Posts – Safe Biologics

Medicare Price “Negotiations” Will Jeopardize Patient Access to New Medicines, Result in Worse Health Outcomes

September 11, 2023

The Centers for Medicare & Medicaid Services (CMS) recently announced the first 10 drugs selected under its Medicare drug price “negotiation” plan, authorized by the Inflation Reduction Act (IRA) signed in to law last year. Over the next 4 years, Medicare will set prices for up to 60 drugs covered under Medicare Part D and Part B. This shortsighted move won’t control costs and threatens to limit patient access to new medicines, ultimately resulting in worse health outcomes for U.S. patients, warns ASBM.

IRA Changes Break a Successful Program
Michael Reilly, ASBM Executive Director and former Associate Deputy Secretary in the U.S. Department of Health and Human Services, worked on the development and implementation of the Part D prescription drug benefit during his six years in the Secretary’s Office. While proponents of government price-setting in Medicare claim this will create savings and lower costs, Reilly disagrees:

“Part D was designed following two decades of experience seeing government price-setting fail to control Medicare costs for services and healthcare provider rates. To avoid this happening with the new prescription drug benefit, we created a new model. Contrary to what many believe, under Part D, drug price negotiations do occur- they are conducted by pharmacy benefit managers (PBMs), and the law specifically forbid government interference in price-setting or formulary selection. As we intended, this approach has been incredibly successful in controlling costs: the Congressional Budget Office projected drug spending between 2004-2013 to be $770 billion; actual expenses were 45% lower- at $421 billion. It has a 90% approval rating among beneficiaries^[1], premiums have held steady around $32/month since 2006, and it holds the distinction of being the only major federal program to ever come in under budget.”

A Better Reform: Ensuring Savings Are Passed Onto Patients
While price-setting proponents say beneficiaries will start to see lower drug prices beginning in 2026, there’s no evidence that this is true, and there are better ways to lower out-of-pocket costs- and much faster, Reilly explains. “Part D has been hugely successful in lowering costs- but these savings are not always being passed on to the patient by the PBMs. Thankfully, there is a broad bipartisan effort underway in Congress to rectify this and provide immediate relief for patients- this year, not in 2026.” No fewer than eight bills have been introduced or advanced out of committee this session, with bipartisan support, to address PBM rebate and pricing policies that result in higher drug prices for patients.

The Consequences of European-style Drug Price-Setting Policies

Not only will it fail to control costs, imposing European-style price controls on Medicare Part D will spell disaster for American patients in the coming years. Reilly remarks, “The U.S. leads the world in drug innovation and patient access precisely because we’ve rejected the kind of price controls that stifle R&D and delay drug availability in Europe and Asia.” For example:

In the 1970s, European companies developed most new drugs; however, since the implementation of price controls in Europe, U.S. companies now produce 60% of new drugs, while European countries often have percentages in the single digits.^[1]
90% of new cancer drugs are available in the U.S. within the first year, whereas fewer than half are available to cancer patients in Germany, the UK, France, and Canada^[2]
European cancer death rates are 1.7 times higher than in the U.S.^[3]

Reilly describes what European-style health outcomes might look like in the U.S: “Imagine if the U.S. had European cancer death rates. That would translate to an extra 420,000 cancer deaths annually. Europe’s drug price-setting is simply not a policy worth emulating, and American patients should be aware of its public health consequences.”

ASBM Leading Education Efforts
ASBM has submitted comments to CMS critical of the policy and is conducting an educational campaign about the policy’s harmful effects. On July 26^th, ASBM hosted a webinar with the Generics and Biosimilars Initiative (GaBI) to examine the price-setting policy’s impact on drug development and reduced patient access to new medicines. The event featured three former government officials who were instrumental in the development of Medicare Part D’s prescription drug benefit; as well as experts from the fields of cancer drug research and patient advocacy, each of whom voiced their strong concerns with the policy individually and in a panel discussion.

ASBM also maintains an educational microsite for the patient community at IRAPatientInfo.org

The Alliance for Safe Biologic Medicines (ASBM) is a diverse group of stakeholders that includes physicians, pharmacists, patient advocates, researchers, and biopharmaceutical manufacturers. Since 2010, ASBM has worked closely with regulators worldwide as they develop and implement health policies, to ensure that these reflect the best interests of patients.

^[1] “Europe negotiates a poor vaccine rollout”; Forbes, April 2021

^[2] IQVIA Analytics, FDA, EMA, PMDA, TGA, & Health Canada data, April 2021.

^[3] “Democrat plan on drug costs will stifle innovation”, San Antonio Express-News, May 12, 2021

^{^[1]} https://www.usatoday.com/story/onpolitics/2012/10/03/poll-medicare-prescription-drug-program-popular/1609995/

Michael Reilly: Congress Should Maintain Current FDA Biosimilars Standards

September 27, 2024

Prioritize Patient Treatment Stability, Physician Confidence

Michael Reilly
September 25, 2024

Biologic medicines have revolutionized the treatment of serious chronic diseases including, arthritis, psoriasis, Crohn’s disease, and cancer. Nearly 10 years ago, the FDA approved the first “biosimilar” – a copycat medicine highly similar, but not identical to a previously-approved biologic. Biosimilars offer new treatment choices and more price competition, increasing access and affordability for patients. To date, 59 biosimilars have been approved and have saved our health system $24 billion. The FDA’s approval standards have rightly earned physician and patient trust. Unfortunately, Congress is now considering weakening those standards – which could inadvertently jeopardize the health of millions of patients and with it, confidence in these medicines.

While safe and effective, biosimilars aren’t generics because they aren’t identical copies of a biologic. Insurance companies and pharmacy benefit managers (PBMs) cannot treat biosimilars like generics and simply switch a patient to their preferred version, usually the more profitable medication. Under state law in all 50 states, only “interchangeable” biosimilars may be substituted by a third-party without prescriber approval. Interchangeables have demonstrated to the FDA through data, including switching studies, that a patient can expect the same results with no additional risks, even after multiple switches, compared to a patient who remained on the original biologic.

Surveys show nearly all physicians – 89% – are confident in biosimilars. Nevertheless, 69% believe that patients and physicians should control the decision to switch medications, not insurers and pharmacists. That’s because treatment plans aren’t universal; they are as individual as patients themselves. Patients often try several different medicines before finding the one that works best to treat their condition. An interchangeable designation makes almost 60% of physicians more comfortable with a biosimilar substitution at the pharmacy, knowing a stable patient won’t be put at risk by third party-switching.

State medical societies nationwide support the laws now permitting the substitution of interchangeable biosimilars. However, that support was conditional on assurances from policymakers that third-party substitution would be limited only to interchangeable biosimilars backed by additional safety and efficacy data.

