Monday 4 February 2013

Depomed Serada: odds stacked against positive Advisory Committee Vote


Thank-you to Adam Feuerstein for publishing this article on the Serada bear thesis.  For those of you who are interested in a bit more depth, the unedited version is featured here.


I don’t disagree with recent reports suggesting Serada, Depomed’s proprietary extended release formulation of gabapentin represents significant upside potential to the stock. Although, I think the probability of a positive panel vote (and subsequent approval) is slim, this does however, provide interesting trading opportunities into the run up to the panel on March 4, 2012 and the release of the FDA briefing documents expected no later than 2/28/2012.

1)      What’s the rationale for using gabapentin to treat menopausal hot flashes?

Vasomotor symptoms (VMS) of menopause  or hot flashes are experienced by the majority of women during the menopausal transition, with prevalence rates varying by racial/ethnic group and being influenced by risk factors such as age, BMI and smoking status . Although the pathophysiology is not fully understood, a reduction in endogenous reproductive hormones and thermoregulatory changes are both thought to contribute to the etiology.  Temperature information is processed within the anterior hypothalamus in the preoptic area (POA), where it is hypothesized that heat-sensitive neurons control the release of heat.  Serotonergic neurons and noradrenergic pathways have both been identified as projecting into the POA and hence, given data linking estrogen fluctuations to a reduction of serotonin and norepinephrine, it has been proposed that pharmacologic agents such as serotonin reuptake inhibitors and serotonin–norepinephrine reuptake inhibitors may help to reestablish levels of these neurochemicals within the thermoregulatory centers, reducing the occurrence of VMS.  The role (if any) of GABA transmission in temperature regulation is undefined.

2)      Why use gabapentin to treat hot flashes if there is no sound physiologic basis?

Good question, maybe the role of gabapentin in this setting is tenuous at best.  The results of the Serada phase 3 program would tend to support this.  BREEZE-1 and BREEZE-2 were two randomized, double-blind, placebo-controlled studies of approximately 540 patients per study, receiving treatment at either 1200mg or 1800mg daily or placebo.  Total treatment duration in BREEZE-1 was six months, with primary efficacy endpoints assessed after 4 and 12 weeks of stable therapy. Persistence of efficacy was to be assessed at 6 months as a secondary endpoint. Treatment duration in BREEZE-2 was three months, also with assessment of efficacy at 4 and 12 weeks. In both studies, the coprimary end points were to assess the mean change in frequency and severity of symptoms from baseline to week 4 and 12.  The results were reported in 2009 and both studies failed to meet all of the primary end points for statistical significance.  There are many issues with the data which only serve to raise questions as to the true clinical benefit for this drug in a VMS setting.  In BREEZE-1, 36% of patients receiving treatment at 1200mg, and 30% of those receiving 1800mg failed to complete the study.  These are very high drop-out rates for any trial and raise concerns as to why patients were leaving the study. Some women can experience VMS for years, so any treatment needs to be well tolerated, safe, and to demonstrate persistent benefit. Serada did not consistently exhibit persistency of effect for even 12 weeks let alone 24. The 24 week data were never reported fully reported but will hopefully surface in March. At best, the results of BREEZE-1 and BREEZE-2 seem to indicate that treatment is associated with ~1 less hot flash per day compared with placebo treatment for a short period of time. Historically, the placebo effect in VMS studies has always been ~50% response without explanation, so how “real” is the Serada treatment effect and how meaningful is it to women who would be taking this especially in light of the overall gabapentin adverse event profile?  The FDA’s responder analyses will surely shed light on some of this. Of course, there is a bull argument in favor of statistically manipulating these data in order to get a positive outcome which has been summarized here by @JNapodano.  I have previously quoted a statistical adage that “if you torture the data long enough, it will confess to anything”. Depomed certainly should be commended on their statistical prowess in explaining why both BREEZE-1 and BREEZE-2 failed, but I am certainly not convinced that removing 2 outliers from a study enrolling >500 patients is enough to make it statistically meaningful.

However, statistics aside, it’s the absolute efficacy benefit that will be a review issue and it will be interesting to see the placebo adjusted frequency and severity scores debated at the Reproductive Health Drugs Advisory Committee. It will also be interesting to see how the lack of any meaningful persistency of effect at 24 weeks will be perceived, this is after all a regulatory benchmark for approval.

