us-fda-guidance-66881d42c4cf2e7951e11f63d6284f00•Chronic Hepatitis D Virus Infection: Developing Drugs for Treatment Guidance for Industry
Chronic Hepatitis D Virus Infection: Developing Drugs for Treatment Guidance for Industry
us-fda-guidance-66881d42c4cf2e7951e11f63d6284f00Chronic Hepatitis D Virus Infection: Developing Drugs for Treatment Guidance for IndustryDraft Guidance
Administrative draft guidance, not enacted legislation. This captured publisher edition preserves the listed document and attachments; later developments are not independently consolidated.
- Docket Number:
- FDA-2019-D-4042
- Issued by:
- Guidance Issuing OfficeCenter for Drug Evaluation and Research
The purpose of this guidance is to assist sponsors in the clinical development of drugs for the treatment of chronic hepatitis D virus (HDV) infection. Specifically, this guidance addresses the Food and Drug Administration’s (FDA’s) current recommendations regarding the overall development program and clinical trial designs for the development of drugs and biologics to support an indication for the treatment of chronic HDV infection.
FDA encourages sponsors to communicate with the Division of Antiviral Products (DAVP) through the pre-investigational new drug application (pre-IND) consultation program to discuss the development of drugs with unique considerations based on mechanism of action, novel treatment approaches, or the use of novel biomarkers. This draft guidance is intended to serve as a focus for continued discussions among DAVP, pharmaceutical sponsors, the academic community, and the public.
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26502073dft.docx 09/03/19 Chronic Hepatitis D Virus Infection: Developing Drugs for Treatment Guidance for Industry DRAFT GUIDANCE This guidance document is being distributed for comment purposes only. Comments and suggestions regarding this draft document should be submitted within 60 days of publication in the Federal Register of the notice announcing the availability of the draft guidance. Submit electronic comments to https://www.regulations.gov. Submit written comments to the Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. All comments should be identified with the docket number listed in the notice of availability that publishes in the Federal Register. For questions regarding this draft document, contact Aimee Hodowanec at 240-402-5752. U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) October 2019 Clinical/Antimicrobial
Chronic Hepatitis D Virus Infection: Developing Drugs for Treatment Guidance for Industry Additional copies are available from: Office of Communications, Division of Drug Information Center for Drug Evaluation and Research Food and Drug Administration 10001 New Hampshire Ave., Hillandale Bldg., 4th Floor Silver Spring, MD 20993-0002 Phone: 855-543-3784 or 301-796-3400; Fax: 301-431-6353; Email: druginfo@fda.hhs.gov https://www.fda.gov/drugs/guidance-compliance-regulatory-information/guidances-drugs U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) October 2019 Clinical/Antimicrobial
TABLE OF CONTENTS I. INTRODUCTION..................................................................................................1 II. BACKGROUND ....................................................................................................2 III. DEVELOPMENT PROGRAM ............................................................................3 A. General Drug Development Considerations ................................................................... 3 1. Early Phase Development Considerations .......................................................................... 3 a. Pharmacology/toxicology development considerations ............................................... 3 b. Nonclinical virology development considerations ....................................................... 3 c. Clinical pharmacology development considerations .................................................... 5 d. Efficacy considerations ................................................................................................ 5 2. Drug Development Population ............................................................................................ 5 3. Safety Considerations .......................................................................................................... 6 B. Phase 3 Efficacy Trial Considerations ............................................................................. 7 1. Trial Design......................................................................................................................... 