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Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug development timelines September 8, 2014 Artisan Healthcare Consulting, Inc. +1 781-221-5656 phone [email protected] www.artisan-consulting.com

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Page 1: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

Have FDA Expedited Programs Shortened Drug Development Timelines?

An analysis of newly approved therapies and how FDA expedited programs impacted drug development timelines

September 8, 2014

Artisan Healthcare Consulting, Inc.+1 781-221-5656 [email protected]

Page 2: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

We collected the following dates for each NME approved from 2009 to 2014:

IND(investigational new drug) submission date of the first approved indication

Date of the FDA end of phase 2 (EOP2) meeting where available or the start date for the pivotal trials

NDA (new drug application)/BLA (Biologics License Application) filing dates

NDA/BLA approval dates We stratified the NMEs by year of approval,

and type of FDA expedited program used. We categorized each NME by therapeutic

area: Allergy, Autoimmune, Cardiovascular, Central Nervous System (CNS), Diabetes/ Metabolism, Diagnostic, Infectious disease, Musculoskeletal, Oncology, Ophthalmology, Rare diseases, Respiratory system, Sexual Dysfunction, Skin, Supportive care, and Women’s Health.

1. We collected key dates for new molecular entities (NME) and biologics approved over the

past 6 years.

Methodology (1 of 2)

3. We compiled and analyzed the findings to determine the effect of FDA expedited programs on drug development timelines.

Fast Track is introduced to accelerate the approval for medications treating serious conditions with unmet medical needs or a drug that has been designated as a qualified infectious disease product.

Accelerated Approval allows for approval of medication treating serious conditions based on surrogate endpoints.

Priority Review is for medications that offer significant improvements in the safety or effectiveness of the treatment, diagnosis, or prevention of serious conditions when compared to standard applications.

Breakthrough therapy designation is for medications that treat serious or life threatening disease and the medications may demonstrate substantial improvement on a clinically significant endpoint(s) over available therapies.

.

2. We looked at the 4 major FDA programs used to expedite clinical development to understand

impact on time to market

Page 3: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

Methodology (2 of 2)

*Sources: “Approved drugs 2013”, “2011 Novel New Drugs”, “2012 Novel New Drugs Summary”

IND filing: As reported in FDA filings - where information not available dates extracted from the Federal Register

End of Phase 2 meeting/beginning of pivotal trial -As reported in FDA filings – where the information was not available start dates of the pivotal trial extracted from www.clinicaltrials.gov

NDA/BLA filing: As reported in FDA filings

NDA/BLA approval: As reported in FDA filings

Excluded NMEs from the analysis

Lumizyme and Corifact: Excluded entirely from the analysis as IND filings and EOP2 meeting data are not available

2014 approved NMEs Belsomra, Cerdelga, Jardiance, Jublia, Orbativ, Otezla, Pledridy, Sivextro, Striverdi Respimat, Tanzeum, Zydelig and Zykadia: Excluded as full FDA documentation is not published

Sources used

Page 4: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

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NMEs That Used Any of the FDA Expedited Programs

Therapeutic area

Autoimmune

Cardiovascular

CNS

Diabetes/Metabolism

Diagnostics

Infectious diseases

Oncology

Rare diseases

Respiratory system

Supportive care

Ophthalmology

2009 2010 2011 2012 2013 2014*

*2014 FDA approvals by August 2014

Page 5: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

5

Which Programs Are Used the Most?

Accelerated programs

Fast track

Accelerated approval

Breakthrough therapy

Priority review

Any program

2009 2010 2011 2012 2013 2014*

1 of 25 (4%)

0 of 20 (0%)

15 of 30 (50%)

14 of 39 (36%)

10 of 27 (37%)

1 of 26 (45%)

2 of 25 (8%)

2 of 20 (10%)

3 of 30 (10%)

4 of 39 (10%)

2 of 27 (7%)

4 of 26 (15%)

-- -- -- -- 3 of 27 (11%)

2 of 26 (8%)

6 of 25 (24%)

6 of 20 (30%)

15 of 30 (50%)

16 of 39 (41%)

10 of 27 (37%)

8 of 26 (31%)

7 of 25 **(28%)

8 of 20** (40%)

17 of 30**(57%)

22 of 39 **(56%)

13 of 27 **(48%)

12 of 26** (46%)

*2014 FDA approvals by August 2014

Since 2011, ~50% Of All Approved Therapies Have Benefitted From An Expedited Pathway, With Priority Review and Fast Track Being the Most Heavily Utilized.

