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CENTER FOR DRUG EVALUATION AND RESEARCH APPLICATION NUMBER: 212028Orig1s000 RISK ASSESSMENT and RISK MITIGATION REVIEW(S)

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Page 1: Risk Assessment and Risk Mitigation Review(s)The actual prevalence of insomnia varies according to the stringency of the definition used. Insomnia symptoms occur in approximately 33%

CENTER FOR DRUG EVALUATION AND RESEARCH

APPLICATION NUMBER:

212028Orig1s000

RISK ASSESSMENT and RISK MITIGATION

REVIEW(S)

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Division of Risk Management (DRISK) Office of Medication Error Prevention and Risk Management (OMEPRM)

Office of Surveillance and Epidemiology (OSE) Center for Drug Evaluation and Research (CDER)

Application Type NDA

Application Number 212028

PDUFA Goal Date December 20, 2019

OSE RCM # 2018-2814

Reviewer Name(s) Leah Hart, PharmD

Team Leader Selena Ready, PharmD

Division Director Cynthia LaCivita, PharmD

Review Completion Date December 4, 2019

Subject Evaluation of Need for a REMS

Established Name Lemborexant

Trade Name Dayvigo

Name of Applicant Eisai Inc.

Therapeutic Class

Formulation(s)

Dual orexin receptor antagonist

5 mg and 10 mg tablets for oral administration

Dosing Regimen Recommended dose is 5 mg taken no more than once per night,

immediately before going to bed, with at least 7 hours remaining

before the planned time of awakening. Maximum dose 10 mg

Reference ID: 4528864

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Table of Contents EXECUTIVE SUMMARY ......................................................................................................................................................... 3

1 Introduction ..................................................................................................................................................................... 3

2 Background ...................................................................................................................................................................... 3

2.1 Product Information ........................................................................................................................................... 3

Regulatory History ............................................................................................................................................................. 4

3 Therapeutic Context and Treatment Options .................................................................................................... 4

3.1 Description of the Medical Condition .......................................................................................................... 4

3.2 Description of Current Treatment Options ............................................................................................... 4

4 Benefit ASSESSMENT ................................................................................................................................................... 9

5 Risk Assessment & Safe-Use Conditions ............................................................................................................ 11

6 Expected Postmarket Use ......................................................................................................................................... 12

7 Risk Management Activities Proposed by the Applicant ............................................................................. 12

8 Discussion of Need for a REMS ............................................................................................................................... 12

9 Conclusion & Recommendations ........................................................................................................................... 13

10 Appendices ................................................................................................................................................................ 13

10.1 References ............................................................................................................................................................. 13

Reference ID: 4528864

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EXECUTIVE SUMMARY This review by the Division of Risk Management (DRISK) evaluates whether a risk evaluation and mitigation strategy (REMS) for the new molecular entity Dayvigo (lemborexant) is necessary to ensure the benefits outweigh its risks. Eisai Inc. (Applicant) submitted a New Drug Application (NDA 212028) for lemborexant with the proposed indication for the treatment of insomnia, characterized by difficulties with sleep onset and/or sleep maintenance. The Applicant did not submit a proposed REMS.

The primary safety concern associated with the use of lemborexant is somnolence and the potential for next day impairment. The risk is increased if Dayvigo is taken with less than a full night of sleep and with the higher dose (10 mg).

DRISK determined that a REMS is not needed to ensure the benefits of Dayvigo outweigh its risks. This decision is supported by the clinical review of the safety data in the development program. Dayvigo will likely be used by primary care physicians, sleep specialists, and psychiatrists to manage adult patients with insomnia disorder in any treatment setting, inpatient or outpatient. The risk of somnolence and the potential for next day impairment associated with Dayvigo will be communicated in the Warnings and Precautions section of the Prescribing Information to inform healthcare providers about this safety concern.

