Forbes: Blood Drug Woes Could Weigh on FDA and its Approval of New, Copycat Biologic Medicines

February 27, 2013

The announcement last night that Affymax (NASDAQ: AFFY) is recalling all lots of its red blood cell stimulating medicine Omontys could have broader implications for how the Food and Drug Administration (FDA) evaluates similar drugs going forward.

Omontys was recalled following some fatal, severe allergic (anaphylactic) reactions that occurred within 30 minutes of receiving the first dose. Unless the problem can be traced to an obvious additive in the product or some characteristic in affected patients that made them susceptible to the reactions (enabling doctors to avoid dosing high risk patients) then quick re-introduction of the drug could be challenging.

In a statement, FDA said that there were 19 anaphylactic reaction reports. Three of these reactions resulted in death. Others required prompt medical intervention and resuscitation. Some required hospitalization.  Omontys is used to treat anemia in kidney dialysis patients. It was supposed to compete directly with Amgen’s older and much more widely used drugs Epogen and Aranesp.

The episode could have broader implications for how FDA looks at biologics more generally, and especially other follow on products aimed at stimulating production of red blood cells. There is an inherent unpredictability in biologics owing to our inability to fully characterize these drugs. This truth is being borne in the relative caution that FDA has shown in fully implementing a pathway for the approval of “biosimilars” – follow on or generic versions of existing biologics. It will also affect how FDA views “bio betters” — new versions of existing drugs that are believed to have superior qualities that enhance the new drug’s safety or effectiveness.

This latest episode is likely to heighten FDA’s caution still more.

While Omontys was a different molecule than either Epogen or Aransep (and a fairly simple molecule) there could be some subtle, long-term lessons for FDA. The agency has years of experience with biological agents that simulate red blood cell production, and the inability to ferret out the risks with Omontys is likely to underscore how hard this science remains. Our tools for identifying both small and more significant differences between otherwise similar-acting biologics, and then translating when these changes can have clinical implications, are still an evolving science.

When these arguments were made during the debate over creating a biosimilars pathway, they were often dismissed. They were characterized as the self-interested pleadings of those trying to protect existing franchises. Perhaps there was some hyperbole on both sides of that debate. But the fact is, the science of biosimilar agents is still evolving. Regulatory constructs are likely to further reflect that evolving uncertainty.

For these reasons, FDA has already shown caution in approving “biosimilar” drugs and — in particular — defining a pathway for these medicines that gives sponsors a sufficiently easier route to the market than the one enjoyed by the innovator drug they are copying. This has created some uncertainty among sponsors whether the biosimilar pathway is really worth pursuing in certain cases, or would they be better off filing applications for new biologics (and securing the benefits that such a new Biologics License Application affords).

That environment of caution is likely to mount. It will blunt at least some of the economic rewards that policymakers envisioned when they created the biosimilars pathway.
The fact that the biosimilars don’t typically offer any clinical advantage (only potentially economic advantages) over their branded complements is likely to only increase the regulatory skittishness. The potential for risk needs to be weighed against the bounded public health benefits that these follow on products offer.

Episodes like these might also give added caution to physicians. Biologics that are seemingly similar in their structure and action can nonetheless have different profiles with important implications. Physicians could have additional pause about using the follow on drugs. All of these facts may weigh on the biosimilars enterprise.

As for FDA, it might well take a harder view that the safety of biosimiliars needs to be even more firmly established before approval. The same could apply to bio-better drugs that try and use new molecular scaffolding to achieve the same ends as existing biological drugs (especially tweaked versions that don’t offer distinct clinical advantages over the older medicines).

The situation involving Omontys is still unfolding, and many questions remain. But it is through episodes like these that FDA has often shaped some of its most cautionary principles.


February 2013 Newsletter

February 27, 2013

State Activity

With the start of a new year, comes the start of a new legislative calendar. The past weeks have been very busy as many states are considering substitution legislation. ASBM and our members have been sending in letters of support in CO, VA, IN and ND and will continue to express our concerns for patient safety as more legislation is introduced.

All state activity can be found on our “In the States” page on our website. You can also find our One Pager on Automatic Substitution stressing that patients and physicians want doctors involved in treatment decisions.


Colorado

Colorado has been buzzing with the introduction of biosimilar substitution legislation House Bill 1121, which ASBM and our members have shown great support for. The CO bill was voted out of the House Health, Insurance & Environment Committee on February 12 and will be sent to the House and then the Senate for a full vote in the coming weeks. Thanks to Allen Todd with Global Healthy Living Foundation for testifying on behalf of patients before the committee.

