and 15 respiratory drugs (8%). Antiulcer drugs comprised 7% (n = 13) and all other drugs each comprised <5% of the total amount.

Table 1.

Overview of the 182 substances included in the analyses (sorted on ATC code)

Number ATC code Generic product
1 A02BA01 Cimetidine
2 A02BA02 Ranitidine
3 A02BA03 Famotidine
4 A02BA04 Nizatidine
5 A02BB01 Misoprostol
6 A02BC01 Omeprazole
7 A02BC02 Pantoprazole
8 A02BC03 Lansoprazole
9 A02BC04 Rabeprazole
10 A02BC05 Esomeprazole
11 A02BC06 Dexlansoprazole
12 A02BX02 Sucralfate
13 A02BX05 Bismuth subcitrate
14 A10AB01 Insulin (inhalation)
15 A10AB02 Insulin (glargine)
16 A10AB03 Insulin (inhalation)
17 A10AB06 Insulin glulisine
18 A10AD04 Insulin lispro
19 A10AD06 Insulin degludec and insulin aspart
20 A10AE04 Insulin glargine
21 A10AE05 Insulin detemir
22 A10AE06 Insulin degludec
23 A10BA02 Metformin
24 A10BB02 Chlorpropamide
25 A10BB07 Glipizide
26 A10BB12 Glimepiride
27 A10BF01 Acarbose
28 A10BG01 Troglitazone
29 A10BG02 Rosiglitazone
30 A10BG03 Pioglitazone
31 A10BH01 Sitagliptin
32 A10BH03 Saxagliptin
33 A10BH04 Alogliptin
34 A10BH05 Linagliptin
35 A10BJ01 Exenatide
36 A10BJ02 Liraglutide
37 A10BJ03 Lixisenatide
38 A10BJ04 Albiglutide
39 A10BJ05 Dulaglutide
40 A10BJ06 Semaglutide
41 A10BK01 Dapagliflozin
42 A10BK02 Canagliflozin
43 A10BK03 Empagliflozin
44 A10BX03 Nateglinide
45 A10BX05 Pramlintide
46 C03DA04 Eplerenone
47 C03XA01 Tolvaptan
48 C03XA02 Conivaptan
49 C04AB01 Phentolamine
50 C07AB09 Esmolol
51 C07AB12 Nebivolol
52 C07AG02 Carvedilol
53 C08CA01 Amlodipine
54 C08CA02 Felodipine
55 C08CA03 Isradipine
56 C08CA16 Clevidipine
57 C09AA02 Enalapril
58 C09AA03 Lisinopril
59 C09AA10 Trandolapril
60 C09AA13 Moexipril
61 C09CA02 Eprosartan
62 C09CA03 Valsartan
63 C09CA04 Irbesartan
64 C09CA06 Candesartan
65 C09CA07 Telmisartan
66 C09CA08 Olmesartan medoxomil
67 C09CA09 Azilsartan medoxomil
68 C09XA02 Aliskiren
69 C10AA01 Simvastatin
70 C10AA02 Lovastatin
71 C10AA03 Pravastatin
72 C10AA04 Fluvastatin
73 C10AA05 Atorvastatin
74 C10AA06 Cerivastatin
75 C10AA07 Rosuvastatin
76 C10AA08 Pitavastatin
77 C10AB05 Fenofibrate
78 C10AB11 Choline fenofibrate
79 C10AC04 Colesevelam
80 C10AX09 Ezetimibe
81 C10AX11 Mipomersen
82 C10AX12 Lomitapide
83 C10AX13 Evolocumab
84 C10AX14 Alirocumab
85 G04BD07 Tolterodine
86 H03AA01 Levothyroxine sodium
87 J01AA12 Tigecycline
88 J01DD15 Cefdinir
89 J01DD16 Cefditoren
90 J01DE01 Cefepime
91 J01DH02 Meropenem
92 J01DH03 Ertapenem
93 J01DH04 Doripenem
94 J01DI02 Ceftaroline fosamil
95 J01FA13 Dirithromycin
96 J01FA15 Telithromycin
97 J01MA12 Levofloxacin
98 J01MA13 Trovafloxacin
99 J01MA14 Moxifloxacin
100 J01MA15 Gemifloxacin
101 J01MA16 Gatifloxacin
102 J01XA03 Telavancin
103 J01XA04 Dalbavancin
104 J01XA05 Oritavancin
105 J01XD02 Tinidazole
106 J01XX08 Linezolid
107 J01XX09 Daptomycin
108 J01XX11 Tedizolid
109 M01AH01 Celecoxib
110 N02AA05 Oxycodone
111 N02AB03 Fentanyl
112 N02AX06 Tapentadol
113 N02BG08 Ziconotide
114 N02CC02 Naratriptan
115 N02CC03 Zolmitriptan
116 N02CC04 Rizatriptan
117 N02CC05 Almotriptan
118 N02CC06 Eletriptan
119 N02CC07 Frovatriptan
120 N03AF02 Oxcarbazepine
121 N03AF03 Rufinamide
122 N03AF04 Eslicarbazepine
123 N03AG04 Vigabatrin
124 N03AG06 Tiagabine
125 N03AX11 Topiramate
126 N03AX14 Levetiracetam
127 N03AX15 Zonisamide
128 N03AX16 Pregabalin
129 N03AX18 Lacosamide
130 N03AX22 Perampanel
131 N03AX23 Brivaracetam
132 N04 BC04 Ropinirole
133 N04 BC05 Pramipexole
134 N04 BC06 Cabergoline
135 N04 BC07 Apomorphine
136 N04 BC09 Rotigotine
137 N04BD02 Rasagiline
138 N04BD03 Safinamide
139 N04BX01 Tolcapone
140 N04BX02 Entacapone
141 N05AE04 Ziprasidone
142 N05AE05 Lurasidone
143 N05AH03 Olanzapine
144 N05AH04 Quetiapine
145 N05AH05 Asenapine
146 N05AX08 Risperidone
147 N05AX12 Aripiprazole
148 N05AX13 Paliperidone
149 N05AX14 Iloperidone
150 N05AX15 Cariprazine
151 N05AX16 Brexpiprazole
152 N05AX17 Pimavanserin
153 N05BA09 Clobazam
154 N05CF02 Zolpidem
155 N05CF03 Zaleplon
156 N05CF04 Eszopiclone
157 N05CH02 Ramelteon
158 N05CH03 Tasimelteon
159 N05CM18 Dexmedetomidine
160 N05CM19 Suvorexant
161 N06AB04 Citalopram
162 N06AB10 Escitalopram
163 N06AX17 Milnacipran
164 N06AX21 Duloxetine
165 N06AX23 Desvenlafaxine
166 N06AX24 Vilazodone
167 N06AX26 Vortioxetine
168 R01AA04 Phenylephrine
169 R01AD13 Ciclesonide
170 R03AC13 Formoterol
171 R03AC18 Indacaterol
172 R03AC19 Olodaterol
173 R03BB04 Tiotropium bromide
174 R03BB05 Aclidinium bromide
175 R03BB07 Umeclidinium bromide
176 R03DC03 Montelukast
177 R03DX05 Omalizumab
178 R06AX17 Ketotifen
179 R06AX24 Epinastine
180 R06AX27 Desloratadine
181 R07AX01 Nitric oxide
182 R07AX02 Ivacaftor