7 2. Trial Population .................................................................................................................. 8 3. Randomization and Stratification ........................................................................................ 8 4. Dose Selection ..................................................................................................................... 8 5. Comparators........................................................................................................................ 9 6. Efficacy Endpoints............................................................................................................... 9 a. Primary endpoints ......................................................................................................... 9 b. Secondary endpoints................................................................................................... 10 7. Trial Procedures and Timing of Assessments ................................................................... 10 8. Statistical Considerations.................................................................................................. 10 a. Efficacy analyses ........................................................................................................ 10 b. Noninferiority trials .................................................................................................... 11 c. Combination regimens ................................................................................................ 11 9. Accelerated Approval (Subpart H) Considerations........................................................... 11 C. Other Considerations ...................................................................................................... 11 1. Clinical Virology Considerations ...................................................................................... 11 REFERENCES.................................................................................................................13
Contains Nonbinding Recommendations Draft — Not for Implementation 1 Chronic Hepatitis D Virus Infection: 1 Developing Drugs for Treatment 2 Guidance for Industry1 3 4 5 6 This draft guidance, when finalized, will represent the current thinking of the Food and Drug 7 Administration (FDA or Agency) on this topic. It does not establish any rights for any person and is not 8 binding on FDA or the public. You can use an alternative approach if it satisfies the requirements of the 9 applicable statutes and regulations. To discuss an alternative approach, contact the FDA staff responsible 10 for this guidance as listed on the title page. 11 12 13 14 I. INTRODUCTION 15 16 The purpose of this guidance is to assist sponsors in the clinical development of drugs for the 17 treatment of chronic hepatitis D virus (HDV) infection.2 Specifically, this guidance addresses the 18 Food and Drug Administration’s (FDA’s) current recommendations regarding the overall 19 development program and clinical trial designs for the development of drugs and biologics to 20 support an indication for the treatment of chronic HDV infection. 21 22 FDA encourages sponsors to communicate with the Division of Antiviral Products (DAVP) 23 through the pre-investigational new drug application (pre-IND) consultation program to discuss 24 the development of drugs with unique considerations based on mechanism of action, novel 25 treatment approaches, or the use of novel biomarkers.3 This draft guidance is intended to serve as 26 a focus for continued discussions among DAVP, pharmaceutical sponsors, the academic 27 community, and the public.4 28 29 This guidance focuses on considerations that are specific to HDV drug development. General 30 topics in early phase drug development, statistical analysis, and clinical trial design are addressed 31 in the International Conference on Harmonisation (ICH) guidances for industry E9 Statistical 32 Principles for Clinical Trials (September 1998) and E10 Choice of Control Group and Related 33 1 This guidance has been prepared by the Division of Antiviral Products in the Center for Drug Evaluation and Research at the Food and Drug Administration. 2 For the purposes of this guidance, the term drug includes both human drugs and therapeutic biological products unless otherwise specified. 3 See the FDA’s Getting Started with the Division of Antiviral Products Pre-IND Process web page at https://www.fda.gov/drugs/pre-ind-consultation-program/getting-started-division-antiviral-products-pre-ind-process. 4 In addition to consulting FDA guidances, sponsors are encouraged to contact DAVP to discuss specific issues that arise during the development of drugs for the treatment of HDV infection.
