Importance of Excellence in Scientific and regulatory Communication

By: Lisa Peluso, Director, Coaching and Client Engagement, NDA Group/PharmApprove

In this white paper, PharmApprove’s Lisa Peluso, discusses how  excellent communications are  the backbone of streamlined, efficient programs achieving approval and market access.


The ever-changing complexities of the regulatory world demand excellence in communicating science, data, development program goals and intentions, as well as how foreseen risks are being managed.

These complexities also mean that drug development companies must engage candidly with regulators and lead the scientific conversation with clarity and flexibility, yet be poised to negotiate their position.

While we work with global companies to strategize and execute successful engagements with regulators  at critical junctures such as Oral Explanations and FDA Advisory Committee meetings, excellent communications are  the backbone of streamlined, efficient programs achieving approval and market access.

A number of potential pitfalls await companies with even the most solid science and robust datasets

To avoid costly delays along the path to regulatory approval and commercialization, companies need to:

1.  Communicate internally

To ensure alignment of clinical goals and regulatory approvability with the reality of a product’s potential market value and accessibility the company needs efficient internal communication. The danger lies in a narrow focus on just regulatory considerations: A product may be effective but if there is no place in the market or doubtful economic defense of pricing, the company is wasting time and money. Development plans must be based on all considerations, requiring careful coordination and collaboration across all divisions.

2. Communicate with regulators

Unfortunately, too many companies engage with regulators much too late, or not at all, or lack the candor and skill needed to usher a product  smoothly  through the approval process. Excellent communication means asking the right questions, clarifying any questions from the regulators and responding in a collaborative and transparent manner. Remember that specific expertise in your company’s product is rare, hence it’s critical to clearly shape the story of not just the data but also the program, goals and risk management commitments.

3. Communicate globally

Just as internal divisions must be aligned, regional requirements vary in Europe and across the globe. Companies risk costly mistakes and a need to “redo” when they don’t share knowledge freely internally.

This is particularly important for US/EU programs. Learnings from multiple regulatory authorities or groups of payers must be transferred so there is no duplication of effort – or waste of time – on the other side  of the pond. Constructive interactions speed efficiency.

4. Engage physicians, patients and advocacy groups

Get the community involved early, including doctors and potential study sites as well as patients and advocacy groups. Communicating with these stakeholders also demands delivering the messages behind the data in a concise and compelling manner to a wide variety of physicians, KOLs and other influencers.

With such deep knowledge of one’s product, it’s a daunting challenge to distill the information, refine the message and keep it brief and clear for the audience.

5.  Negotiate with payers

Companies put enormous effort into developing slide  decks, internal FAQs and value proposition documents.  This plethora of planning and information is to no avail if the company does a poor job of interacting with payers. In addition to understanding the audience around the table and their goals, the company must respond deftly to questions, defend the data, and communicate persuasively. Every interaction is an opportunity and certainly, when it’s time to negotiate pricing, excellence in communications is critical.

How we can help?

NDA Group supports life science companies all over the world with the single aim to streamline the global development and commercialization process in order to accelerate patient  access to important medical therapies.

Whatever regulatory hurdle you’re facing — a Type B meeting, a document submission, or a SAG hearing — our industry-leading professionals will help you strategize and execute successful engagements with any global authority. We’ll help you optimize every regulatory interaction and shape the dialogue about your product to create a more direct path to approval.

In the US, our Principals and Communications Strategists are particularly experienced at preparing for FDA Advisory  Committee meetings, in addition to pre-IND,  end of phase 2, pre-NDA/BLA, PMA, and mid- and late-cycle review meetings. In Europe, we assist with Scientific Advice Group meetings, Oral Explanations, PRAC meetings and preparation for intense pricing negotiations. We offer our clients an unparalleled breadth of global experience and expertise to drive efficient product development and health authority interactions across the US and Europe.

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Meet the NDA Group at DIA

Meet the NDA Group at DIA in San Diego 23-27 June

Optimising the development of innovative medicines

NDA is a world leading drug development consultancy helping clients achieve regulatory and market access success in the US and EU.

Our goal is to streamline the global development and commercialisation process in order to accelerate patient access to important medical therapies.

Over the last 5 years, NDA Group has supported the approval of over 40% of new medicinal products in the EU and among our FDA advisory committee clients 80% have achieved product approval. We work across a range of disease areas including oncology, hematology, infectious disease, metabolic and immunologic disorders and CNS and have supported the development of over 50 rare disease programs.


