Update on Risk
Management Activities for Lotronex (alosetron hydrochloride)
Executive Summary
GlaxoSmithKline (GSK), manufacturer of Lotronex, and the
Food and Drug Administration’s Division of Gastrointestinal and Coagulation
Drug Products are providing the Drug Safety and Risk Management Advisory
Committee an update on the status of the risk management plan (RMP). Both GSK and FDA view the RMP as
satisfactorily meeting the goals of:
- limiting
use to a subpopulation of patients in whom the benefits exceed risks
- informing
patients and physicians of the risks and benefits of Lotronex so that they
can make informed decisions
- limiting
use of the drug to physicians who can manage severe diarrhea-predominant
irritable bowel syndrome and adverse events associated with Lotronex
(ischemic colitis and severe complications of constipation)
- having
an on-going program evaluation to ensure goals are met
This briefing package contains:
- Background
and summary of risk management plan
- Summary
of outcomes under the risk management plan.
- FDA
summary of adverse events.
- The
FDA approval letter dated June 7, 2002 that provides for the risk
management plan for Lotronex and the approved labeling.
- Office
of Drug Safety Postmarketing Safety Review of April 1, 2004
Background and Summary of Risk Management Plan
Lotronex is a 5-HT3 serotonin receptor
antagonist. It inhibits activation of
non-selective cation channels which results in the modulation of the enteric
nervous system and affects pain and discomfort and gastrointestinal transit in
patients with diarrhea-predominant irritable bowel syndrome (IBS). It was first approved with warnings for
ischemic colitis in February, 2000. However, after a few short months of
marketing FDA received about a dozen cases of ischemic colitis and serious
consequences of severe constipation. The
June 27, 2000 Gastrointestinal Drugs Advisory Committee recommended labeling
and education for safe use. However, by November 28, 2000, the manufacturer
voluntarily withdrew the drug from marketing when more cases, including
fatalities, were received. After
withdrawal, the FDA heard from hundreds of patients urging access to
Lotronex. GSK agreed to pursue
re-marketing of Lotronex under restrictions.
On April 23, 2002,
the Gastrointestinal Drugs Advisory Committee and the Drug Safety and Risk
Management Advisory Committee met and recommended approval of Lotronex Tablets
with restrictions, such as having patient and physician registries and
physician certification training for prescribing. On June 7, 2002, the U.S. Food and Drug Administration
(FDA) approved the restricted marketing of Lotronex with a risk management plan
(RMP) which was mutually agreed upon by GlaxoSmithKline (GSK) and FDA. The approval and RMP provide for:
- Revised
labeling, including a Medication Guide, with lower dosing recommendations
and a limited indication for women with severe diarrhea-predominant IBS
who fail to respond to conventional therapy and have specified symptoms.
- A
prescribing program that enrolls prescribing physicians who meet the
qualifications for diagnosing and managing IBS and drug adverse events
(ischemic colitis and severe complications of constipation), and who agree
to specific responsibilities. The
program allows pharmacists to check if prescribers are enrolled. GSK has implemented a sticker system.
- Adverse
event reporting to FDA within 15 days of specified serious adverse events.
- Risk
management evaluation plans.
- Postmarketing
commitments to study
- Efficacy
of lower doses
- “prn”
dosing efficacy
- DNA
analyses of subjects in a. and b. who develop ischemic colitis and to
determine genotype polymorphic CYP enzymes responsible for Lotronex
metabolism
- Mechanistic
studies to explore Lotronex-induced ischemic colitis and small bowel
ischemia
- Pharmacokinetic
studies in hepatically-impaired subjects and drug-drug interaction
studies with CYP inhibitors
- Prescribing
of enrolled prescribers versus all Lotronex prescribers
- Compliance
with Patient-Physician Agreements, appropriate use of Lotronex, knowledge
and understanding of patients, serious adverse events to estimate rates,
possible risk factors for serious gastrointestinal adverse events
Summary
of Outcomes
Since marketing began on
November 20, 2002,
through December 2003 a total of 5,053 physicians have enrolled in the
Prescribing Program for Lotronex (PPL) to prescribe Lotronex. The PPL is one of the key elements of the RMP
for Lotronex. To enroll, physicians must
attest to qualifications of being able to diagnose and manage IBS, ischemic
colitis, and severe complications of constipation, as well as being
knowledgeable about the drug's labeled information. The attestation must be submitted before
prescribing materials, including prescription stickers for pharmacists to recognize
the prescriber is enrolled, are sent.
About 2,500 physicians (approximately 50% of enrolled physicians) have
prescribed or currently are prescribing the drug. However, only about 20% of the enrolled
physicians actually prescribed the drug in a given month. For the quarter, September-December 2003,
about 60% of the enrolled physicians were gastroenterologists, 34% were primary
care physicians and 5% were "other."
From month to month approximately 20% of all prescribers of Lotronex are
not enrolled in the PPL (most are primary care physicians and family
practitioners). Non-enrolled prescribing physicians are sent enrollment kits
and informational letters in efforts to get them to enroll. Over time these interventions have resulted
in approximately 75% of the non-enrolled prescribers either enrolling or
ceasing to prescribe. Thus, the "20% group" constantly changes in
membership as previous non-enrolled prescribers either enroll or cease to
prescribe and "new" non-enrolled prescribers become a part of the
group. Pharmacies in areas where non-enrolled
prescribers practice, are sent information regarding the Prescribing Program
for Lotronex. Whether
patients managed by non-enrolled physicians are at a different risk for clinically
serious outcomes is unknown.
Over the
same time period, November 2002 through December 2003, 9,365 patients were
prescribed Lotronex at least once. This
represents a small portion of potential patients. However, only 10-20% of these patients have
had additional prescriptions of Lotronex. The reasons for this low rate of
additional prescriptions are not yet known.
In addition, patterns of usage (e.g., doses, drug holidays) need to be
clarified.
As of December
31, 2003, approximately 36% of the total patients prescribed
Lotronex had completed a questionnaire about patient knowledge of risks, most
scoring 90% or higher for correctly answering questions about the risks of
Lotronex. The generalizability of the
results in this survey population to the larger group of all patients treated
with Lotronex is unknown. Eighty percent
(80%) of the patients eligible for Lotronex fulfilled all three severity
criteria listed in the approved indication whereas, only one severity criterion
is required, in addition to diarrhea. It
should be noted that the percentage of patients with one of the listed criteria
of severity that also report the other two is unknown.
FDA Report of Adverse Events
From November 20,
2002 until February 21,
2004, there have been 8 reported cases of ischemic colitis (3
requiring hospitalization, no surgeries) and 5 reported cases of severe
complications of constipation (2 requiring hospitalization and 1 unconfirmed
laparoscopy). There have been no
drug-related deaths.
Conclusion
GSK has conducted focus testing to explore where there could
be improvements in risk communication and enrollment procedures. FDA and GSK continue to review the RMP and
outcomes to improve the program.