For the majority of the drugs, the initial approval documents in the database did show information on pharmacokinetics in elderly (n = 113; 62%). For 1 drug, it was explicitly stated that information on pharmacokinetics, safety and efficacy in elderly was not applicable (ivacaftor). Furthermore, over time, the availability of information on pharmacokinetics in elderly increased statistically significantly from zero in the period 1979–1979 to 76% (n = 32) in the period 2010–2018 (p = .02; Table 2). For safety and efficacy information in elderly, detailed information was present in respectively 77 and 81 documents (42% and 45%). In addition, the availability of information on safety and efficacy in elderly did not improve over time (p = 0.13 and 0.11, respectively).

Table 2.

Availability of information on pharmacokinetics, safety or efficacy with regard to elderly in the initial approval documents in the Food and Drug Administration database for the 10 most frequently prescribed drug classes, drugs with known large or small volumes of distribution, and/or high or low hepatic clearance or renal excretion, or which are relatively contraindicated in elderly per time period

Before 1950 1950–1959 1960–1969 1970–1979 1980–1989 1990–1999 2000–2009 2010 onwards Total
Number of available initial approval documents 0 1 0 2 9 59 69 42 182
Information on pharmacokinetics with regard to elderly sufficient, n (%) NA 0 (0) NA 0 (0) 1 (11) 36 (61) 44 (64) 32 (76) 113 (62)
Information on safety with regard to elderly sufficient, n (%) NA 1 (100) NA 0 (0) 4 (44) 19 (32) 30 (43) 23 (55) 77 (42)
Information on efficacy with regard to elderly sufficient, n (%) NA 1 (100) NA 0 (0) 4 (44) 20 (34) 32 (46) 24 (57) 81 (45)

NA, not available.

4. DISCUSSION

In this study the availability of pharmacokinetic, safety and efficacy analyses specifically targeted at the elderly, prior to the authorization of the most frequently prescribed drug classes was evaluated. Based on the available initial approval documents, it was concluded that 62% of the FDA documents included reports on pharmacokinetic analyses, and 42 and 45% on safety and efficacy analyses in the elderly. For the majority of the drugs, the initial approval documents were not available in the database; however, over time, the percentage of available initial approval documents, as well as the information on pharmacokinetics increased significantly. With regard to crucial data on safety and efficacy, presence of information specifically on elderly was insufficient and did not increase over time.

