Tag: Molly Burich

Will Government Action to Spur the Biosimilars Industry Have Any Bite?

“Biosimilars are such an underutilized entity to truly drive down costs and generate savings. We are heartened by the fact that several pieces of legislation have been introduced to help change provider and patient incentives,” said Molly Burich, MS, Director, Public Policy, Biosimilars and Reimbursement at Boehringer Ingelheim.

A panel at last week’s GRx+Biosims meeting focused its remarks on the potential of legislative proposals brewing on Capitol Hill to incentivize biosimilar uptake.

Incentives for Patients and Doctors

In Medicare Part B, Ms. Burich explained, beneficiaries have a 20% co-insurance, and about 85% will have wraparound or gap insurance that covers this out-of-pocket cost. However, about 15% do not. According to Ms. Burich, removing this co-insurance for biosimilar use through the legislative process would generate sufficient savings through the lower costs of these drugs to fund it.

Molly Burich, MS

“Physicians say that patient out-of-pocket costs,” she noted, “are their number 2 concern.” She also raised the potential of utilizing a shared-savings model to incentivize biosimilar use, such as allowing clinicians who prescribe the lower-cost drug to share in the government’s savings. Legislation containing this provision has not yet been introduced, she emphasized.

Another mechanism to induce greater physician prescribing is to increase the average sales price (ASP) add-on payment, where ASP+8% may incent more physicians to prescribe biosimilars. The current payment of ASP+6% hasn’t encouraged sufficient physicians and groups to move to biosimilars, said Ms. Burich.

What About Part D?

Recognizing that virtually all marketed biosimilars are covered under a medical or Part B benefit, Mr. Burich pointed out that “we should be using this time to prepare the Part D benefit for biosimliars.” Many payers currently manage the use of self-administered injectables under the pharmacy (or Part D) benefit, and when adalimumab biosimilars are available in 2023, payers will need to be ready. She said that a couple of ideas were introduced around the Medicare Star ratings for Medicare Advantage plans, by perhaps alerting beneficiaries of lower-cost products being available on formulary.

Erika Satterwhite

As Erika Satterwhite, Head of Global Biosimilars Policy at Mylan, stated, “The core principal of biosimilars is access.” Yet, patent abuse is the number 1 challenge to bringing new biosimilars to the market. Admittedly, after the flurry of discussions earlier this year about the Federal Trade Commission (FTC) exercising its authority to invalidate anticompetitive patents, there is little activity to change this at the moment. Several current proposals in the Congress and Senate attempt to limit the number of patents for biologics that can be claimed subject to infringement (e.g., 20 in at least one proposal), but these bills, if passed, would only affect new biosimilar applications and companies choosing to participate in the “patent dance.”

    James Carey

    Even some biotechnology manufacturers are beginning to recognize the inherent problems with patents and access. James Carey, Executive Director, US Health Policy, Merck & Co., Inc, said, “Intellectual property [IP] is the lifeblood of our innovation. However, we have made it clear that we have a strong belief that once the IP has been exhausted, safe and effective biosimilars should be available on the market.” One bill in the House would require more transparency around patents; this would be reflected in a far more useful Purple Book than exists today.

    Christine Simmons, Executive Vice President of the Association of Accessible Medicines, and President of the Association’s Biosimilar Council, reminded the audience that the inter partes review system “still remains an important avenue to resolve patent disputes.” Yet, as Mr. Carey pointed out, “The courts are clogged with cases—we need more judges to get through the backlog.” Ms. Simmons believes that we must maintain the ability for the biosimilar and innovator manufacturer to settle, and avoid waiting for the full patent expirations (perceived by the reference manufacturer).

    What should be the role of the FTC? Ms. Simmons commented that the FTC has long been active on the biosimilars front. “The agency argued that an exclusivity period for biologics was unnecessary, and the FTC argued that the use of four-letter suffixes would harm their uptake. They’ve been engaged around the misinformation as well. However, much of their participation has been rhetorical. They haven’t had the opportunity to dig in,” she said. The panelists would not comment on FTC’s potential role in considering whether rebates were anticompetitive.