Contains Nonbinding Recommendations Draft — Not for Implementation 2 Issues in Clinical Trials (May 2001).5 The draft guidance for industry Chronic Hepatitis B Virus 34 Infection: Developing Drugs for Treatment (November 2018) also contains information that is 35 relevant to HDV drug development.6 36 37 In general, FDA’s guidance documents do not establish legally enforceable responsibilities. 38 Instead, guidances describe the Agency’s current thinking on a topic and should be viewed only 39 as recommendations, unless specific regulatory or statutory requirements are cited. The use of 40 the word should in Agency guidances means that something is suggested or recommended, but 41 not required. 42 43 44 II. BACKGROUND 45 46 HDV is a replication-defective virus that uses the hepatitis B virus (HBV) surface antigen 47 (HBsAg) as its envelope protein. Therefore, HDV infection only occurs in the setting of 48 concurrent HBV infection (Wranke and Wedemeyer 2016). According to the World Health 49 Organization, an estimated 15–20 million people worldwide are living with HBV/HDV co- 50 infection.7 Subsequently, a meta-analysis reported a much higher worldwide HBV/HDV co- 51 infection prevalence of 62–72 million (Chen et al. 2019). Areas of high HDV prevalence include 52 Eastern and Mediterranean Europe, the Middle East, Central and North Asia, the Amazon basin, 53 and parts of Africa (Chen et al. 2019). HDV prevalence is thought to be relatively low in the 54 United States overall, but may be increased in certain subpopulations, such as in persons who 55 inject drugs and in persons born in, or who have lived in, countries where the disease is endemic. 56 Population-based data from the National Health and Nutrition Examination Survey estimated 57 that the anti-HDV antibody prevalence among adults in the United States is 0.15 percent (Patel et 58 al. 2019). There are eight recognized genotypes of HDV (1 to 8); the globally prevalent genotype 59 1 is the predominant genotype in the United States. 60 61 Relative to HBV monoinfection, HBV/HDV co-infection may be associated with more severe 62 liver disease, leading to increased rates of cirrhosis, hepatocellular carcinoma, hepatic 63 decompensation, and liver failure (Fattovich et al. 1987; Romeo et al. 2009). Although currently 64 available HBV therapies are effective in suppressing HBV replication, the rate of HBsAg loss 65 remains low (Tang et al. 2018). In the absence of HBsAg loss, HDV infection persists. 66 Therefore, therapies directly targeting HDV may be of clinical benefit. At present there are no 67 drugs approved for the treatment of chronic HDV infection, although pegylated interferon-alpha 68 (PEG-IFN-α) is commonly used. However, PEG-IFN-α is associated with significant toxicity 69 and sustained virologic response rates (defined as undetectable HDV RNA levels 6 months after 70 5 We update guidances periodically. To make sure you have the most recent version of a guidance, check the FDA guidance web page at https://www.fda.gov/regulatory-information/search-fda-guidance-documents. 6 When final, this guidance will represent the FDA’s current thinking on this topic. For the most recent version of a guidance, check the FDA guidance web page at https://www.fda.gov/regulatory-information/search-fda-guidance- documents. 7 See the World Health Organization’s Hepatitis D web page at https://www.who.int/en/news-room/fact- sheets/detail/hepatitis-d.
Contains Nonbinding Recommendations Draft — Not for Implementation 3 treatment) of only 25 to 30 percent (Erhardt et al. 2006; Wedemeyer et al. 2011). In addition, late 71 virologic relapses are common following treatment with PEG-IFN-α, and it is not known if HDV 72 sustained clearance can be achieved in the setting of persistent HBsAg positivity (Heidrich et al. 73 2014). 74 75 Because chronic HDV infection is considered serious and life-threatening and there are no 76 approved treatments, investigational anti-HDV drugs may be eligible for FDA’s expedited 77 programs, such as fast track, breakthrough therapy, and priority review designations.8 78 79 80 III. DEVELOPMENT PROGRAM 81 82 A. General Drug Development Considerations 83 84 This section discusses nonclinical and early phase clinical development considerations, including 85 the evaluation of antiviral activity and resistance, issues related to the target population for drug 86 development, and safety considerations. 87 88 1. Early Phase Development Considerations 89 90 Early clinical evaluation should provide sufficient data to establish safety and antiviral activity in 91 support of phase 3 trials. 92 93 a. Pharmacology/toxicology development considerations 94 95 Sponsors should refer to the following guidance documents for nonclinical development 96 considerations: 97 98 • Guidance for industry Chronic Hepatitis B Virus Infection: Developing Drugs for 99 Treatment 100 101 • ICH guidance for industry M3(R2) Nonclinical Studies for the Conduct of Human 102 Clinical Trials and Marketing Authorization for Pharmaceuticals (January 2010) 103 104 • ICH guidance for industry S6(R1) Preclinical Safety Evaluation of Biotechnology- 105 Derived Pharmaceuticals (May 2012) 106 107 • ICH guidance for industry S1A The Need for Long-Term Rodent Carcinogenicity Studies 108 of Pharmaceuticals (March 1996) 109 110 b. Nonclinical virology development considerations 111 112 Sponsors should consider recommendations for general antiviral and HBV drug development 113 addressed in the guidances for industry Antiviral Product Development — Conducting and 114 8 See the guidance for industry Expedited Programs for Serious Conditions — Drugs and Biologics (May 2014).
