Category 4 Can we prove that ADF opioids really are?

Similar documents
Opioid Analgesics with Abuse- Deterrent Properties: Current Data and Future Opportunities

Effect of Abuse-Deterrent Formulations and IR Opioids on Abuse, Overdose and Death from Rx Opioids

The Evolution of Abuse Deterrent Drug Formulations: Testing Effectiveness from the Benchtop to the Real World

Prescription Opioid Dependence and Addiction: Experience in the United States

Interventions in Prescription Opioid Abuse Do (or can) Prescription Monitoring Programs Make a Difference?

Challenges in Conducting Postmarketing Abuse Investigations

Evolution of the Opioid Epidemic

Evolution of the Opioid Epidemic

Postmarketing Surveillance of Prescription Drug Abuse

Diversion, Misuse and Trafficking of Methadone and Buprenorphine in the US and Europ

A National Perspective on the Abuse and Diversion of Prescription Drugs

Diversion, misuse and trafficking of methadone and buprenorphine

Setting the Stage: Are Abuse-Deterrent Opioids Formulations Ready for Prime Time?

Richard C. Dart, MD, PhD Executive Director, RADARS System Denver Health and Hospital Authority

Value of Abuse-Deterrent Opioids. For your personal use. Not for further distribution.

Prescription Drug Abuse: Colorado and Nationwide

Abuse, Misuse, and Diversion of Prescription Opioids: Evaluating the Problem and Proposed Solutions

Evaluating the Impact of Abuse Deterrent Formulations: Methodological Challenges in Postmarketing Data

Substance Abuse in US and Europe

A LOOK AT ABUSE-DETERRENT OPIOIDS

The Challenge of Treating Pain

RADARS System International Pre-Symposium 11 May Global Insights in Prescription Drug Misuse

Dan Cohen Forum Chair - Abuse DeterrentCoalition. Abuse Deterrent Formulations of Opioids and the Abuse Deterrent Coalition

Potential Solutions to Epidemic Substance Abuse in US and Europe

Prescription Opioid Abuse: Abuse-Deterrent Opioids as Part of a Multipronged Approach. For Pfizer Use Only

RADARS R SYSTEM INTERNATIONAL PRE-SYMPOSIUM. International Landscape of Prescription Medication Misuse

Documents Regarding Drug Abuse Assessments

Understanding the US Opioid Analgesic Market

25/03/2014. Workshop Overview. Hot Topics in FDA Regulations and Pharmacotherapy Research that Impact Patient Care:

Do Pre Marketing Studies Anticipate Post Market Consequences? A Case Study of Reformulated Oxycontin

In Vitro Considerations for Development Abuse Deterrent Dosage Forms

Trends in Opioid Analgesic Abuse and Mortality in Europe

Abuse-Deterrent Formulations of Opioids: Effectiveness and Value

Key points. o Potential for nonmedical use, abuse, and diversion of new products

RAPID Analysis of Routes of Administration: Oral to Non-Oral Transitions

Reference ID: NDA was approved on December 12, The product was not formulated with properties to deter abuse,

Gabapentin diversion and misuse in the United States from a law enforcement perspective: Diversion rates and qualitative research findings

Identifying Key Characteristics and Habits of the Recreational Drug User

Assessing the Clinical Abuse Potential of Abuse Deterrent Opioid Formulations

Prescription Drug Monitoring Program Update. Rebecca R. Poston, BPharm., MHL Program Manager August 26, 2017

Post-Marketing Surveillance: Lessons Learned and Recommendations for the Future

Lessons Learned from the US Prescription Opioid Abuse Epidemic

New Guidelines for Prescribing Opioids

Key points. Background

Gabapentin diversion and misuse: Data from law enforcement and substance users

TITLE: Tamper-Resistant Oxycodone: A Review of the Clinical Evidence and Costeffectiveness

Rule Governing the Prescribing of Opioids for Pain

Opioid Analgesics. Recommended starting dose for opioid-naïve patients

SAFE OPIOID PRESCRIBING C.U.R.E.S. PROGRAM

FDA Briefing Document

Expanding hot-melt extrusion based abuse-deterrent formulation technology from extended release (ER) to immediate release (IR) application

Prescription Drug Abuse Task Force Rx Report Card

Blueprint for Prescriber Continuing Education Program

Responding to the Prescription Opioid and Heroin Crisis: An Epidemic of Addiction

Virtual Mentor American Medical Association Journal of Ethics April 2014, Volume 16, Number 4:

