06 RSV Adult Lloyd 508

CDC ACIP — Vaccine Advisory Committee

Acip

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19

Document text

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Evaluation of Guillain -Barré Syndrome (GBS) 
following Respiratory Syncytial Virus (RSV) 
Vaccination Among Adults 65 Years and Older
Dr. Patricia Lloyd, ScM PhD
Health Statistician
Office of Biostatistics and Pharmacovigilance
Center for Biologics Evaluation and Research
U. S. Food & Drug Administration
MEETING OF THE ADVISORY COMMITTEE ON IMMUNIZATION PRACTICES (ACIP)
Respiratory Syncytial Virus (RSV) Vaccine, Adults 
June 26 – 28, 2024
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Outline
•Introduction
•Observed vs. Expected Analysis Summary
▪Study Methods and Results
•Self-Controlled Case Series (SCCS) Analysis
▪Study Methods and Results
•Discussion
•Conclusion
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Introduction
•Two* RSV vaccines were approved for use in the U.S. in adults 60 years and 
older
▪RSVPreF3+AS01 (GSK - AREXVY)
▪RSVPreF (PFIZER - ABRYSVO)
•An imbalance in the rates of Guillain -Barré syndrome (GBS) between vaccine 
and placebo recipients was identified in clinical trials supporting licensure of 
RSV vaccines 1, 2
•FDA is conducting a post -licensure RSV vaccine safety study using two designs:
▪Observed vs. Expected Analysis
▪Self-Controlled Case Series (SCCS) Analysis
*mRNA -1345 (Moderna - mRESVIA ®) was approved on May 31, 2024.
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Observed vs. Expected Analysis Summary
Methods
•Evaluated risk of GBS following one dose of either RSVPreF3+AS01 
or RSVPreF vaccines using a retrospective cohort design with the 
2022 historical comparator
•Estimated the observed incidence rates (IRs) and compared to 
historical comparator (expected) rates, to obtain incidence rate 
ratios (IRRs) with 95% confidence intervals (CIs)
•Estimation of GBS positive -predictive value (PPV) -adjusted rates is 
based on multiple imputed datasets
▪Chart review, PPV for GBS: 71% (95% CI: 63%, 79%) 3
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Observed vs. Expected Analysis Summary
Results
RSVPreF3+AS01 RSVPreF
Inferential Analysis Results 
Observed vs. Expected Analysis 2.76 (95% CI: 1.32, 5.07) 6.94 (95% CI: 3.70, 11.87)
PPV-Adjusted Analysis 2.75 (95% CI: 0.46, 5.04) 6.91 (95% CI: 1.85, 11.97) 
GBS Cases per 1 million Doses 10.0 25.1 
Descriptive Analysis Results
Total RSV Vaccine Doses 2,061,602
RSV Vaccine Doses 1,379,335 682,267 
Observed GBS cases <11 13
Data Through Date: Dec 02, 2023•An elevated IRR was observed for GBS following RSV vaccination
•Only RSVPreF association was statistically significantly elevated in PPV -adjusted analysis
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•The observed vs. expected analysis is a crude method with 
limited adjustments for confounding, utilizing aggregate 
historical incidence rates rather than individual historical persons 
as comparators, increasing the potential for confounding and 
bias
•The SCCS is a robust method that controls for time -invariant 
confounding and does not rely on historical background 
incidence ratesMotivation for SCCS Study
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Self-Controlled Case Series (SCCS) Design
•Population Exclusion Criteria: 
▪Beneficiaries with no incident 
GBS outcome in the 
observation period 
OR
▪Beneficiaries who do not 
meet criteria to identify an 
incident outcome**
Days  43-90 Days 1 -42
365 Days Prior
Study Start Date
May 2023Study End Date
Apr 2024
RSV Vaccination (Day 0)= Risk Interval
= Control Interval
= GBS Outcome
*The clean window is relative to the outcome date; risk and control intervals are relative to the vaccination date
