Changes in the Incidence of PML in Tysabri-treated Patients: How best to communicate to patients and physicians

Similar documents
Progressive Multifocal Leukoencephalopathy (PML) in Natalizumab-Treated Patients: Experience of the FDA Division of Neurology Products

Regulatory Status FDA-approved indication: Tysabri is an integrin receptor antagonist indicated for treatment of (1):

Regulatory Status FDA-approved indication: Tysabri is an integrin receptor antagonist indicated for treatment of:

Expectation of a Rare Event. Laura Meyerson, Ph.D Midwest Biopharmaceutical Statistics Workshop Ball State University Muncie, IN

TYSABRI Treatment Initiation Form

natalizumab (Tysabri )

CLINICAL MEDICAL POLICY

EMA confirms recommendations to minimise risk of brain infection PML with Tysabri

The TOUCH Program and Risk Management. Updated Safety Results From the Use of Natalizumab in Patients With Relapsing Multiple

Helpful Information for evaluation of new neurological symptoms in patients receiving TYSABRI

Pharmacy Management Drug Policy

Local Natalizumab Treatment Protocol

Risk of Natalizumab-Associated Progressive Multifocal Leukoencephalopathy

Did the July 2008 PML announcement affect the Tysabri brand? PatientsLikeMeListen Report November 3, 2008

Regulatory Status FDA-approved indication: Tecfidera is indicated for the treatment of patients with relapsing forms of multiple sclerosis (1).

TYSABRI (natalizumab) BENEFIT INVESTIGATION WORKSHEET GUIDE

ACTEMRA Risk Mitigation Strategy Presenter Name, Degree

MULTIPLE SCLEROSIS - REVIEW AND UPDATE

Mellen Center Approaches: Natalizumab

TYSABRI FOR CROHN S DISEASE

Clinical Policy: Natalizumab (Tysabri) Reference Number: ERX.SPA.162 Effective Date:

Annex I. Scientific conclusions

Prior treatment with non-biologic Disease- Modifying Antirheumatic. Not to be used in combination with another biologic DMARD

ENTYVIO (vedolizumab)

Advances in the Management of Multiple Sclerosis: A closer look at novel therapies. Disclosures

Natalizumab (Tysabri; Biogen Idec, Inc, Elan Pharmaceuticals,

Acthar Gel. H. P. Acthar Gel (corticotropin; ACTH) Description

Clinical Policy: Natalizumab (Tysabri) Reference Number: ERX.SPA.162 Effective Date:

1. ABSTRACT. PASS Clinical Study Report Version 1.0

PATIENT INFORMATION: Patient Surname First Name Middle Initial Sex Date of Birth Alberta Personal Health Number M / F Year Month Day

See Important Reminder at the end of this policy for important regulatory and legal information.

Withdrawal of Proposed Rule on Supplemental Applications Proposing Labeling Changes for

The following MS experts were involved in the development of this Position Statement:

Pharmacoepidemiology and the Regulation of Medicines

Acthar Gel. H. P. Acthar Gel (corticotropin; ACTH) Description

Objectives. There Aren t Enough Hours in the Day

NDA NDA APPROVAL

Opinion 23 July 2014

Welcome to todays Webinar

Medication Policy Manual. Topic: Tecfidera, dimethyl fumarate Date of Origin: May 16, 2013

Regulatory Status FDA-approved indications: Entyvio is an α4β7integrin receptor antagonist indicated for: (1)

European Commission Grants Approval for Mavenclad (Cladribine Tablets)

Clinical Policy: Natalizumab (Tysabri) Reference Number: CP.PHAR.259 Effective Date: Last Review Date: Line of Business: Medicaid

Strategies for Ensuring Diversity, Inclusion, and Meaningful Participation in Clinical Trials: A Workshop

See Important Reminder at the end of this policy for important regulatory and legal information.

CENTER FOR DRUG EVALUATION AND RESEARCH. APPLICATION NUMBER: Orig1s000 APPROVAL LETTER

Acthar Gel. H. P. Acthar Gel (corticotropin; ACTH) Description

See Important Reminder at the end of this policy for important regulatory and legal information.

KEEPING IN TOUCH WITH THE NORTHUMBERLAND CHAPTER MS SOCIETY

TYSABRI (natalizumab) injection, for intravenous use Initial U.S. Approval: 2004

Response to: Concept paper of 9 February 2011 submitted for public consultation by the European Commission on the

Gilenya. Gilenya (fingolimod) Description

Use of Standards in Substantial Equivalence Determinations

Pharmacotherapy of Inflammatory Bowel Disorder

Committed to Transforming the Treatment Paradigm for Migraine Prevention

Clinical Policy: Natalizumab (Tysabri) Reference Number: ERX.SPA.162 Effective Date:

Clinical Policy: Natalizumab (Tysabri) Reference Number: CP.PHAR.259 Effective Date: Last Review Date: Line of Business: Medicaid

What you should know about Truxima (rituximab)

