FDA Introductory Remarks January 17, 2019 Endocrinologic and Metabolic Drugs Advisory Committee Meeting
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FDA Introductory Remarks January 17, 2019 Endocrinologic and Metabolic Drugs Advisory Committee Meeting Lisa Yanoff, MD, Acting Director Division of Metabolism and Endocrinology Products Office of New Drugs Center for Drug Evaluation and Research Food and Drug Administration Introduction • Diabetes mellitus affects over 30 million people in the United States – Approximately 5-10% are type 1 diabetes • Increases risk of micro- and macro-vascular complications • Improving glycemic control has been main goal of treatment – Reduce risk for microvascular complications such as diabetic retinopathy, diabetic nephropathy, diabetic neuropathy 2 Establishing Benefit of a Drug for Diabetes • HbA1c (hemoglobin A1c / glycated hemoglobin) – Irreversible attachment of glucose to hemoglobin – Directly proportional to the ambient glucose concentration – Correlates with average blood glucose over the preceding 2 or 3 months. – Standardized assay • HbA1c reduction is surrogate for benefit on microvascular disease – Clinical trials have established that glycemic lowering results in a reduction in the onset and progression of microvascular complications (DCCT, UKPDS) DCCT: Diabetes Control and Complications Trial; UKPDS: United Kingdom Prospective Diabetes Study 3 Available Therapies for Diabetes Mellitus Drug Class Drug Products Insulin and insulin analogs Multiple products including basal, prandial, and mixed insulin Biguanides Metformin Sulfonylureas Chlorpropamide, Glimepiride, Glipizide, Glyburide Thiazolidinediones Rosiglitazone, Pioglitazone Meglitinides Repaglinide, Nateglinide Alpha glucosidase inhibitors Acarbose, Miglitol Dipeptidyl peptidase-4 (DPP-4) inhibitors Sitagliptin, Saxagliptin, Alogliptin, Linagliptin Glucagon-like peptide-1 (GLP-1) receptor agonists Exenatide (as a twice daily and as a once weekly), Liraglutide, Albiglutide, Dulaglutide, Lixisenatide, Semaglutide Sodium glucose cotransporter-2 (SGLT2) inhibitors Canagliflozin, Dapagliflozin, Empagliflozin, Ertugliflozin Amylin analogs Pramlintide Bile acid sequestrants Colesevelam Dopamine agonists Bromocriptine Drugs in bold and red font are indicated for type 1 diabetes 4 SGLT2 Inhibitors • As an adjunct to diet and exercise to improve glycemic control in adults with type 2 diabetes mellitus – Canagliflozin (2013) – Dapagliflozin (2014) – Empagliflozin (2014) – Ertugliflozin (2017) • Cardiovascular indications in adult patients with type 2 diabetes mellitus and established cardiovascular disease – Empagliflozin (2016) – Canagliflozin (2018) There are no SGLT inhibitors approved as adjunct to insulin treatment of T1DM 5 Sotagliflozin • SGLT2: acts systemically at renal proximal tubule to inhibit reabsorption of filtered glucose – Increased urinary glucose excretion – Lower plasma glucose levels • SGLT1: present in the small intestine – Clinical impact unclear • Adjunct to insulin in adults with type 1 diabetes mellitus • Proposed doses are 200 mg daily and 400 mg daily SGLT2i: sodium glucose co-transporter 2 inhibitor 6 Meeting Agenda • Presentations from Applicant • Presentations from FDA • Open Public Hearing • Questions to the Panel 7 Question 1 (Discussion) Discuss the benefits claimed by the applicant, e.g. glycemic control, effects on body weight and risk for hypoglycemia, for patients with type 1 diabetes. Comment on the strength of the statistical evidence and clinical meaningfulness of each of these claimed benefits. 8 Question 2 (Discussion) Discuss your level of concern about the observed risk of diabetic ketoacidosis (DKA) in adult patients in the sotagliflozin clinical studies and DKA risk associated with sotagliflozin use in a real-world setting. 9 Question 3 (Discussion) Comment on any relevant differences in efficacy and/or safety observed between the two proposed doses of sotagliflozin (200 mg and 400 mg). In your discussion please consider the clinical pharmacology data as well as clinical trial data, i.e. improvement in glycemic control and risk for DKA. 10 Question 4 (Discussion) Discuss the overall benefit risk profile of sotagliflozin for patients with type 1 diabetes. What specific benefits and risks did you consider; what was your approach and rationale for how they were weighed against each other? Specifically comment on the composite endpoint used by the applicant (HbA1c<7% with no episodes of severe hypoglycemia or diabetic ketoacidosis) to represent net benefit. If you would recommend an alternative strategy, please explain your rationale. 