FDA Complete Response Letter on KemPharm’s Pain Drug

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FDA has issued KemPharm a complete response letter for its NDA for Apadaz (benzhydrocodone and acetaminophen), an investigational abuse-deterrent product candidate for the short-term management of acute pain. The letter is in response to an NDA amendment that the company filed last week (see story) that seeks to strengthen the drug’s labeling related to its abuse-deterrent properties.

The amendment presumably addresses concerns expressed by members of the FDA Anesthetic and Analgesic Drug Products Advisory Committee when they voted last month 16-4 to recommend approval for the drug. During the committee meeting, FDA asked the advisors to vote on whether data submitted by the company support a labeling claim that Apadaz is an abuse-deterrent product. On an 18-2 vote, committee members said Apadaz should not be labeled as abuse-deterrent. They acknowledged that the available data suggest the potential for a marginal benefit in preventing abuse via the intranasal route and encouraged the company to continue studying the drug’s abuse-deterrent properties to acquire data that in the future could reach the standards needed for a labeling claim.

KemPharm says it developed the drug using its proprietary Ligand-Activated Technology, which creates a new prodrug by chemically attaching one or more molecules, or ligands, to an FDA-approved parent drug.  “Once administered, human metabolic processes, such as those in the gastrointestinal tract, separate the ligand from the prodrug and release the parent drug, which can then provide its therapeutic effect,” it says.

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