1 Introduction This review by the Division of Risk Management (DRISK) evaluates whether a risk evaluation and mitigation strategy (REMS) for the new molecular entity (NME),a Dayvigo (lemborexant), is necessary to ensure the benefits outweigh its risks. Eisai Inc. (Applicant) submitted a New Drug Application (NDA) 212028 for Dayvigo with the proposed indication for the treatment of insomnia, characterized by difficulties with sleep onset and/or sleep maintenance. This application is under review in the Division of Psychiatric Products (DPP). The Applicant did not submit a REMS with this application.

2 Background 2.1 PRODUCT INFORMATION Dayvigo (lemborexant) is an orexin receptor antagonist proposed for the treatment of insomnia, characterized by difficulties with sleep onset and/or sleep maintenance. The mechanism of action of lemborexant in adult patients with insomnia (sleep onset and/or sleep maintenance) is sleep maintenance is unclear. However, its efficacy could be mediated through its activity as an orexin receptor antagonist. Lemborexant is a competitive antagonist of both orexin receptors, OX1R and OX2R, with a higher affinity for OX2R. The orexin neuropeptide signaling system is a central promoter of

a Section 505-1 (a) of the FD&C Act: FDAAA factor (F): Whether the drug is a new molecular entity.

Reference ID: 4528864

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wakefulness. Blocking the binding of wake-promoting neuropeptides orexin A and orexin B to receptors OX1R and OX2R is thought to suppress wake drive.

The proposed dosing regimen is 5 mg once daily immediately before going to bed, with at least 7 hours remaining before the planned time of awakening. The dose may be increased to the maximum recommended dose of 10 mg once daily if the 5 mg dose is well-tolerated but greater effect is needed.

REGULATORY HISTORY The following is a summary of the regulatory history for Dayvigo NDA 212028 relevant to this review:

• 12/27/2018: NDA 212028 submitted for the treatment the treatment of insomnia, characterized by difficulties with sleep onset and/or sleep maintenance,

3 Therapeutic Context and Treatment Options

3.1 DESCRIPTION OF THE MEDICAL CONDITION Insomnia disorder is characterized by a subjective report of difficulty with sleep initiation, duration, consolidation, or quality that occurs despite adequate opportunity for sleep, and that results in some form of daytime impairment.1

The actual prevalence of insomnia varies according to the stringency of the definition used. Insomnia symptoms occur in approximately 33% to 50% of the adult populationb; insomnia symptoms with distress or impairment (i.e., general insomnia disorder) in 10% to 15%; and specific insomnia disorders in 5% to 10%. Risk factors for insomnia include increasing age, female sex, comorbid (medical, psychiatric, sleep, and substance use) disorders, and shift work.1,2

Insomnia causes both individual and societal burdens. Patients with chronic insomnia are more likely to use healthcare resources, visit physicians, be absent or late for work, make errors or have accidents at work, and have more serious road accidents. There is an increased risk for suicide and substance use/relapse.c 2,3

3.2 DESCRIPTION OF CURRENT TREATMENT OPTIONS Patients should receive treatment for any medical condition, psychiatric illness, substance abuse, or sleep disorder contributing to insomnia. Patients should also receive counseling about sleep hygiene (exercising regularly, avoiding daytime naps, adjust bedroom environment, etc.) and stimulus control (not spending more than 20 minutes in bed awake, engaging in relaxing activities such as reading or listening to soothing music). Cognitive behavioral therapy for insomnia has been shown to be effective in moderate- to high quality randomized trials.4,5 Insomnia that does not respond to these non-

b Section 505-1 (a) of the FD&C Act: FDAAA factor (A): The estimated size of the population likely to use the drug involved.

c Section 505-1 (a) of the FD&C Act: FDAAA factor (B): The seriousness of the disease or condition that is to be treated with the drug.