But the safeguards physicians count on may soon be removed. This week, the Senate HELP Committee, which includes my own senator, Tim Kaine of Virginia, will vote on a bill that would classify all biosimilars as interchangeable. It would permit insurance companies to switch patients to any biosimilar as if they were generics, removing prior physician approval, in absence of now-required data demonstrating that switching won’t reduce safety and efficacy. The Biosimilar Red Tape Elimination Act would also remove the FDA’s ability to ask for switching studies when appropriate, dangerously lowering current safety standards. If this bill becomes law, it could negatively impact treatment stability for millions of patients.

Both policies are strongly opposed by the clinicians who best understand these medicines. A recent survey of 270 physicians who prescribe biologics revealed that a mere 11% believe all biosimilars should be classified as interchangeable, and 88% said biosimilar switching studies increase their confidence in safe switching.

Congress has a responsibility to retain the rigorous standards for interchangeability that have kept U.S. patients safe, earned the trust of physicians, and lowered health care costs. A failure to do so will put patient health outcomes, and physician trust in these important medicines, in jeopardy.

Michael Reilly served in the Office of the Secretary of the U.S. Department of Health and Human Services from 2002-2008, including three years as Associate Deputy Secretary. He serves as Executive Director of the Alliance for Biologic Medicines and resides in Alexandria, VA.

Read the oped at RealClearHealth

Fact Sheet: Physicians Oppose S.2305 -That Would Make All Biosimilars Interchangeable

August 27, 2024

In August, ASBM released an updated fact sheet on Senate Bill S. 2305 “the Biosimilar Red Tape Elimination Act”, sponsored by Sen. Mike Lee (R-UT), shoing how physicians overwhelmingly oppose its provisions.

From the Fact Sheet:

U.S. Physicians Strongly Oppose Pharmacy Substitution of Non-Interchangeable Biosimilars

While 89% of U.S. physicians are confident in the safety and efficacy of biosimilars, 69% also say the physician and patient should determine which biologic to use, not a third-party such as a pharmacy or insurance company. That’s because treatment plans aren’t one-size-fits-all. Each is uniquely tailored, and patients frequently try several products before finding one that best stabilizes their condition. Physicians need to be confident that a substitution by a pharmacy or insurance company won’t disrupt the patient’s treatment stability. The interchangeable standard’s data requirements provide that assurance, making a majority (59%) of U.S. physicians more comfortable with a pharmacy-level substitution.

From 2013-2021 all 50 state legislatures passed laws restricting automatic pharmacy substitution of biosimilars ONLY to interchangeable biosimilars. These laws were passed with the support of state medical
societies and patient organizations, conditional on these limits.

S.2305 would classify ALL biosimilars as interchangeable-inappropriately
permitting generic-style pharmacy substitution by insurance companies and pharmacy benefit managers, without the safety and efficacy data now needed. This would jeopardize treatment stability for millions of patients and betray the assurances made to physicians and patients nationwide that only biosimilars which had provided additional safety and efficacy data would ever be substituted without physician approval.

It would also restrict what data FDA can ask for to approve an interchangeable biosimilar, requiring the HHS Secretary to hold a private briefing with the chairs and ranking members of the Senate HELP and House Energy and Commerce Committees to justify asking for a study demonstrating switching won’t reduce safety or efficacy in patients.

Read the full Fact Sheet here.

S2305BSRedTape Download

ASBM Submits Comments on FDA Draft Guidance Proposing Eliminating Switching Studies for Interchangable Biosimilars

August 27, 2024

On August 20th, ASBM submitted comments on the FDA draft guidance for industry entitled “Considerations for Demonstrating Interchangeability with a Reference Product: Update”, published June 20th. This draft guidance describes considerations regarding a switching study or studies intended to support a demonstration that a biological product is interchangeable with a reference product.

From ASBM’s comments:

In addition to the FDA Draft Guidance, several legislative and regulatory proposals have been introduced at the state and federal level that would reduce requirements for interchangeability, declare all biosimilars interchangeable (making all biosimilars pharmacy-substitutable in the manner of generics), and/or restrict the FDA’s use of switching studies in determining interchangeability. Data has shown, however, that these policies are strongly opposed by physicians who prescribe biologics.

A 2024 survey of 270 U.S. physicians shows the importance of maintaining the robust data requirements undergirding the interchangeable designation. Respondents were drawn from nine practice areas: Dermatology, Endocrinology, Gastrointestinal, Immunology, Nephrology, Neurology, Oncology, Ophthalmology, and Rheumatology. All prescribe biologics.

87% of respondents agreed that they are more comfortable switching a patient from an originator biologic to a biosimilar if that medicine has been specifically evaluated for the impact of switching on safety and efficacy.
88% of respondents believe each interchangeable biosimilar should be individually evaluated specifically for the impact of switching on safety and efficacy.
Only 11% believe all biosimilars should be deemed interchangeable.
85% of respondents agreed that only biosimilars that have been individually evaluated specifically for the impact of switching on safety and efficacy should be deemed interchangeable.

These new data are consistent with previous findings demonstrating the value of the FDA’s current data standards for interchangeable biosimilars in providing assurances to physicians that third-party substitution will not impact safety or efficacy.

The role and value of switching studies in the approval of interchangeable biosimilars has been a subject of much discussion recently, and ASBM has generated several educational resources on the subject:

Read ASBM’s comments to the FDA here.

Read ASBM’s whitepaper about how misinformation regarding interchangeable biosimilars is undermining U.S. policy here.

View the webinar on Interchangeable Biosimilars here.

Read the article in GaBI Journal here.

