3. Q4: Possibly communication of PK modelling results – best outcome would be straightforward PK comparability (AUC[0-inf] 80-120%) – otherwise question is if FDA can be convinced by PD data showing similarity between DPs regarding efficacy-linked immunological markers
4. Possibly (Q1/2022?) communication around another Type A meeting prior to re-submitting BLA to double-check all issues are addressed
5. Re-submission of the BLA (Q1/2022?) and outcome within 6 months (PRVB think may come earlier as CRL did not mention clinical/safety questions).
Personally, I have some questions around Teplizumab’s efficacy in HLA subgroups. In underpowered post-hoc exploratory subgroup analyses of the TN-10 study, it did not delay T1D in persons lacking HLA DR4, see FDA AdCom slide below (but: tiny N, wide CIs &c.)
And I am really curious about the regulatory strategy for the new-onset T1D indication with the PROTECT study as the pivotal trial given that the FDA does not currently accept C-peptide as the sole primary EP in pivotal trials.
I am involved in consortia that try to provide FDA/EMA with enough evidence to allow them to accept C-peptide preservation as a sole primary (surrogate) EP - but we are a few years removed from that to happen (I think) and both FDA and EMA have made clear
that C-peptide is not currently considered a reasonably likely surrogate EP (in the accelerated approval/cMA context). What is Provention’s strategy here given that C-peptide preservation is the sole primary EP of PROTECT?
Do they think the FDA will have changed their mind by the time they’ve read out PROTECT and file for approval? Have they received any indication from the FDA that applying with a single pivotal trial with only C-peptide preservation as primary EP is acceptable
(which would be contrary to official communications from the FDA, e.g. at the recent Critical Path Institute workshop on C-peptide). That would be interesting to hear more about.
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Update #ProventionBio#Provention $PRVB #teplizumab. For a summary of AdCom etc. see thread below. I am not involved with the company but have other conflicts of interest. All is based on public information and personal opinion.
Recap: Company has Breakthrough Therapy Designation and Priority Review, an AdCom vote 10-7 in favour for “delay of Type 1 diabetes #T1D”, and got a CRL stating CMC problems and failure to demonstrate PK/PD comparability between the studied Lilly-produced
and to-be commercialized ACG-produced teplizumab drug product (DP). A PK/PD substudy in the ongoing phase 3 PROTECT trial of 2 x 12 days of IV teplizumab 6 months apart in new-onset T1D has been completed (AGC Biologics DP ca. 30 patients, Lilly DP ca. 130 patients).
(4) If risk/benefit is acceptable, which target population is deemed suitable by the FDA? There were proponents of 3 options in EMDAC: (a) Stage 1 + 2, (b) Stage 2, or (c) Stage 2 + family Hx of T1D (= inclusion criteria of TN-10).
(a) is unlikely, I think, my vote is with (b). With regards to age, I think >8 years (as in TN-10) will be a requirement, given the SEs associated with teplizumab.
Thread on #ProventionBio#Provention $PRVB and their flagship #antiCD3 monoclonal antibody #teplizumab under #FDA consideration for the “delay of clinical #Type1Diabetes#T1D in at-risk individuals”. I have no connection to the company – but I do have COIs. No recommendations
or claims of accuracy, just a summary of the status quo and personal opinion. Assume I’m biased. All public information. Feel free to correct me. For references & links, contact me. Some pictures are copies from public PRVB presentations/FDA briefing docs.
*Summary*
PRVB are seeking approval of 14-day IV teplizumab for the delay of T1D. Teplizumab is a humanised Fc-mutated anti-CD3 monocl Ab that, simply put, turns autoreactive T-cells (regardless of antigen) into exhausted T-cells