Our results are in line with earlier studies on under‐representation of the elderly in (pre‐authorization) trials and published reports.12, 13, 18, 22, 23, 24, 25 It was reported that only 3 of the 155 clinical trials on 4 widely prescribed drugs were exclusively designed for patients aged 65 years and older.30 Moreover, a recent assessment of all performed clinical trials in 2012 revealed that only 2% of the randomized controlled trials were designed for elderly aged 65 and over.31

Unfortunately, we have shown that despite efforts to include elderly patients in clinical drug trials, under‐representation of elderly patients is still present, which challenges the external validity of benefit/risk assessments of launched drugs and leads to the phenomenon of off label prescribing in old patients.32 With regard to elderly, adequate representation of the targeted population in clinical trials is of pivotal importance as pharmacokinetic differences may give rise to differences in safety and efficacy. However, there are differences in opinion on this issue between EU countries leading to differences in clinical trial regulations and practice in older people, further complicating the adequate inclusion of elderly in clinical trials.16 Efforts have been made to overcome the underrepresentation of the elderly in clinical research. The updated ICH E7 guideline emphasizes the need for additional short‐ and long‐term safety data, adapted age‐specific endpoints and subjective outcomes such as quality of life. Moreover, the population under research should reflect the population at which the drug under investigation is aimed. Unfortunately, no specific percentage can be given as the percentage of elderly in the target population differs per drug. Nevertheless, efforts should be made to include patients aged >80 years with different degrees of comorbidity and frailty.33 For example, it was recommended to include older people in phase 1 clinical trials on gynaecological cancers, as they have similar toxicity profiles compared to their younger counterpart.34 However, including elderly in clinical trials remains challenging: given the presence of protocol restrictions (e.g. exclusion criteria on age, polypharmacy and multimorbidity), many elderly must be screened before 1 study participant can be enrolled.30

One of the major drawbacks of this study is that it could not be verified which specific older patients in terms of age, ethnicity, sex and comorbidities were included in the clinical trials. This is important as the elderly population included in the assessed initial approval documents could have consisted of relatively healthy elderly with 1 disease, thus not being representative of the target population of elderly which the drugs are using namely those elderly with multiple comorbidities and polypharmacy.33 Furthermore, the presence of information on pharmacokinetic studies could only be quantitatively assessed and not qualitatively. The available information was highly variable per assessed molecular entity; for example, different definitions of elderly were used, and information on numbers of elderly in clinical trials was missing frequently. As noticed in the methods section, the ICH7 guideline was used to deem whether numbers of included elderly were adequate, a random sample (10%) of the assessed reports was double checked to verify correct assessment of adequateness. Also, pages of the assessed initial approval reports were regularly withdrawn for confidentiality reasons of the submitting company. Furthermore, there is no way to determine whether all data submitted to the FDA are available in the online published documents. Lastly, not all pharmaceutical ingredients were found as drugs in the FDA database, which probably leads to nondifferential misclassification.

To our knowledge, this is the first study to assess the presence of information on pharmacokinetics, safety and efficacy in initial approval documents accessible in the FDA database. During the period 1927–2013, a total of 1453 drugs obtained FDA approval and the FDA still approves dozens of drugs each year.35 However, an analysis on the availability of pre‐authorization information on pharmacokinetics, safety and efficacy in elderly in the FDA database has not yet been performed. In a methodological guideline on the use of FDA documents for evidence syntheses, the benefit of using aggregated clinical trial information from FDA documents for the interpretation of data was emphasized, as it is less biased than published trial information.36 Nevertheless, since 2010, there is still insufficient data available on safety and efficacy of the most frequently prescribed drugs in the elderly. Knowing that older people account for the majority of all drug consumers, priority should be given to clinical research with a study population that is representative for the actual patient population.10

COMPETING INTERESTS

There are no competing interests to declare.

CONTRIBUTORS

Ri.R., J.B. and Ro.R. designed the study. Ri.R. and Ro.R. performed the analyses. Ri.R., J.B. and Ro.R. wrote the manuscript.

Supporting information

Table S1:

an overview of all selected medical substances from the World Health Organization database for the analyses.

ACKNOWLEDGEMENTS

We would like to express our gratitude to Ms Karen Broekhuizen, PhD, for her advice in writing the manuscript.

Ruiter R, Burggraaf J, Rissmann R. Under‐representation of elderly in clinical trials: An analysis of the initial approval documents in the Food and Drug Administration database. Br J Clin Pharmacol. 2019;85:838–844. 10.1111/bcp.13876

The authors confirm that the PI for this paper is Rikje Ruiter.

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Associated Data

This section collects any data citations, data availability statements, or supplementary materials included in this article.

Supplementary Materials

Table S1:

an overview of all selected medical substances from the World Health Organization database for the analyses.


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