PRESENTATIONS BY NDA’S EXPERTS

Lisa Peluso
Director, Coaching and Client Engagement
Kaia Agarwal
Strategic Advisor and Global Regulatory Affairs Consultant

(Pre-Conference Short Course)
Short Course 3 | Sun, 23rd June- 09:00-12:30
Preparing for a US FDA Advisory Committee Meeting

More information


Lisa Peluso
Director, Coaching and Client Engagement
Steffen Thirstrup
Director NDA Advisory Board

(Pre-Conference Short Course)
Short Course 3 | Sun, 23rd – 13:30-17:00
European Regulatory Meetings: How Best to Prepare and Perform

More Information


Brian Edwards
Principal Consultant, Pharmacovigilance & Drug Safety

Session #106 | Mon, 24th June- 11:00-12:00
Moving forward in EU Pharmacovigilance

Session #155 | Mon, 24th June- 15:30-16:30
Incorporating Systems: Theory and Human factors into the Investigations of Serious Harm in Clinical Research

Session #403 | Thur, 27th June- 09:00-10-15
Successes and Challenges in Pharmacovigilance for Biologics and Biosimilars


NDA supported over 40% of the new medicinal products that were approved in the EU during the last five years.

Do you want your product to reach the world’s two largest markets with minimum delay?

Arrange to meet us at the DIA USA now.

GET IN TOUCH

info@ndareg.com

info@Pharmapprove.com

Abraham Lincoln’s Jury Lawyering: Lessons for Sponsors Before FDA Advisory Committees

By John Ellis, Communications Coach

Recently, while reading “Lincoln’s Last Trial” by Dan Abrams and David Fisher, I was struck by strong parallels between Lincoln’s famously successful jury lawyering and the ways successful sponsors communicate with panelists at FDA advisory committee meetings:

  • First, Lincoln kept a laser-like focus on those one or two issues most likely to determine the jurors’ votes.
  • Second, he did everything in his power to keep the jurors’ minds and hearts open; he built a relationship with them as colleagues in a common enterprise; he didn’t pick needless fights; he treated everyone—from witnesses to prosecutors to judges—with respect.
  • Third, he marshaled the facts into a clear and compact narrative that embodied his interpretation of those facts in a way the jurors could easily follow and remember.

As you read the short excerpts from the book in the bullets below—with some coach’s comments from me in sub-bullets—please note that while some of the aspects of what Lincoln did in the courtroom and what a sponsor needs to do at White Oak are not completely interchangeable, their similarity in spirit is striking.

  • [Just before his summation]: “Abraham Lincoln spent several seconds straightening the papers on the table in front of him, took a moment to fix his stock [tie], then stood…and faced the jury. And smiled…When [he] approached the jury box and leaned over close, he was just talking to some friends.”
    • Lincoln gave the jury a moment so they could give him their full attention. For any of us to have a chance of persuading people, they must first be giving us their full attention. 
    • Also, it’s remarkable how quickly all of us can forge feelings of friendly respect with others when we’re bound together in a common purpose.
  • “…weaving facts and emotions into a plausible tale….”
    • When creating a persuasive argument, facts and emotions are not either/or. The trick, as Aristotle well knew, is to make facts and emotions reinforce each other.
  • “…people simply liked him.”
    • A gift? Yes. But it was also a reflection of the attitude he radiated.
  • “He showed jurors a different way of looking at the same facts….”
    • This, of course, is the nub of it.
  • “[M]ost cases, he knew, turned on one significant point. He willingly conceded those points he couldn’t win or that made little difference, building up goodwill with the judge and jury that might pay off when he pounced on the salient issue.”
    • What to say when becomes much clearer when you’re focused on the verdict or the vote.
  • [Lincoln once gave this advice to his partner, Herndon:] ‘Billy, don’t shoot too high; aim lower and the common people will understand you. They are the ones you want to reach. The educated and refined people will understand you, anyway. If you aim too high, your idea will go over the head of the masses and hit only those who need no hitting.’
    • While there aren’t, in Lincoln’s sense, ‘common people’ among FDA staffers and panelists, there are always salient differences in educational and professional experiences whenever an Advisory Committee is convened. So, speak in a way that includes everyone–clear, concise, and compelling, using easily grasped comparisons for highly technical points.
  • “Lincoln rarely attacked a witness, believing the damage done to his relationship with the jury by that action might be more harmful than any gain from disputing facts. These were all friends and neighbors, good people, and it was taken for granted they were telling the truth. But even good people tended to remember things different, ‘specially when there was a whole hullabaloo going on around them.’”
    • For “friends and neighbors,” read the panelists and FDA staffers (whether physicians, statisticians, etc.). For “telling the truth,” read interpreting and conveying the data the way they understand it. For ‘hullabaloo,’ read a highly complex data set.
  • “…in his summation, Lincoln’s real focus was on those few issues that made all the difference in the outcome…Slowly he wound his way into the core of the case, moving step-by-step away from the facts into his interpretation of them.”
    •  In a similar way, no therapy, or its clinical development program, is perfect. You keep minds open by acknowledging that. At the same time, you know that what influences votes is not so much the facts as what committee members think the facts mean.
  • “[As the summation proceeded] his voice grew louder and was colored by emotion. His words cut through the calm he had created. Lincoln had laid the groundwork, he had done the legal job, now he was going for the heart….[Yet] this wasn’t a performance; this wasn’t an attempt to manipulate emotions. Lincoln meant every word he said.”
    • May it be so for all of us.