PRESCRIPTION DRUG ABUSE: THE NATIONAL PERSPECTIVE

Prescription Drug Abuse: Prevention and Treatment Across the Continuum of Care

Strategies for Federal Agencies

Michael M. Miller, MD, FASAM, FAPA

6/6/2018. Conflict of Interest Statement. Emerging Data on Non-opioid Prescription Drug Abuse

Increase in Opioid Related Deaths What the Data Can Tell us. Ontario Methadone Prescriber s Conference November 7, 2014 Tara Gomes

Top 10 narcotic pain pills

PK/PD analysis in assessment of abuse deterrence

Article #2 Prescription Drug Overdose CDC: Centers for Disease Control and Prevention. Understanding the Epidemic

Responding to the Prescription Opioid and Heroin Crisis: An Epidemic of Addiction

High-Decile Prescribers: All Gain, No Pain?

OHIO S PRESCRIPTION DRUG OVERDOSE EPIDEMIC:

Managed Care Pushes for Safer Opioid Oversight

Responding to the Prescription Opioid and Heroin Crisis: An Epidemic of Addiction

Identification of Specific Drugs and Drug Diversion in Drug Overdose Fatalities

Working with Policymakers and Payers to Improve the Incentives for ADFs. Dan Cohen Forum Chair - Abuse Deterrent Coalition

GOVERNMENT S ROLE IN ADDRESSING PRESCRIPTION DRUG ABUSE

Opioid Addiction Statistics

Abuse of opioid painkillers in the US is a major problem

Easy ways to save patients lives: How to prevent, recognize and deter prescription drug abuse.

Understanding and Combating the Heroin Epidemic

Investors Update: Abuse-Deterrent d-amphetamine Immediate Release (ADAIR) for ADHD

Implementing the 2017 President s Challenge: Primary, Secondary & Tertiary Prevention of Addiction & Substance Misuse

FDA Briefing Document

6/6/2017. The Role of ADFs in Curbing Opioid Abuse Can ADFs Reduce Opioid Abuse? 12-Month Financial Disclosures* Objectives

Prescription Drug Monitoring Programs and Other State-Level Strategies

FDA s Response to the Opioid Crisis and the FDA Safe Use Initiative

Opioid analgesic therapy in pain management: how we got here from there

Online Appendix. Supply-Side Drug Policy in the Presence of Substitutes: Evidence from the Introduction of Abuse-Deterrent Opioids

Medicare Advantage Outreach and Education Bulletin

Changing Prescribing Practices In Dentistry

PURDUE PHARMA L.P. NDA Avridi (Immediate-Release Oxycodone Hydrochloride) Tablets

Prescription Drug Abuse National Perspective

Academic Medical School: Implementing Curriculum in Chronic Pain and Opioid Misuse. Jill M Williams, MD

Role of PMPs in Preventing Substance Abuse National Conference of State Legislatures December 6, 2006 San Antonio, Tx

Medicare Advantage Outreach and Education Bulletin

PDMP Track: Linking and Mapping PDMP Data. Gillian Leichtling Acumentra Health Chris Baumgartner, WA State Dept. of Health

Shining a Light on MEDs Understanding morphine equivalent dose

As part of the Opioid Analgesic REMS, all opioid analgesic companies must provide the following:

Available for Public Release

How to inject op oxycontin

THE PRESCRIPTION OPIOID EPIDEMIC: IN SEARCH OF MISSION CONTROL. G. Caleb Alexander, MD, MS November 11, 2014

Opioids drive continued increase in drug overdose deaths

Egalet Corporate Presentation

Dangerous Liaisons. Overdose, Diversion & Deception

Transcription:

Human Abuse Liability & Abuse-Deterrent Formulations Category 4 Can we prove that ADF opioids really are? March 7, 2016 Richard C. Dart, MD, PhD Director, Rocky Mountain Poison and Drug Center Executive Director, RADARS System Professor, University of Colorado School of Medicine

Outline FDA Guidance on Abuse Deterrent Formulations A rigorous examination of the data currently available What s the problem? Some unique observations Low volume drugs are the real challenge

Abuse-Deterrent Opioids - Evaluation and Labeling Guidance for Industry Categories 1, 2, 3 have become routine. The goal of postmarket studies, Category 4, is to determine whether the marketing of a product with abuse-deterrent properties results in meaningful reductions in abuse, misuse, and related adverse clinical outcomes, including addiction, overdose, and death in the post-approval setting. Formal Studies Supportive Information Add to the totality of evidence to support ADF claim

National Academy of Medicine Session 4 Opioid Analgesics with Abuse- Deterrent Properties: Current Data and Future Opportunities Richard C. Dart, MD, PhD Director, Rocky Mountain Poison and Drug Center Executive Director, RADARS System Professor, University of Colorado

Opioids with Abuse Deterrent Properties: Current Data and Future Opportunities Oxycodone ER fulfills the Hill causation criteria Plausibility Temporality Effect Size Consistency Specificity Biologic gradient Coherence Experiment Analogy Alternative explanations International Society of Pharmacoepidemiology, August 26, 2015

Hill Criteria: Plausibility A plausible mechanism between cause and effect is helpful (but understanding of the mechanism is limited by current knowledge) Hill AB. Proc Royal Soc Med 1965;58:295-300.