Reference ID: 4528864

(b) (4)

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pharmacological therapies may be treated with medication. Selection of which pharmacologic treatment to use is usually based on the type of insomnia (i.e. sleep onset or sleep maintenance) and the duration of the effect. Currently approved treatments for insomnia include benzodiazepines, nonbenzodiazepine hypnotics, melatonin agonists, doxepin, and suvorexant.4,6 On August 18, 2019, the FDA issued a safety labeling change requiring the addition of a Boxed Warning that complex sleep behaviors including sleep-walking, sleep-driving, and engaging in other activities while not fully awake may occur following use of certain nonbenzodiazepine hypnotics. The warning states that some of these events may result in serious injuries, including death and to discontinue treatment immediately if a patient experiences a complex sleep behavior. Table 1 provides the list of medicines approved by the FDA for the treatment of insomnia.

Product Trade Name (Generic)

Year of Approval

Indication Dosing/Administration Risk Management Approaches/Boxed Warning, Medication Guide

Triazolam7

1982

Short-term treatment of insomnia (generally 7-10 days)

0.25 mg before bedtime with a maximum dose of 0.5 mg

Boxed Warning: concomitant use of benzodiazepines and opioids may result in profound sedation, respiratory depression, coma, and death

Warnings and Precautions: Sleep-driving and other complex sleep behaviors

Estazolam8

1990

Short-term management of insomnia characterized by difficulty falling asleep, frequent nocturnal awakenings, and/or early morning awakenings

1 mg at bedtime, can increase to 2 mg if indicated

Boxed Warning: concomitant use of benzodiazepines and opioids may result in profound sedation, respiratory depression, coma, and death

Warnings and Precautions: Sleep-driving and other complex sleep behaviors

Reference ID: 4528864

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Product Trade Name (Generic)

Year of Approval

Indication Dosing/Administration Risk Management Approaches/Boxed Warning, Medication Guide

Temazepam9

1981

Short-term treatment of insomnia (7-10 days)

15 mg before retiring; doses can range from 7.5 mg to 30 mg

Boxed Warning: concomitant use of benzodiazepines and opioids may result in profound sedation, respiratory depression, coma, and death

Warnings and Precautions: Sleep-driving and other complex sleep behaviors

Flurazepam10

1970

Treatment of insomnia characterized by difficulty falling asleep, frequent nocturnal awakenings, and/or early morning awakenings

Initial dose is 15 mg for women and either 15 mg or 30 mg for men. The 15 mg dose can be increased to 30 mg if necessary, for efficacy

Boxed Warning: concomitant use of benzodiazepines and opioids may result in profound sedation, respiratory depression, coma, and death

Warnings and Precautions: Next-day impairment, sleep-driving and other complex sleep behaviors

Quazepam11

1985

Treatment of insomnia characterized by difficulty falling asleep, frequent nocturnal awakenings, and/or early morning awakenings

Initial dose is 7.5 mg Boxed Warning: concomitant use of benzodiazepines and opioids may result in profound sedation, respiratory depression, coma, and death

Warnings and Precautions: Impaired alertness and motor coordination, including risk of daytime impairment; sleep-driving and other complex sleep behaviors

Reference ID: 4528864

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Product Trade Name (Generic)

Year of Approval

Indication Dosing/Administration Risk Management Approaches/Boxed Warning, Medication Guide

Zaleplon12

1999

Short-term treatment of insomnia

5 mg to 20 mg immediately before bedtime or after the patient has gone to bed and has experienced difficulty falling asleep

Boxed Warning: Complex sleep behaviors including sleep-walking, sleep-driving, and engaging in other activities while not fully awake. Some of these events may result in serious injuries, including death.

Warnings and Precautions: Next-day impairment

Zolpidem IR13

1992

Short-term treatment of insomnia characterized by difficulties with sleep initiation

Initial dose is a single dose of 5 mg for women and a single dose of 5 or 10 mg for men, immediately before bedtime with at least 7-8 hours remaining before the planned time of awakening (maximum dose of 10 mg)

Boxed Warning: Complex sleep behaviors including sleep-walking, sleep-driving, and engaging in other activities while not fully awake. Some of these events may result in serious injuries, including death.