Europe vs USA: new drug product approvals in 2018

By Anna Leitgeb, Consultant, NDA GroupB

2018 was another exceptional year for the life science industry with a total of 103 new therapeutic drugs (NTDs) approved in EU and US.

Every year NDA reviews the NTD approvals in EU and US from previous year to spot trends and assess the year that has passed. The data is taken from the FDA and EMA websites on the new approved products during 2018 (i). In this review we include NTD product approvals with new active substance (chemical, biological, biotechnology or radiopharmaceutical substance), new biological entity, new drug combinations, biosimilars, new active ingredients and vaccines, but excluded generic and duplicate applications.

The following summary provides an overview of the key findings and an analysis of what the data means for the industry. The data is visually represented in an infographic below.

This year the regulators have ruled positively on some high-profile and high-stakes project. Important new drugs for indications with unmet medical need, for neglected diseases or where exciting new technologies are explored have been approved within the area of neurology (Aimovig, Emgality, Ajovy), infectious disease (Xofluza, Trogarzo),and women health (Orilissa). Important orphan drugs were also approved within neurology (Namuscla, Epidiolex, Onpattro, Tegsedi) and hematology (Crysvita) and advancements within precision medicine have been achieved within oncology (Vitrakvi).

It’s interesting to note that the number of NTD approvals in the two markets has not changed markedly from 2017 to 2018. However, the landscape of approvals in the different markets, indications, and company features has moved somewhat over the last 12 months. Out of the 103 approvals 45 were solely FDA-approved and 9 approved only in EU, indicating an increase in dual market approvals compared to 2017.

There was a rise in the number of NTDs approved for both the US and EU markets from 36 in 2017 to 49 in 2018. This indicates that the joint application strategy was more popular than previous years.

Approvals for oncology and infectious disease products increased in 2018 whilst the number of approvals within hematology, neurology and immunology/rheumatology has decreased during the same time frame.

SUCCESSFUL EXPLORATION OF NOVEL DRUGS

2018 was a significant year for approvals of novel drugs, i.e. treatments based on new active substances. Out of the 103 new drugs, 89 were based on new active substances. This number has increased since the year before when 56 approvals were for novel drugs. This high number of green lights from the agencies follows a few successful years for drug developers. The agencies involvement and support during drug development has increased which also contributes to improvements to strategy rather than to only secure compliance with existing regulations.

After decades of work on migraine prevention drugs finally an antibody-based approach has been approved. Aimovig (Amgen and Novartis) was first approved, and short thereafter came Emgality (Eli Lilly) and Ajovy (Teva). These are self-injected molecules and they all belong to a new class of drugs called calcitonin gene-related peptide receptor (CGRP-R) antagonists. They offer patients treatments that can reduce the number of days with migraine.

Other standouts include new drugs to treat infectious diseases. Xofluza (Roche), a polymerase acidic endonuclease inhibitor, is the first novel flu drug to reach the market in 20 years. This antiviral flu drug is the first that inhibit virus replication. Trogarzo(TaiMed) is a first in class antiretroviral monoclonal antibody approved for the treatment of HIV-1 infection in patients who are multidrug resistant to available treatments. Trogarzo may be able to improve patients’ outcomes when other options have run out.

Women health is historically a neglected field and has been a highly underserved market. However the field has received more attention in recent years. This year, the first new pill, Orilissa (Abbvie) for treatment of moderate to severe pain associated with endometriosis was approved. Orilissa lowers the amounts of estrogens which are expected to decrease the moderate and severe symptoms of endometriosis. It was more than 10 years since the last treatment for endometriosis was approved and there is still a lack of treatment options for this potentially debilitating condition.

A NOBEL PRIZE AND ITS RESULT IN A NOVEL DRUG

One of the highlights of the year was the approval of the first drug that acts by RNA interference (RNAi), Onpattro (Alnylam). The research that lead to the 2006 Nobel Prize in Physiology or Medicine on RNAi was published in 1998 (ii) and has now, 20 years later, successfully been translated into a novel therapy for treatment of a neurology disorder. The transfer of RNAi technology into drug development has been a scientific triumph with great potential to generate treatments for many more indications in the future. Onpattro treat nerve damage caused by hereditary transthyretin (hATTR) amyloidosis and was designated an ‘orphan medicine’.

