FDA Questions Single Trial Adequacy for Avacopan
FDA reviewers are questioning the adequacy of a single Phase 3 trial submitted to support a ChemoCentryx NDA for avacopan, an oral small molecule C5a receptor inhibitor indicated for treating adult patients with anti-neutrophil cytoplasmic autoantibody (ANCA)-associated vasculitis (AAV).
In a briefing document for a 5/6 advisory committee meeting, the reviewers said there are “substantial uncertainties around the Phase 3 study design and results, raising questions about the adequacy of this single trial to inform the benefit-risk assessment.” While the study demonstrated avacopan’s non-inferiority to a pre-specified prednisone taper at Weeks 26 and 52 with both arms receiving background therapy and glucocorticoids, FDA said that a “non-inferiority comparison would not be sufficient to show that avacopan can replace glucocorticoids as it would be difficult to distinguish whether avacopan is effective or whether the induction treatment with rituximab/cyclophosphamide was the primary driver of the efficacy in both treatment arms.”
FDA reviewers also raised concerns about the trial’s ability to “adequately justify a margin as the benefit of glucocorticoids when administered with rituximab or cyclophosphamide induction therapy...The utility of a non-inferiority comparison is dependent on knowing that the active control had its expected effect in the non-inferiority study. However, the applicant has not provided adequate data or information that would isolate the effect of prednisone to inform the margin of the non-inferiority comparison in this study. Furthermore, non-protocol-specified glucocorticoids were used to control disease activity which resulted in glucocorticoid use in both treatment arms. Thus, the assessment of non-inferiority is a comparison of avacopan and lower dose glucocorticoids to higher dose glucocorticoids.”
Additionally, the briefing document continued, data from the clinical pharmacology program has identified avacopan as a CYP3A4 inhibitor “that has the potential to increase exposures to systemic glucocorticoids which are CYP3A4 substrates, raising further questions about the true difference in glucocorticoid exposures and its impact on the non-inferiority comparisons between the two groups, and respectively the proposed role of avacopan as a steroid-sparing agent.”
FDA is seeking input from the advisory committee on whether the application provides substantial evidence of efficacy for the proposed indication and overall benefit-risk considerations in AAV as a rare and serious disease.