June-July Newsletter

August 23, 2024

ASBM Whitepaper: Misinformation About Interchangeable Biosimilars Undermines US Health Policy, Physician Confidence, and Patient Health On July 16th, GaBI Journal published a whitepaper authored by ASBM Chairman Ralph McKibbin, MD and Executive Director Michael Reilly, which underscores the critical role of the FDA’s interchangeable biosimilar data requirements in maintaining the safety and efficacy of biosimilar substitutions. Titled “Misinformation about interchangeable biosimilars undermines US health policy, physician confidence, and patient health,” the paper discusses the successes of the FDA’s data-driven approach in building physician and patient confidence in biosimilars and provides an analysis of the potential risks associated with weakening these proven standards. In the U.S. as in most advanced nations, a prescribing physician may substitute any biosimilar for its reference product. However, substitution of biosimilars at the pharmacy level is controversial, opposed by majorities of physicians worldwide, and banned in many countries including most of Western Europe. In the U.S., only biosimilars deemed “interchangeable” by the FDA may be substituted by a pharmacist. 13 of the 53 approved biosimilars have earned that designation by providing additional data to the FDA demonstrating no loss of safety or efficacy even following multiple switches between a reference biologic and the biosimilar. This data may or may not include a switching study; several interchangeables have been approved without them. “All FDA-approved biosimilars are safe and effective, but treatment plans are not one-size-fits-all”, says McKibbin. “Each is uniquely tailored, and patients frequently try several products before finding one that best stabilizes their condition. Physicians need to be confident that a substitution by a pharmacy or insurance company won’t disrupt the patient’s treatment stability. The interchangeable standard’s data requirements provide that assurance.” “While 89% of U.S. physicians are confident in the safety and efficacy of biosimilars, 69% believe only the physician and patient should determine which biologic to use, not a third-party such as a pharmacy or insurance company”, notes Reilly. “These views are shared by physicians worldwide. But when a biosimilar carries an interchangeable designation, the majority (59%) of U.S. physicians are more comfortable with a pharmacy-level substitution because of the additional safety and efficacy data. The FDA’s standards are working, and any effort to lower them could compromise the progress we’ve made in building physician and patient confidence in biosimilars.” The publication of this paper comes at a critical time as the FDA seeks public comment on recent draft guidance that proposes to lower the data requirements for demonstrating interchangeability, and the U.S. Senate is considering a bill that would deem all biosimilars interchangeable and severely restrict the FDA’s ability to ask for additional data. The paper critically examines the recent meta-analysis often cited by proponents of lowering these standards. Focusing on safety but neglecting efficacy impacts and extrapolating multi-switch safety from mostly single-switch studies, McKibbin and Reilly argue the data do not support the proposed policy change. Read ASBM’s statement about the paper’s release here. Read the full paper here.

COMMENT PERIOD OPEN: FDA Draft Guidance Proposes Eliminating Switching Studies for Interchangable Biosimilars On June 20th, the FDA released new draft guidance for industry entitled “Considerations for Demonstrating Interchangeability with a Reference Product: Update.” This draft guidance describes considerations regarding a switching study or studies intended to support a demonstration that a biological product is interchangeable with a reference product. In a statement, Sarah Yim, MD, director of the FDA’s Office of Therapeutic Biologics and Biosimilars said: “The recommendations in today’s draft guidance, when finalized, will provide clarity and transparency about the FDA’s thinking and align the review and approval process with existing and emerging science.” From the FDA’s statement: FDA has generally recommended switching studies in the past as part of the data package needed to demonstrate interchangeability of a biosimilar; however, of the 13 approved interchangeable biosimilars, 9 were approved without additional clinical (switching study) data. With the publishing of today’s draft guidance, FDA is seeking comment on a revised approach where such studies will generally not be needed. The FDA is accepting public comment on the draft guidance from stakeholders until August 20, 2024. ASBM will be submitting comments and encourages others in the patient advocacy community to do so as well. Interested parties may submit their own comments here. The role and value of switching studies in the approval of interchangeable biosimilars has been a subject of much discussion recently, and ASBM has generated several educational resources on the subject. On November 30th, 2023 ASBM cohosted a webinar with GaBI November 30th on the topic. On May 10th, the Journal of the Generics and Biosimilars Initiative (GaBI Journal) published an article by ASBM’s Executive Director Michael Reilly entitled “Preserve the US Interchangeable Standard that Has Helped Drive Physician and Patient Confidence in Biosimilars”, which sought to address a recent push by U.S. policymakers to weaken or undermine the standard. In the article, Reilly explains the importance of additional data in building physician confidence: “The interchangeable standard, through its additional data requirements, reassures physicians that switching won’t reduce treatment efficacy: 59% are more comfortable with an interchangeable being substituted at the pharmacy. “Biosimilars, while safe and effective, aren’t generics and shouldn’t be treated as such. 50 U.S. state legislatures were not confused when they passed legislation limiting pharmacy substitution only to interchangeable biosimilars”, says Reilly. “These were supported by state medical societies conditional on these assurances. Breaking this commitment to physicians would be an unconscionable bait-and-switch by policymakers.” Read ASBM’s whitepaper about how misinformation regarding interchangeable biosimilars is undermining U.S. policy here. View the webinar on Interchangeable Biosimilars here. Read the article in GaBI Journal here. Submit comments on the draft guidance by August 20, 2024 here.

ASBM Fact Sheet: Senate Bill S.2305 Would Require FDA to Deem ALL Biosimilars Interchangeable, Restrict FDA From Considering Switching Studies to Establish Safety and Efficacy After Switching In July, ASBM released a fact sheet on Senate Bill S. 2305 “the Biosimilar Red Tape Elimination Act”, sponsored by Sen. Mike Lee (R-UT). From the Fact Sheet: S. 2305 would inappropriately eliminate the FDA safeguards now required for the pharmacy substitution of biosimilars. This would undermine physician confidence, risk treatment stability for millions of patients, and give PBMs and insurance companies control of treatment decisions that should be made by physicians and patients. U.S. Physicians Strongly Oppose Pharmacy Substitution of Non-Interchangeable Biosimilars

While 89% of U.S. physicians are confident in the safety and efficacy of biosimilars, 69% also say the physician and patient should determine which biologic to use, not a third-party such as a pharmacy or insurance company. That’s because treatment plans aren’t one-size-fits-all. Each is uniquely tailored, and patients frequently try several products before finding one that best stabilizes their condition. Physicians need to be confident that a substitution by a pharmacy or insurance company won’t disrupt the patient’s treatment stability. The interchangeable standard’s data requirements provide that assurance, making a majority (59%) of U.S. physicians more comfortable with a pharmacy-level substitution. From 2013-2021 all 50 state legislatures passed laws restricting automatic pharmacy substitution of biosimilars ONLY to interchangeable biosimilars. These laws were passed with the support of state medical
societies and patient organizations, conditional on these limits.
S.2305 would classify ALL biosimilars as interchangeable-inappropriately
permitting generic-style pharmacy substitution by insurance companies and pharmacy benefit managers, without the safety and efficacy data now needed. This would jeopardize treatment stability for millions of patients and betray the assurances made to physicians and patients nationwide that only biosimilars which had provided additional safety and efficacy data would ever be substituted without physician approval.
It would also restrict what data FDA can ask for to approve an interchangeable biosimilar, requiring the HHS Secretary to hold a private
briefing with the chairs and ranking members of the Senate HELP and
House Energy and Commerce Committees to justify asking for a study
demonstrating switching won’t reduce safety or efficacy in patients. Read the full Fact Sheet here.