Last year Tegsedi (Akcea and Ionis), also an antisense oligonucleotide therapy developed for the same disorder, similarly won approvals by FDA and EMA. And more will come, at least six other RNAi therapeutics are in phase III clinical trials for other indications (iii).

SMES AND APPROVED ORPHAN DRUG DESIGNATIONS

In 2018, small and medium sized enterprises (SMEs) contributed with 56% of the approved NTD. We commented on the trend that more and more SMEs are able to take their products through to regulatory approval by themselves last year, and 2018’s figures only strengthen this trend (iv). One driver for this development is the great expansion of the orphan field that provides opportunities to run much smaller late stage trials, thereby limiting the cost of development in a way that suits SMEs. The orphan market accelerated significantly during this year as compared to the previous year.

In 2018 the number of approved new drugs designated orphan status almost doubled in both EU and US, as compared to 2017. Twenty and 42 new orphan drugs were approved in EU and US, respectively, during 2018 (in 2017 12 in EU and 24 in US). Interestingly, nearly 70% of all approved orphan drugs were sponsored by SMEs. This marks great progress of options for patients living with rare diseases, and proves that the drug development companies and the agencies have continued to speed up promising drugs to markets even if the patient groups are limited.

Some of the outstanding contributions to significantly benefit patients living with rare diseases include Epidiolex (GW Research) which is approved by FDA for seizures associated with two rare and severe forms of epilepsy, Lennox-Gastaut syndrome and Dravet syndrome. Its attention is also due to that it is the first FDA-approved drug that contains a purified drug substance derived from Cannabis sativa plant (marijuana). Another interesting new therapy is Namuscla (Lupin).

In EU, Namuscla is the first approved treatment for symptomatic treatment of myotonia in adult patients with non-dystrophic myotonic disorders, a group of inherited muscle disorders where muscles are slow to relax after contraction. These disorders are chronic life-long debilitating conditions characterized by long lasting pain.

Crysvita (Ultragenyx) is an additional exciting new treatment approved in US for patients with X-linked hypophosphatemia (XLH), a rare, inherited form of rickets. Crysvita is the first and only therapy that addresses the underlying cause of X-linked hypophosphatemia.

IMPROVEMENTS WITHIN PRECISION MEDICINE

The ideas of precision medicine are not new, but recent advances in science and technology have helped speed up the pace of this area of research, and major efforts are being invested in the fields.

A notable new oncology drug is Vitrakvi (Loxo and Bayer), a kinase inhibitor for solid tumors in various sites of the body. Vitrakvi became the second cancer therapy to be approved by FDA treating adult and pediatric patients whose cancers have a specific genetic feature, rather than a specific location of the tumor. This approval is a continuation of the new paradigm in the development of cancer drugs that are “tissue agnostic” set by Merck’s Keytruda in 2017.

EXPEDITED APPROVAL OF NOVEL DRUGS

It is obvious that the agencies are working hard to increase the patient access of important medicines where there is huge unmet medical need. In US as many as 53 NTDs were approved through fast track, breakthrough, accelerated approval or priority review approval. In EU only two expedited approvals of NTDs were granted by conditional approval last year.

The trend from 2017 remains during 2018 with more expedited approvals in US than in EU. This might be because of the eligibility to use the expedited pathways is much more limiting in the EU than in the US or that the alternatives in EU for expedited approvals are not as well established with the industry as they are in the US.

NDA SUPPORTED OVER 40% OF THE APPROVALS IN THE EU

NDA had a strong presence in the EU regulatory arena and supported over 40% of the new products approved from 2013 to 2018.

To read the statistics of new drug product approvals from last year click here.


References

i. The data was gathered from the EMA and FDA official websites, as reported on the FDA and the EMA official websites on January 2019.
ii. Fire A., et al. Potent and specific genetic interference by double-stranded RNA in Caenorhabditis elegans. Nature 1998; 391:806-811.
iii. Mullard A. FDA approves landmark RNAi drug, Nature Reviews Drug Discovery 2018;17:613
iv. https://www.ndareg.com/europe-vs-usa-new-drug-product-approvals-in-2017/

Free Webinar – Be Heard: The Patient Voice at FDA Advisory Committee Meetings







In recent years, the global trend in drug development has included more active and influential patient activity. Patient and caregiver voices have become a key part of the regulatory process, and FDA Advisory Committee Meetings are no exception. At the Open Public Hearing (OPH) part of these meetings, patients have an opportunity to educate the committee and the Agency, impact regulatory decision-making and even help guide the future of drug development. This is particularly important for rare disorders. 

Join us on September 27th, 15:00 UK / 16:00 CEST / 10:00 EDT, for this engaging webinar where NDAs Lisa Peluso, Director of Coaching and Client Engagement, will cover:

• Quick guide to FDA Advisory Committees
• The Open Public Hearing and what it means
• Registering, Preparing, Delivering
• Tips on making sure your voice is heard

The webinar will be followed by a Q&A session for you to get direct feedback on key areas of uncertainty.