Scientific Basis of Abuse-Deterrent Opioids Prescription drug abuse is like other drug abuse, except with an additional route of abuse: Oral = intact + chewed or crushed Intranasal Intravenous Importance of manipulating drug Crucial transition Changes perception of heroin use 1 Risk of acute (overdose, death) and chronic events (addiction, infections, death) higher after intranasal or IV abuse than oral abuse 1. Vosburg. J Child Adol Subst Abuse 2016.

Biological Plausibility Person in Pain Filling the Balloon Susceptible Person Intact Chewed Crushed Outcomes Addiction Recreational Abuser Overdose Abuse of Other Drugs Death Dart RC, Iwanicki JL. Can J Diag 2015;32:10.

Intervening in Prescription Drug Abuse Person in Pain Emptying the Balloon Guidelines Susceptible Person P D M P Intact A D F Chewed A D F Crushed Outcomes Addiction Recreational Abuser A D F Overdose Death A D F Dart RC, Iwanicki JL. Can J Diag 2015;32:10.

What if we had the perfect ADF? Two phases of abuse Obtaining the drug Friends and family Doctor shopping Pill mills Dealers Increased Intensity of Abuse Abusing the drug Neophyte swallow Experienced swallow

Hill Criteria: Temporality and Effect Size Effect has to occur after the cause (including a delay, if expected) Minimal delay expected for oxycodone ER All drug shipped after August 9, 2010 was reformulated version Pharmacy turnover of opioids is rapid A small association does not exclude a causal effect, though the larger the association, the more likely that it is causal. Hill AB. Proc Royal Soc Med 1965;58:295-300.

Oxycodone ER Prescriptions Dispensed Decreased Promptly After Reformulation 30% % Change in Prescriptions Dispensed 20% 10% 0% -10% -20% -30% Other Opioids Oxycodone ER -40% Reformulation of Oxycodone ER IMS, 2015-50% 2011 2012 2013 2014 2015 2016 Other Opioids = Oral dosage forms of opioid analgesics: hydrocodone, hydromorphone, morphine, oxymorphone, tramadol, tapentadol, and IR oxycodone

RADARS System - Mosaic Surveillance of Prescription Drug Abuse - 2015 Acute Health Events 49 Poison centers 46 states 512,609 cases 552,732 opioid mentions Drug Transactions Criminal Justice 260 agencies; 49 states 188,635 cases with 194,999 opioid mentions Entering Treatment Opioid Tx Program 72 programs; 42 states 43,861 cases with 201,099 opioid mentions Entering Treatment SKIP 135 practices, 47 states 12,328 cases with 80,617 opioid mentions General Population NMURx 30,0000 survey biannually All age groups Illicit Market Price StreetRx.com Users/Buyers, 50 states 25,250 price entries for an opioid Web Monitoring > 150 million sites monitored 13

Effect Size & Temporality: Oxycodone ER Abuse and Diversion, Population Adjusted, 2010-2016

Abuse Deterrent ER Oxycodone Reduces IV Abuse in Australia 4500 Introduction of Reformulated ER oxycodone 4000 3500 3000 Number of IV Cases 2500 2000 1500 1000 500 Non-abuse-deterrent oxycodone Reformulated ER oxycodone 0 Degenhardt et al., Drug Alc Depend 2015; 151: 56-57.

Hill Criteria: Consistency Consistent findings observed by different persons in different places with different samples strengthens the likelihood of an effect

Consistency: Oxycodone ER has Lower Rates Across Many Data Sources after Rx Adjustment Outcome Misuse Abuse Source RADARS (Poison Centers) RADARS (Poison Centers) NPDS (Poison Centers) NAVIPPRO (Treatment Centers) RADARS SKIP (Treatment Centers) Pre vs. Post % Change [95% CI] Since Reformulation ER Oxycodone Other Opioids Opioid Use Disorder Overdose Diversion Doctor Shopping RADARS OTP (Treatment Centers) Database of Opioid Users (Marketscan) Database of Opioid Users (Marketscan) RADARS (Drug Diversion) IMS Prescription Data Data adjusted for prescription volume Coplan et al. Clin Pharmacol Ther. 2016. -100% -50% 0% 50% 100% Decrease Increase

