Issue of "safety" in PACE, data obscured by a large grey area
In
post #490, Dolphin very briefly raised the issue of "non-serious adverse events" (saying that they were very common, that people have not paid much attention to them because of the title, and that the title may be misleading). Other posters may have also raised the issue of safety as well, but Angela's concerns helped me realise this issue is as important as other major flaws discovered so far. I think the key to understanding the relative "safety" of PACE is a synergy between the following two issues:
(1) The "safety net" of caution in the trial.
I have already covered this before, but basically, although encouraged to increase activity if possible (and encouraged to maintain activity during exacerbations), patients didn't actually have to do this if they didn't want to. The authors seem to imply there was an increase in activity by nature of the CBT/GET rationale but then provide no data on changes in overall activity. It is possible that there was no increase in activity on average, which according to other studies using actigraphy and finding no objective improvements to overall activity, is hardly surprising. Attempts at increasing activity would have been made as per protocol, and if done very gently and cautiously, most incidents of symptom exacerbation could be "contained" within the questionable classification of adverse events.
(2) I have underestimated the importance of how adverse events have been classified in PACE, being fooled initially by the relatively low rates of serious events and drop-outs. There is a high threshold for a "serious adverse event", arbitrary decisions were made about whether any such event was a reaction to the therapy or not, and we are given no data whatsoever for "non-serious adverse reactions" to therapy despite being in the original protocol (both the short published one and the long unpublished one).
From the original (published) protocol, page 12:
Adverse outcomes (score of 57 of the self-rated CGI) will be monitored by examining the CGI at all follow-up assessment interviews [49]. An adverse outcome will be considered to have occurred if the physical function score of the SF-36 [28] has dropped by 20 points from the previous measurement. This deterioration score has been chosen since it represents approximately one standard deviation from the mean baseline scores (between 18 and 27) from previous trials using this measure [23,25]. Furthermore, the RN will enquire regarding specific adverse events at all follow-up assessment interviews.
Again they use the "one standard deviation from the mean" calculation, which like the definition of a "normal" PF/SF-36 score, may be misleading (haven't looked into that yet but I imagine going from 30 to 10 is worse than going from 60 to 40). From the original (published) protocol, page 13 (describes the classes of adverse effects, some of which I quote below, I won't quote the serious categories because more detailed information can be gained from the larger unpublished protocol, more on that later):
Adverse events (AE) are any clinical change, disease or disorder experienced by the participant during their participation in the trial, whether or not considered related to the use of treatments being studied in the trial.
Non-serious adverse events or reactions will be assessed by the RN at each follow-up assessment interview. A risk assessment has been undertaken, and we have concluded that the therapies are of low risk to participants. Non-serious adverse events will be reported according to the usual regulatory requirements.
From the Lancet paper:
For safety outcomes, we included non-serious adverse events, serious adverse events, serious adverse reactions to trial treatments, serious deterioration, and active withdrawals from treatment.[10] Adverse events were defined as any clinical change, disease, or disorder reported, whether or not related to treatment. Three scrutinisers (two physicians and one liaison psychiatrist who all specialised in chronic fatigue syndrome) reviewed all adverse events and reactions, independently from the trial team, and were masked to treatment group, to establish whether they were serious adverse events. Scrutinisers were then unmasked to treatment allocation to establish if any serious adverse events were serious adverse reactions. Serious deterioration in health was defined as any of the following outcomes: a short form-36 physical function score decrease of 20 or more between baseline and any two consecutive assessment interviews;[16] scores of much or very much worse on the participant-rated clinical global impression change in overall health scale at two consecutive assessment interviews;[25] withdrawal from treatment after 8 weeks because of a participant feeling worse; or a serious adverse reaction.
A persistent decline of 20 points in PF/SF-36 score would be deemed serious by patients too, but according to White et al anything less than that is tolerated. Note that we have another goalpost shift, an "adverse outcome" was originally a decline of 20 points in PF/SF-36 at the next assessment, but now for the replacement outcome (a "serious deterioration") it must persist for two consecutive assessments (there are other ways to meet criteria for a serious deterioration, but these are strict as well).
Also, in [Table 4: Safety outcomes], "non-serious adverse events" are common while "serious adverse events" and "serious deterioration" were relatively rare. SAEs were more common in the GET and APT groups compared to the CBT and SMC groups, but it was decided these were generally not related to the trial.
Also, in [Table 5: Participant-rated clinical global impression of change in overall health], the proportion of participants reporting being "much worse or very much worse" were similar and under 10% in each group, and in each group more than half reported "a little worse, no change, or a little better" in the CGI (however, the CGI was only used to measure outcomes at 52 weeks, not "events").
From the long unpublished protocol (p66):
[14.2 Non-serious adverse events and reactions]
Non-serious adverse events or reactions will be assessed by the RN at each follow-up assessment interview (see 10 & 11). A risk assessment has been undertaken, and we have concluded that the therapies are of low risk to participants.
Examples of expected nonserious adverse events have been identified, and these include:
Development of new mood disorder
Musculoskeletal injuries - e.g. ankle sprains etc.,
Transient exacerbation of fatigue or pain, expected as a normal reaction to CBT or GET in patients with CFS/ME, which does not have significant impact upon function (see 14.1.1 (a))
Development of new sleep disturbance
Falls (e.g. due to tripping, etc.)