Click here to book your place today.

Lisa Peluso is Director of Coaching and Client Engagement at PharmApprove/NDA, where she helps development teams, doctors, patients and advocates to create and deliver clear, consistent, and convincing messages to regulators in the US and Europe. Lisa has coached hundreds of individuals and provided presentation/Q&A training and workshops to teams in pharma and biotech, and has helped over 45 clinical development teams prepare to present at FDA Advisory Committee meetings and EMA Oral Explanations. Her experience and familiarity with high-stakes regulatory meetings allows her to get to the heart of the challenge, and she excels at giving presenters and responders clear and actionable feedback, to instill confidence and help them communicate with clarity and impact. Prior to joining PharmApprove, Lisa worked at Kyowa Pharmaceuticals, where she supported both commercial and clinical teams and served as the principal liaison between the Tokyo, UK and US offices. Lisa spent 12 years in Japan, where she worked in communications in the legal, financial and hospitality industries.

 

 


 

Professor Carole Longson to join NDA as Scientific Adviser







Carole Longson MBE, former Executive Director and Board member at the National Institute for Health and Care Excellence (NICE), has joined the NDA Advisory Board. Carole will act as an adviser within NDA on matters relating to drug approval, scientific advice and Health Technology Assessments, areas in which she has had great impact in her previous role.


Carole brings tremendous research, academic and pharmaceutical industry experience to the role, including seven years as a Research Lead at GlaxoSmithKline R&D.

She has extensive expertise of directing multidisciplinary life sciences research programmes, managing large scientific departments and collaborating on multinational research grants.

Carole was a past member of the Scientific Advisory Committee for Innovative Medicines Initiative (IMI), the leading pan-European public- private partnership which funds health research and innovation. She also holds non-Executive Director and advisory roles in other scientific organisations in the UK and abroad. These positions give her a unique and extensive perspective on the changing face of industry.

Carole has unparalleled insight into the fast evolving medicines pipeline having spent the past 18 years at NICE where she has pioneered and led the organisation’s technology appraisal programme. Carole is highly respected as a leader in HTA & Market Access, both in the UK and internationally and was formerly President of Health Technology Assessment International.

Throughout her career and role at NICE, Carole has gained valuable understanding of how the public and private sector must continue to collaborate to meet the shared aims of ensuring medical innovation benefits patients in the UK.

Johan Strömquist, CEO NDA Group, commented on the appointment:
“I am delighted to see Carole join us. Not only will she bring a wealth of knowledge and experience to NDA that fits intimately with our strategic direction, her reputation in the industry and among her former Agency peers, also stems from her positive and collaborative personality.”

Werner Van den Eynde, Vice President NDA Advisory Services, commented:
“This appointment is a major step in our continuing aim to broaden our reach and expand HTA and market aspects into our drug development service offerings. It is also a testament to NDAs reputation amongst regulators and HTA bodies – NDA remains the undisputed prime destination for the greatest contributors to our regulatory and assessment systems.”


NDA media contact: anna.perrin@ndareg.com

About NDA
NDA is an independent consulting group with offices in Stockholm, London, Zürich, Munich, Paris, Princeton, Boston and San Francisco. Its mission is to ensure that good medicines reach patients without unnecessary delay. It accomplishes this by providing the pharmaceutical industry with a comprehensive range of professional drug development services focusing on regulatory affairs, health technology assessment, pharmacovigilance and quality assurance. NDA’s team of more than 150 full time professionals is comprised of more than 25% ex-regulators from major EU Agencies, and a specialist Advisory Board consisting of Europe’s leading regulatory and HTA experts. The NDA Advisory Board provides scientific advice to pharmaceutical companies supporting them in gaining fast and constructive assessment of applications from regulatory agencies and HTA bodies. www.ndareg.com

Dr. Thomas Lönngren to Present at the Chief Medical Officer Summit, May 7th







Dr. Thomas Lönngren, Strategic Advisor to NDA Group and former Executive Director of the European Medicines Agency (EMA), has been invited to present at the Chief Medical Officer Summit, Omni Parker House, Boston, MA on 7th May. 

Thomas will present along with Jeffrey Sherman, CMO, EVP R&D, Horizon Pharmaceuticals, in the session ‘Taking a Strategy Approach to Global Regulatory and Market Access Challenges’, were they will discuss:

  • Is a global regulatory and market access strategy the way to go?
  • Why isn’t EMA approval the same as market access in Europe?
  • What is the difference between EMA and FDA in regulating and approving medicines?
  • When and how to generate evidence that will satisfy regulators and payers
  • What is the best strategy to interact with regulators and payers?
  • Early access schemes in EU and how to qualify
  • How will trends like Real World Evidence influence regulatory decision making?
  • Brexit and its consequences for the EU regulatory system and how will it affect pharmaceutical companies

As well as presenting at the event, NDA Group is ‘Associate Sponsor’ of the CMO Summits, demonstrating its commitment and support towards the CMO community.

