The FDA has recently provided clarification on post-approval changes for biosimilars, offering new pathways for manufacturers to innovate and expand the utility of these cost-effective alternatives to reference biologics. This guidance addresses modifications to the production process, quality controls, and even the introduction of new indications.
Manufacturing Changes and Comparability
The FDA's clarification emphasizes a thorough study of any changes made to the product, production process, quality controls, equipment, facilities, or responsible personnel in the approved biologics license application (BLA). These changes must be assessed for their potential impact on the product's identity, strength, quality, purity, or potency, which could potentially impact its safety or effectiveness.
The agency underscores the importance of comparability studies when manufacturing modifications are implemented. These studies should compare pre- and post-change data on intermediates most affected by the manufacturing modification in addition to the drug substance and drug product. Comparative stability studies under relevant storage conditions are crucial when manufacturing modifications affect protein structure or purity and impurity profiles.
New Indications and Dosage Forms
One of the most significant clarifications is that a biosimilar can now secure a new indication that is not included in the reference product's license without being filed as a new biological drug. This opens up opportunities for biosimilar manufacturers to explore new therapeutic applications for their products, potentially addressing unmet medical needs at a lower cost.
Changes to the dosage form or strength are also addressed. While not permitted under the 351(k) BLA filing directly, the FDA outlines a pathway for approval via a Prior Approval Supplement (PAS). This requires adequate comparability data between a licensed biosimilar (pre-change product) and the proposed new dosage form or strength (post-change product), comparative analytical assessment (CAA) data, and manufacturing data to support the proposed post-change product.
Addressing Intellectual Property Barriers
Biosimilar applicants can change their product to match changes made by reference product manufacturers (such as formulation or route of administration) only if their intellectual property (IP) is not hindered. To overcome potential IP challenges, the US Senate has passed a new S-150 Bill that would forbid reference product manufacturers from securing patents for such changes. This bill, if passed by the House of Representatives, is anticipated to significantly support the cause of biosimilars.
BioRationality
These clarifications from the FDA are seen as a significant step towards supporting the rationality of biosimilars, promoting innovation, and increasing access to affordable medicines. By allowing biosimilars to adapt to changes in the reference product and pursue new indications, the FDA is fostering a more competitive and dynamic market that benefits patients and healthcare systems alike.