ASBM to Update Ohio State University Biosimilars Course In the coming weeks, ASBM will announce updates to its 7-part Biosimilars Continuing Education Course produced in cooperation with Ohio State University College of Pharmacy. ASBM Chairman Ralph McKibbin and Advisory Board Chair Philip Schneider will be recording the first of the updated course modules (Biosimilars Module 2: Substitution and Interchangeability) in the coming weeks. The course is fully ACPE-accredited and available to pharmacists nationwide for 7 hours of CE credit. “Much has happened in the past year or two regarding biosimilar substitution; particularly regarding the role of interchangeable biosimilars,” said Schneider. “As the healthcare provider responsible for substitution, it’s important that pharmacists are kept up to date with accurate information.” Schneider, a professor at OSU’s College of Pharmacy, will also record a 5-minute promotional video for the course, previewing some of the updates regarding interchangeable biosimilars. ASBM will share this video when it becomes available.

BIO 2024: ASBM Participates in Annual Biotechnology Conference From June 3rd-6th, the Biotechnology Innovation Organization held its Annual International Conference in San Diego, CA. ASBM was well represented at the conference, with several member groups in attendance including AiArthritis, the Alliance for Patient Access, and the Lupus and Allied Diseases Association. Executive Director Michael Reilly also attended in the conference, where he participated in educational sessions and met with representatives of the biotechnology industry and patient advocacy communities. A key topic of discussion included the effects of the Inflation Reduction Act (IRA), which is expected to disincentivize drug research in the coming years, ultimately reducing patient access to new innovative therapies. ASBM has developed a number of educational resources discussing these themes: View ASBM’s IRA patient education microsite IRAPatientInfo.org here. View ASBM’s educational resource guide on the IRA for patient access here.

Forbes: IRA’s Small Molecule Price Controls Are Short Sighted On June 24, Forbes published an op-ed by Pacific Research Institute President Sally Pipes discussing the IRA’s highly controversial “small molecule penalty” and in particular its negative consequences for cancer research: AstraZeneca’s Tagrisso “can contain lung cancer nearly three years longer than chemotherapy and radiation alone.” Pfizer’s Lorbrena helps keep 60% of advanced lung cancer patients “alive without their disease advancing at five years,” compared to just 8% of patients who hit that milestone after taking a similar, older drugs.We’re likely to see fewer of these innovative drugs hit the market in the years to come, thanks to the Democrats’ Inflation Reduction Act, which President Biden signed into law in 2022. Starting in 2026, ten drugs under Medicare’s Part D prescription drug benefit will be subject to government price controls. Medicare will cap the prices of steadily more drugs dispensed via Part D and the Part B physician services program in the years that follow.Companies that refuse to sell at government-ordered prices may either withdraw from Medicare and Medicaid — a non-starter given that the government covers roughly half of all healthcare expenses. Or they can pay an excise tax that could reach up to 95% of the drug in question’s sales.Price controls are disincentive enough to invest in the development of new cancer drugs. But the IRA also targets the types of drugs that most commonly treat cancer for price controls four years sooner than it does biologics. Read the full op-ed here.

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

UPCOMING EVENTS ACR Convergence 2024
Washington, DC – November 14-19, 2024 WHO 79th INN Consultation
Geneva, Switzerland – October 22, 2024

Analysis Finds Misinformation About Interchangeable Biosimilars Undermining US Health Policy, Physician Confidence, and Patient Health

July 16, 2024

WASHINGTON, July 16, 2024 – The Alliance for Safe Biologic Medicines (ASBM) announces the publication of a paper underscoring the critical role of the FDA’s interchangeable biosimilar data requirements in maintaining the safety and efficacy of biosimilar substitutions. Titled “Misinformation about interchangeable biosimilars undermines US health policy, physician confidence, and patient health,” the paper discusses the successes of the FDA’s data-driven approach in building physician and patient confidence in biosimilars and provides an analysis of the potential risks associated with weakening these proven standards.

In the U.S., as in most advanced nations, a prescribing physician may substitute any biosimilar for its reference product. However, substitution of biosimilars at the pharmacy level is controversial, opposed by majorities of physicians worldwide, and banned in many countries including most of Western Europe. In the U.S., only biosimilars deemed “interchangeable” by the FDA may be substituted by a pharmacist. Thirteen of the 53 approved biosimilars have earned that designation by providing additional data to the FDA demonstrating no loss of safety or efficacy even following multiple switches between a reference biologic and the biosimilar. This data may or may not include a switching study; several interchangeables have been approved without them.

ASBM Chairman and paper co-author Ralph McKibbin, MD: “All FDA-approved biosimilars are safe and effective, but treatment plans are not one-size-fits-all. Each is uniquely tailored, and patients frequently try several products before finding one that best stabilizes their condition. Physicians need to be confident that a substitution by a pharmacy or insurance company won’t disrupt the patient’s treatment stability. The interchangeable standard’s data requirements provide that assurance.”

ASBM Executive Director and paper co-author Michael S. Reilly: “While 89% of U.S. physicians are confident in the safety and efficacy of biosimilars, 69% believe only the physician and patient should determine which biologic to use, not a third-party such as a pharmacy or insurance company. These views are shared by physicians worldwide. But when a biosimilar carries an interchangeable designation, the majority (58%) of U.S. physicians are more comfortable with a pharmacy-level substitution because of the additional safety and efficacy data. The FDA’s standards are working, and any effort to lower them could compromise the progress we’ve made in building physician and patient confidence in biosimilars.”

The publication of this paper comes at a critical time as the FDA seeks public comment on recent draft guidance that proposes to lower the data requirements for demonstrating interchangeability, and the U.S. Senate is considering a bill that would deem all biosimilars interchangeable and severely restrict the FDA’s ability to ask for additional data. The paper critically examines the recent meta-analysis often cited by proponents of lowering these standards. Focusing on safety but neglecting efficacy impacts and extrapolating multi-switch safety from mostly single-switch studies, McKibbin and Reilly argue the data do not support the proposed policy change.

Reilly attributes the push to weaken the current standard to widespread misconceptions and misinformation about interchangeability: “Some incorrectly believe switching studies are mandated by the FDA for a biosimilar to be deemed interchangeable, when in fact the FDA has flexibility and approved several without switching studies. Others confuse European Medicines Agency’s definition of “interchangeable” (meaning physician-substitutable) with the U.S. definition (meaning pharmacist-substitutable) and incorrectly believe the proposed policy change would bring the U.S. in line with Europe. In reality, pharmacy substitution of biosimilars is rare in Europe and frequently banned by EU member states. Accurate information and education are critical to avoid policy missteps that will undermine the FDA’s success in building physician confidence in biosimilars and protecting patients’ health.”

The full paper can be accessed in the latest issue of the Journal of the Generics and Biosimilars Initiative (GaBI Journal) here.