    Reference Pricing and Drug Pricing

    Ms. Satterwhite asserted that the success of biosimilars in Europe was not the result of an external referencing pricing model. “Implementing tenders in a place that does not use them does not get you to lower pricing,” she said.

    Reference pricing, Ms. Satterwhite emphasized, could actually reduce access. “The European Commission has recommended against its use on the continent,” she said. “You need to look at the market context of the country you’re focused on.” Ms. Burich added that in the different EU countries, “many incentives were implemented for physicians and patients,” with the objective of  driving awareness of biosimilars.

    Biosimilars in the US have long been viewed as a market-based way of increasing competition and lowering drug prices. The proposals today to negotiate Medicare drug prices for up to 250 drugs (as well as use of reference pricing mechanisms) could have a dramatic adverse impact on the pharmaceutical industry—perhaps up to $1.2 trillion over 10 years. “That means jobs will be lost and products won’t make it to market,” said Mr. Carey. He pointed out that Medicare drugs (in the Part B benefit by Medicare Advantage plans and in the Part D benefit by Part D plans) are negotiated heavily today.

    Ms. Satterwhite reemphasized that the key point is sustainability of the biosimilar market in the US. “We need to unlock the barriers to sustainable competition, not just seek a short-term price cut.”

    The question remains whether the myriad proposals put forth will enable the federal government to have a greater ability to assure this sustainability. To date, there is a great deal of talk but very little substantive action.

    In other biosimilar news…Biogen is taking a more active role in promoting biosimilars in the US market. The Massachusetts-based company has been a principal investor in Samsung Bioepis. In 2018, it increased its investment in the South Korean company (to 50%). On November 6, it announced a deal with Samsung Bioepis to be the commercial marketer for SB11, an investigational ranibizumab biosimilar (reference drug, Lucentis®), and SB15, an investigational aflibercept (Eylea®). The new agreement also covers marketing rights for these products in Australia, Canada, Europe, and Japan. Biogen already markets Samsung biosimilars for etanercept, infliximab, and adalimumab biosimilars in Europe.

    Boehringer Ingelheim Gives up the Fight, Signs AbbVie Agreement on Adalimumab

    It seems that AbbVie has won the battle and the war. The last remaining holdout in the fight to bring a biosimilar adalimumab to market before 2023 has capitulated, as AbbVie announced May 14 that Boehringer Ingelheim agreed to the terms of a licensing arrangement. This agreement allows Boehringer Ingelheim to enter the marketplace July 1, 2023, getting a slight jump on some other licensees, but it effectively ends the protracted patent litigation that Boehringer hoped to win.

    In an interview with BR&R, Molly Burich, Boehringer Ingelheim’s Director, Public Policy, Biosimilars and Pipeline, told us in October 2018, “We are committed to making Cyltezo® available to US patients as soon as possible and certainly before 2023.”

    WHICH COMPANIES HAVE SIGNED LICENSING DEALS WITH ABBVIE?

    Company/Partner Drug Name Launch Date
    Amgen Amjevita* January 2023
    Samsung Bioepis/Merck SB5 June 2023
    Boehringer Ingelheim Cytelzo* July 2023
    Mylan/Fujifilm Kyowa Kirin Biologics Hulio August 2023
    Sandoz Hyrimoz* September 2023
    Fresenius Kabi MSB11022 September 2023
    Pfizer TBDNovember 2023
    Momenta M923 December 2023
    Coherus CH-1420 December 2023
    *Received FDA Approval.

    However, at that time, Ms. Burich also disclosed that Cyltezo would not be commercialized in Europe; in October, the stampede of biosimilar manufacturers had just left the starting gate. In addition, Boehringer had earlier decided to drop plans to develop other biosimilars in the pipeline and focus solely on Cyltezo. That would seem to leave Boehringer out in the cold until July 2023.