Worsening of anxiety - e.g. health anxiety, exacerbated by a transient increase in symptoms
So they actually expected symptom exacerbation due to CBT and GET. And everything in the above list was within the authors' tolerance of "safe". As for their notion of exacerbation "which does not have significant impact upon function", see [14.1.1 (a)] which is under "14.1.1 Serious Adverse Events (SAEs)". Because (a) was "Death" (an absurd threshold for a significant impact upon function) I have to assume we are referred to the rest of the subsection or at least (d), again from the long unpublished protocol (p65):
[14.1.1 Serious Adverse Events (SAEs)]
An adverse event (AE) is defined as serious (an SAE) if it results in one of the following outcomes:
a) Death,
b) Life-threatening (i.e., with an immediate, not hypothetical, risk of death at the time of the event),
c) Requires hospitalisation (hospitalisation for elective treatment of a pre-existing condition is not included),
d) Increased severe and persistent disability, defined as: severe = a significant deterioration in the participant's ability to carry out their important activities of daily living (e.g. employed person no longer able to work, caregiver no longer able to give care, ambulant participant becoming bed bound); and persistent = 4 weeks continuous duration
e) Any other important medical condition which, though not included in the above, may jeopardise the participant and may require medical or surgical intervention to prevent one of the outcomes listed.
f) Any episode of deliberate self-harm
In the Lancet paper WebAppendix, the description for serious adverse events and serious adverse reactions are the same, as one of the following:
(a) Death; b) Life-threatening event; c) Hospitalisation (hospitalisation for elective treatment of a pre-existing condition is not included), d) Increased severe and persistent disability, defined as a significant deterioration in the participants ability to carry out their important activities of daily living of at least four weeks continuous duration; e) Any other important medical condition which may require medical or surgical intervention to prevent one of the other categories listed; f) Any episode of deliberate self-harm.
As you can see, the threshold for a "serious" event or reaction is high, and all events which aren't as bad as that are assumed by the authors to be "safe" and have no "significant impact upon function"! Further, we are not told how many "non-serious adverse EVENTS" were deemed to be due to the treatment ie "non-serious adverse REACTIONS".
Assuming it was reported/recorded and as long as the participant did not withdraw, it was possible for a patient to experience substantial post-exertion symptom exacerbation and even become housebound/bedridden due to CBT or GET then gradually recover over the next week or so, and have this classified as a "non-serious adverse event" having "no significant impact upon function" and used as evidence that CBT or GET are safe!
The proportion of patients experiencing "non-serious adverse events" was the same between SMC vs GET (93%). I don't know how to explain that, but it does seem very strange to me that 7% of patients in two moderately affected cohorts (one doing exercise) never experienced a single "non-serious adverse event" over 52 weeks while the other 93% experienced about 6 such events on average. I also don't know how to explain the relatively low drop out rates other than patients simply didn't have to push themselves if they didn't want to, everything was supposedly done with great caution, and for other reasons believed in or wanted to stick out the duration of the trial.
Also in the long unpublished protocol, form A6.35 on p209 on the PDF which asks:
[A6.35 Non-serious Adverse Event report log]
Start date of AE (dd/mm/yy);
Stop date of AE (dd/mm/yy);
Description of adverse event (Brief description);
Was the event related to trial treatment? (Definitely related / Probably related / Possibly related / Definitely unrelated / Uncertain);
Has participant withdrawn from trial follow-up (Yes / No);
Please rate the severity of the event, if unsure or concerned, consult with Centre Leader (Mild / Moderate / Severe);
Any medication or therapy taken as a result? (Yes / No).
So again, they clearly did record both qualitative and crude quantitative data on "non-serious adverse events", but information on whether these were deemed a reaction to the trial therapy was omitted from the Lancet paper. Therefore, it is plausible that a large proportion of these events were "reactions" to CBT or GET, apparently the authors even expected such reactions but chose not to report them. As Dolphin pointed out, it was possible to have a "severe" non-serious adverse event as well.
Basically, unless CBT or GET caused a severe and persistent decline in health, all adverse events/reactions are deemed insignificant. PACE are claiming and promoting CBT/GET as safe for CFS because a good majority of moderately affected Oxford criteria patients in the early stages of illness didn't end up dead, or hospitalised, or with a severe increase in disability for several weeks at a time, or attempt self-harm/suicide, or report feeling "much worse or very much worse", etc. Very sneaky on behalf of the authors, how PACE handled adverse effects from therapy strongly resembles spin doctoring!
Page 13 of the published protocol mentions the "Safety of participants":
There is a discrepancy between patient organisation reports of the safety of CBT and GET and the published evidence of minimal risk from RCTs. Surveys by Action for M.E. of its members suggest that people becoming worse with these treatments is caused by either rigidly applied programmes that are not tailored to the patient's disability, or by improperly supervised programmes [13-15]. PACE treatment manuals minimize this risk by being based on mutually agreed and flexible programmes that vary according to the patient's response. The RN will also carefully monitor for any adverse effects of the treatments.
How the authors interpret adverse effects and safety is an important clue into the "discrepancy" between published RCT's and patient surveys. Considering how the authors show little regard for the grey area between therapy being ineffective and therapy causing a "serious"/"severe" event, I think the people who have filled out the patient surveys have a different interpretation of what a significant adverse effect is for them based on their own personal experience, which can in part explain the "discrepancy".