Hogan Lovells Skeptical of New Generics Pilot
A new CDER Office of Generic Drugs pilot program to offer meeting opportunities to ANDA applicants who intend to use model-integrated evidence (MIE) approaches for bioequivalence (BE) determinations is drawing skepticism from some food and drug lawyers. “The use of MIE approaches for BE establishment is increasingly prevalent, particularly in the development of challenging products, such as long-acting injectables, orally inhaled drugs, and topically applied dermatological products,” an agency notice said earlier this month when the pilot was announced. “Industry regularly seeks FDA guidance on best practices for implementing MIE, including common model approaches and addressing complex scientific and regulatory issues.”
According to the agency, the pilot’s primary goal is to foster early and focused interactions between industry and agency reviewers on science-driven topics related to MIE approaches for establishing BE in generic drug development. It will focus the scientific communication on employing quantitative methods and modeling techniques. It is also intended to :
- address common issues across multiple products and complex issues for non-complex products that fall outside the scope or focus of current pre-ANDA and ANDA meetings, and
- provide a dedicated platform for in-depth discussions on scientific and technical matters related to MIE implementation
In a just-posted client update, lawyers from Hogan Lovells notes that while the MIE approach “remains largely untested,” the overall goal is “geared to reducing reliance on in vivo studies in generic drug development, and to extend the use of in vitro, in silico, and biowaiver options, including the use of model-integrated approach to potentially increase the use of BCS [Biopharmaceutics Classification System] waivers.
“This wider trend is of concern to the extent it reaches beyond the science,” the Hogan Lovells update continues. “Brand manufacturers should be on the lookout for premature changes; for example, new or revised product-specific BE guidances indicating the adoption of these alternate approaches to BE. We continue to cast a critical eye at these alternate approaches, and we intend to closely monitor the potential use of MIE for complex and non-complex generics alike, and to update our innovator clients on potential shortfalls in FDA’s methods and where we see these programs developing.”