Warnings and Precautions: Impaired alertness and motor coordination, including risk of morning impairment

Zolpidem ER14

2005

Treatment of insomnia characterized by difficulties with sleep onset and/or sleep maintenance

Recommended initial dose is a single dose of 6.25 mg for women and a single dose of 6.25 or 12.5 mg for men, immediately before bedtime with at least 7-8 hours remaining before the planned time of awakening (maximum dose of 12.5 mg)

Boxed Warning: Complex sleep behaviors including sleep-walking, sleep-driving, and engaging in other activities while not fully awake. Some of these events may result in serious injuries, including death.

Warnings and Precautions: Impaired alertness and motor coordination, including risk of morning impairment

Reference ID: 4528864

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Product Trade Name (Generic)

Year of Approval

Indication Dosing/Administration Risk Management Approaches/Boxed Warning, Medication Guide

Eszopiclone15

2004

Treatment of insomnia (shown to decrease sleep latency and improve sleep maintenance)

Recommended initial dose is 1 mg, immediately before bedtime, with at least 7-8 hours remaining before the planned time of awakening (maximum dose 3 mg)

Boxed Warning: Complex sleep behaviors including sleep-walking, sleep-driving, and engaging in other activities while not fully awake. Some of these events may result in serious injuries, including death.

Warnings and Precautions: Impaired alertness and motor coordination, including risk of morning impairment

Ramelteon16

2005

Treatment of insomnia characterized by difficulty with sleep onset

8 mg taken within 30 minutes of going to bed (maximum dose 8 mg)

No boxed warning

Warnings and Precautions: severe anaphylactic reactions; abnormal behavioral changes; complex sleep behaviors

Suvorexant17

2014

Treatment of insomnia, characterized by difficulties with sleep onset and/or sleep maintenance

10 mg, no more than once per night taken within 30 minutes of going to bed, with at least 7 hours remaining before the planned time of awakening (maximum dose 20 mg)

No boxed warning

Warnings and Precautions: daytime somnolence; nighttime “sleep-driving” and other complex sleep behaviors; depression; compromised respiratory function; sleep paralysis, hypnagogic/hypnopompic hallucinations and cataplexy like symptoms

Doxepin18

2010

Treatment of insomnia characterized by difficulties with sleep maintenance

6 mg within 30-minutes of bedtime

Warnings and Precautions: Sleep-driving and other complex sleep behaviors

Non-FDA approved treatments include sedating antidepressants (trazodone), gabapentin, tiagabine, quetiapine and olanzapine.3,19 Over-the-counter products that have been used as sleep aids include antihistamines. Melatonin and herbal products such as valerian extracts have also been used to aid in

Reference ID: 4528864

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sleep. Long-term use of non-prescription treatments is not recommended, and efficacy and safety data are limited.1,6

4 BENEFIT ASSESSMENT Studies 303 and 304 were the pivotal trials used to support the proposed indication, treatment of insomnia, characterized by difficulties with sleep onset and/or sleep maintenance,

.20

The Applicant listed one primary efficacy endpoint for studies 303 and 304, two key secondary endpoints, and over a dozen other secondary and exploratory endpoints for each study. Only the primary efficacy endpoints for studies 303 and 304 were used in the determination of efficacy.21

Study 303 was a 12-month, multicenter, randomized, double-blind, placebo-controlled, parallel-group study of 2 dose levels of lemborexant in approximately 900 male or female subjects with insomnia disorder. Approximately 40% of the population was to be age 65 years or older. The primary efficacy endpoint was the mean change from baseline (CFB) of subjective sleep onset latency (sSOL defined as the estimated minutes from the time the subject attempted to sleep until sleep onset measured by sleep diary) at Month 6 for lemborexant 5 mg and 10 mg compared to placebo. There are two key secondary endpoints: change from baseline of mean subjective sleep efficiency (sSE defined as the proportion of time spent asleep per time in bed from “lights off” until “lights on” measured by sleep diary) and mean subjective wake after sleep onset (sWASO defined as the minutes of wake from the onset of persistent sleep until lights on measured by sleep diary) at Month 6 for lemborexant 5 mg and 10 mg compared to placebo.20