Aspiring to seize victory from the jaws of defeat,  Depomed went back to FDA and reached agreement on a Special Protocol Assessment (SPA) for BREEZE-3, a double-blind, placebo-controlled study of approximately 600 patients, randomized to receive either placebo or a total dose of 1800mg of Serada. The co-primary efficacy endpoints were reductions in the mean frequency of moderate-to-severe hot flashes, and the average severity of hot flashes, measured after 4 and 12 weeks of stable treatment. As in the prior BREEZE-1 trial, the treatment duration of the study was 24 weeks, to establish the regulatory requirement for persistence of efficacy. The results were reported in October 2012: Using the pre-specified non-parametric statistical analysis, the trial results for the co-primary endpoints were statistically significant for the reduction in average frequency of hot flashes at 4 weeks (p=0.0003), the reduction in the average severity of hot flashes at 4 weeks (p<0.0001) and 12 weeks (p=0.0102), but were not statistically significant for the reduction in average frequency of hot flashes at 12 weeks (p=0.10). The results were not statistically significant at 24 weeks for the reduction of hot flash frequency (p=0.2351) or severity (p=0.1510).  Oh dear.

At the end of the day, the conditions of the SPA were not fully met in this study, the drug still doesn’t show a significant reduction in frequency of hot flashes beyond 4 weeks, and given that the two supporting trials failed to hit a single end point, it casts major doubts as to why Serada would provide any meaningful clinical benefit in VMS, especially when women experience symptoms for months to years.

3)      Bulls argue that we need safer alternatives to hormone replacement therapy(HRT)

Firstly we know a lot more today about HRT and the long term risk profile in women treated for early menopausal symptoms and late menopausal symptoms. The 2012 Hormone Therapy Position Statement of The North American Menopause Society clarifies the benefit-risk ratio of estrogen therapy versus estrogen-progestogen therapy for both treatment of menopause-related symptoms and disease prevention at various time intervals since menopause.  In many cases, estrogen therapy with or without progesterone therapy (the most effective treatment for VMS) and can be used safely for prolonged periods of treatment (e.g. 3-7 years) without any increased risk of malignancy. Obviously there will be women whose risk profile is not appropriate for HRT and there are effective alternatives in the pipeline, which brings me to a major reason I feel Depomed will not get a positive Committee Panel vote.  

On March 4, 2013, during the afternoon session, the Committee will discuss the NDA submitted by Noven Therapeutics, LLC, for Low-dose Mesylate Salt of Paroxetine (LDMP) for the treatment of VMS associated with menopause. Paroxetine is a potent and highly selective serotonin-reuptake inhibitor and the putative mechanism for efficacy in VMS would relate to regulation of serotoninergic transmission in the POA/thermoregulatory center.

Noven has completed 2 studies as part of the clinical development program.  The first trial was a 24-week, multicenter, double-blind, randomized, placebo-controlled, Phase 3 study of LDMP in postmenopausal women with moderate to severe VMS. Eligible subjects entered a 12-day, single-blind run-in period, and were randomized 1:1 to receive LDMP 7.5 mg or placebo for 24 weeks. Unlike Serada which is dosed twice a day, LDMP is taken as a single nightly dose. Primary efficacy end points were mean changes in frequency and severity of moderate to severe VMS from baseline to Week 4 and Week 12.  Persistence of effect at week 24 was evaluated with a responder analysis, where a responder was defined as a subject with ≥50% reduction in VMS frequency from baseline to Week 24. Mean weekly reductions in VMS frequency were significantly greater for LDMP than placebo at Week 4 (–28.9 and –19.0, respectively; P<0.0001) and at Week 12 (–37.2 and –27.6, respectively; P=0.0001).  Of course, this also needs to be translated into absolute placebo-adjusted efficacy benefit for patients, but overall the study met all end points.

Importantly, unlike Serada, significantly more subjects treated with LDMP than placebo were responders at Week 24 (47.5% vs. 36.3%, respectively; P=0.0066), demonstrating persistence of treatment benefit.  Most commonly reported treatment emergent adverse events were nasopharyngitis (5.1% vs 4.9%), headache (4.3% vs 3.7%), nausea (3.8% vs 1.4%),fatigue (3.4% vs 1.5%), diarrhea (2.9% vs 2.5%), and dizziness (2.0% vs 0.8%).

