FDA Abandoning Biosimilar Switching Studies
FDA is moving away from recommending switching studies to support an interchangeability determination for biosimilar products. In a just-published draft guidance, the agency is seeking comments on a revised approach where such studies will generally not be needed.
FDA’s recommendation for switching studies first appeared in its interchangeability guidance in 2019 (Considerations in Demonstrating Interchangeability With a Reference Product) before receiving and reviewing any applications for an interchangeable biosimilar. “Since publication of the interchangeability guidance, experience has shown that for the products approved as biosimilars to date, the risk in terms of safety or diminished efficacy is insignificant following single or multiple switches between a reference product and a biosimilar product,” an agency notice says.
In the past, FDA generally recommended switching studies as part of the data package needed to demonstrate a biosimilar’s interchangeability. However, it notes that “of the 13 approved interchangeable biosimilars, nine were approved without additional clinical (switching study) data.”
The agency says its scientific approach to when a switching study may be needed to support a demonstration of interchangeability has evolved. “FDA researchers found no differences in the risk of death, serious adverse events, and treatment discontinuations between participants who switched between biosimilars and reference products and participants who did not switch in a recently conducted systematic review and meta-analysis,” it says. “Additionally, today’s analytical tools can accurately evaluate the structure and effects biologic products, both in the lab (in vitro) and in living organisms (in vivo) with more precision and sensitivity than switching studies.”
Instead of conducting switching studies, the new draft guidance says biosimilar applicants can otherwise choose to “provide an assessment of why the comparative analytical and clinical data provided in the application or supplement support a showing that the switching standard set forth in section 351(k)(4)(B) of the PHS Act has been met. Any such assessment should include any other information the applicant considers relevant to support a showing that the risk, in terms of safety and diminished efficacy, from alternating or switching between the reference product and the proposed interchangeable product is not greater than the risk of using the reference product without such alternation or switch.”