Biosimilar Interchangeability Final Guidance

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FDA has released a final guidance entitled “Considerations in Demonstrating Interchangeability With a Reference Product” to help sponsors navigate the pathway for “interchangeable” biologics/biosimilars, which may be substituted without prescriber involvement. Although the 351(k) biosimilar pathway applies generally to biological products, the guidance focuses on therapeutic protein products and gives an overview of important scientific considerations in demonstrating interchangeability of a proposed therapeutic protein product with a reference product.

 

The guidance also explains potential ways to address the Biologics Price Competition and Innovation (BPCI) Act of 2009 “requirement for interchangeability that, for a biological product that is administered more than once to an individual, the risk in terms of safety or diminished efficacy of alternating or switching between use of the biological product and the reference product will not be greater than the risk of using the reference product without such alternation or switch,” an agency release notes.

 

Additionally, FDA says the guidance will help enable biosimilar or interchangeable insulin products to come to market in the future. “There are currently no approved insulin products that can be substituted at the pharmacy level,” it says. “But, under the BPCI Act, on 3/23/2020, insulin and other biological products that were approved as drugs under the federal Food, Drug, and Cosmetic Act will be deemed biological products licensed and regulated under the PHS Act. After this transition, the FDA will be able to license biosimilar and interchangeable insulin products that meet the requirements of the PHS Act, and today’s guidance will, among other things, help developers seek licensure for such products.”

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