Noven also reached SPA agreement with the FDA for the second study in the clinical development program. This was a 12-week, multicenter, double-blind, randomized, placebo-controlled, phase 3 study of LDMP in postmenopausal women with moderate to severe VMS (>7-8 moderate to severe hot flashes daily).  This study was identical in design to the first, with the same 12-day run in period prior to randomization. Overall, 614 subjects were randomized, and importantly, 549 subjects(271/306 [88.6%] LDMP; 278/308 [90.3%] placebo) completed the study (a stark contrast to the completion rates observed in BREEZE-1). Mean weekly reductions in VMS frequency from baseline were significantly greater for LDMP than placebo at week 4 (–33.0 and –23.5, respectively; P < 0.0001) and at week 12 (–43.5 and –37.3, respectively; P = 0.0090). Mean weekly reductions in the frequency of moderate to severe hot flashes were significantly greater for the LDMP group than for placebo beginning at week 1 and continuing until the end of treatment (P ≤ 0.0259 for all comparisons). Mean weekly reductions in VMS severity from baseline were significantly greater for LDMP than placebo at Week 4 (–0.09 and –0.05, respectively; P = 0.0048) but not at week 12 (–0.10 and –0.09, respectively; P = 0.2893). Mean weekly reduction in VMS hot flash composite scores (moderate and severe) from baseline were significantly greater for LDMP than placebo at week 4 (–85.51 and –60.83 respectively; P < 0.0001) and at Week 12 (–111.9 and –96.85 respectively; P = 0.0063).  There were no new safety signals and the drug was well tolerated.

Now given that the Advisory committee will be reviewing both NDA’s for the exact same indication on the same day, it is very likely that the same panel members (or at least a large overlap) who review Depomed Serada in the morning will be reviewing LDMP in the afternoon, and hence will be reviewing both sets of briefing documents ahead of time.

Let’s don our committee member hats and consider the two packages for a moment:

AM Session Serada :       Minimal mechanistic plausibility as to why it should work in VMS, dosed twice a day, high patient dropout rates in clinical studies, failed to meet majority of prospectively defined end points in two large randomized controlled studies, failed to demonstrate significant reduction in frequency of hot flashes beyond 4 weeks in third confirmatory study, failed to demonstrate persistency of benefit at 24 weeks in every study, overall side effect profile and tolerability issues with gabapentin

PM Session LDMP:          Mechanistic rationale for efficacy in treating VMS, dosed once nightly, met 8/9 prospectively defined end points in two large, randomized controlled studies, significantly reduced the frequency of moderate to severe hot flashes at 12 weeks, and maintained persistence of effect at 24 weeks, excellent overall safety and tolerability profile

Hmmm….I know which way I would vote.

On a final note, in the extremely unlikely event that FDA were ever to approve Serada for the treatment of moderate to severe VMS, realistically, what could the drug potentially do in terms of peak sales? Here is my liberal sales estimate with assumptions. (The conservative version is a lot lower).

10 MM per year seeking treatment for hot flashes

75% agreeing to try pharmacotherapy following consultation (high estimate)

30% requiring alternative to HRT

5% peak market share for Serada

90% patients given a prescription choosing to fill it

50% likelihood that prescription filled with Serada first as opposed to generic substitution with gabapentin. (Note: this drug is “extended release” yet needs to be dosed twice daily, there is no evidence that this confers any benefit over generic gabapentin from a managed care perspective so it is  likely (if ever approved) Serada will have a low tier formulary status and will frequently be subject to generic substitution)

Average course of treatment 3 months (Note: 30% of patients failed to complete the studies so there is no reason to believe real world experience would be different, in fact I would predict a high drop off rate after the first script. The drug does not demonstrate persistent effects beyond 4 weeks under clinical trial conditions, so it is extremely unlikely the average course of therapy will be as high as 9 months).

Average cost per script $225

Peak Sales Estimate: 10MM x 75% x 30% x5% x 90% x50% x3 x 225 = $34 MM

 

Disclosure:  I am long in March puts

This article is not intended as, nor should it be taken as investment advice. Do you own due diligence before trading securities.

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