    In response to BR&R’s query, Susan Holz, Boehringer’s Director of Communications, Specialty Care, provided the following statement: “As we previously shared, at this point in time, our focus remains on providing patient access to our biosimilar Cyltezo in the US, and future biosimilars activities will be driven out of this market. Boehringer Ingelheim continuously evaluates our business portfolio, and we assess potential strategic partnerships to help enhance our pipeline and development capabilities. As you know, we have stopped development activities for the rest of the world, and I am not able to comment on specifics regarding our biosimilar in- or out-licensing strategy.”

    Boehringer Ingelheim had reported that it is seeking the interchangeability designation for its adalimumab biosimilar. In the possible scenario where Cyltezo won its patent challenge, and gained the interchangeability designation from the FDA (note that FDA only issued its final interchangeability guidelines draft this week), the marketing potential was rosy indeed. However, suppose the FDA approves the interchangeability label for Cyltezo. It cannot leverage it until after Amgen’s and Samsung Bioepis’ adalimumab biosimilars have launched. Will it have the same advantage? That’s difficult to say. Payers will be anxious to grab immediate savings on this product, and interchangeability may not be considered such a great benefit. That is, in four years, will payers routinely switch available biosimilar agents anyway? My guess is that health plans and insurers will be leaning in that direction.

    On the other hand, it will be easier to automatically switch patients in nearly every state. That lever will only be used if Boehringer gives payers a real reason to use it—a significantly better deal than the existing options. AbbVie offered huge discounts (on the order of 80% in some countries) in an effort to hang on to some marketshare once biosimilars were available in the EU. After all, why worry about interchangeability and switching when you can continue to use Humira® at a 75% discount?

    Ms. Holz told BR&R, “In regards to interchangeability, this is a very important issue for many stakeholders, as it is the catalyst for automatic substitution at the pharmacy level, which in turn may help drive efficient use of biosimilars and maximize the cost-saving potential of these important medicines.” She added, “We were very pleased to see the Agency finalized interchangeability guidance that retained the appropriate balance between a high-bar to prove interchangeability and product-specific flexibility to make such a status attainable.”

    In the next four years, the price of Humira will undoubtedly rise. This will mean that savings gained in 2023 will be little more than money lost to the system over the previous 48 months. As significantly, it represents tens of billions of dollars into AbbVie’s bottom line from a product that was approved in the US 17 years ago.

    An Update on Potential Biosimilars for Bevacizumab

    Embroiled in patent litigation, the partnership of Amgen and Allergan have waited for the opportunity to launch Mvasi® since September 2017. During this time, the competition has not been stagnant, with Pfizer moving towards an FDA decision. The next 6 months may prove critical, but when will providers, patients, and payers have access to Avastin® biosimilars? That may be based more on guesstimates than on fact.

    Avastin patent litigation

    WHAT DO WE KNOW?

    (1) Amgen and Allergan received its FDA approval for Mvasi (bevacizumab-awwb) September 17, 2017. The approval covered all of the reference product’s indications. The drug was approved for use by the European Medicines Agency in January 2018.

    (2) In court documents filed during its patent battle with Genentech, Amgen had originally stated that it planned to begin marketing Mvasi once the last 8 patents it considered valid expired on December 18, 2018.

    (3) Amgen then revised this potential launch date, according to the court filing, saying that it could launch several months earlier, on April 5, 2018.

    (4) In either case, the launch has not occurred. According to the Purple Book, Avastin was first approved by the FDA February 26, 2004. That is approximately 15 years, and counting.

    (5) The US District Court handling the litigation is expressing impatience with the back and forth between the two parties (read the Judge’s concluding remarks). A trial court date was set for June 2020.

    (6) Pfizer completed its phase 3 trial for PF-06439535 in nonsquamous non–small cell lung cancer and filed for FDA approval in August 2018. An FDA decision is expected in the second quarter of this year.

    (7) In November 2018, Boehringer Ingelheim completed its phase 3 trial in lung cancer for BI 695502.