May 2024 Newsletter

June 7, 2024

ASCO 2024: ASBM Releases Resource Guide for Cancer Patients on IRA’s Impact on R&D, Access From May 31st – June 4th, the American Society of Clinical Oncology (ASCO) held its Annual Meeting in Chicago, IL. ASBM was well represented at the conference, with several member groups were in attendance including the International Cancer Advocacy Network (ICAN), and the Global Colon Cancer Association (GCCA). Executive Director Michael Reilly also attended the conference, where he met with representatives of the cancer community and discussed the IRA’s likely negative impacts on cancer drug research and development, biosimilar competition, and patient access to new innovative therapies. In conjunction with ASCO 2024, ASBM released a resource guide for the cancer community, which assembles a variety of ASBM-created educational content detailing the IRA’s effects. These include a webinar featuring an analysis of the policy by former government health officials responsible for developing and implementing Medicare’s prescription drug benefit, a podcast episode, a research paper, a fact sheet, and a patient-education microsite. View the resource guide here.

ASBM Discusses Biosimilar Interchangeability and Substitution at Oregon’s St. Charles Health System Grand Rounds On May 17, ASBM Executive Director Michael Reilly led a Grand Rounds at St. Charles Health System focused on biosimilar interchangeability and substitution. The Bend, OR-based health system is the state’s largest. Among the topics Reilly covered were recent efforts at the state, federal, and international level to eliminiate the distinction between biosimilars (which may be substituted in place of their reference product by a prescribing physician) and interchangeable biosimilars, which may be substituted under state laws by a pharmacist. Interchangeables have earned this classification by providing additional data to the FDA demonstrating that neither safety nor efficacy diminish for patients, even after repeated switching, relative to patients who remained on the reference product. This discussion is particularly relevant for Oregon healthcare providers as last year, the states’s Prescription Drug Affordability Board (PDAB) recommended the Oregon legislature alter state law to permit the automatic substitution of non-interchangeable biosimilars; that is, the substitution at the pharmacy level of a biosimilar without prescriber involvement. The automatic substitution of biosimilars is a controversial practice, banned in many countries including nearly all of Western Europe.Oregon state law currently only permits biosimilars that the FDA has approved as interchangeable to be automatically substituted. ASBM submitted comments opposing the proposal and defending the current state law. From the comments: As Congress and the FDA intended, the interchangeable biosimilar designation has proven successful in promoting confidence in biosimilars, and in their automatic and third-party substitution: 57% of physicians said they’d be more likely to prescribe an interchangeable biosimilar; 59% said that an interchangeability designation makes them more comfortable with a pharmacy-level substitution of a biosimilar in place of the originator.States like Oregon were able to gain physician support for their biosimilar substitution legislation due to the assurances provided in the legislation that only interchangeable biosimilars would be substituted without prescriber approval. They were able to secure support from patient advocacy organizations conditional on patients being notified if their medicine were to be switched. The proposal under consideration by the PDAB strikes at the heart of these reasonable protections, and betrays the promises made to physicians and patients. View Mr. Reilly’s Grand Rounds presentation here. Read ASBM’s comments on the OR PDAB legislation here.

ASBM’s Michael Reilly: Preserve the US Interchangeable Standard that Has Helped Drive Physician and Patient Confidence in Biosimilars
On May 10th, the Journal of the Generics and Biosimilars Initiative (GaBI Journal) published an article by ASBM’s Executive Director Michael Reilly entitled “Preserve the US Interchangeable Standard that Has Helped Drive Physician and Patient Confidence in Biosimilars”. The article was written in a r esponse to an April article in EndpointsNews, in which an FDA official called on Congress to eliminate the distinction between biosimilars (which can be prescribed in place of their reference products by a physician) and “interchangeable” biosimilars, which can be substituted by pharmacists the way generics are. Doing so would undermine physician confidence in biosimilars and jeopardize treatment stability for many patients, according to Reilly. The FDA official’s comments echoed language in the Administration’s FY2025 HHS Budget which alleges the interchangeable standard creates “confusion” among healthcare providers. On the contrary, Reilly explains, it creates confidence: The interchangeable standard, through its additional data requirements, reassures physicians that switching won’t reduce treatment efficacy: 59% are more comfortable with an interchangeable being substituted at the pharmacy. “Biosimilars, while safe and effective, aren’t generics and shouldn’t be treated as such. 50 U.S. state legislatures were not confused when they passed legislation limiting pharmacy substitution only to interchangeable biosimilars”, says Reilly. “These were supported by state medical societies conditional on these assurances. Breaking this commitment to physicians would be an unconscionable bait-and-switch by policymakers.” Moreover, while the Administration claims eliminating the distinction would bring the U.S. more into line with European substitution practices, in fact the opposite is true: The EMA does not weigh in on pharmacy substitution of biosimilars; this is reserved for member states and nearly every Western European country has decided (like U.S. states) that this is not acceptable. A 2019 survey revealed a strong majority (73%) of Europe’s physicians, like their U.S. counterparts, oppose third-party biosimilar substitution. Finally, biosimilar uptake is largely determined by insurer and PBM formulary design, not a biosimilar’s interchangeable designation, Reilly explains. “CVS Caremark, which controls 34% of the market, recently dropped the reference adalimumab in favor of its own co-branded biosimilar version. Within a week, adalimumab biosimilar market share rose from 5% to 36%.” Cigna, a PBM controlling 24% of the U.S. market, has announced plans to make a similar move in June. “The interchangeable biosimilar standard is working as intended: building physician confidence through data and providing a biosimilar option physicians can be certain will not jeopardize the treatment stability of a patient for whom maintaining it is a critical concern.There are several promising bipartisan legislative effortsunderway in Congress bring more transparency to PBM formulary design and rebate practices. These represent a far more productive -and medically appropriate- target for reform efforts for those seeking to boost biosimilar uptake.” Read the article in GaBI Journal here.

FDA Approves First Interchangeable Biosimilar for Two Rare Diseases On May 28th, the U.S. FDA approved Bkemv (eculizumab-aeeb) as the first interchangeable biosimilar to Soliris (eculizumab) to treat certain rare diseases. Bkemv is approved for the following treatment indications, which are also currently approved for Soliris:the treatment of patients with paroxysmal nocturnal hemoglobinuria (PNH) to reduce hemolysis; andthe treatment of patients with atypical hemolytic uremic syndrome (aHUS) to inhibit complement-mediated thrombotic microangiopathy.“Many rare conditions are life-threatening, and many do not have treatments,” said Sarah Yim, director of the Office of Therapeutic Biologics and Biosimilars in the FDA’s Center for Drug Evaluation and Research. “The FDA is committed to help facilitate the development of safe and effective interchangeable biosimilar treatments that can expand access for individuals with rare diseases whose current treatment options are limited.”
Read approval the FDA approval here.