**Outcomes that are considered ‘incident’ after implementing the outcome -specific cleaning window are included, 
and only first incident outcome in the observation period are retained•Population Inclusion Criteria: 
▪Enrolled in Medicare Fee -
for-Service (FFS) during the 
clean window
▪65 years of age or older on 
RSV vaccination date
▪No GBS outcome during the 
clean window= Clean Window (365 days)*
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SCCS Analysis: Study Methods
Study Design Self-Controlled Case Series (SCCS) 4, 5
Data Sources and 
Study PopulationCenters for Medicare & Medicaid Services (CMS)  Medicare Beneficiaries ages 65 years 
and older, enrolled in:
▪Medicare FFS (Parts A and B) and Part D on the date of RSV vaccination
▪Medicare FFS and in 1 -year prior
Study Period May 2023* – April 2024 ⬧**
GBS Outcome 
Definition▪Risk Interval: 1 - 42 days
▪Control Interval: 43 - 90 days
▪Care Setting: inpatient – primary position only; ICD -10-CM DGN G61.0
Statistical 
Analyses▪IRRs with 95% CIs
▪Absolute Risk: Attributable Risk (AR) with 95% CIs per 100,000 doses and 100,000 
person -years (PY)
▪Adjustment for outcome -dependent observation time (Farrington) 6, seasonality, PPV
*FDA approval dates for RSVPreF3+AS01 and RSVPreF were May 3, 2023 and May 31, 2023, respectively
⬧Study end date for initial SCCS analysis was April 6, 2024
**RSV vaccinations prior to October 8, 2023 to have complete observation in 90 days post -vaccination and is expected to have 90%  or greater data -completeness
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SCCS Analysis: Vaccination Uptake Trends
020,00040,00060,00080,000100,000120,000140,000160,000180,000200,000Number of RSV Vaccinations
Calendar WeekWeekly Vaccination Uptake Trends in RSV Vaccines, By Vaccine Type
RSVPreF RSVPreF3+AS01
 Vaccination Cut -off Date to ensure complete observation of 90 -day window
Data Through Date: Apr 06, 2024
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Case Population Eligibility 
CriteriaRSV Vaccinations
(n=1.33 M individuals; 1.33 M doses)*
RSVPreF3+AS01 
(n= ~872k doses)*RSVPreF
(n= ~456k doses)*
Total GBS cases and total number 
of days in study period160 cases [339 days] 92 cases [311 days]
GBS cases  during 90 -day 
observation period 105 74
Incident GBS cases after applying 
clean window restriction55 36
GBS cases qualifying for SCCS 
analysis
(vaccinated before Oct 8, 2023)11 17Case Counts for GBS following RSV vaccination by Vaccine Type
* n = Medicare Beneficiaries that received RSV vaccination and eligible for SCCS analysis are presentedSCCS Analysis: Descriptive Results
Data Through Date: Apr 06, 2024
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 Data Through Date: Apr 06, 2024SCCS Analysis: Results for GBS
Most Adjusted 
Analysis
Least
Adjusted 
Analysis
SCCS Analysis including most adjustments are highlighted in Blue
Farrington -Adjusted Analysis = Outcome -Dependent Observation Time AdjustmentIRR with 95% CI of GBS following RSV Vaccination Adjusted for Combinations of PPV, 
Seasonality with Outcome -Dependent Observation Time
•An elevated IRR was observed for GBS following RSVPreF vaccination with two analyses that had the least adjustments
•Results additionally adjusted for PPV were no longer statistically significant
▪PPV, Seasonality with Farrington -Adjusted Analysis: 4.48 (95% CI: 0.88, 22.90) ▪PPV, with Farrington -Adjusted Analysis: 3.96 (95% CI: 0.77, 20.28) 
Seasonality, 
Farrington
FarringtonPPV, FarringtonPPV, Seasonality, 
FarringtonAnalyses
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SCCS Analysis: Results for GBS and                         
RSV vaccination
Inferential Analysis Results RSVPreF3+AS01 RSVPreF
Eligible Vaccinees 872,068 456,107
Cases in the Risk and Control 
Intervals<11 12.1
IRR (95% CI) 2.30 (0.39, 13.72) 4.48 (0.88, 22.90)
AR per 100,000 Doses (95% CI) 0.32 ( -0.30, 0.95) 1.57 (0.30, 2.85)