Gazyva. Gazyva (obinutuzumab) Description

Subject: Natalizumab (Tysabri ) IV

The legally binding text is the original French version TRANSPARENCY COMMITTEE OPINION. 3 October 2012

HIGHLIGHTS OF PRESCRIBING INFORMATION

Current Enrolling Clinical Trials

EHR Developer Code of Conduct Frequently Asked Questions

Multiple Sclerosis , The Patient Education Institute, Inc. nr Last reviewed: 04/17/2017 1

Withdrawal of drug therapy in patients with quiescent Crohn s disease

Pharmacotherapy of Inflammatory Bowel Disorder

Lecture 2. Key Concepts in Clinical Research

Clinical Study Synopsis

Acthar Gel. H. P. Acthar Gel (corticotropin; ACTH) Description

ACTEMRA (tocilizumab)

Supplementary Appendix

Disease-modifying therapies

Multiple Sclerosis. Brain Spinal Cord. Peripheral Nerves

EMEA WORKING PARTY ON HERBAL MEDICINAL PRODUCTS

TYSABRI (tie-sa-bree)

Overview of methodologies and studies evaluating risk minimisation measures

Gilenya. Gilenya (fingolimod) Description

For Immediate Release Contacts: Jenny Keeney Astellas US LLC (847)

Of Treatment For Inflammatory Bowel Diseases

An Update on the Biologic Treatment for Patients with Inflammatory Bowel Disease. David A. Schwartz, MD

Biothérapies et risques infectieux en. neurologie

Switching from natalizumab to fingolimod: an observational study

Medical Devices and the Public s Health: The FDA 510(k) Clearance Process at 35 Years. Written Statement of

MEDICATION GUIDE. (belatacept) For Injection, For Intravenous Use

Guideline on good pharmacovigilance practices (GVP)

GOVERNING BOARD. Assisted Conception (IVF): Review of access criteria. Date of Meeting 21 January 2015 Agenda Item No 13. Title

Committee Approval Date: May 9, 2014 Next Review Date: May 2015

European Risk Management Plan. Measures impairment. Retreatment after Discontinuation

Biologics and Beyond: Treatment of Multiple Sclerosis. Rita Jebrin, PharmD, BCPS

MDWISE PRIOR AUTHORIZATION CRITERIA TYSABRI (natalizumab): 300mg/15mL single use vial

Committed to Transforming the Treatment Paradigm for Migraine Prevention

RECENT MAJOR CHANGES Warnings and Precautions (5.1, 5.

Using medicines beyond licence

Evidence review for Surrey Prescribing Clinical Network SUMMARY

Corporate Medical Policy

Gazyva. Gazyva (obinutuzumab) Description

TREATING MULTIPLE SCLEROSIS The Current Disease Modifying Therapies Beverly Gilder, M.D. Blue Sky Neurology MS Center

Pharmacy Medical Policy Natalizumab (Tysabri )

Simple Linear Regression One Categorical Independent Variable with Several Categories

Transcription:

Changes in the Incidence of PML in Tysabri-treated Patients: How best to communicate to patients and physicians Division of Neurology Products Perspective Alice Hughes, M.D. Deputy Director for Safety Division of Neurology Products Food and Drug Administration July 25, 2011

Background When Tysabri was re-introduced to the market in 2006, we did not know what the incidence of Progressive Multifocal Leukoencephalopathy (PML) would be in the post-marketing setting Three cases in clinical trials (2/1869 patients with multiple sclerosis [MS] and 1/1043 patients with Crohn s disease [CD]) MS patients were on concomitant beta-interferon CD patient had had recent immunosuppressive therapy (azathioprine) treatment Risk of PML at that time roughly estimated to be 1/1000 Risk in monotherapy setting unknown Risk with long term treatment unknown MS trials: median duration 120 weeks Since marketing re-introduction, we have been getting expedited reports of all new cases and regular updates of PML incidence according to duration of exposure TOUCH program places us in the unique position of having reliable numerator (PML cases) and denominator information (number of patients treated according to exposure duration)

Background What we ve learned about PML incidence since 2006 Risk for PML not limited to patients receiving Tysabri with other immunomodulatory medications (or with very recent history of such) Risk increases with increasing durations of exposure Risk increased in patients with a history of immunosuppressant treatment

Background How do we best communicate what we ve learned, and the latest incidence information, to patients and physicians? Our overarching principle has been that it is important to communicate important new information related to PML incidence as we learn it so patients and physicians can make informed decisions about Tysabri treatment in the context of an individual patient s illness But what forum/fora is best? How much quantitative information is useful? How best to express incidence quantitatively?

Outline History of our communications related to PML incidence over time Key labeling changes Drug safety communications Unanswered questions

History of Key Labeling Changes June 2006 Label approved when Tysabri was re-marketed for MS: Two cases of PML were observed in 1869 patients with multiple sclerosis treated for a median of 120 weeks. The third case occurred among 1043 patients with Crohn's disease after the patient received 8 doses. The absolute risk for f PML in patients treated with Tysabri cannot be precisely estimated, and factors that might increase an individual patient's risk for PML have not been identified. August 2008 Label updated after we received the first postmarketing case reports Stated that additional cases of PML had been reported in the postmarketing setting in MS patients not taking other immunomodulatory therapy Number of cases not given The relationship between the risk of PML and the duration of treatment is unknown, but most cases of PML were in patients who received more than one year of treatment.