FDA Approves First Interchangeable Biosimilars to Treat Macular Degeneration In May, the FDA approved Yesafili (aflibercept-jbvf) and Opuviz (aflibercept-yszy) as interchangeable biosimilars to Eylea (aflibercept). Aflibercept products work by inhibiting vascular endothelial growth factor (VEGF) which prevents abnormal blood vessel growth within the eye. By blocking VEGF, aflibercept products can slow down or reduce damage to the retina and help preserve vision. Both Yesafili and Opuviz are used to treat:Neovascular (wet) age-related macular degenerationMacular edema following retinal vein occlusionDiabetic macular edemaDiabetic retinopathyBoth Yesafili and Opuviz are administered intravitreally (in the eye) as a 2 mg (0.05 mL of 40 mg/mL) injectable solution to treat patients for the conditions listed above according to dosing regimens as recommended in the labeling. Read more about the FDA approvals here.

Pennsylvania Senate Introduces PBM Bill The Pennsylvania Senate Health and Human Services Committee recently unanimously amended SB 1000, An Act amending the act of November 21, 2016 (P.L.1318, No.169), known as the Pharmacy Audit Integrity and Transparency Act; It was introduced and referred to the Committee on January 8th of this year and has now been presented for first consideration. Senate Bill 1000 directs the Insurance Department to develop a process for hearing and resolving pharmacy complaints against a PBM. PBMs shall report to the department the amount of rebates and payments received from drug manufacturers, and how those rebates and payments were distributed by the PBM. The legislation will also limit or ban several practices by PBMs, including patient steering, spread pricing and retroactive recoupment of money paid by the PBM to the pharmacy. Read more about PA SB 1000 here.

April 2024 Newsletter

May 21, 2024

ASBM’s Michael Reilly: Preserve the US Interchangeable Standard that Has Helped Drive Physician and Patient Confidence in Biosimilars
In an April interview with EndpointsNews, an FDA official called on Congress to eliminate the distinction between biosimilars (which can be prescribed in place of their reference products by a physician) and “interchangeable” biosimilars, which can be substituted by pharmacists the way generics are. Doing so would undermine physician confidence in biosimilars and jeopardize treatment stability for many patients, according to ASBM’s Executive Director, Michael Reilly in a r esponse published in GaBI Journal. The FDA comments echo language in the Administration’s FY2025 HHS Budget which alleges the interchangeable standard creates “confusion” among healthcare providers. On the contrary, Reilly explains, it creates confidence: The interchangeable standard, through its additional data requirements, reassures physicians that switching won’t reduce treatment efficacy: 59% are more comfortable with an interchangeable being substituted at the pharmacy. “Biosimilars, while safe and effective, aren’t generics and shouldn’t be treated as such. 50 U.S. state legislatures were not confused when they passed legislation limiting pharmacy substitution only to interchangeable biosimilars”, says Reilly. “These were supported by state medical societies conditional on these assurances. Breaking this commitment to physicians would be an unconscionable bait-and-switch by policymakers.” Moreover, while the Administration claims eliminating the distinction would bring the U.S. more into line with European substitution practices, in fact the opposite is true: The EMA does not weigh in on pharmacy substitution of biosimilars; this is reserved for member states and nearly every Western European country has decided (like U.S. states) that this is not acceptable. A 2019 survey revealed a strong majority (73%) of Europe’s physicians, like their U.S. counterparts, oppose third-party biosimilar substitution. Finally, biosimilar uptake is largely determined by insurer and PBM formulary design, not a biosimilar’s interchangeable designation, Reilly explains. “CVS Caremark, which controls 34% of the market, recently dropped the reference adalimumab in favor of its own co-branded biosimilar version. Within a week, adalimumab biosimilar market share rose from 5% to 36%, lack of automatic-substitutability by a pharmacist posed no obstacle”. Cigna, a PBM controlling 24% of the U.S. market, has announced plans to make a similar move in June. “The interchangeable biosimilar standard is working as intended: building physician confidence through data and providing a biosimilar option physicians can be certain will not jeopardize the treatment stability of a patient for whom maintaining it is a critical concern.There are several promising bipartisan legislative efforts underway in Congress bring more transparency to PBM formulary design and rebate practices. These represent a far more productive -and medically appropriate- target for reform efforts for those seeking to boost biosimilar uptake.” Read the article in GaBI Journal here.

ASBM Comments Urge EMA Not to Abandon Clinical Data in Biosimilar Approvals
On April 30, ASBM submitted comments to the European Medicines Agency’s (EMA’s) Committee for Medicinal Products for Human Use (CHMP) as part of a public consultation periodon the Agency’s “Concept paper for the development of a Reflection Paper on a tailored clinical approach in Biosimilar development”. The document expresses the EMA’s intent to streamline biosimilar development by re-evaluating the role of clinical safety and efficacy data. Read the concept paper here. Read ASBM’s comments here.

FDA Celebrates 50th Biosimilar Approval On April 25, the FDA approved its 50^thbiosimilar. Its announcement was accompanied by a statement touting the many successes of the U.S. biosimilar program since the first approval in 2015, including savings to the U.S. health system and increased access to biologic treatments for patients. From the FDA statement: According to a 2023 report by the Association of Accessible Medicines, FDA-approved biosimilars have saved the health care system $23.6 billion since the first biosimilar product was approved in 2015. Collectively, patients have used biosimilars for almost 700 million days of therapy, 344 million days of which patients received care they otherwise may not have received. The impact and potential of biosimilars are significant not only in terms of savings to the health care system, but also for health equity and helping improve patients’ access to medications that were previously beyond their reach.
Read the FDA’s statement on this milestone here.

ASBM Chairman Urges State and Federal Lawmakers to Help Ensure Patient Access, Treatment Choice In early April ASBM Chairman Ralph McKibbin joined with the Pennsylvania Nonmedical Switching Coalition to meet with members of the Pennsylvania House of Representatives Insurance committee to answer questions and advocate regarding the impact of nonmedical switching on patients in the state. PA State Senate bill 348 amends the Unfair Insurance Practices Act to prevent nonmedical switching and a House companion bill is pending. Dr. McKibbin also participated as part of the American College of Gastroenterology Board of Governors in their legislative action session April 17-19 in Washington, DC. Meetings were held with both U.S. Senate and House members to advocate for patient access to care. During the educational session, Dr. McKibbin presented on the importance of the leadership provided by stakeholder organizations.