Read his testimony here.


Prior to the hearing, Andrew Spiegel with the Colon Cancer Alliance sent in a letter of support saying:

“If patients and their physicians do not know what medicines they are taking, they can’t make the right decisions; they deserve to know when a biologic that has been working to keep them alive is being substituted, especially until we learn more about biosimilars.

“We agree that when interchangeable biosimilar products are substituted, communication among patients, pharmacists, and health care providers is essential to patient care. Opponents of the bill suggest that its provisions are onerous and intended to prevent the substitution of biosimilars from occurring, however, the physician notification requirement does not kick in until after the substitution has occurred. Physicians and pharmacists work together on a daily basis to ensure patients receive proper care, and there is no reason why dealing with highly complex, next generation medicines should be any different.”

Read ASBM, GHLF and CCA’s letters here.


Virginia

In Virginia, ASBM and several members sent letters of support for House Bill 1422. When the Senate version failed to adopt all of all patient protections that the House included in their bill ASBM, AfPA, CCA, GHLF, ICAN, Kidney Cancer and RetireSafe signed onto a joint letter with other patient groups urging the Senate to include provisions from the house bill.

The letter stated:

“For many of the more than two million Virginia patients—including our seniors, children and veterans—who suffer from one or more chronic illnesses, biologic medicines represent life-changing, and often lifesaving, therapies. They have improved quality of life, mitigated symptoms and reduced both disability and mortality rates.

“As important as these therapies are, it is just as important that public officials take special care to ensure the safety of the patients who rely upon them…That is why we strongly urge adoption by the Senate of all patient protections contained in House Bill 1422. This measure will bring Virginia state law in line with advances in modern medicine while also providing the essential safeguards that will ensure that Virginia patients receive exactly the medicines they need and will not be subject to potentially harmful substitutions.”

Read the full letter here.


Advisory Board Members Weigh In

Dr. Harry Gewanter, a pediatric rheumatologist in Richmond and member of the ASBM Advisory Board, penned an Op-Ed for the Richmond Times-Dispatch and also wrote a letter to the editor to the Lynchburg News & Advance in response to VA legislation.

In his Op-Ed “Legislation would protect patients taking complex meds,” he said:

“Specifically, the legislation would permit pharmacists to dispense a biosimilar that has been licensed by the FDA as substitutable with a prescribed biologic product, unless the patient’s doctor indicates otherwise or the patient asks for the brand-name version. It also would require the pharmacist to provide timely notification of this substitution to the doctor in a manner that is not a burden upon the pharmacist…Why is this important? We already know that each person responds differently to any medication, chemical or biologic. Generic chemical medications are easier to manufacture with less variability between them. However, since biologics and biosimilars are created using living cells, using current technology they can be closely approximated, but not necessarily exactly replicated. This creates a much greater chance of differences during the creation of a biologic and its biosimilar imitations. Any slight alteration in the production process could influence the effectiveness of a biologic and create unknown or negative consequences.”

Read the Op-Ed here.

In his letter “Healing or dollars?” Dr. Gewanter points out that the Senate version of the VA bill:

“Eliminates this critical communication between pharmacists, patients and their physicians in 2015. If I do not know that my patient with juvenile arthritis is not doing well because a substitution of a medication has occurred, I may change treatments or submit this child to many other evaluations that are not necessary. Chronic illness care requires close and ongoing communication between all members of a patient’s health care team. As a physician and a parent, I believe this communication and the resultant patient safety is far more important than any theoretical monetary savings [the Senate bill] touts.”

Read the full letter to the editor here.


Indiana and North Dakota

We have also been following the bills in both Indiana and North Dakota and have sent in letters of support, highlighting the importance of allowing substitution as long as the biosimilar has been determined by the FDA to be interchangeable with the prescribed product for the specified indicated use and that the physician is notified.

Read the letters here.


Upcoming Conference

Dr. Dolinar will be presenting at CBI’s 8th Biosimilars Summit, on the “Assess Global Quality Standards for Biologics in Regulated and Unregulated Markets” panel on March 5 in Washington, D.C.

Read more on the conference here.



ASBM One Pager on Automatic Substitution

February 19, 2013

Automatic Substitution One PagerAutomatic Substitution One Pager


Dr. Gewanter Featured in Lynchburg News & Advance

February 15, 2013

A letter to the editor on the Virginia Biosimilars bill by ASBM Advisory Board member, Dr. Harry Gewanter, ran in the Lynchburg News & Advance.