**Number of drugs approved in particular year

Page 6: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

6

Which Therapeutic Areas Use the Expedited Programs the Most?Therapeutic area/ All programs

Oncology

Rare diseases

Supportive care

Diagnostics

Infectious diseases

Diabetes/Metabolism

Cardiovascular

Autoimmune

Ophthalmology

CNS

Respiratory system

Other

Total

3 of 5 2 of 2 7 of 7 10 of 11 8 of 8 4 of 4 34 of 37 (92%)

0 of 1 1 of 1 0 2 of 2 0 2 of 2 5 of 6 (84%)

0 0 2 of 3 1 Of 1 0 0 3 of 4 (75%)

0 0 1 of 1 2 of 2 1 of 3 0 of 1 4 of 7 (60%)

1 of 4 1 Of 1 2 of 4 3 of 3 3 of 4 3 of 6 13 of 22 (60%)

0 of 1 0 of 2 0 of 1 1 of 7 0 of 2 0 of 4 1 of 17 (59%)

2 of 5 2 of 3 1 of 4 1 of 3 1 of 3 0 of1 7 of 19 (37%)

0 of 3 2 of 4 3 of 3 0 of 3 0 1 of 4 6 of 17 (35%)

0 0 0 1 of 3 0 0 1 of 3 (33%)

1 of 4 0 1 of 4 0 of 1 0 of 3 2 of 3 4 of 16 (25%)

0 0 0 of 2 1 of 2 0 of 2 0 of 1 1 of 7 (14%)

0 0 0 0 0 0 0 of 8 (0%)

7 of 25 (28%)

8 of 20 (40%)

17 of 30 (57%)

22 of 39 (56%)

13 of 27 (48%)

12 of 26 (46%)

79 of 167 (47%)

2009 2010 2011 2012 2013 2014 Total

In Oncology, Rare Diseases and Supportive Care over 75% of Approved Therapies Utilized an Expedited Program.

Page 7: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

7

Which Expedited Programs Are Used the Most by Individual Therapeutic Areas? 2009-2014

Fast track Priority review

Accelerated approval

Breakthrough therapy

Any single Program 2 programs 3

programsAll 4

programs

Autoimmune 3 of 17 5 of 17 0 0 6 of 17 2 of 17 0 0

Cardiovascular 1 of 19 7 of 19 0 0 7 of 19 1 of 19 0 0

CNS 1 of 16 2 of 16 1 of 16 0 4 of 16 0 0 0

Diabetes/Metabolism 0 1 of 17 1 of 17 0 1 of 17 1 of 17 0 0

Diagnostics 0 4 of 7 0 0 4 of 7 0 0 0

Infectious diseases 9 of 22 11 of 22 2 of 22 1 of 22 13 of 22 8 of 22 1 of 22 0

Oncology 20 of 37 24 of 37 12 of 37 4 of 37 34 of 37 16 of 37 2 of 37 1 of 37

Rare diseases 2 of 6 3 of 6 1 of 6 0 5 of 6 1 of 6 0 0

Respiratory system 1 of 7 0 0 0 1 of 7 0 0 0

Supportive care 3 of 4 3 of 4 1 of 4 0 3 of 4 2 of 4 1 of 4 0

Ophthalmology 0 1 of 3 0 0 1 of 3 0 0 0

Other 0 0 0 0 0 0 0 0

Total40 of 167

(23%)61 of 167

(37%)20 of 167

(12%) 3 of 167 (18%) 79 of 167 (47%)

31 of 167 (19%)

3 of 167(18%)

1 of 167 (1%)

In Oncology, Infectious Diseases and Supportive Care, over 35% of NMEs Use Multiple Expedited Programs.

Page 8: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

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Have Expedited Programs Shortened the Time from IND to NDA/BLA Approval?

2009 2010 2011 2012 2013 20140

2

4

6

8

10

12

8.810.1 10.2

8.7

6.6

8.79.0 8.6 8.9 9.2

7.5

5.6

NMEs Using 1+ Expedited Programs

NMEs Not Using Expedited Programs

# of

yea

rs fr

om IN

D to

NDA

/BLA

Ap

prov

al (a

vera

ge)

Year of NDA/BLA approval

When Considering the Time from IND to NDA Approval, Expedited Programs Do not Appear to Reduce Time to NDA/BLA Approval.

Page 9: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

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Have Expedited Programs Shortened the Time from the EOP2 Meeting to NDA/BLA Approval?

2009 2010 2011 2012 2013 20140.0

1.0

2.0

3.0

4.0

5.0

6.0

7.0

3.64.0

4.9 5.0

3.6

4.7

5.3

6.3

5.25.8 5.7

5.0

Expedited programs

Non expedited programs

Year of NDA/BLA approval

# of

yea

rs fr

om E

OP2

mee

ting/

Star

t of

Pivo

tal t

rial t

o N

DA/

BLA

Appr

oval

(ave

rage

)On Average, NMEs Using Expedited Programs Reduced the Time from EOP2 to NDA/BLA Approval by 1.2 Years.

Page 10: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

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Have Expedited Programs Shortened the Time from IND to NDA/ BLA Approval?