    (8) Samsung Bioepis completed its phase 3 trial in lung cancer in October 2018 (compared with EU-licensed Avastin).

    (9) In addition, Centus Biotherapeutics is scheduled to complete its phase 3 trial in June 2019 as well.

    WHAT WE DON’T REALLY KNOW

    So much for what we know. Here are some things we know less well.

    At a drug pipeline update at the Academy of Managed Care Pharmacy in October 2018, Express Scripts’ Aimee Tharaldson, PharmD, Senior Clinical Consultant—Emerging Therapeutics, offered a projected launch date of July 2019. In an E-mail communication with Biosimilars Review & Report, Dr. Tharaldson clarified that this estimate was based on the anticipated expiration of a key patent on Avastin that month.

    Bevacizumab Biosimilars
    Aimee Tharaldson, PharmD

    When we contacted a senior Amgen executive, he stated that the company declined to discuss potential launch dates.

    Goodwin’s Big Molecule Watch, which keeps a close eye on biosimilar-related patent litigation, does not list any ongoing suits between Genentech and Pfizer or Boehringer Ingelheim regarding Avastin (which may be surprising in itself).

    We would anticipate that Pfizer will launch as soon as feasible, if they receive an FDA approval by June. Pfizer has an established record of moving their biosimilars quickly to market (e.g., Inflectra® [with Celltrion], Retacrit®, and Nivestym®).

    Samsung Bioepis has not yet revealed their plans around an FDA filing for their investigational biosimilar of bevacizumab.

    Boehringer had not yet filed a 351(k) application for approval of BI 695502. Comments by Molly Burich, Director, Public Policy: Biosimilars and Pipeline, in our interview last Fall, made it clear that the company is laser focused on bringing its adalimumab biosimilar (Cytelzo®) to market. In fact, this bevacizumab biosimilar was no longer posted on their pipeline at that time.

    WHAT WE FOUND OUT

    Today, Susan Holz, Director, Communications, Specialty Care, confirmed that the company decided that this agent was not in its strategic plans and it simply allowed the study to be completed. She said, “Boehringer Ingelheim made the decision to terminate all activities related to the BI 695502 program, a biosimilar candidate to Avastin. It is important to note that this decision was not based on any safety or efficacy findings with the investigational medicinal product BI 695502. Boehringer Ingelheim continuously evaluates our business portfolio and assesses potential strategic partnerships to help enhance our pipeline and development capabilities.”

    Perhaps several of these unknowns will be resolved by the end of July, and the clouds will lift a bit. I suspect at that time, we’ll be much closer to biosimilar access for this biologic, which racked up $7 billion worldwide in sales in 2017.

    Federal Policy and Biosimilars: A Conversation With Molly Burich, MS, Boehringer Ingelheim: Part 2

    In part two and the conclusion of this interview, Molly Burich, MS, Director, Public Policy: Biosimilars and Pipeline, speaks to Boehringer Ingelheim’s progress in Cytelzo interchangeability studies, its plans for the product in Europe in the face of several adalimumab biosimilars launches in the EU, and also the complexity inherent in CMS’s plans to move biologic agents from part B to part D coverage.

    Molly Burich, Boehringer Ingelheim
    Molly Burich, MS

    BR&R: Boehringer Ingelheim indicated that it started the study on Cytelzo interchangeability last year. What’s the progress on this effort?

    Burich: The trial is continuing to progress. It’s a high bar and a big commitment. We will certainly publicize relevant information in due course.

    We feel that for Cyltezo, in particular, interchangeability is an important component. It may drive switching. The study will also show a complement of clinical data around that topic. We hope to have information to share in the future. [Editor’s Note: The VOLTAIRE-X study, which will evaluate the effect of switching between Cyltezo and Humira in patients with plaque psoriasis, has an estimated primary study completion date of March 2020 and full study completion of July 2020, according to ClinicalTrials.gov]

    BR&R: Speaking about Cyltezo, I have a question about the marketing floodgates being opened in the EU for adalimumab biosimilars. At least 4 are being launched in the EU after the October 16th patent expiration. Does Boehringer Ingelheim plan to join the fray?

