Actual Use Study Flagged in OTC Birth Control NDA
FDA reviewers are questioning the reliability of an actual use study that was submitted to support approval of a Laboratoire HRA Pharma NDA seeking a prescription-to-nonprescription switch of its Opill, a norgestrel tablet 0.075 mg oral contraceptive pill.
In a briefing document released in advance of a 5/9-10 advisory committee meeting, the reviewers said they found that a substantial portion of individuals in the actual use study over-reported the number of tablets they took. “The improbable dosing and the substantial proportion of subjects with improbable dosing, without identifiable root cause(s), call into question the reliability of all of the actual use data in ACCESS-UP — therefore not providing reliable information to assess an individual’s ability to appropriately use this product,” the reviewers wrote.
They said they were also concerned about data supporting “comprehension and deselection in females with a history of or current breast cancer” because hormonal contraception is contraindicated in females with a history of, or current, breast cancer. “Comprehension of this contraindication did not approach the prespecified target threshold in the LCS [label comprehension study], and there were participants who failed to correctly deselect in the targeted breast cancer and ACCESS self-selection studies," they wrote.
FDA’s briefing document says that the advisory committee members will be asked to discuss both concerns and other issues during the two-day panel meeting.