Please come by booth #2 and meet us;

  • Dr. Thomas Lönngren, Strategic Advisor to NDA Group and former Executive Director of the EMA
  • Laurie Smaldone-Alsup, MD, COO/CSO
  • Barbara Clendenen, Director, Business Development

The CMO conference is an annual gathering for physicians and scientists in biotech to exchange best practices in the advancement of drug development and business management. Although the program is primarily designed for CMOs of emerging biotech companies, CMOs of large pharma and other R&D decision-makers will also benefit.

To find out more about the event click here.


Meet NDA Group at PEGS Boston







NDA Group will be attending PEGS Boston, that takes place in Seaport World Trade Center, Boston April 30 – May 4, 2018

NDA supported over 40% of the new medicinal products that were approved in the EU during 2013 -2017. In 2016 NDA acquired PharmApprove, the market leader in managing critical FDA interactions to help us achieve the same results in the US.

If you are planning to attend this year’s PEGS, we would really like to meet up with you. We will have a few of our experts available at the event at booth 437:

  • Dr Niamh Kinsella, Biologics Expert
  • Dr Jenny Sims, Non Clinical Expert
  • Dr Josefin-Beate Holz, Clinical Strategy Expert

If you would like to arrange a meeting, please contact Niamh Kinsella, who will be happy to assist, niamh.kinsella@ndareg.com

Presentations

Three of our experts will present at the event:

 

Jenny Sims: Monday 30th April 12.20 pm, Immunogenicity Case Studies and Clinical Management Track.

Title: Early Development Strategy for Bacterial- or Viral-Vectored Gene Therapies: 2 Case Studies

Josefin-Beate Holz
Monday 30th April and Tuesday 1st May, Poster Session A
Developing an Integrated Summary of Immunogenicity (ISI) to Effectively Manage Regulatory Risks in Product Development

Niamh Kinsella
Wednesday 2nd May and Thursday 3rd May, Poster Session B
Maximising Value in Early Development

 

 

Click here to find out more about the event.

We look forward to hearing back from you about a meeting and to seeing you at the event!

Europe vs USA: new drug product approvals in 2017







By Terese Johansson PhD, Consultant, NDA Group

It’s been an exciting year for new drug approvals! Many of the new drugs approved during the year address significant and meaningful needs or give additional therapeutic choices for patients and physicians. In the US we have seen a ground breaking approval in oncology that changes the way we look at and relate to indications; in addition the first digital pill has seen the light of day.

The following summary provides an overview of the key findings and an analysis of what the data means for the industry. The data is visually represented in an infographic below.

 

More approvals and more novel drugs

Last year there were a total of 103 new drug approvals granted in US and EU together that meet our selection criteria (i). Of these new products, 15 were approved only in the EU, 52 only in the US, and 36 were granted approval in both regions. It’s a large improvement compared to last year’s figures that showed 19 only in EU, 19 only in US and 36 in both regions, with a total 74 new approvals. In addition, 56 of the new approvals in 2017 were classified as novel drugs (ii). Our data show that the trend to apply for approval in the US prior to registration in the EU is, as usual, still a regular practice.

In the US expedited drug development and nonstandard review approval pathways are the new normal. In 2017 special approval and designation procedures like Fast Track, Breakthrough (BTD), Accelerated Approval and Priority Review was used for 37 of the new approvals, in many cases more than one of these approval pathway designations was granted per product. FDA has a higher rate of granting special approval status compared to EMA, 37 vs 10. One can only conclude that the policy groundwork laid by FDA in the past years to speed up drug approvals with the introduction of shorter nonstandard approval pathways has a clear overall effect on shortening the mean approval timelines.

Ground Breaking Oncology approval and the rise of CAR-T therapies

It’s been an exciting year for oncology with a total of 27 new approvals, so far 12 of these are only approved in the US and one of them were rejected by the EMA in 2008 (Mylotarg, gemtuzumab ozogamicin), however EMA now granted approval during 2018. A ground breaking approval was granted in the US where FDA (CDER) approved Keytruda (pembrolizumab) by Merck & Co Inc as the first drug ever where a biomarker (PD-1 (programmed death receptor-1) defines the indication (iii). The scientific rationale underpinning the Keytruda approval has effectively created a single therapeutic approach for patients with different tumour types, allowing extrapolation of the observed treatment effect to diverse tumours. The approval is likely to have implications for how the drug development process is pursued in the future, in oncology, but most likely also for other therapeutic areas as science progress.