The trial was conducted at a total of 119 sites, including 40 in the US. Of the 971 patients randomized, 949 completed the study (315 in the 10 mg group, 316 in the 5 mg group and 318 in the placebo group).21

The lemborexant treatment group had a statistically significant change from baseline of sSOL (minutes) of 0.73 (p<0.001) for the 5 mg dose and 0.70 (p<0.001) for the 10 mg dose compared to placebo. All treatment groups showed a decrease in sSOL score over 6 months, with numerically greater change from baseline for both lemborexant groups at all time points. The two lemborexant groups have the overlapping time course profiles.21

Table 3: Primary Efficacy Results for Change from Baseline in Sleep Onset Latency (sSOL) at 6 Months in Patients with Insomnia (Study 1)22

Treatment Group Number of Patients

ITT

Baseline Meana sSOL minutes (SD)

Month 6 LS Meana sSOL minutes (SE)

Treatment Effectb (95% CI)

DAYVIGO 5 mg* 316 43.0 (31.5) 20.0 (1.1) 0.73 (0.64, 0.84)

DAYVIGO 10 mg* 315 45.0 (33.4) 19.2 (1.1) 0.70 (0.61, 0.81)

Reference ID: 4528864

(b) (4)

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Placebo 318 45.0 (31.8) 27.3 (1.4)

ITT: intention to treat; sSOL: subjective sleep onset latency; SD: standard deviation; LS: least squares; SE: standard error; CI: confidence interval ageometric mean, used due to the approximately log normal distribution of the outcomes. bTreatment effect refers to the ratio of [Month 6 sSOL / Baseline sSOL] for DAYVIGO versus placebo, such that a smaller ratio corresponds to a greater improvement.

*statistically significant after multiplicity adjustment

The Applicant listed two key secondary endpoints: CFB of mean subjective sleep efficiency (sSE) and mean sWASO at Month 6 for LEM10 and LEM5 compared to PBO. The lemborexant treatment group had a statistically significant change from baseline of sSE (%) of 4.5 (p<0.001) for the 5 mg dose and 4.7 (p<0.001) for the 10 mg dose. The second key endpoint, sWASO (minutes), was statistically significant for both the 5 mg dose (-17.5; p<0.001) and the 10 mg dose (-12.7; p=0.011).21

Study 304 was a randomized, double blind, placebo- and active-controlled (with zolpidem extended release), parallel-group study of 2 dose levels of lemborexant in male subjects 65 years or older or female subjects 55 years and older with insomnia disorder. The trial was conducted at a total of 67 sites, including 45 in the US. Of the 1006 patients randomized, 962 completed the study, however all 1006 patients were included in the planned analyses (269 in the 10 mg group, 266 in the 5 mg group, 208 in the placebo group and 263 in the zolpidem group).20

The primary efficacy endpoint was the CFB for mean latency to persistent sleep (LPS measured in minutes) on days 29/30 compared to placebo. The results on the primary efficacy endpoint was considered statistically significant for lemborexant 5 mg (0.77; p<0.001) and lemborexant 10 mg (0.72; p<0.001).21

Table 4: Primary Efficacy Results for Change from Baseline in Latency to Persistent Sleep (LPS) at 1 Month in Patients with Insomnia (Study 2)22

Treatment Group Number of Patients

ITT

Baseline Meana LPS

minutes (SD)

Day 29/30 LS Meana LPS

minutes (SE)

Treatment Effectb

(95% CI)

DAYVIGO 5 mg* 266 33.0 (27.2) 15.5 (0.8) 0.77 (0.67, 0.89)

DAYVIGO 10 mg* 269 33.3 (27.2) 14.5 (0.7) 0.72 (0.63, 0.83)

Placebo 208 33.6 (25.9) 20.0 (1.1)

ITT: intention to treat; LPS latency to persistent sleep; SD: standard deviation; LS: least squares; SE: standard error; CI: confidence interval ageometric mean, used due to the approximately log normal distribution of the outcomes. bTreatment effect refers to the ratio of [Day 29/30 LPS / Baseline LPS] for DAYVIGO versus placebo, such that a smaller ratio corresponds to a greater improvement.