Contains Nonbinding Recommendations Draft — Not for Implementation 4 Submitting Virology Studies to the Agency (June 2006), and Chronic Hepatitis B Virus Infection: 115 Developing Drugs for Treatment, including recommendations for studies of mechanism of 116 action, determination of antiviral activity in cell culture, cytotoxicity, and mitochondrial toxicity. 117 118 Sponsors should also consider the following recommendations specific for HDV drug 119 development: 120 121 • Antiviral activity determination in cell culture: To assess the breadth of activity of the 122 investigational drug, the effective drug concentration at which virus replication is 123 inhibited by 50 and 90 percent (EC50 and EC90 values) should be determined against 124 different genotypes of HDV, including genotype 1, in cell culture. If EC50 values vary 125 significantly across genotypes, indicating a lack of conservation of the drug target, the 126 breadth of activity against genotype 1 should also be determined by testing multiple 127 geographically and temporally distinct isolates of this genotype. 128 129 • Cell culture combination antiviral activity: Cell culture combination antiviral activity of 130 an investigational drug against HDV should be determined with approved drugs for HBV 131 and for HDV (when anti-HDV drugs are approved) to determine the likelihood of 132 antagonism when used in combination for the treatment of HBV/HDV infection. 133 Sponsors should assess the effect of approved drugs for HBV on the activity of the 134 investigational HDV drug, and conversely, the effect of the investigational HDV drug on 135 the activity of approved HBV drugs. 136 137 • Activity in animal models:9 Animal models of HDV infection may be important for 138 assessing the antiviral activity of investigational drugs, given the difficulty in propagating 139 the virus in cell culture. Sponsors should consider the following recommendations related 140 to animal models: 141 142 − Animal models for consideration may include immunocompromised mice with 143 chimeric human/mouse livers and transgenic mice expressing human sodium 144 taurocholate cotransporting polypeptide (NTCP) receptor and HBsAg (Winer et al. 145 2018). The woodchuck model using HDV pseudotyped with woodchuck hepatitis 146 virus envelope proteins can be considered for drugs that do not specifically target the 147 HDV/HBV envelope protein or human NTCP receptor (Aldabe et al. 2015). 148 149 − If studies are conducted in animal models to support an HDV treatment program, we 150 recommend including time course plots of viral load (RNA) and antigen expression 151 data for each animal. We recommend testing different HDV/HBV genotypes and 152 assessing resistance development where feasible. 153 154 • Evaluating HDV resistance: FDA encourages sponsors to investigate resistance in 155 nonclinical models of infection where feasible, although such studies may be challenging 156 9 We support the principles of the 3Rs (reduce/refine/replace) for animal use in testing when feasible. FDA encourages sponsors to consult with review divisions when considering a nonanimal testing method believed to be suitable, adequate, validated, and feasible. FDA will consider if the alternative method could be assessed for equivalency to an animal test method.