History of Key Labeling Changes January 2010 Label updated with information about link between exposure duration and PML risk that we had concluded was present At that time, risk in patients treated for two years or more was approximately 1/1000..the risk of developing PML increases with longer treatment duration, and for patients treated for 24 to 36 months is generally similar to the rates seen in clinical trials. There is limited experience beyond 3 years of treatment. No precise quantification of risk added to label just the reference to the clinical trial rate Developments after label change: Additional data accrued showed that the PML risk in patients treated for two years or more was becoming greater than the rate of 1/1000 that we had estimated ed from clinical trials We accumulated enough data for treatment beyond 3 years to give risk estimates for treatment beyond 3 years Growing desire for transparency about PML incidence information label seemed like the best repository for this information Readily accessible to patients and physicians Increasing need to give more quantitative risk information according to exposure duration as we accumulated more data General statement comparing risk to rates observed in clinical trials t no longer seemed sufficient

History of Key Labeling Changes April 2011 Label updated with: The risk of PML is also increased in patients who have been treated ted with an immunosuppressant (not including prior treatment with short courses of corticosteroids) prior to receiving TYSABRI. No estimate of the magnitude of risk increase conferred by such prior treatment A table providing incidence of PML according to duration of therapy/number of infusions: Duration of Therapy (Number of Infusions) Estimated Incidence of PML in the Postmarketing Setting Up to 24 0.3 25-36 1.5 37-48 0.9 PML Incidence per 1000 Patients Data as of January 2011 Data beyond 4 years of treatment are limited

History of Key Labeling Changes Medication Guide Part of approved label written directly to patients that presents s key risk information Medication Guide revisions have generally accompanied our other labeling changes Given to the patient at every Tysabri infusion Opportunity to communicate directly to patients Information about PML incidence currently in the Medication Guide: Your chance of getting PML increases: With a longer period of Tysabri treatment If you have received medicines that can weaken your immune system m prior to starting Tysabri

History of Drug Safety Communications Primary FDA risk communication tool currently in use is the Drug Safety Communication Provides information to patients and healthcare professionals in a standardized format (Summary, Additional Information for Patients, Additional Information for Healthcare Professionals, Data Summary) DSCs issued related to Tysabri since 2006: August 2008: first postmarketing cases Numerator and denominator information provided February 2010: PML risk/exposure duration association discussed at length Table provided showing cumulative risks above certain thresholds of exposure April 2011: PML risk/prior immunosuppressant therapy association and new incidence table being added to label discussed Explanation of our new data presentation format: FDA believes that presenting PML incidence for discrete intervals of treatment instead of showing cumulative e risks above certain thresholds of exposure will allow prescribers to better assess risk based on duration of treatment, and will aid healthcare professionals in discussing the risk of PML with their patients. DSCs have generally paralleled our labeling changes More detail and supportive data provided vs. label Updated number of PML cases and number of patients treated given

Change in presentation of incidence information: Old vs. new formats using latest incidence data (through July 5, 2011) Number of Tysabri Infusions received > 1 1.6 > 12 2.4 > 24 3.0 > 30 2.5 > 36 1.8 Cumulative rate of PML per 1000 patients Duration of therapy (number of infusions) Up to 24 0.4 25-36 1.9 37-48 1.3 PML Incidence per 1000 Patients We decided that the presentation on the right is more clinically useful for assessing an individual patient s s risk at a given point in time, and in discussing risk over time e with patients Which presentation is more understandable to patients and physicians? ians? We have limited the incidence presentation in label to one known risk factor Risk over time is important for ongoing treatment decisions As known risk factors accumulate, this table may grow more complex and unwieldy

Historical trends in our communications Move towards greater transparency regarding incidence information Move towards placing more granular incidence information in the label itself Move towards presentation of more quantitative information Move from presentation of risk according to cumulative durations of exposure to presentation of risk according to discrete intervals of exposure Move toward tabular presentation of risk vs. descriptive text Communication of up to date information leads to the need for updates; information becoming quickly outdated

Unanswered questions What does this information mean to patients and physicians? How do they integrate PML incidence information into their treatment decisions? What s s a regulatory agency s s role in disseminating real time incidence information for an adverse event? Are we overcommunicating? Undercommunicating? Providing necessary risk context? We have not assessed the effect of our communications on patient or physician understanding of risk Once TOUCH is approved as a Risk Evaluation and Mitigation Strategy, mandatory assessments of understanding will be included What else can we do? What other forms of communication should we w be using? Who else can be productively involved? How much granularity should be in the label itself? Is there another forum that should serve as a repository for up to date incidence information? Will patients and physicians think to look ok at the label for the latest incidence information? Tysabri.com website? What is an acceptable level of risk?