Healing or dollars?

As one of the few pediatric rheumatologists in Virginia, I am extremely disappointed by the misinformation presented in The News & Advance’s Feb. 2 article, “Newman’s Senate bill addresses drug prices.” There is no mention of prices or pricing within either Sen. Steve Newman’s bill or the similar House bill, and the implication that there will be cost savings is pure speculation.

Biologic medications have proven to be miracle agents for thousands of Virginians with a wide variety of chronic illnesses, including arthritis, multiple sclerosis and many cancers. Any agent that can produce such significant benefits carry with it significant potential risks.

Virginia has a responsibility to ensure that any biologic substitution not only follows the FDA rules on interchangeability, but also that the process is transparent. We already have had experiences with chemical generic medications producing differing positive and negative effects in patients and those medications are incredibly easier to produce than any biologic agent.

As their name implies, “biosimilar” medications are not the same as the original “biologic” agent. It is critically important that patients and prescribing physicians know which agent is being dispensed by the pharmacist so that appropriate medical decisions can be made if there are adverse effects or a change in efficacy.

Sen. Newman’s bill eliminates this critical communication between pharmacists, patients and their physicians in 2015. If I do not know that my patient with juvenile arthritis is not doing well because a substitution of a medication has occurred, I may change treatments or submit this child to many other evaluations that are not necessary.

Chronic illness care requires close and ongoing communication between all members of a patient’s health care team. As a physician and a parent, I believe this communication and the resultant patient safety is far more important than any theoretical monetary savings Sen. Newman touts.

DR. HARRY L. GEWANTER
Richmond


January 2013 Newsletter

January 27, 2013

ASBM Shows Support for VA Legislation on Interchangeability

The Virginia House of Delegates introduced legislation on interchangeable biosimilars and held a hearing on the bill, H.B.1422, on January 15. To show support of the bill, Dr. Dolinar, the Colon Cancer Alliance, Global Healthy Living Foundation and the Kidney Cancer Association sent letters to members of the House Committee on Health, Welfare and Institutions.

We expect to see legislation on substitution in many other states and will monitor and engage accordingly.

Read more here.


Inside Health Policy Article on VA Legislation

Inside Health Policy highlighted the ASBM letters to VA delegates in the article “VA Bill Raising Bar For Biosimilars Substitution Falls In Line With BIO’s Principles.” The article said:

“The alliance principles call for physician authority to prevent the substitution, a requirement that physicians be notified of the product’s manufacturer and a notification process that doesn’t impose a burden on the pharmacist. The group also noted to Virginia lawmakers that ASBM and the Virginia Biotechnology Association hosted a September 2011 biosimilar education forum in Richmond that included local patient advocates and physicians.”

Read the article here.


ASBM Hosts Biosimilars Forum at University of Rhode Island, College of Pharmacy

On December 13, ASBM hosted a Biosimilars Education Forum at the University of Rhode Island, College of Pharmacy in Kingston, RI, after ASBM members took a tour of a facility that manufactures biologic medicines. The forum brought together policymakers, patient advocates, physicians, pharmacists and other stakeholders who discussed the importance of patient safety as biosimilars are introduced in the United States.

Participants included:
Dr. Richard Dolinar, ASBM Chairman
Andrew Spiegel, CEO of the Colon Cancer Alliance
Ronald Jordan, Dean of the University of Rhode Island – College of Pharmacy
Bruce Babbitt, PAREXEL Consulting
Doug Kraus, patient advocate

Read more about the event here.


Members Participate in CO BioScience Forum

A week before the RI event on December 6, several ASBM members took a tour of a biologic manufacturing facility in Longmont, CO and then attended a biosimilars forum hosted by Colorado BioScience, BIO and ASBM.

Dr. Dolinar participated in a panel discussion with Andrew Spiegel, CEO of the Colon Cancer Alliance, Philip Schneider, Associate Dean of the College of Pharmacy Administration at the University of Arizona and Fritz Bittenbender, Vice President of Alliance Development and State Government Affairs at BIO.

Read more here.


Food and Drug Law Institute Publishes ASBM White Paper

The Food and Drug Law Institute (FDLI) Policy Forum published a white paper on biosimilar naming authored by ASBM.