Furthermore, also in oncology, the two first chimeric antigen receptor T-cell (CAR-T) therapies have been approved by FDAs CBER unit, its Novartis Kymriah (tisagenlecleucel, for the treatment of B-cell acute lymphoblastic leukemia) and Gilead’s Yescarta (axicabtagene ciloleucel, for the treatment of relapsed or refractory large B-cell lymphoma). Both drugs are currently under assessment in EU with Kymriah being granted an accelerated assessment by CHMP.

The Approval of a Pill with a Digital Sensor

Other noteworthy approvals from the US includes Abilify MyCite, the first pill with a sensor that digitally tracks if patients have ingested their medication (aripiprazole, for the treatment of schizophrenia, acute treatment of manic and mixed episodes associated with bipolar disorder and as an add-on treatment for depression) (iv).

Noteworthy Orphan Approvals

Several important ultra-orphan medicines have been approved in the US and EU, Mepsevii (vestronidase alfa-vjbk, for the treatment of the inherited metabolic condition mucopolysaccharidosis type VII, also known as Sly syndrome, approved in the US only) and Brineuria (cerliponase alfa, an enzyme replacement therapy for the treatment of Batten’s Disease, approved in both regions). With more treatments for orphan diseases hitting the market the debate on the pricing of these drugs intensifies: Drug developers are increasingly meeting the treatment demand from the patients and physicians but are the payers willing to pay the price? Drug developers will benefit from being prepared early on to develop strategies to ensure patient access to and affordability of their orphan agents.

The Birth of EU Public Hearings

2017 is also the birth year of public hearings at EMA. The EU Pharmacovigilance legislation enabled the Pharmacovigilance Risk Assessment Committee (PRAC) to hold public hearings during certain safety reviews of medicines allowing the committee and EMA to engage with citizens in the EU. Unlike the US, where public hearings for new drugs approvals has been going on for years, the system in EU focuses on post approval hearings in the context of urgent safety procedures / referrals and public hearings for new drug approvals is out of scope for now.

In the US public hearings of new drug approvals and how to deal with them can be an important part of drug developers planning for success. Drug developers aiming for US approval should consider building awareness of public hearings into their planning and ongoing relations with medical societies, patient organisations, physicians and other healthcare professionals. The perspectives from these groups can provide an important context for the safety and efficacy data submitted by drug developers and have additions to the severity and impact of a condition and the limitations of current standards of care. The Sarepta Exondys 51 approval in 2016 (for the treatment of Duchenne muscular dystrophy, only approved in the US, a review decision from EMA is expected during 2018) is an excellent example of a public hearing playing an important role in the approval process of a new drug. The approval showed the US Advisory Committees receptiveness to public perspectives as they evaluate the benefit-risk of new drug under review.

The Era of New Designation Pathways Continues

It’s also been an exciting year for drug developers in advanced medicines (e.g. ATMP in EU and Regenerative Medicines in US). FDA has during 2017 launched its new designation pathway Regenerative Medicine Advanced Therapy (RMAT) to further enable the development of these drugs. RMAT may be considered as analogous to BTD for regenerative medicines, with some additional advantages in comparison: it does not require evidence to indicate that the drug may offer a substantial improvement over available therapies. The RMAT designation gives drug developers access to increased meeting opportunities in a manner comparable to BTD therapies.

In EU, special designation pathways and approval procedures is not as common as in the US. In March 2016, EMA launched PRIME (PRIority MEdicines), the EU counterpart to FDAs BTD. Last year the NDA Group published data showing that most products approved for PRIME was from companies based in US and most of the companies also already had BTD (v).

It is too early to tell if RMAT and PRIME will add to the strategies used by some companies that see cumulative advantages and/or benefits from obtaining multiple designation pathways, a phenomenon used mainly in the US and known as ‘layering,’ or ‘stacking’ of special designations with the intent to increase overall product value.

Continued Negative Trend of First-in-class Medicine Approvals

The approvals for targeted novel, first-in-class mechanism of action drugs continue to decrease, a trend that has been going on for years. Is it a sign of drug developer’s increasingly competitive nature around targets that “work” in specific diseases? If this is the case, drug developers can expect the competition on pricing amongst innovator products to increase and become the norm from the beginning. Historically, price competition has been occurring later on during the life cycle. In an environment where it becomes increasingly important to distinguish oneself, drug developers should focus on creative clinical strategies for differentiation. This could include co-development of biomarkers and tests to target sub-populations, companion diagnostics and innovative designs for dosing and patient follow-up.

Small and Medium Sized Pharma Dominate

For the first time since we started mapping the new drug approvals small and medium sized pharma have surpassed big pharma (vi) – quite an achievement! In total small and medium sized pharma contributed with 51% of the new drug approvals, to be compared to 49% from big pharma.