11 Question 5 (Vote) Do the available data suggest that the benefits outweigh the risks and support approval of sotagliflozin, administered orally once daily, as an adjunct to insulin to improve glycemic control in adults with type 1 diabetes mellitus? a. If yes, comment on whether you recommend any labeling restrictions, whether any additional studies should be required after approval, and comment on whether your vote indicates support for both proposed doses of sotagliflozin (200 mg and 400 mg). b. If no, please describe your rationale and what further studies you believe the applicant should conduct to establish a favorable benefit risk profile to support approval. 12 Overview of the Clinical Pharmacology and Development Program for Sotagliflozin January 17, 2019 Endocrinologic and Metabolic Drugs Advisory Committee Meeting Mitra Rauschecker, MD Division of Metabolism and Endocrinology Products Office of New Drugs Center for Drug Evaluation and Research Food and Drug Administration 1 Outline of FDA Presentations • Clinical Pharmacology • Sotagliflozin development program • Efficacy findings • Diabetic Ketoacidosis (DKA) in the Sotagliflozin Clinical Development Program • Presentation of DKA cases from the FDA Adverse Event Reporting System (FAERS) • Sentinel Analysis of DKA cases 2 Clinical Pharmacology of Sotagliflozin Clinical Pharmacology Agenda • Pharmacokinetics of Sotagliflozin • Pharmacodynamics of sotagliflozin: SGLT-1 and SGLT-2 – Mechanistic study in healthy subjects – Dose-ranging study in Type 1 Diabetes (T1DM) • Correlation of relevant clinical observations to sotagliflozin systemic exposure – Insulin dose – Glucose (urinary glucose excretion) – HbA1c SGLT: sodium glucose co-transporter 4 Sotagliflozin Clinical Pharmacokinetics Representative Pharmacokinetic Profile of Single 400 mg Dose in Healthy Subjects (n=8) • Once-daily dosing supported with >20 hour t1/2 • Exposure affected by: . body weight . renal impairment (>1.5-fold in eGFR < 45) . hepatic impairment (>3-fold in moderate and severe) • Not proposed for eGFR<45 and moderate and severe hepatic impairment eGFR=estimated glomerular filtration rate 5 Sotagliflozin Effect on Urinary Glucose Excretion (UGE) in T1DM • Study 206 - Randomized, double-blind, parallel design dose ranging study in T1DM • Placebo, 75, 200, and 400 mg once daily dosing over 12 weeks • This dose ranging study was conducted in parallel with the phase 3 studies • Sotagliflozin increases UGE in a dose dependent manner 6 Sotagliflozin Effect on Glucose Absorption Absorption rate of Glucose • Study 111- Randomized, single dose, crossover study in healthy subjects (n=24) Placebo • Isotope tracer glucose drink within 15 minutes after 400 mg sotagliflozin or placebo Sotagliflozin • Sotagliflozin delays glucose absorption without change in the total amount of glucose absorbed 7 Sotagliflozin Effect on Self-Monitored Blood Glucose (SMBG) SMBG Data from Phase 3 Trial 309 8 Insulin Dose Change with Sotagliflozin Treatment Insulin Data from Phase 3 Trial 309 Transient bolus insulin dose reductions may affect post-prandial glucose excursions 9 Distribution of Average Plasma Concentrations 10 Flat Exposure-Response Relationship for HbA1c Pooled Data from Phase 3 Trial 309 and 310 11 Sotagliflozin Exposure - UGE and Insulin Dose Relationship Trend in UGE had a mirror image pattern with insulin dose reduction 12 Clinical Development Program for Sotagliflozin Study 309/310- Trial Design Insulin Screening Core Treatment Period Extension Follow-up Optimization/Single- Period 24 weeks Period Period Blind Run-In Period Inclusion criteria: Sotagliflozin 200 mg adults 18 yrs or older with T1DM Randomization Sotagliflozin 400 mg HbA1c 7.0-11.0% BMI≥18.5 kg/m2 Placebo eGFR ≥45 ml/min/m2 Week -8 Week -6 Week -2 Day 1-Baseline Week 24 Week 52 14 Study 312- Trial Design Double-blind Screening Single-Blind Placebo Follow-up Treatment Period Period Run-In Period Period 24 weeks Inclusion criteria: Sotagliflozin 400 mg adults 18 yrs or older with T1DM HbA1c 7.0-11.0% Randomization BMI≥18.5 kg/m2 eGFR ≥45 ml/min/m2 Placebo Week -4 Week -2 Day 1 Week 24 Baseline 15 Study Outcomes • Efficacy Outcomes – HbA1c – Fasting Plasma Glucose – Body Weight – Insulin Dose – CGM time-in-range in small subset • Safety Outcomes – Adverse Events – Deaths – Adverse Events of Special Interest (AESI) • DKA • Hypoglycemia CGM=continuous glucose monitoring 16 Results of Phase 3 Studies Study Disposition Study 309/310 Study 312 200 mg 400 mg Placebo 400 mg Placebo Randomized patients/ 524 525 1049 700 705 mITT population Discontinued before 24 weeks 45 (8.6) 49 (9.3) 55 (10.5) 95 (13.6) 81 (11.5) n (%) Completed 24 weeks n (%) 479 (91.4) 476 (90.7) 471 (89.5) 605 (86.4) 624 (88.5) 18 Demographic Characteristics Study 309 Study 310 Study 312 200 mg 400 mg Placebo 200 mg 400 mg Placebo 400 mg Placebo Randomized patients 263 262 268 261 263 258 699 703 Duration of T1DM (yrs) 25.0 24.0 24.2 18.2 18.9 18.1 20.5 19.6 Age in years (mean) 46.6 46.4 45.2 42.3 41.7 39.7 43.3 42.4 HbA1c (%) 7.6 7.6 7.5 7.7 7.7 7.8 8.3 8.2