    Burich: Boehringer Ingelheim had planned to bring Cyltezo to patients in the EU. Due to the patent litigation with AbbVie in the US, we will not commercialize Cyltezo in the EU. Boehringer Ingelheim will continue all activities for our biosimilar in the United States. We are committed to making Cyltezo® available to U.S. patients as soon as possible and certainly before 2023.

    PART B TO PART D TRANSITION BY CMS 

    BR&R: Medicare has indicated that it will move many Medicare part B drugs into part D. To what extent will this affect biosimilar access and utilization?

    Burich: It is a very hot topic these days. We have some pretty significant concerns on conceptually around what it means for moving from part B to part D. The key reason revolves around the access question, including patient cost sharing.

    A move from part B to plan D could mean that patient cost sharing may jump significantly. We know that part B beneficiaries have wraparound or Medigap coverage to protect them from cost sharing issues. In part D, there is not such protection. Aside from the biosimilar question, the move from part B to part D really has to be explored and discussed a lot more to understand how we can ensure that patient access is not reduced through high cost sharing. That needs to be ironed out as it applies to any part B drug before we can speculate whether this is an opportunity for a biosimilar. Time will tell what that really looks like.

    Last month, CMS released the Medicare Advantage guidance allowing for step therapy for part B drugs. That could be a potential opportunity for biosimilars, if we know how some of the access concerns will be addressed. We just don’t have the full picture at this point.

    BR&R: Is it possible that this move to part D might spur some payers to create biosimilar tiers? These would require lower cost sharing for patients compared with reference biologics, assuming contracts with the reference manufacturer permits it.

    Burich: In my opinion, we’ll need access to more biosimilars before we see a lot of that activity. It’s hard to foresee what big benefit design changes will be coming, but it’s certainly possible. We’ll need a mature market in the US before that will happen.

    BR&R: The devil is in the details with this switching issue but there’s also an access issue. Plans can make midyear formulary changes, this would then apply to biosimilars and reference drugs covered under part D.

    Burich: This is an important issue. The latest guidance that we saw from CMS, which is now a couple of years old, allowed positive formulary changes. Adding the biosimilar to a formulary is always allowed mid-year. The question involves removing an originator product or changing its tier.

    CMS has said that those situations would be reviewed on a case-by-case basis. These rules preventing negative formulary changes midyear are there to protect patient access. It will take CMS some time to iron out what the process looks like for this type of potential formulary change midyear. For now, we’ll have to rely on CMS’s case-by-case review

    BR&R: In general, payers do not consistently fund and manage self-injectable specialty drugs in the same way. In some cases, they cover these agents under the pharmacy benefits, medical benefit, or even both. Further, they can be managed under either benefit as well. However, it seems we are moving toward pharmacy management of these agents. How does this affect biosimilar access, if at all?

    Burich: There will be more benefit design changes once we have a more robust biosimilar market. More specifically, when we have pharmacy benefit biosimilars.

    We’ve mentioned CMS’s intention to move more of these products from part B to part D. It is possible that commercial plans will have different benefit designs and treat injectables differently than Medicare does. We want to make sure that biosimilar or not, the access piece is really at the center of those changes; it will not be beneficial to the biosimilar market if this move causes significant patient access issues (e.g., actual access to this drug or big swings in cost sharing). All of those things will be equally problematic for a biosimilar as they are for an originator, so we want to make sure we have our eye on the access component.

    BR&R: Health and Human Services Secretary Azar and FDA Commissioner Gottlieb have loudly stated their desire to improve biosimilar patient and market access. The Biosimilar Action Plan was released earlier in the summer to that end. What is the one aspect of the Biosimilar Action Plan that appeals most to manufacturers like Boehringer Ingelheim?

    Burich: The aspect of education, tackling both proactive education and countering misinformation is very critical from our perspective. We’d like to see more materials moving forward that focus on switching and on interchangeability. We haven’t really scratched the surface on those topics from an education standpoint.

