ASH Clinical News November 2015 | Page 15

PAID ADVERTISEMENT Approving Biosimilars in the United States: The Food and Drug Administration (FDA) Perspective The Biologics Price Competition and Innovation (BPCI) Act was signed into law as part of the Affordable Care Act in 2010, amending the Public Health Service (PHS) Act and facilitating the creation of an abbreviated, or tailored, licensure pathway for biological products shown to be “biosimilar” to or “interchangeable” with an FDA-licensed biological product.1 This abbreviated pathway, which is made possible by utilizing knowledge from the reference products and the European Medicines Agency experience, which approved its first biosimilar in 2006, is intended to eliminate unnecessary (and, therefore, unethical) testing of biosimilars in animals and humans.2 TOTALITY OF EVIDENCE: WHAT DOES IT MEAN? FDA guidance represents a paradigm shift in the way biosimilars are evaluated. The biosimilar approval pathway that the FDA has outlined builds on the knowledge gained from the reference biologic, and is based on a “Totality of Evidence” Approach.3 The “Totality of Evidence” Approach4 When a manufacturer decides to submit a product for review as a biosimilar, a 351(k) biologics license application is submitted, which must include information demonstrating biosimilarity, such as1: • Analytical studies that demonstrate that the biological product is “highly similar” to the reference product (only minor differences in clinically inactive components are permitted) • Animal studies (including assessment of toxicity) • Clinical studies, including the assessment of immunogenicity and pharmacokinetics (PK) or pharmacodynamics (PD), that sufficiently demonstrate safety, purity and potency in one or more appropriate conditions of use for which the reference product is licensed and for which licensure is sought for the biosimilar product ity r a il is m o Bi Pa ay w th 2012 Clinical Knowledge Human PK and PD Structural and Functional Characterization The goal of this stepwise approach is to establish the totality of the evidence that supports the demonstration of biosimilarity.3 This pathway also takes into account the lack of scientific benefit in repeating the entire development program of the reference product.2 Establishing a high degree of similarity at the molecular level with a robust foundation of analytical characterization reduces the need for extensive animal and clinical testing, compared with that required for a new originator biologic.3 First Biosimilar Approved11: 1. Scientific Considerations5 2. Quality Considerations6 3. Questions and Answers7 Draft Guidance Clinical Pharmacology Data on Biosimilarity9 The first approved biosimilar is filgrastim, currently referred to as filgrastim-sndz until the FDA clarifies how to “name” biosimilars. Draft Guidance on Biosimilars: FEBRUARY MAY MARCH MAY Draft Guidance on Biosimilars: 2011 Animal Studies Clinical Immunogenicity The FDA Has Developed Guidance for the Regulatory Approval of Biosimilars 2010 Clinical Studies 2013 2014 Additonal Questions and Answers14 2015 MARCH MARCH SEPTEMBER APRIL BPCI Act Passed as Part of the Affordable Care Act Draft Guidance on Formal Meetings With FDA and Sponsors (procedural) 8 FDA Announces “Purple Book”10: Final Guidance on Biosimilars: Lists biological products, including FDA licensed biosimilar and interchangeable biological products. It enables users to see whether a licensed biologic is biosimilar to, or interchangeable with, a reference biologic. 1. Scientific Considerations 3 2. Quality Considerations12 3. Questions and Answers13