Reference ID: 4528864

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* statistically significant after multiplicity adjustment

The three key secondary endpoints were CFB for mean sleep efficiency (SE) on days 29/30 compared to placebo, CFB of mean wake after sleep onset (WASO) on days 29/30 compared to placebo and the CFB for mean wake after sleep onset in the second half of the night (WASO2H) on days 29/30 compared to zolpidem. The results of the three key secondary endpoints were considered statistically significant for both the 5 mg and 10 mg dose. For mean SE (%) the placebo-subtracted difference was 7.1 (p<0.001) for the 5 mg dose and 8.0 (p<0.001) for the 10 mg dose. For mean WASO (minutes) the placebo subtracted difference was -24 (p<0.001) for the 5 mg dose and -25.3 (p<0.001) for the 10 mg dose. Although the comparisons of lemborexant to Zolpidem in WASO2H were statistically significant (-6.6; p=0.001 for 5 mg dose and -8 p<0.001 for the 10 mg dose), Zolpidem was statistically worse than placebo in the primary endpoint, LPS.

The clinical reviewer concluded that the Applicant provided substantial evidence of effectiveness for the treatment of insomnia, characterized by difficulties with sleep onset and/or sleep maintenance.d

5 Risk Assessment & Safe-Use Conditions The Integrated Summary of Safety (ISS) includes safety data from 20 clinical studies in 3371 subjects, 1847 of which received lemborexant.20

No deaths occurred in the lemborexant development program.e,f In the development program, the most common Treatment Emergent Adverse Events (TEAEs) occurring in lemborexant-treated patients and at a frequency greater than in the placebo group (≥2% and greater than PBO) in the 5 mg group were headache (8.4%), somnolence (6.7%), upper respiratory tract infection (3.8%), arthralgia (2.8%), back pain (2.5%), dizziness (2.4%), fatigue and fall (2.2% each), and nausea (2.1%). In the 10 mg group, the most common (≥2%) TEAEs were somnolence (10.9%), influenza and urinary tract infection (3.4% each), fatigue (2.6%), and back pain (2.1%).23

d Section 505-1 (a) of the FD&C Act: FDAAA factor (C): The expected benefit of the drug with respect to such disease or condition.

e Any adverse drug experience occurring at any dose that results in any of the following outcomes: Death, a life-threatening adverse drug experience, inpatient hospitalization or prolongation of existing hospitalization, a persistent or significant disability/incapacity, or a congenital anomaly/birth defect. Important medical events that may not result in death, be life-threatening, or require hospitalization may be considered a serious adverse drug experience when, based upon appropriate medical judgment, they may jeopardize the patient or subject and may require medical or surgical intervention to prevent one of the outcomes listed in this definition.

f Section 505-1 (a) of the FD&C Act: FDAAA factor (E): The seriousness of any known or potential adverse events that may be related to the drug and the background incidence of such events in the population likely to use the drug.

Reference ID: 4528864

(b) (4)

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The primary safety concern associated with the use of lemborexant is somnolence and the potential for next day impairment. The next-day driving performance of healthy adults (21 to 64 years) and elderly subjects (≥65 years) following a single dose and multiple doses of lemborexant at bedtime was evaluated in a Phase 1 study (Study 106). Each subject received 2 of the 3 dose levels of lemborexant (2.5, 5 or 10 mg), zopiclone (7.5 mg, positive control) and placebo (negative control) for 8 consecutive nights. The driving performance was assessed in the morning following the first (Day 2) and last doses (Day 9) of the treatments. The primary endpoint was the standard deviation of the lateral position (SDLP) during an on-road driving test in the morning on Day 2 and Day 9 following lemborexant dosing compared to placebo. The clinical pharmacology review concluded that there is a potential for next-day residual effects in some patients taking 10 mg lemborexant.23

