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January 2020

Who We Are

The Alliance for Safe Biologic Medicines is an organization of patients, physicians, pharmacists, biotechnology companies that develop innovative and biosimilar medicines and others, who are working together to ensure that patient safety is at the forefront of the biosimilars policy discussion. It is the mission of the Alliance to serve as an authoritative resource center of information for the public, medical community, the FDA and other state and federal policymakers during the implementation of the biosimilars approval pathway and beyond.

Our Perspective

Biologics are advanced prescription drugs to treat cancer, rheumatoid arthritis and other debilitating diseases. In November 2010 the Food and Drug Administration began consultation with patient groups, physicians and industry on how to approve the first copies of these drugs, known as follow-on biologics or biosimilars. As the FDA moves forward in implementing this pathway, the Alliance for Safe Biologic Medicines will work to ensure patient safety remains the priority.

ASBM’s Andrew Spiegel Interviewed on Susan G. Komen Podcast
On January 28, the Susan G. Komen Foundation released an episode of their podcast “Real Pink” entitled  “The Evolution of Biosimilars as a Cancer Treatment” featuring Andrew Spiegel. Mr. Spiegel is Executive Director of the Global Colon Cancer Association and a founding member of ASBM. 

 

In the podcast, Spiegel explains how biologic medicines have extended the life expectancy of cancer patients, and how biosimilars can bring these patients new treatment options at reduced cost.

 

He also details concerns among the physician and patient community surrounding “non-medical switching“- forced switching by third parties such as insurance companies, for financial reasons rather than the health of the patient.
Download/Listen to the podcast here. 

 

Learn more about non-medical switching here. 

 

AHA Adds its Opposition to MFN Rule with Letter to CMS

 

On January 25th, the American Hospital Association (AHA) joined the ever-growing ranks of those opposing the Most Favored Nation (MFN) model interim final rule. The rule should be withdrawn immediately, the American Hospital Association (AHA) said in a letter to CMS.
The MFN model reduces Medicare Part B payments for certain drugs and biologicals to no more than the lowest price the drug manufacturers receive in countries with a similar level of economic development. The AHA contends that the rule is not a serious attempt at drug pricing reform because it does not directly address the cost of drugs. Instead, the rule places financial burden on provider organizations and forces them to divert resources to purchase drugs necessary for patient care, the AHA said.

Opposition to the MFN rule has been broad and come from many quarters, including physicians, patient advocacy organizations, the pharmaceutical industry, hospital associations, and others.

Read more about the AHA letter here.

ASBM Submits Comments on FDA Draft Guidance on Biosimilarity and Interchangeability

 

On January 19th, ASBM submitted comments on Draft Guidance issued November 19, 2020 by the FDA entitled “Biosimilarity and Interchangeability: Additional Draft Q&As on Biosimilar Development and the BPCI Act”
The document offers insights into how FDA will handle certain aspects of submissions and labeling for interchangeable biosimilars.

 

These include how an applicant may seek FDA review for licensure for an interchangeable biosimilar, and how a 351(a) BLA holder should proceed if it seeks licensure of its biological product under section 351(k) as biosimilar to or interchangeable with another biological product licensed under section 351(a) (a “reference product”). In addition, the document discusses recommendations for labeling of interchangeable biosimilars.

ASBM’s comments reiterated support for the FDA interchangeability standard, and for transparent labeling that facilitates informed treatment decision-making by healthcare providers and patients:

 

It is ASBM’s view that biosimilars and interchangeable biosimilars are two separate classes of medicines. The statutory requirements to achieve the designation of interchangeability are appropriately designed to necessitate a higher burden of proof, with a greater focus on the individual patient.

 

To meet these standards, ASBM believes a robust clinical program is required, such that it can be demonstrated, with near certainty, that the biosimilar product will produce the same clinical result as the reference product in any given patient, AND in the case of a biological product administered more than once to a patient, the risk in terms of safety or diminished efficacy of alternating or switching between use of the biosimilar product and the reference product is not greater than the risk of using the reference product without such alteration or switch.

 

Regarding Q.I.27 (Labeling of interchangeable biosimilars), ASBM believes that transparent labeling for biosimilar and interchangeable biosimilar products is critical for building physicians’ confidence in the safety of these medicines. Inclusion of approval and safety information generated by the biosimilar sponsor and transparency concerning studied versus extrapolated indications would provide a more comprehensive label to inform physician and pharmacist decisions regarding their patients.

 

Once finalized, FDA will move the questions and answers from the draft guidance to its companion Final Questions and Answers Guidance on biosimilar development.
Read the Draft Guidance here.
 

 

ICYMI: US Biosimilar Market on Pace with Europe
In January, the ASBM-authored whitepaper “US Biosimilars Market on Pace with Europe” was published in the print edition of GaBI Journal 2020 Issue 4. The paper is co-authored by ASBM’s Chair Madelaine Feldman and Executive Director Michael Reilly.

 

The paper demonstrates FDA is moving at approximately the same pace as EMA based on the number of approvals at the same time after implementation of its regulatory pathway:

  • As of September 2020, approximately 10 years after implementation of the biosimilar approval pathway, 28 biosimilars have been approved by FDA, with 18 of those approvals granted in the last 2 years. (Note: this figure has since risen to 29 approvals with the  December 17 approval of Rianbi (rituximab-arrx), which launched January 2021). 
  • For comparison, in the 10-year time period following the creation of Europe’s biosimilar regulatory pathway, EMA approved just 13 biosimilar products (some of which were marketed under several different brand names)
  • Currently, there are 46 biosimilars approved in Europe; however, this fall to 35 when products approved in the US as follow on biologicals via the 505(b)(2) pathway, e.g. somatropin, insulin, teriparatide, or abbreviated new drug application (ANDA) are excluded. Furthermore, Europe’s filgrastim biosimilar Tevagrastim®/Ratiograstim® was approved as Granix® (tbo-filgrastim) in the US via a Biologic License Application (BLA) prior to the implementation of a biosimilars approval pathway and is not included in the US biosimilar count.

In addition, US biosimilars have gained significant share in the majority of therapeutic areas in which they have been introduced, ranging on average from 20% to 25% within the first year of launch, with some projected to reach greater than 50% within the first 2 years:

  • As expected, first-to-market biosimilars tend to capture a greater portion of the segment compared to later entrants. Filgrastim biosimilars have been on the market the longest at 5 years and have achieved a 72% share.
  • Bevacizumab and trastuzumab biosimilars, launched in 2019-2020 have approximately 40% share.
  • Rituximab and infliximab have had the most limited adoption, with approximately 20% market share.

Read the full whitepaper here. 

 

 

 

 

Missed last month’s ASBM Newsletter? Read it Here.

 

 

 

UPCOMING EVENTS

 

DIA Latin America Regulatory Conference

Virtual – February 22-23, 2021

 

World Biosimilar Congress USA 2021

Virtual – March 29-31, 2021

 

WHO 72nd INN Consultation

Geneva, Switzerland/Virtual – April 13, 2021

 

Biologics Europe Online (Webinar)

Virtual – April 26-27, 2021

 

 

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The Alliance for Safe Biologic Medicines is an organization composed of diverse healthcare groups — from patients to physicians, medical innovators, and others who are working together to ensure patient safety is at the forefront of the biosimilars policy discussion.

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