Contains Nonbinding Recommendations Draft — Not for Implementation 5 given the limitations of propagating HDV in cell culture and animal models and the 157 dependency of HDV on HBV envelope proteins for infection. 158 159 • Evaluating HDV cross-resistance: If a drug for treatment of HDV infection is approved 160 and HDV variants resistant to the drug are identified, these variants should be assessed 161 for susceptibility to the investigational drug. Likewise, HDV variants resistant to the 162 investigational drug should be assessed for susceptibility to any approved drugs for HDV. 163 164 c. Clinical pharmacology development considerations 165 166 Studies to characterize pharmacokinetics including the effect of extrinsic (e.g., drug-drug 167 interaction studies, food effect studies) and intrinsic factors (e.g., pharmacokinetic studies in 168 subjects with renal impairment or hepatic impairment) should be conducted early in development 169 to inform the trial design for phase 2 and phase 3 trials. Sponsors should consider 170 recommendations in the pertinent guidances for industry. 171 172 d. Efficacy considerations 173 174 In early clinical trials, the sponsor should measure HDV RNA levels during a short treatment 175 period (i.e., one to three months, depending on the drug’s mechanism of action) to assess 176 activity. The sponsor should assess changes in alanine aminotransferase (ALT) as a key 177 secondary endpoint. 178 179 2. Drug Development Population 180 181 Development programs should include a diverse and representative clinical trial population, and 182 sponsors should consider the following points related to trial populations: 183 184 • HDV infection is a global disease with the greatest burden of infection occurring in 185 Eastern and Mediterranean Europe, the Middle East, the Amazon Basin, and parts of Asia 186 and Africa. 187 188 − Under 21 CFR 312.120, FDA will accept data from a well-designed, well-conducted, 189 non-IND foreign trial as support for an IND or application for marketing approval if 190 the trial was conducted in accordance with good clinical practice and if FDA is able 191 to validate the data from the trial through an onsite inspection, as necessary.10 192 193 − Although foreign data may be acceptable as a sole basis for marketing approval under 194 certain circumstances (see 21 CFR 314.106), FDA encourages sponsors to include 195 U.S. patients in development programs to provide additional experience relevant to 196 the U.S. population. 197 198 10 For additional information, see the guidance for industry and FDA staff FDA Acceptance of Foreign Clinical Studies Not Conducted Under an IND: Frequently Asked Questions (March 2012).
Contains Nonbinding Recommendations Draft — Not for Implementation 6 • FDA encourages sponsors to discuss their enrollment strategies and plans for phase 2 and 199 phase 3 trials with DAVP. Eligibility criteria should allow the clinical trial population to 200 reflect the diversity of the patients who will be using the drug if the drug is approved.11 201 202 • Sponsors should conduct initial trials to define antiviral activity and dose-response in 203 patients without cirrhosis or with compensated cirrhosis, as these patients are at lower 204 risk of imminent clinical progression or decompensation. In the later stages of drug 205 development, enrollment of patients with decompensated liver disease may be considered 206 (see section III.B.2., Trial Population). 207 208 • In the absence of a serious safety signal in adults, it may be appropriate to enroll 209 adolescent patients (for the purpose of this guidance, ages 12 to younger than 18 years of 210 age) concurrently with adults in phase 3 trials and to make every effort to obtain 211 confirmatory pharmacokinetic and safety data from a cohort in this age group as part of 212 the data included at the time of filing of the original new drug application or biologics 213 license application. 214 215 3. Safety Considerations 216 217 An initial marketing application should include adequate safety data, such as the following, to 218 allow for a benefit-risk assessment of the drug: 219 220 • Safety data from 300 to 500 patients exposed to the proposed drug dose and treatment 221 duration (or greater) may be adequate; however, the size of the safety database could be 222 smaller for investigational drugs that demonstrate substantial efficacy and safety 223 compared to available therapies. Nonclinical or clinical safety signals may necessitate a 224 larger safety database or the conduct of additional safety studies. For a drug approved for 225 use in patients without cirrhosis or with compensated cirrhosis, the safety database 226 needed to extend use of the drug to the decompensated cirrhotic population would depend 227 on the safety profile of the investigational drug and the overall benefit-risk profile for the 228 indicated population. 229 230 • Clinical trial protocols should include predefined algorithms for data collection in the 231 setting of significant hepatic events, such as ALT flares or reactivation of HDV or HBV. 232 FDA encourages use of an independent adjudication committee to evaluate significant 233 hepatic events to determine whether the events represent drug-related toxicity, flares 234 related to viral reactivation, or immunologic responses to virologic infection. 235 236 • Severe acute exacerbations of HDV and HBV infection may occur after antiviral therapy 237 is discontinued. Hepatic function should be monitored closely with both clinical and 238 laboratory follow-up for at least several months in patients who discontinue anti-HDV 239 and/or anti-HBV therapy. In certain circumstances, resumption of antiviral therapy may 240 be warranted. The sponsor should adequately monitor and evaluate these concerns in the 241 11 For additional information, see the draft guidance for industry Enhancing the Diversity of Clinical Trial Populations — Eligibility Criteria, Enrollment Practices, and Trial Designs (June 2019). When final, this guidance will represent the FDA’s current thinking on this topic.