The proposed Prescribing Information (PI) contains a Warning (Section 5.1) that states Dayvigo can impair daytime wakefulness even when used as prescribed. The risk is increased if Dayvigo is taken with less than a full night of sleep remaining. The warning advises against co-administration with other CNS depressants (e.g. benzodiazepines, opioids, tricyclic antidepressants, alcohol) due to the increased risk of CNS depression which can cause daytime impairment. If CNS depressants must be administered together, dose adjustments of both that and Dayvigo may be necessary because of the potential additive effects. This is also covered in the drug interaction section (7.1) of the PI.

Other warnings and precautions to be included in the PI are the potential for sleep paralysis, hypnagogic/hypnopompic hallucinations, and cataplexy-like symptoms; complex sleep behaviors and worsening of depression/suicidal ideation.

6 Expected Postmarket Use Dayvigo will likely be used by primary care physicians, sleep specialists, and psychiatrists to manage adult patients with insomnia disorder in any treatment setting, inpatient or outpatient. Insomnia can be a chronic disorder and therefore Dayvigo could be used for an extended period. In a human abuse potential (HAP) study, oral administration of lemborexant at therapeutic (10 mg) and supratherapeutic (20-30 mg, 2-3X) doses produced statistically significant increases on positive subjective measures such as Drug Liking, Overall Drug Liking, and Good Drug Effects that were greater than those produced by placebo. These subjective responses were similar to those produced by the positive control drugs, zolpidem (30 mg) and suvorexant (40 mg), both of which are Schedule IV sedatives under the CSA. This demonstrates that lemborexant produces rewarding effects that are similar to Schedule IV drugs. Therefore, the Controlled Substance Staff (CSS) has recommended that lemborexant should be recommended for control under the Controlled Substances Act in Schedule IV.24

7 Risk Management Activities Proposed by the Applicant The Applicant did not propose any risk management activities for Dayvigo beyond routine pharmacovigilance and labeling.

8 Discussion of Need for a REMS

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Lemborexant is an orexin receptor antagonist proposed for the treatment of insomnia, characterized by difficulties with sleep onset and/or sleep maintenance.

Currently, there are numerous FDA-approved treatments for insomnia and one orexin antagonist. None of these medicines are approved with a REMS.

Lemborexant efficacy and safety in the treatment of insomnia is supported by 2 clinical studies in adult patients and the clinical reviewer recommends approval of Dayvigo for insomnia based on the efficacy and safety information currently available. The main identified safety concern with lemborexant is somnolence and the potential for next day impairment. We agree with the clinical reviewer that the risk associated with lemborexant use at recommended doses in insomnia appear to be manageable in the context of standard clinical care and that measures beyond labeling are not necessary for the benefits of Dayvigo to outweigh the risks.

9 Conclusion & Recommendations DRISK determined that a REMS is not necessary to ensure the benefits of Dayvigo outweigh the risk. This decision is supported by the clinical review of the safety data in the development program. The risk of impaired alertness/daytime somnolence associated with Dayvigo (with the 10 mg dose) can be addressed in the Warnings and Precautions and other sections of the PI, which will inform healthcare providers about this potential safety concern.

Should DPP have any concerns or questions or if new safety information becomes available, please send a consult to DRISK.

10 Appendices

10.1 REFERENCES

1 Schutte-Rodin S, Broch L, Buysse D, et al. Clinical Guideline for the Evaluation and Management of Chronic Insomnia in Adults. J Clinical Sleep Medicine, Vol. 4, No. 5, 2008

2 Ancoli-Israel S, Roth T. Characteristics of insomnia in the United States: results of the 1991 National Sleep Foundation Survey. Sleep 1999; 22:S347-53.

3 National Institutes of Health. National Institutes of Health State of the Science Conference statement on Manifestations and Management of Chronic Insomnia in Adults, June 13-15. Sleep 2005; 25:1049.

