Given the novel mechanisms and technical intricacies of GTMPs, there is a potential for emerging risks to patients, emphasizing the need for early risk detection and the implementation of effective risk mitigation strategies [5]. This study aimed to contribute to the establishment of a comprehensive pharmacovigilance plan for GTMPs by analyzing the characteristics of the ICSRs in VigiBase.
Because most GTMPs are orphan drugs administered to a limited number of patients, we expected that USR would be quite rare. Contrary to our expectations, USR comprised 72.4% of the total ICSRs of the GTMPs, surpassing SR. The proportion of USR remains high, although safety studies have been actively planned for GTMPs following regulatory requirements. There is no question that proactive initiatives such as long-term follow-up studies and registries are important for safety assessment of GTMPs. However, as shown in this study, a significant portion of ICSRs have been reported as USR, mainly as spontaneous reporting. Therefore, we need to plan an effective implementation of spontaneous reporting for GTMPs. Despite its limitations in data quality, spontaneous reporting has been recognized as a valuable tool for detecting safety signal or generating hypotheses in pharmacovigilance [28, 29].
Upon closer examination, it was observed that the proportion of USR was high in anticancer drugs with a relatively large patient population, but the proportion of USR was low in products with a small patient population. For Voretigene (Luxturna) and Onasemnogene (Zolgensma), utilized for patients diagnosed with inherited retinal dystrophy and spinal muscular atrophy, respectively, the proportion of USR was 52.1% and 54.1% each. This was lower than the USR proportion of 70.6–80.3% for anticancer GTMPs. This could be attributed to the limited patient pool utilizing GTMPs, prompting efforts to engage those available in regulatory-committed studies, or to the rarity of the disease, leading to increased research activities. Consequently, it is imperative to develop strategies for capturing USR to increase AE reporting in patients not enrolled in clinical trials or observational studies, particularly those with ultra-rare diseases.
In this study, the analysis of USR characteristics revealed that reports from physicians were the most prevalent (42.5%), followed by reports from other healthcare professionals (39.9%), whereas reports from consumers or non-health professionals were notably low (8.6%). The proportion of ICSRs reported by consumers or non-health professionals in our study was significantly lower compared to the range of 36–46.9% reported by consumers for other drugs in other studies [30, 31]. Given the nature of the diseases targeted by GTMPs, patients typically maintain regular contact with their healthcare providers, suggesting that AEs are often reported indirectly by physicians. However, safety concerns associated with GTMPs may manifest long after administration, highlighting the importance of patients being informed and empowered to report AEs, either directly or through healthcare providers. When patients assess potential ADRs, they often consider temporal relationships and provide information [32]. Patient reporting of ADRs increases when they know the purpose of the ADR reporting system and receive guidance on ADR reporting from healthcare professionals [33]. Hence, strategies to enhance patient awareness and facilitate ADR reporting are imperative to ensure comprehensive pharmacovigilance of GTMPs.
One of the main concerns when collecting safety information related to GTMPs is whether AEs that occur long after GTMP administration can be reported. Therefore, this study examined TTO. However, TTO had a significant proportion of missing information (82.6%), which was similar to SR and USR. Contrary to our expectations that more detailed data would be collected in SR, as ICSRs collected in a program with a planned data collection system were classified as SR, there were many missing TTOs even in SR. Clinical and observational studies have separate study databases to analyze the study data and write study reports. Thus, ICSRs could have been reported to regulatory authorities or national drug safety centers with the minimum elements to meet AE reporting requirements. Additionally, if the date is unclear when reporting an AE, the approximate time may be described only in the narrative instead of entering the date as the year, month, or day in the appropriate fields. In this study, the TTOs were calculated using information regarding the date of GTMP administration and AE occurrence. If dates were not entered into the relevant fields, the TTO could not be calculated, even though the information existed somewhere in the report. This may be the cause of many misses in TTO. Because the TTO is one of the key data points in evaluating causal relationships between drugs and events, it needs to be considered to ensure that it is collected well.
Among ICSRs with TTO, cases reported within 30 days accounted for 11.4% of all SRs and 13.7% of USRs, approximately 3.9 times and 6.9 times higher than those reported more than 90 days later (SR 2.9%, USR 2.0%). Although there were numerous missing values, making it challenging to draw general conclusions, the results aligned with our expectation that AEs occurring long after administration would be reported less frequently as USR than as SR.
In this study, Serious Adverse Events (SAEs) accounted for 89.0% of all ICSRs (SR, 88.5%; USR, 89.3%). Moreover, in patients with TTO > 90 days, the proportion of SAE was notably higher in the USR group (95.7%). In contrast, the proportion of SAE in the SR with TTO exceeding 90 days decreased to 79.1%. Encouraging the reporting of SAEs affecting the risk-benefit balance is emphasized for long-term safety assessments. Despite the relatively small proportion of cases reported beyond 90 days in the USR, important safety information is consistently reported in the USR.
Meanwhile, when considering the frequently reported AEs categorized by SOC, “Investigations” was the most frequently reported in SR, whereas “Nervous system disorders” was the most frequently reported in USR. This suggests that in the USR, there is a tendency to report signs, symptoms, and diagnoses with clinical significance, whereas in the SR, AEs related to tests are often reported according to the study protocols. This difference is further highlighted when examining PTs; none of the top 10 PTs reported in USR were classified as “Investigations,” whereas 50% of the top 10 PTs reported in SR were classified as “Investigations.”
One of the most prevalent concerns associated with GTMPs is their potential risk of cancer induction through gene therapy. Although many AEs were reported under the SOC of “Neoplasms benign, malignant, and unspecified (including cysts and polyps)” (SR 937, USR 1,434), they were reported from antineoplastic GTMPs except one event of meningioma reported as USR for voretigene (Luxturna). When evaluated with the PTs, such as malignant neoplasm progression and diffuse large B-cell lymphoma, many events were judged to be related to pre-existing conditions rather than suspected secondary malignancy. Therefore, a careful review is required to determine the association between the reported AEs and GTMPs.
To the best of our knowledge, this study is the first attempt to assess the characteristics of adverse events reported by GTMPs according to their reporting sources. This study had some limitations. First, the accuracy of the AE reporting sources was unknown. While most national monitoring centers review ICSRs before sending them to VIgiBase, and the WHO-UMC also evaluates the quality of ICSRs with vigiGrade [32, 34], the reliability of specific data, including reporting source records, remains uncertain. Second, our analysis was conducted in an aggregated manner without considering the indications or manufacturing characteristics of the GTMPs. Given that GTMPs target diverse diseases and may use different vectors for gene delivery, disease-specific characteristics and safety issues may vary. However, because of the limited number of patients eligible for GTMPs, analyzing each product individually could have posed challenges in obtaining sufficient data for review; hence, an integrated analysis was performed. Future studies should explore products with similar characteristics in greater detail. Thirdly, when evaluating the safety of GTMPs, it is crucial to assess both short-term and potentially delayed AEs. However, the lack of TTO data in many cases makes it difficult to ascertain the extent of long-term safety reports. Although AEs with TTO were evaluated, the high missing rate (> 80%) raised concerns regarding potential biases in interpretation. The results of our study should be interpreted in consideration of these limitations.