    The reality is that the FDA has an important voice and bringing validity to educational materials is so critical for patients, physicians, and health plans as well. We hope that the FDA will stand by its public commitment to release more reading materials, more videos, more web info, etc. It is especially important at this juncture; we are seeing misinformation and a lack of clarity on certain things.

    IS THE BIOSIMILAR ACTION PLAN ACTIONABLE?

    BR&R: One of the biggest barriers to biosimilar access is the patent thickets. The rebate trap problem is another story. What power does HHS have to clear out the patent thickets? Or is this an area that can only be addressed by Congress?

    Burich: This is the most difficult part of the Action Plan, because it is unclear who can truly implement change and what change might be realistic. We have to protect true innovation that’s important to all stakeholders.

    At the same time, there’s no question that patent litigation is the leading barrier to biosimilar accesss. Some makers of branded pharmaceuticals have constructed patent thickets so that they could sustain prolonged, expensive litigation against competitors, while stifling competition. Humira is the prime example: More than 15 years after the molecule was approved , no biosimilar is being marketed – in the U.S. What the answer is and which government agency can effect change has yet to be determined.

    BR&R: That change won’t come quickly, in any case. Whether enacted by Congress or the Office of the Inspector General, which may have to reinterpret the safe harbor statutes, this may only first apply to the second-generation of biosimilar agents, beyond 2021 perhaps. It seems likely that this will be a very deliberate process.

    Burich: I do believe Commissioner Gottlieb is thinking about both how to get more products launched in the short term and also the long-term vision of a sustainable biosimilar market. That is such an important part of the problem.

    We were very happy that the FDA had their public hearing. The FDA panel asked a lot of thoughtful and probing questions to the individual speakers. We are fully supportive of the Action Plan and its individual components. If we saw all of those things come together and start to see action, including finalizing the interchangeability guidance and providing more education, the biosimilar market would be in a far better place.

    BR&R: We say that biosimilar manufacturers can make their products attractive to payers, but payers need to play a positive role here. Commissioner Gottlieb has said that payers have to help in this process by taking the long-term view, by not automatically sticking with the reference product because of the rebate revenue. They have to be open to using the biosimilars and nurturing the health of the industry. Is there anything else the biosimilar manufacturer can do to convince payers to make this market viable?

    Burich: Certainly, biosimilar manufacturers have to approach these payer negotiations and conversations with competitive and innovative contracting approaches. That does not just include pricing but also how do you drive volume and true savings to both payers and patients. That kind of innovative approach is necessary, because we know it’s a challenging market.

    Biosimilar manufacturers have to look at the whole picture as well. That means providing targeted patient/physician services to really help ensure that the switching experience is seamless for the patient and the physician so that biosimilar utilization is not viewed as something very disruptive.

    Word From the Adalimumab Front: A Conversation With Molly Burich, MS, Boehringer Ingelheim: Part 1

    In the first portion of a two-part interview with Molly Burich, MS, Director, Public Policy: Biosimilars and Pipeline, Boehringer Ingelheim, we cover the challenges of driving biosimilar uptake, as well as the unique situation that has focused this manufacturer’s attention on biosimilars and interchangeability. 

    BR&R: The viability of the US biosimilar industry is being challenged if companies cannot rely on revenue from switching, especially for the autoimmune category.

    Molly Burich, Boehringer Ingelheim
    Molly Burich, MS

    Molly Burich: Yes, biosimilar uptake is certainly going to be dependent on switching. But switching comes in a few different types. One case involves patients who are going to be switched to a therapy with a different mechanism of action. Perhaps their existing therapy no longer works (or didn’t work in the first place).

    Another case is medication substitution by the physician. The doctor drives that decision to switch the patient either to a biosimilar or to an interchangeable.

    Lastly is automatic substitution, which will come as a result of interchangeability and enabled by state laws. However, that is only in play once a product gains the interchangeability designation.

