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U.S. Department of Health and Human Services

Post-Approval Studies (PAS) Database

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The FDA has the authority to require sponsors to perform a post-approval study (or studies) at the time of approval of a premarket approval (PMA), humanitarian device exemption (HDE), or product development protocol (PDP) application. Post-approval studies can provide patients, health care professionals, the device industry, the FDA and other stakeholders information on the continued safety and effectiveness (or continued probable benefit, in the case of an HDE) of approved medical devices. This database allows you to search Post-Approval Study information by applicant or device information.

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Cologuard PAS


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General
Study Status Completed
Application Number /
Requirement Number
P130017 / PAS001
Date Original Protocol Accepted 02/02/2015
Date Current Protocol Accepted 09/25/2015
Study Name Cologuard PAS
Device Name COLOGUARD
General Study Protocol Parameters
Study Design Prospective Cohort Study
Data Source New Data Collection
Comparison Group No Control
Analysis Type Descriptive
Detailed Study Protocol Parameters
Study Objectives The study objective is to collect longitudinal data on subjects for whom Cologuard is used over the course of 3 years. It is a prospective, longitudinal, multi-center study.
Study Population The study population is defined with the following criteria: Subjects must meet the following criteria to be eligible for the study:
1. Subject has been prescribed Cologuard for colorectal cancer screening
2. Subject is at average risk for development of colorectal cancer
3. Subject is 50 years or older
4. Subject willing and able to sign informed consent.
5. Subjects not listed in the exclusion criteria, described in 6.2 of the protocol.
Sample Size A total of 2,173 subjects will be enrolled to have 1,119 subjects at the year 3 visit (T3) for the Cologuard evaluation assuming
16.1% positivity rate at T0, with 15% annualized lost to follow up (LTFU). Further, it is assumed that 15% of the 1,119 subjects will refuse T3 colonoscopy to result in 951 being evaluable for T3 analyses.
Key Study Endpoints The primary endpoint for this study is the difference between the positive predictive value (PPV) at T3 (PPV3) and 1 minus the negative predictive value (NPV) at T3 (NPV3).
The secondary endpoint is the observed vs. the expected reduction in CRC incidence at T3.
Other outcomes to be assessed include the following:
¿The predictive values of a positive Cologuard at T0 and T3 and of a negative Cologuard atT3;
¿The sensitivity and specificity of Cologuard at T3;
¿The positive (PLR) and negative (NLR) likelihood ratios at T3;
¿The cumulative risk of false positive result (cFPR) and cumulative risk of a true positive result
¿(cTPR);
¿The probability that a negative Cologuard result at baseline remains negative through 3 years;
¿The probability that a negative Cologuard result at baseline (T0) results in no CRC/AA through 3 years;
¿The distribution of colorectal epithelial lesions overall and among positive Cologuard subjects at T0 and
¿T3 will be reported with counts and proportions;
¿The rate of adherence to repeat Cologuard at T3 will be reported with counts and proportions;
¿The Cumulative compliance to Colonoscopy following a positive Cologuard result
¿The rate of crossover to alternative screening methodologies (e.g. FOBT, colonoscopy, other) at T1
and T2;
¿The rate of no Cologuard result (e.g. invalid result); and
¿The adverse event rate (events occurring between collection kit distribution and sample submission).
Follow-up Visits and Length of Follow-up Study participants will be followed for 3 years
Interim or Final Data Summary
Actual Number of Patients Enrolled 2,321
Actual Number of Sites Enrolled 40
Patient Follow-up Rate Of the 2,321 subjects enrolled in the study, T0 Cologuard results were obtained for 2,073 (89.3%), with 284 subjects obtaining a positive result and 1,760 subjects obtaining a negative result. The study design required all subjects with a negative T0 Cologuard result to remain in the study and return for follow-ups. A total of 1,645 of the possible 1,760 eligible subjects (93.5%) completed the T1 office/phone visit, 1,510 (87.1%) subjects completed the T2 office/phone visit, and 1,223 (75.7%) p
Final Safety Findings No adverse events were reported.
Final Effect Findings The primary endpoint is the Predictive Summary Index (PSI), defined as (PPV3-[1-NPV3]), where PPV3 is the positive predictive value at T3 and NPV3 is the negative predictive value at T3. The primary endpoint was calculated for CRC alone and for CRC+AA combined. A PSI value of 0% reflects a test with no predictive value. No CRCs were detected at T3, the PSI for CRC alone was 0, and the PSI for CRC+AA combined was 9.29% (95% CI 1.83%, 17.63%, p-value = 0.0124).

The secondary endpoint was the observed versus the expected reduction in colorectal cancer (CRC) incidence at T3. Only 1 case of CRC occurred after T0, giving an observed incidence after a negative T0 Cologuard of 0.001374, numerically less than expected (two-sided p=0.0729 or one-sided p = 0.0402.
Study Strengths & Weaknesses Weakness: low procedure compliance rate for primary endpoints, only 37.1% patients (653 out of 1760) had colonoscopy at T3, only 33.5% patients (591) had both valid Cologuard and colonoscopy at T3 for study endpoint analyses. No statistical adjustment for multiplicity.
Strength: 3-year long term data
Recommendations for Labeling Changes Yes


Cologuard PAS Reporting Schedule

Reporting Schedule
Report
Date Due
FDA Receipt
Date
Applicant's Reporting Status
6 month report 02/09/2015 02/24/2015 Overdue/Received
1 year report 08/11/2015 08/07/2015 On Time
18 month report 02/09/2016 02/04/2016 On Time
2 year report 08/10/2016 08/09/2016 On Time
3 year report 08/10/2017 08/08/2017 On Time
4 year report 08/10/2018 08/09/2018 On Time
5 year report 08/10/2019 08/08/2019 On Time
final report 09/01/2020 09/01/2020 On Time


Contact Us

Mandated Studies Program
Food and Drug Administration
10903 New Hampshire Ave.
Silver Spring, MD 20993-0002
Email: MandatedStudiesPrograms@fda.hhs.gov

Additional Resources

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