Biosimilar Program Review Finds Higher First-Cycle Approvals
An independent review of FDA’s user fee program for biosimilars found that first-cycle approval rates were higher (67%, 14 of 21) during the first four years of the current five-year program than during the program’s 2013-2017 baseline first five years (39%, 9 of 23). The assessment said that “based on the quantitative data, observations, and feedback from interviews, it is reasonable to conclude that the BsUFA II Program has created conditions that enhance the ability of applicants and FDA reviewers to work toward application approval in the first review cycle.”
Data from the current biosimilar user fee program also suggest a possible relationship between an application’s proposed indications and first-cycle approval. The assessment found that “applications with hematologic or solely oncologic indications were less likely to receive a first-cycle approval (33%, 3 of 9) than applications with other indications (92%, 11 of 12).” It found that baseline and BsUFA II program applications with a major amendment were associated with a higher first-cycle approval rate (100%, 3 of 3 baseline, 1 of 1 BsUFA II program) than those without a major amendment (30%, 6 of 20 for baseline; 65%, 13 of 20 for BsUFA II program). “This aligns with the expectation that FDA will accept and review a major amendment when the agency believes that this will lead to approval in the first cycle rather than requiring resubmission and a second cycle of review,” it says.
Additionally, product quality and facilities approvability issues were commonly cited in baseline and BsUFA 2 complete response (CR) letters, it says. “Sponsors of baseline applications with first-cycle CR letters due to product quality and facilities issues often resubmitted their applications and gained FDA approval in subsequent review cycles. Nearly all of the (BsUFA II) Program applications that received a first-cycle approval were submitted by sponsors who had previous applications approved in the baseline (first or subsequent cycles). This might suggest that sponsors possessing biosimilar product quality and facilities expertise, whether gained through experience or through external hiring, consulting, and contracting, are more likely to receive first-cycle approval.”