4 McCurry SM, Logsdon RG, et al. Evidence-based psychological treatments for insomnia in older adults. Psychol Ageing 2007; 22:18

5 Trauer JM, Qian MY, et al. Cognitive Behavioral Therapy for Chronic Insomnia: A Systematic Review and Meta-analysis. Ann Intern Med 2015; 163:191

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6 Sateia MJ, Buysse DJ, et al. Clinical practice guideline for the pharmacologic treatment of chronic insomnia in adults: an American Academy of Sleep Medicine clinical practice guideline. J Clin Sleep Med. 2017; 13(2):307-349.

7 Halcion (triazolam) tablets Prescribing Information. Pfizer Pharmacia & Upjohn Co. New York, New York 10017. Revised October 2019; accessed at https://www.accessdata.fda.gov/drugsatfda docs/label/2019/017892s050lbl.pdf

8 Prosom (estazolam) tablets Prescribing Information. Teva Pharmaceuticals USA, Inc. North Wales, PA 19454. Revised December 2016; accessed at https://www.drugs.com/pro/estazolam.html

9 Restoril (temazepam) capsules Prescribing Information. Mylan Pharmaceuticals Inc. Canonsburg, PA 15317. Revised August 2019; accessed at https://www.drugs.com/ppa/temazepam.html

10 Dalmane (flurazepam) capsules Prescribing Information. Mylan Pharmaceuticals Inc. Morgantown, WV 26505. Revised February 2019; accessed at https://www.drugs.com/pro/flurazepam.html

11 Doral (quazepam) tablets Prescribing Information. Galt Pharmaceuticals, LLC. Atlanta, GA. Revised 12/2018; accessed at https://www.accessdata.fda.gov/drugsatfda docs/label/2019/018708s025lbl.pdf

12 Sonata (zaleplon) capsules Prescribing Information. Pfizer Inc. New York, NY 10017. Revised August 2019; accessed at https://www.accessdata.fda.gov/drugsatfda docs/label/2019/020859s016lbl.pdf

13 Ambien (zolpidem) tablets Prescribing Information. Sanofi Aventis U.S. LLC Bridgewater, NJ 08807. Revised August 2019; accessed at https://www.accessdata.fda.gov/drugsatfda docs/label/2019/019908s046lbl.pdf

14 Ambien CR (zolpidem tartrate) extended release tablets Prescribing Information. Sanofi Aventis U.S. LLC Bridgewater, NJ 08807. Revised August 2019; accessed at https://www.accessdata.fda.gov/drugsatfda docs/label/2019/021774s027lbl.pdf

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16 Rozerem (ramelteon) tablets Prescribing Information. Takeda Pharmaceuticals America, Inc. Deerfield, IL 60015. Revised December 2018; accessed at https://www.accessdata.fda.gov/drugsatfda docs/label/2018/021782s021lbl.pdf

17 Belsomra (suvorexant) tablets Prescribing Information. Merck & Co, Inc. Whitehouse Station, NJ 08889. Revised July 2018; accessed at https://www.accessdata.fda.gov/drugsatfda docs/label/2018/204569s005lbl.pdf

18 Silenor (doxepin) tablets Prescribing Information. Somaxon Pharmaceuticals, Inc. San Diego, CA 92130. Revised March 2010; accessed at https://www.accessdata.fda.gov/drugsatfda docs/label/2010/022036lbl.pdf

19 Yi XY, Ni SF, et al. Trazodone for the treatment of insomnia: a meta-analysis of randomized placebo-controlled trails. Sleep Med 2018; 45:25.

20 Eisai Inc. Dayvigo (lemborexant), Module 2.5 Clinical Overview

Reference ID: 4528864

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21 Eisai Inc. Dayvigo (lemborexant), Module 2.7.3 Summary of Clinical Efficacy

22 Redwood, S., D’Alessandro D. Patient Labeling Review dated November 25, 2019

23 Eisai Inc. Dayvigo (lemborexant), Module 2.7.4 Summary of Clinical Safety

24 Bonson, K. General Consult Review dated October 30, 2019

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