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

UPCOMING EVENTS ASCO Annual MeetingChicago, IL – May 31-June 4, 2024 BIO International Meeting
San Diego, CA – June 3-6, 2024 DIA Global Annual Meeting
San Diego, CA – June 16-20, 2024 ACR Convergence 2024
Washington, DC – November 14-19, 2024

March 2024 Newsletter

May 10, 2024

Biden Administration HHS Budget Would Permit Third-Party Substitution of All Biosimilars
On March 11th, the Biden Administration released its FY25 HHS Budget. In response, ASBM Executive Director Michael Reilly published a blog post sharing his concerns with the Administration’s proposal to permit widespread automatic (pharmacy-level) substitution of all biosimilars in place of their reference products; without physician approval or FDA evaluation as current law requires. From the post: The HHS Budget in Brief document describes the policy objective simply enough: “Permit Biosimilar Substitution without Prior FDA Determination of Interchangeability” and clarifies that this means “deem all approved biosimilars to be interchangeable with their respective reference products”.
It justifies the policy by claiming “this change makes the U.S. biosimilar program more consistent with the approach adopted by other major regulatory jurisdictions such as the European Union where biosimilars are interchangeable with their respective reference products upon approval.”
In the U.S. and Europe alike, prescribers can already substitute any biosimilar for its reference product. What is at stake and where the two regions differ somewhat in policy is when and how pharmacies can substitute biosimilars. The confusion stems from the fact that the term “interchangeable” has different meanings in the U.S. and Europe:
In Europe,“Interchangeable” means prescriber-substitutable:
The European Medicines Agency (EMA) has stated all biosimilars it approves are “interchangeable” in that they “may be prescribed interchangeably” and that this does not refer to pharmacy substitution: “Member States will continue to decide…whether automatic substitution is allowed at the pharmacy level.” In the U.S., however, “interchangeable” refers to a biosimilar which under state law may be substituted at the pharmacy level without physician approval because its manufacturer has provided additional data to the FDA demonstrating a patient can be switched between the biosimilar and reference product and expect the same result. Currently there are 10 biosimilars that can be substituted by U.S. pharmacies in this manner, with more on the way. 69% of US physicians surveyed consider it “very important or critical” that patients and physicians decide the most suitable biologic to use- be it the reference product or one of the biosimilars to that product. However 59% of physicians are more comfortable with an interchangeable being substituted in place of the prescribed originator product. The Biden budget proposal would undermine this hard-won confidence by eliminating the FDA’s science-based data requirements for permitting pharmacy-substitution of biosimilars, and declaring by fiat that all biosimilars substitutable by the pharmacy, despite the opposition from U.S. physicians. And it does so based at least in part on a serious misunderstanding of what the health systems of other advanced countries permit. Read more here. View ASBM’s educational fact sheet “Interchangeability: US vs EU” here.

Biden’s SOTU: 500 Drugs To Be Subject to Medicare Drug Price Controls
On March 7th, President Biden gave his State of the Union address to Congress, wherein he laid out upcoming policy priorities for a potential second term. Among these was an expansion of the Medicare Drug price setting provisions passed in 2022 as part of the Inflation Reduction Act (IRA). Biden seeks to dramatically increase the number of drugs subject to Medicare price negotiations, said President Biden in the address:This year Medicare is negotiating lower prices for some of the costliest drugs on the market that treat everything from heart disease to arthritis. Now it’s time to go further and give Medicare the power to negotiate lower prices for 500 drugs over the next decade. CMS is currently working to set prices for 10 drugs, with the final prices set to be announced by Sept. 1 and go into effect in 2026. Without a change, the number of eligible drugs will increase to 15 in 2027 and 2028 and to 20 every year thereafter. ASBM recently hosted a webinar in which former government health officials who worked on Medicare Part D, the program’s prescription drug benefit, discuss the harmful impacts of the IRA’s price setting policies. Read more about how IRA Medicare Drug price setting will negatively affect patient access to new medicines at ASBM’s microsite IRAPatientInfo.org.

ASBM Presents at World Health Organization’s 78th INN Consultation
On March 19th, ASBM presented to the World Health Organization International Nonpropretary Names (INN) Expert Group at the 78th Consultation on International Non-proprietary Names for Pharmaceutical Substances (INN), held in Geneva, Switzerland on October 18th, 2023. ASBM was represented at the session by Executive Director Michael Reilly, Esq., and Advisory Board Chair Philip Schneider, MS, FASHP. The proceedings of the INN Consultation are bound by confidentiality pending the publication of the Executive Summary by the WHO. However, the recently-released Executive Summary from the 77th INN Consulation (held October 19, 2023) lays out the benefits for a distinct nomenclature standard, and highlights the ongoing support for such a standard, both from ASBM as well as from regulators. From the Executive Summary: The ASBM has supported the INN Group’s Biological Qualifier (BQ) scheme since its inception in 2012, and since then has doggedly presented data on the importance of a BQ to enhancing patient safety and pharmacovigilance (PV). However, they have also learned that WHO moves slowly, has many global health issues to deal with and has many stakeholders. Almost 10 years after the inception of the BQ, with no further action ensuing, a WHO report in 2021 highlighted that a lack of consistency in naming biosimilars had caused concern in prescribing, prescription mix-ups, unintended switching and traceability, and concluded that naming and labelling was important for product identification, PV and prescribing. When the BQ was first proposed, ASBM noted that several global regulatory agencies supported the scheme, including the US FDA which eventually adopted its own not dissimilar system comprising a random four-letter suffix. Other supporting agencies await the WHO implementing a global system. In the EU, the EMA has stated that it does not need a BQ as it has an alternative system in place but recognises the value of a unified system. Several arguments have been raised by stakeholders opposed to a BQ; however, in each case these have proven to be unfounded. For example, it had been stated that distinguishable names may imply inferior products, but this has not been the case in USA. In addition, surveys have shown that a supposed lack of support by physicians and global regulators was incorrect. Over these years also, the ASBM has surveyed and met with many global regulators and physicians and the vast majority support distinct nomenclature. The lack of action with the BQ has forced many regulators, either assigning the same non-proprietary name to biosimilars or in some cases to adopt their own system. However, most of them are willing to support a WHO system if it is implemented. The ASBM made a proposal to quantify support for the BQ. . It acknowledged support for a BQ system and with the debate having continued for 10 years now it strongly encourage the WHO to take a leadership role. Dr Balocco noted that the department had a new ADG and that WHO was soon to have a new Director-General. The WHO has been asked to work on a Global Substance Identifier (GSID) and there may be an opportunity to bring in the BQ as part of this. The INN Programme is in fact ready to implement a BQ. Dr Balocco expressed hope that a decision would be taken soon as the INN by itself is not sufficient for PV. Read the full Executive Summary of the 77th INN Consultation here.