Contains Nonbinding Recommendations Draft — Not for Implementation 7 development program and convey, as appropriate, these concerns in proposed drug 242 labeling. 243 244 B. Phase 3 Efficacy Trial Considerations 245 246 1. Trial Design 247 248 No drugs have been approved for the treatment of chronic HDV infection. Therefore, a double- 249 blind, placebo-controlled trial is the FDA’s preferred trial design for a phase 3 clinical trial. 250 251 Alternative trial design options include the following: 252 253 • Three-arm, randomized, controlled trial comparing investigational drug, standard-of-care 254 treatment, and placebo. 255 256 − Although PEG-IFN-α has not been approved by FDA for the treatment of chronic 257 HDV infection, it is used in clinical practice and is considered the standard-of-care in 258 some parts of the world. As such, the use of PEG-IFN-α as a comparator in a clinical 259 trial may be acceptable. However, the treatment effect of PEG-IFN-α over placebo 260 has not been well established; therefore, superiority of the investigational drug versus 261 placebo should be demonstrated to support efficacy. The comparison between PEG- 262 IFN-α and placebo can establish the effect of PEG-IFN-α, and the comparison 263 between the investigational drug and PEG-IFN-α can help to evaluate the efficacy 264 and the safety profile of the investigational drug. 265 266 • Randomized, controlled trial in which subjects are randomized to the investigational drug 267 (immediate treatment group) or placebo for a prespecified duration followed by open 268 label treatment with investigational drug (deferred treatment group). Effectiveness would 269 be demonstrated by showing an early significant improvement over the placebo control. 270 271 • Randomized, controlled superiority trial comparing the investigational drug plus 272 standard-of-care treatment to standard-of-care treatment alone (i.e., an add-on trial). In 273 this case, although effectiveness is demonstrated, it would have been shown only when 274 the investigational drug is added to the standard-of-care treatment; the sponsor would not 275 know whether the investigational drug has an effect when used alone. 276 277 • Randomized, controlled superiority trial comparing different doses and/or durations of 278 the investigational drug. 279 280 After approval of a drug for the treatment of HDV infection, a randomized, controlled superiority 281 or noninferiority trial comparing the investigational drug against an active comparator is 282 appropriate. 283 284
Contains Nonbinding Recommendations Draft — Not for Implementation 8 2. Trial Population 285 286 Sponsors should include the following virologic and clinical characteristics in patient eligibility 287 criteria: 288 289 • Documentation of chronic HDV infection, defined as positive serum anti-HDV 290 antibodies 291 292 • Quantifiable HDV RNA of at least 6-month duration 293 294 • Receiving HBV treatment in accordance with current treatment guidelines. Patients who 295 qualify for HBV treatment should be on a stable regimen for at least 3 months with 296 documented HBV DNA suppression before initiating the HDV investigational therapy. 297 298 Sponsors should enroll sufficient numbers of patients in the trials who are infected with HDV 299 genotype 1 to assess efficacy in this population. 300 301 Sponsors should consider the following when enrolling patients without cirrhosis or with 302 compensated cirrhosis: 303 304 • The presence or absence of cirrhosis at trial entry should be documented. The use of a 305 noninvasive modality to define the presence or absence of cirrhosis in a trial should be 306 supported by references that summarize the performance characteristics and sensitivity 307 and specificity of the modality for its intended purpose in the proposed population. 