FDA Says it Hasn’t Abandoned LDL-C Lowering as a Surrogate Endpoint

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A regulatory update by Esperion 6/28 indicated FDA may not accept low density lipoprotein cholesterol (LDL-C) lowering as a surrogate endpoint in Phase 3 studies of the hypercholesterolemia candidate, bempedoic acid (see story). Despite this uncertainty, the agency told FDA Webview 6/29 that it continues to view LDL-C as a viable surrogate in many trial settings.

“The goal of LDL-C lowering therapy is to reduce the risk for cardiovascular disease,” a CDER spokesman told us. “FDA continues to view the reduction of LDL-C as a surrogate outcome for reduced risk of cardiovascular disease. The regulatory approval of drugs such as statins was based on LDL-C, and recently, changes in LDL-C were accepted as the basis for approval of the PCSK9 inhibitors Praluent (alirocumab) and Repatha (evolocumab) in 2015. For these recent approvals, however, FDA indicated these drugs for specific high-risk populations where, even before the availability of results from ongoing cardiovascular outcomes trials, benefit was expected to outweigh risk.”

The spokesman further noted that whenever a drug’s benefit is measured by its effect on a biomarker, such as LDL-C, “the true benefit with respect to clinical outcomes remains uncertain to some degree. A drug’s mechanism of action, magnitude of treatment effect, potential for off-target effects, and/or the target patient population could all affect the likelihood that FDA would find benefit/risk favorable to support approval of a novel LDL-C-lowering drug based on its effects on LDL-C.”

Last year, an FDA advisory committee discussed (see meeting minutes) discussed the position of LDL cholesterol as a surrogate in non-statin cholesterol-lowering drugs. The committee had varying opinions. Some members stated that LDL-C remains one of the best surrogates around and that there is not much doubt that lowering LDL-C by a large amount will lead to cardiovascular risk reduction provided the drug has no off-target effects that offset this benefit. Some panel members believed that LDL-C is generally a biomarker but it can be a surrogate in some circumstances, such as when studying familial hypercholesterolemia. Others stated that whether LDL-C could be a surrogate is mechanism-dependent. And some said FDA should require outcomes data for a new drug class.

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