NDA supported over 40% of the approvals in the EU

NDA had a strong presence in the EU regulatory arena and supported over 40% of the new products approved from 2013 to 2017.
To read the statistics of new drug product approvals from last year click here.


Data collection and disclaimer

(i) The data was gathered from the EMA and FDA official websites, as reported on the FDA and the EMA official websites on January 2018, The data collected contains drug approvals for new active substances (chemical, biological, biotechnology or radiopharmaceutical substance), new molecular entity, new biological entity, new drug combination, biosimilars, new active ingredient and vaccines, excluding only generic and duplicate applications from the data. As it is challenging to pull together data from two regions with different classification and reporting styles some general inclusion and exclusion criteria to create consistent indicators of the yearly trends in the EU vs the US has been applied. The above article provides an overview of the key findings and an analysis of what the data means for the industry. The data is also visually represented in an infographic. As experience tells us, the final number of approvals reported normally fluctuates for some time after the end of the year, as the Agencies go through their house keeping processes. There could therefore be some slight changes to the findings outlined in this report before the data is completely finalised. The PRIME analysis was based on publically available data from the EMA website and by mapping publically disclosed BTD.

(ii) FDA Novel Drug Approvals for 2017
https://www.fda.gov/Drugs/DevelopmentApprovalProcess/DrugInnovation/ucm537040.htm
https://www.fda.gov/BiologicsBloodVaccines/DevelopmentApprovalProcess/BiologicalApprovalsbyYear/ucm547553.htm

(iii) First FDA Approval Agnostic of Cancer Site – When a Biomarker Defines the Indication. Lemery S, Keegan P, Pazdur R. N Engl J Med. 2017 Oct 12; 377(15):1409-1412

(iv) FDA approves pill with sensor that digitally tracks if patients have ingested their medication
https://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm584933.htm

(v) PRIME time for early designation pathways in Europe, T Johansson, Pharmafocus June edition 2017

(vi) The list of the top 50 pharma companies in 2017 was obtained from: EvaluatePharma 2017 Evaluate Ltd www.evaluate.com

Meet NDA at DIA Europe 2018







We will be attending in full force during this year’s DIA Europe Meeting 17- 19 April, in Basel, Switzerland.

If you are planning to be there, we would really like to meet up with you!

You can find us throughout the event at booths: 72 & 73 where we have a range of experts covering the full regulatory affairs spectrum – from preclinical and clinical to pharmacovigilance and health technology assessment – all of whom are looking forward to meeting you:

  • Professor Beatriz Silva Lima, Non clinical Expert,
  • Dr Thomas Lönngren, Former head of the EMA and strategic advisor to NDA Group
  • Professor Steffen Thirstrup, Clinical development and regulatory strategies Expert
  • Dr Markku Toivonen, Clinical development and clinical strategies Expert
  • Shelley Gandhi, Ex MHRA regulator, Pharmacovigilance & Drug safety Expert

In addition, there will be many of NDA’s expert consultants attending the event and happy to help.

We definitely recommend booking a meeting in advance to ensure availability, but do feel free to pop by booths 72 & 73.

If you would like to arrange a meeting, please contact my colleague Anna Perrin who will be happy to assist: Phone +44 (0) 1372 860 610 or Email anna.perrin@ndareg.com


Sessions

We will also have some of our team presenting on interesting industry topics during the event. Please look out for them:

 

Shelley Gandhi – Strategic Advisor, Pharmacovigilance & Drug Safety
Dr Bill Richardson – Medical Assessor, Pharmacovigilance & Risk Management Expert
(Pre-Conference Short Course)
Short Course 3 | Mon, 16th April – 14:00-17:30
Moving from Risk Management to Benefit-risk Management-Embedding Pharmacovigilance Principles into the product life cycle


 

Prof. Beatriz Silva Lima – Non clinical Expert
DIAlogue 2 – Session 1100 | Tues, 17th April – 14:00 -15:30
The New EMA first-in-human (FIH) guideline Part1: Non – Clinical aspects

 


Dr Brian Edwards – Principal Consultant, Pharmacovigilance & Drug Safety
Session 0502 | Wed, 18th April – 14:00-15:15
Innovative approaches to safety information
A proposal for a new systems-based approach to medication errors

 


Shelley Gandhi – Strategic Advisor, Pharmacovigilance & Drug Safety
Session 0504 | Thurs, 19th April – 08:30-10:00
Five years on – pharmacovigilance legislation Delivers on long-promised elements

 


Click here to download the Preliminary Programme.


 

Meet us at DIA Europe 2018

 

To book a meeting contact Anna Perrin: anna.perrin@ndareg.com or visit us at booths 72 & 73.
We look forward to hearing back from you about a meeting and to seeing you at the event!