    All of those are important components, but certainly switching overall is an important part of the market viability.

    BR&R: When we’re talking about automatic switching, multiple stakeholders are involved, including the prescribers, pharmacies, payers, patients. And none of it matters if we don’t have an interchangeable product or even final guidelines from the FDA on interchangeability. In retrospect, should we have made automatic switching for biosimilars based on something other than interchangeability?

    Burich: There are a lot of stakeholders involved and this is. why multiple ways of switching will likely occur. In terms of switching, interchangeability allows pharmacists to switch one reference product prescription for an interchangeable one without intervention of the physician at the front end—pending state laws of course. The physician must be notified of the change.

    In our opinion though, automatic switching is certainly not the only way to drive uptake of biosimilars. We believe physician-driven switching and payer-drive substitution via formulary decision-making are very important to drive the uptake of biosimilars.

    BOEHRINGER INGELHEIM’S SINGULAR PRODUCT FOCUS

    BR&R: Biosimilar utilization, and the overall market, has been growing slowly since the first biosimilar approval. Prospective biosimilar manufacturers have tended to jump into the market with both feet, filling their pipelines with multiple biosimilar agents. Boehringer Ingelheim may be the only major manufacturer with a single biosimilar listed on its pipeline web page. Is the company in a wait-and-see mode, to see if the industry will survive? Or is Boehringer making further investments in biosimilar development behind the scenes?

    Burich: We are constantly in an evaluation process of our portfolio. Obviously, we are focused on our approved biosimilar Cyltezo® (adalimumab-adbm) and also on interchangeability, here in the U.S. That is our focus area. We believe that the introduction of biosimilars will improve the lives of patients, as well as contribute to the quality and economic sustainability of healthcare systems.

    INTERCHANGEABILITY: MISUNDERSTOOD BUT NO SILVER BULLET

    BR&R: The issues around interchangeability are particularly frustrating. At the time the BPCIA was written, was the concept of interchangeability (which does not exist in EMA regulations) an attempt to give prescribers and consumers a warm and fuzzy feeling of an AB-rated generic?

    Burich: It’s an important question. As you said, when the BPCIA was written, interchangeability was viewed as a sort of silver bullet. The reality is that interchangeability is an important concept, but perhaps it makes more sense for only certain products. As we gain experience in the biosimilar market, we’re starting to see this.

    We believe in the concept of interchangeability and in what the FDA has put forth about interchangeability. We do think there are questions about how an interchangeable product may be perceived compared with one that is not interchangeable. In our comments to the FDA, we encouraged the FDA to come out with educational materials that are geared toward talking about interchangeability, and talking about switching. These are all important questions and need to be addressed for the broad stakeholder community. The FDA is obviously best positioned to bring that type of education in the next round of materials they develop.

    BR&R: We’ve heard a great deal about people mischaracterizing interchangeable products as being superior to biosimilars (for the same reference product). Why is this differentiation so important?

    Burich: This issue speaks to education. All people engaging in the biosimilar space must realize that the designation of interchangeability does not mean it’s a higher-quality, safer, or more-efficacious product. It means that the manufacturer has conducted additional studies required by the FDA to enable that automatic substitution at the pharmacy level.

    The FDA has issued clarifying pieces of information and education on their website about this, but there is room for more. The reality is that when a drug is approved as a biosimilar, it has attained the foundational designation proving that the drug is highly similar to the reference biologic, without any clinically meaningful differences. On the other hand, gaining the interchangeability designation is about conducting trials of multiple switches within the patient and expecting the same results in any given to patient. Those are two different distinctions. It proves something different, allowing for automatic substitution to occur.

    In part two and the conclusion of this interview, which will be published in a separate post, Molly Burich speaks to Boehringer Ingelheim’s progress in Cytelzo’s interchangeability studies, its plans for the product in Europe in the face of several adalimumab biosimilars launches in the EU, and also the complexity inherent in CMS’s plans to move biologic agents from part B to part D coverage.