Breakthrough therapy

Fast track

Priority review

Accelerated approval

Any program

0 2 4 6 8 10 12

2009 2010 2011 2012 2013 2014

Average time: 7.4 years

Average time: 4.5 years

Average time: 8.6 years

# of years from IND to NDA/BLA Approval (average)

Average time: 9.0 years

Average time: 8.8 years

Breakthrough Therapy Has the Greatest Impact on Time to Approval of All Accelerated Programs; Accelerated Approval Also Provides Benefit.

Page 11: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

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Have Expedited Programs Shortened the Time from EOP2 meeting to NDA/ BLA Approval?

Breakthrough therapy

Fast track

Priority review

Accelerated approval

Any program

0 1 2 3 4 5 6

2009 2010 2011 2012 2013 2014

Average time: 4.7 years

Average time: 2.5 years

Average time: 4.5 years

# of years from IND to NDA/BLA Approval (average)

Average time: 4.4 years

Average time: 4.7 years

When Considering Time from EOP2 Meeting to NDA/BLA Approval, Only Breakthrough Therapy Significantly Improves Time to Approval Compared to Other Expedited Programs.

Page 12: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

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In Which Therapeutic Areas Have the Expedited Programs Shortened the Time from IND to NDA/BLA Approval?

Autoimmune Cardiovascular CNS Diagnostics Infectious diseases

Oncology Rare diseases Supportive care0

2

4

6

8

10

12

14

16

11.5

8.2

9.9

8.6

7.0

8.6

6.1

15.0

8.0

10.0

11.6

7.9

6.5

7.8 7.8

12.9

Used 1+ Expedited Program No Expedited Programs Utilized

# of

yea

rs f

rom

IND

to N

DA/

BLA

Appr

oval

(ave

rage

)

Reduction in Time From IND Submission to NDA/BLA Approval Is not Consistent Across Therapeutic Areas.

Page 13: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

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In Which Therapeutic Areas Have the Expedited Programs Shortened the Time from Time from EOP2 meting to NDA/BLA approval?

Autoimmune Cardiovascular CNS Diagnostics Infectious diseases

Oncology Rare diseases Supportive care0

1

2

3

4

5

6

7

8

4.65

5.24

6

2.73

3.724.25 4.19

7.19

5.06

6.566.88

4.66 4.52 4.5

3.293.59

Used 1+ Expedited Program No Expedited Programs Utilized

# of

yea

rs y

ears

from

End

of P

hase

2 m

eetin

g/St

art o

f Piv

otal

tria

l to

ND

A/BL

A Ap

prov

al(a

vera

ge)

For Most of the Therapeutic Areas Using Expedited Program Has Shorten the Time from EOP2 to NDA /BLA Approval.

Page 14: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

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Conclusions

Since 2011, ~50% Of All Approved Therapies Have Benefitted From An Expedited Pathway, With Priority Review and Fast Track Being the Most Heavily Utilized.

When Considering Time from EOP2 meeting to NDA Approval FDA Expedited Programs Reduced the Time from EOP2 to Approval by 1.2 Years. The Expedited Programs Do not Shorten the Time from IND Submission to NDA/BLA Approval.

✔ Breakthrough Therapy Was introduced the Latest but Seems to Have the Biggest Impact on Approval Time Compared to Other Expedited Programs.

In Oncology, Rare Diseases and Supportive Care over 75% of Approved Therapies Utilized an Expedited Program. In Oncology, Infectious Diseases and Supportive Care, over 35% of NMEs Use Multiple Expedited Programs.

Page 15: Have FDA Expedited Programs Shortened Drug Development Timelines? An analysis of newly approved therapies and how FDA expedited programs impacted drug

Brad Payne - Bio

Brad Payne is a Team Leader for Artisan Healthcare Consulting. He has over 5 years experience in the healthcare consulting space, with expertise in domestic and international reimbursement and market access. • Lead of the global market access practice• Extensive knowledge of national and regional payers in Europe, Canada, Latin America, and

Asia/Pacific• Advanced understanding of U.S. market access, with a proven track record of developing strategy

that influenced national and regional payer coverage and payment decisions• Proven ability to develop market access strategies utilizing experience across a number of

therapeutic areas including oncology, immunology, infectious diseases, rare diseases, and devices• Understanding of health economics, with extensive expertise in Health Technology Assessment

(HTA) analyses

Prior to joining Artisan, Brad was a consultant at Trinity Partners, a pharmaceutical and biotech consulting firm, where he provided insight on forecasting projects, licensing and acquisition opportunities, and provided recommendations for managed care contracting strategies.

Brad graduated with a degree in economics Cum Laude from Harvard University and received an MBA from the W.P. Carey School of Business at Arizona State University.

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Brad PayneTeam Leader

+1 781.996.7338 office+1 702.250.3136 cell

[email protected]