Additional Studies Epidemiology Cassidy 2014 Cicero 2015 Gomes 2012 Havens 2014 Hwang 2015 Larochelle 2015 McNaughton 2014 Sankey 2016 Hill Experimental (Abuse Liability) Darwish 2017 Gudin 2015 Hale 2015, 2016 Harris 2014 Setnick 2013 Stauffer 2009 Taber 2016 Webster 2011, 2012 Wen 2015 18

National Survey of Drug Use and Health, OxyContin Nonmedical Use 2 Introduction of Reformulated Oxycodone ER 1.6 # Cases of Past Year Nonmedical OxyContin Use (in millions) 1.2 0.8 0.4 0 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

20094 20102 20104 20112 20114 20122 20124 20132 20134 20142 Rate per 100,000 population Poison Centers: Response to Reformulation of Oxycodone ER and Oxymorphone ER Oxycodone ER Oxymorphone ER Other Opioids Reformulation of: OxyC ER OxyM ER Reformulation of: OxyC ER OxyM ER Reformulation of: OxyC ER OxyM ER 0.08 0.035 0.7 0.07 0.06 0.05 0.04 0.03 0.02 0.01 0.03 0.025 0.02 0.015 0.01 0.005 0.6 0.5 0.4 0.3 0.2 0.1 0 0 0

Hill Criteria: Specificity The more specific an association between a factor and an effect is, the bigger the probability of a causal relationship 1 Results specific to oxycodone ER compared to other analgesic opioids FDA Concerns 2 1. Hill AB. Proc Royal Soc Med 1965;58:295-300. 2. International Society of Pharmacoepidemiology, August 26, 2015

Hill Criteria: Specificity Michna 2014 22

For data streams that collect information on a variety of events (e.g., abuse, adverse reactions), changes should be limited to abuse-related categories Abuse Misuse Suicide Unintentional Unintentional therapeutic error therapeutic error Unintentional general exposure Unintentional general exposure -100% -50% 0% 50% 100% Relative Change in Population Rate

For evaluation of ADFs, changes should be seen only in the routes of abuse expected to be affected Inhale or Inject Oral -100% -50% 0% 50% 100% Relative Change in Population Rate All routes of abuse should be low with an effective ADF

Rate Percent of States Confounders? RADARS PC 0.8 WA Rx Guidelines Reformulation Natl Drug Take Back FL TIRF REMS ER/LA REMS HC-APAP Tramadol 100% 0.7 90% 0.6 80% 0.5 Ox ER 70% 0.4 0.3 Other Opioids 60% 50% 0.2 40% 0.1 PDMPs 30% 0 20% All Other Opioids (per 100,000 population) Oxycodone ER (per 10,000 population) Operational PDMPS

26

The Problem FDA has legal regulatory requirements that they must fulfill. These are somewhat open to interpretation. FDA doesn t want to get burned again. Opinion: Unlikely that epidemiological data alone will satisfy FDA. 27

Solutions Prospective study mentioned by FDA repeatedly. But impossible to do? Improved epidemiological studies Can t meet FDA standard Will always have substantial issues with confounding and bias. 28

Experiment What if we had site that provided consistent stream of cloned substance abusers who could be randomly assigned a drug to abuse? Randomized New ADF drug IR version Non-ADF ER formulation of same API Patients are followed over time for abuse behaviors 29

Problems IRB/Ethics, is it ethical to let a person continue abuse once it s discovered? Most abuse is not by the patient If study works on one group or a few groups of patients, how do we know they are valid externally? If the drug is used throughout the US, will it still be abuse deterrent? Use epidemiological data to buttress and expand the data? 30

Results Might Look Like Havens, 2014 31

Problems for a Low Volume Category Killer Baseline for comparison is not high Abusers haven t been exposed to your product. Do they not like it, or just not know about it? Shortest possible time because sponsor wants to achieve market share Lack of familiarity may be difficult to identify product Limitations of subanalyses (e.g. route of abuse) because of small number of abuse cases and outcomes. 32

Low Volume Solutions Emphasizes need for a prospective study Epidemiological data Diffuse Enriched Prolonged 33

Conclusions and Implications Specificity, consistency and effect size indicate that abuse deterrent opioids are likely to be effective in reducing abuse and its outcomes Two drugs: Similar effects for crush-resistant oxymorphone ER Widespread use - prices, reduce the crucial transition from intact swallowing to crushing Education, training, and other interventions needed as well How can we do any type of study in abuse subjects?

35