Reminder: EMA Seeks Public Comment on Re-evaluating the Need for Clinical Safety and Efficacy Data in Biosimilar Development; Comments Due April 30
On January 25, the European Medicines Agency’s (EMA’s) Committee for Medicinal Products for Human Use (CHMP) released a document entitled “Concept paper for the development of a Reflection Paper on a tailored clinical approach in Biosimilar development”. The document expresses the EMA’s intent to streamline biosimilar development by re-evaluating the role of clinical safety and efficacy data; it also announces a three-month public consultation period running from February 1 to April 30, 2024. From the announcement: Constantly striving for scientifically sound yet efficient processes, the Biosimilar regulatory framework has constantly been evolving towards increasingly tailored developments, starting from smaller and “simpler” biologics, such as recombinant Granulocyte-Colony Stimulating Factor (rG-CSF), insulins or somatropin where the need for comparative clinical efficacy trials is in general not required any more. With growing knowledge and the increasing possibilities of analytical and functional characterisation, revisiting the need for clinical efficacy trials for biosimilars (especially recombinant proteins and mAbs) is considered the next important step in order to keep the Biosimilar pathway attractive for developers and, at the same time, guarantee future access to safe and efficacious biologics for European patients. The CHMP recognizes that there may be the potential to waive certain clinical data requirements even for complex biosimilars such as mAbs based on solid evidence of quality comparability. When the biosimilar demonstrates a high degree of similarity to the RMP at the analytical and functional level, it may be possible to justify the omission of dedicated CES. Comments may be submitted here until April 30, 2024. Read the concept paper here.

How IRA Price Setting Disccourages Biosimilar Development
In a recent op-ed in USA Today, Rutgers University professor Sandip Shah, argues that the price-setting provisions of the Inflation Reduction Act (IRA) are unintentionally disincentivizing biosimilar development:The IRA permits Medicare officials to impose price controls on certain brand-name drugs, including many biologics. But the government does not have to reveal which medicines will be subject to price caps until just two years prior to the lower prices taking effect.As a result, a firm could hypothetically spend nearly a decade and hundreds of millions of dollars developing a biosimilar — only to find out that the original brand-name biologic will suddenly be much cheaper, courtesy of government price controls. In such a scenario, the biosimilar developer would be unable to gain enough market share to break even on its R&D investments, let alone earn a modest return.Lawmakers can restore incentives for biosimilar drug makers by automatically — and permanently — exempting from price controls any biologic for which there is a biosimilar competitor in development.Unless and until that happens, the legacy of the Inflation Reduction Act will be reduced access to low-cost biosimilars — ultimately leading to higher drug spending. Read the op-ed here.

FDA Approves Three Interchangeable Biosimilars in First Quarter of 2024
During the first quarter of 2024, the FDA approved three additional interchangeable biosimilars, bringing the total number of approved interchangeable biosimilars to 10, and the total number of biosimilars to 48. On February 24th, the FDA approved Simlandi (adalimumab-ryvk), a biosimilar to Humira (adalimumab). The TNF alpha inhibitor was approved for treating plaque psoriasis, Crohn’s disease, ulcerative colitis, rheumatoid arthritis, juvenile idiopathic arthritis, psoriatic arthritis, ankylosing spondylitis, hidradenitis suppurativa, and uveitis. On March 5th the FDA approved two interchangeable biosimilars: Jubbonti (denosumab-bbdz), interchangeable for Prolia (denosumab), and Wyost (denosumab-bbdz), interchangeable for Xgeva (denosumab). Jubbonti was approved for increasing bone mass in men and women and breast cancer, for osteoporosis (induced by glucocorticoid treatment or otherwise) in men and women, and for preventing fracture in post-menopausal women with osteoporosis. Wyost was approved for treating patients with multiple myeloma and solid tumor bone metastases, giant cell bone tumors, and treatment of hypercalcemia of malignancy refractory to bisphosphonate therapy. Read more about the approvals here and here.

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

ASBM’s Michael Reilly: Preserve the US Interchangeable Standard that Has Helped Drive Physician and Patient Confidence in Biosimilars

May 10, 2024

In an April interview with EndpointsNews, an FDA official called on Congress to eliminate the distinction between biosimilars (which can be prescribed in place of their reference products by a physician) and “interchangeable” biosimilars, which can be substituted by pharmacists the way generics are. Doing so would undermine physician confidence in biosimilars and jeopardize treatment stability for many patients, according to ASBM’s Executive Director, Michael Reilly in a r esponse published in GaBI Journal. The FDA comments echo language in the Administration’s FY2025 HHS Budget which alleges the interchangeable standard creates “confusion” among healthcare providers. On the contrary, Reilly explains, it creates confidence:

The interchangeable standard, through its additional data requirements, reassures physicians that switching won’t reduce treatment efficacy: 59% are more comfortable with an interchangeable being substituted at the pharmacy. “Biosimilars, while safe and effective, aren’t generics and shouldn’t be treated as such. 50 U.S. state legislatures were not confused when they passed legislation limiting pharmacy substitution only to interchangeable biosimilars”, says Reilly. “These were supported by state medical societies conditional on these assurances. Breaking this commitment to physicians would be an unconscionable bait-and-switch by policymakers.”

Moreover, while the Administration claims eliminating the distinction would bring the U.S. more into line with European substitution practices, in fact the opposite is true: The EMA does not weigh in on pharmacy substitution of biosimilars; this is reserved for member states and nearly every Western European country has decided (like U.S. states) that this is not acceptable.

A 2019 survey revealed a strong majority (73%) of Europe’s physicians, like their U.S. counterparts, oppose third-party biosimilar substitution. Finally, biosimilar uptake is largely determined by insurer and PBM formulary design, not a biosimilar’s interchangeable designation, Reilly explains. “CVS Caremark, which controls 34% of the market, recently dropped the reference adalimumab in favor of its own co-branded biosimilar version. Within a week, adalimumab biosimilar market share rose from 5% to 36%, lack of automatic-substitutability by a pharmacist posed no obstacle”. Cigna, a PBM controlling 24% of the U.S. market, has announced plans to make a similar move in June. “The interchangeable biosimilar standard is working as intended: building physician confidence through data and providing a biosimilar option physicians can be certain will not jeopardize the treatment stability of a patient for whom maintaining it is a critical concern.

There are several promising bipartisan legislative efforts underway in Congress bring more transparency to PBM formulary design and rebate practices. These represent a far more productive -and medically appropriate- target for reform efforts for those seeking to boost biosimilar uptake.”

Read the article in GaBI Journal here.

ASBM Chairman Urges State and Federal Lawmakers to Help Ensure Patient Access, Treatment Choice

April 30, 2024

In early April ASBM Chairman Ralph McKibbin joined with the Pennsylvania Nonmedical Switching Coalition to meet with members of the Pennsylvania House of Representatives Insurance committee to answer questions and advocate regarding the impact of nonmedical switching on patients in the state. PA State Senate bill 348 amends the Unfair Insurance Practices Act to prevent nonmedical switching and a House companion bill is pending. Dr. McKibbin also participated as part of the American College of Gastroenterology Board of Governors in their legislative action session April 17-19 in Washington, DC. Meetings were held with both U.S. Senate and House members to advocate for patient access to care. During the educational session, Dr. McKibbin presented on the importance of the leadership provided by stakeholder organizations.