In the paper, ASBM made four policy recommendations:

All biologics should receive distinct non-proprietary names.
United States Pharmacopeia (USP) should work with FDA to adapt the product monograph system to accommodate the unique attributes of structurally-related, but distinct, biologic medicines.
The non-proprietary name of a reference product and product/s biosimilar to it should have a common, shared root but have distinct and differentiating suffixes.
Products designated interchangeable should have a distinct name from the reference product for which they are considered interchangeable to facilitate accurate attribution of adverse events.

Read the paper here.

Biosimilar News featured an article on the paper, as did Generics and Biosimilars Initiative (GaBI).


FDA Law Blog Post on White Paper

FDA Law discussed the ASBM white paper in the blog post “ASBM Says Distinct USAN Names for Biosimilars are Needed.” The blog points to ASBM’s call for:

“The need for clear, defined naming considerations and a system to implement an effective tracking and tracing of all biologics – not just biosimilars – stems from the potential of these products to be unexpectedly altered by the manufacturing process, handling, etc., in a manner that could cause unintended harm to patients. Whether the products that FDA approves will have the same name or a different name than the originator biologic will determine how well products can be traced back to a patient who has an adverse reaction.”

Read the blog here.


Alliance for Patient Access Releases White Paper

AfPA National Physicians Biologics Working Group released a white paper entitled, “Biologics: Can Patients Get What the Doctor Orders?” that examines barriers to therapeutic access resulting from current healthcare benefits design. This is their second paper in a series designed as an educational resource to inform the public and policymakers about the benefits of biologics, what makes them unique and distinct from conventional pharmaceuticals, and why these distinctions matter.

Read the paper here.



Dr. Gewanter Op-Ed in Richmond Times-Dispatch

January 24, 2013

Advisory Board member Dr. Harry Gewanter penned an Op-Ed for the Richmond Times-Dispatch on legislation around biosimilar substitution. Read “Legislation would protect patients taking complex meds.”


ASBM Included in IHP Article: Stakeholders Gear Up For Biosimilar Substitution Battle In 2013

January 9, 2013

Inside Health Policy’s “Stakeholders Gear Up For Biosimilar Substitution Battle In 2013” article includes mentions of ASBM and quotes Dr. Dolinar:

“Still, groups like the Alliance for Safe Biologic Medicines, which has a broad membership of patient groups and innovator biologic companies, are pressing for a unique naming scheme, saying it is pertinent for ensuring safety and tracking adverse events.

“‘[I]t is important to understand that biosimilar and interchangeable biological products will be only similar to, but not the same as, an original reference product. From a patient and provider perspective, it would be inappropriate, unsafe, and misleading to allow biosimilar products to use the same name for biological products that are not exactly the same,’ Richard Dolinar, the group’s chairman wrote in a recent Food and Drug Law Institute Policy Forum. Tracking products by National Drug Codes, as some pharmacy groups have suggested, has limitations because the numbers are not uniformly used in medical billing, and doctors and patients associate products by name, not a number, the group says.”

Read the full Inside Health Policy article here.


ASBM Included in IHP Article: Stakeholders Gear Up For Biosimilar Substitution Battle In 2013

January 9, 2013

Inside Health Policy’s “Stakeholders Gear Up For Biosimilar Substitution Battle In 2013” article includes mentions of ASBM and quotes Dr. Dolinar:

“Still, groups like the Alliance for Safe Biologic Medicines, which has a broad membership of patient groups and innovator biologic companies, are pressing for a unique naming scheme, saying it is pertinent for ensuring safety and tracking adverse events.

“‘[I]t is important to understand that biosimilar and interchangeable biological products will be only similar to, but not the same as, an original reference product. From a patient and provider perspective, it would be inappropriate, unsafe, and misleading to allow biosimilar products to use the same name for biological products that are not exactly the same,’ Richard Dolinar, the group’s chairman wrote in a recent Food and Drug Law Institute Policy Forum. Tracking products by National Drug Codes, as some pharmacy groups have suggested, has limitations because the numbers are not uniformly used in medical billing, and doctors and patients associate products by name, not a number, the group says.”

Read the full Inside Health Policy article here.


ASBM Forum in Rhode Island

December 21, 2012

On December 13th, ASBM members were invited to take a tour of a biologics manufacturing facility in Rhode Island to learn about the intricacies and complex processes involved with making biologic medicines.

Continue reading…


ASBM Forum in Rhode Island

December 21, 2012

On December 13th, ASBM members were invited to take a tour of a biologics manufacturing facility in Rhode Island to learn about the intricacies and complex processes involved with making biologic medicines.

Continue reading…


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