AR Per 100,000 PY (95% CI) 2.81 ( -2.64, 8.26) 13.69 (2.59, 24.79)Incidence Rate Ratio (IRR) and Attributable Risk (AR) of GBS - Adjusted for PPV, Seasonality and 
Outcome -Dependent Observation Time
Data Through Date: Apr 06, 2024
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•SCCS study design provides 
robust adjustment for potential 
time-invariant confounding
•Large database facilitates 
more precise evaluation of 
health outcomes
•Study findings are 
generalizable to U.S. 
population 65 years and olderDiscussion
Strengths Limitations
•Potential outcome 
misclassification 
•Potential misspecification of 
risk and control intervals
•Potential for residual 
confounding
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Discussion
Observed vs. Expected Analysis
•An elevated IRR was observed for GBS following RSV vaccination, 
but only RSVPreF association was statistically significantly elevated 
PPV (chart review) adjustment
•Crude method that utilized aggregate historical comparator rates 
rather than individuals, increasing the potential for confounding
•Statistically significant results of GBS do not establish a causal 
association between RSV vaccines and GBS
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Discussion
SCCS Analysis
•Although, an elevated IRR was observed for GBS following 
RSVPreF vaccination for two analyses that had fewer adjustments, 
the results were not statistically significant when adjusted for PPV
•Only cases, i.e., persons with an incident outcome contribute to the 
SCCS analysis
•Estimation of outcome risk occurs within, rather than between 
individuals, adjusting for time -invariant confounding
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Conclusion
•The results from two different types of analyses of potential GBS risk 
following RSV vaccination are mixed and highly uncertain
•These analyses do not provide clear, conclusive evidence of an elevated 
risk of GBS and an elevated risk cannot be ruled out at this time
•FDA is conducting medical chart review on GBS cases and will continue to 
evaluate the safety of RSV vaccines as more data are available
•FDA maintains that the b enefits of RSV vaccination in preventing RSV 
hospitalizations outweigh the potential risks associated with the vaccines
References
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1.Respiratory Syncytial Virus Vaccine Recombinant, Adjuvanted ( Arexvy ). Vaccines and Related Biological 
Products Advisory Committee Meeting. FDA Briefing Document. March 1, 2023. 
https://www.fda.gov/media/165622/download
2.Respiratory Syncytial Virus Stabilized Bivalent Prefusion F Subunit Vaccine ( Abrysvo ). Vaccines and 
Related Biological Products Advisory Committee Meeting. FDA Briefing Document. March 1, 2023. 
https://www.fda.gov/media/165625/download
3.Arya,D.P ., et al. Surveillance for Guillain -Barré syndrome after 2015 -2016 and 2016 -2017 influenza 
vaccination of Medicare beneficiaries. Vaccine, 2019. 37(43): p. 6543 -6549.
4.Petersen I, Douglas I, Whitaker H. Self controlled case series methods: an alternative to standard 
epidemiological study designs. 2016;354:i4515. 
5.Evaluation of Multiple Safety Outcomes following RSV Vaccination in Adults 60 Years and Older. 
https://bestinitiative.org/wp -content/uploads/2024/01/BEST_RSV_Safety_Older_Adults_2023 -2024.pdf
6.Farrington, C. P., Anaya -Izquierdo , K., Whitaker, H. J., Hocine , M. N., Douglas, I., & Smeeth, L. (2011). Self -
Controlled Case Series Analysis With Event -Dependent Observation Periods. Journal of the American 
Statistical Association, 106(494), 417 –426. https://doi.org/10.1198/jasa.2011.ap10108
Acknowledgements
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Steven Anderson
Richard Forshee
Narayan Nair
Joann Gruber
Carla Zelaya
Tainya Clarke
FDA Partners: 
Acumen, CMS
Questions?
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