308 309 • FDA recommends that sponsors exclude patients with decompensated cirrhosis or a 310 history of any prior hepatic decompensation event until data on the safety and 311 effectiveness of a given therapy in patients without cirrhosis and with compensated 312 cirrhosis are obtained. 313 314 3. Randomization and Stratification 315 316 If multiple subpopulations are included in the same trial, sponsors can consider stratifying groups 317 at randomization based on key variables such as presence or absence of cirrhosis, baseline HDV 318 RNA level, and genotype/region. 319 320 4. Dose Selection 321 322 FDA encourages sponsors to use quantitative clinical pharmacology approaches that leverage 323 prior information to optimize dose selection for phase 3 trials. These approaches are addressed in 324 other guidances for industry.12 325 326 12 See the guidance for industry Exposure-Response Relationships — Study Design, Data Analysis, and Regulatory Applications (April 2003) and the draft guidance for industry Population Pharmacokinetics (July 2019) (when final, this guidance will represent the FDA’s current thinking on this topic).
Contains Nonbinding Recommendations Draft — Not for Implementation 9 5. Comparators 327 328 See section III.B.1., Trial Design, for a description of potential comparators for use in different 329 trial designs. 330 331 6. Efficacy Endpoints 332 333 a. Primary endpoints 334 335 FDA anticipates that initial approvals for anti-HDV drugs will be based on a surrogate endpoint 336 that is reasonably likely to predict clinical benefit. An appropriate surrogate endpoint for the 337 treatment of HDV should provide evidence of both a decline in virologic replication and an 338 improvement in associated liver inflammation as evident by biochemical response (see section 339 III.B.9., Accelerated Approval (Subpart H) Considerations, for additional information regarding 340 approval under the accelerated approval pathway). For FDA, the following surrogate endpoint 341 could reasonably predict clinical benefit and could be considered to support an accelerated 342 approval: 343 344 • The proportion of trial patients with undetectable serum HDV RNA (defined as less than 345 the lower limit of quantification (LLOQ), target not detected (TND)) and ALT 346 normalization. 347 348 There are some data suggesting that a 2-log10 decline in HDV RNA is associated with clinical 349 benefit (Farci et al. 2004; Yurdaydin et al. 2019); therefore, in certain situations, such as for 350 drugs that are intended to be used as chronic suppressive therapy, a greater than or equal to 2- 351 log 10 decline in HDV RNA and ALT normalization on-treatment could be considered an 352 acceptable surrogate endpoint reasonably likely to predict clinical benefit (see section III.B.9., 353 Accelerated Approval (Subpart H) Considerations). The sponsor can request a Type C formal 354 meeting to discuss the use of a novel surrogate endpoint as the primary basis for drug approval.13 355 356 The timing of the primary endpoint assessment (whether on-treatment, at the end-of- treatment, 357 or off-treatment after a specified duration of follow-up) will depend on the treatment strategy 358 used (i.e., finite duration of therapy versus chronic suppressive therapy) for a specific drug. FDA 359 encourages the sponsor to discuss its proposed primary efficacy endpoint and the timing of the 360 endpoint assessment with DAVP. 361 362 Approval based on a surrogate endpoint reasonably likely to predict clinical benefit will require 363 subsequent confirmation using a clinical endpoint. FDA’s preferred clinical endpoint is 364 improvement in clinical outcomes such as decrease in progression to cirrhosis, progression to 365 decompensated liver disease, liver transplantation, hepatocellular carcinoma, and liver-related 366 death. These clinical outcomes should be collected as long-term follow-up data. 367 368 13 See the draft guidance for industry Formal Meetings Between the FDA and Sponsors or Applicants of PDUFA Products (December 2017). When final, this guidance will represent the FDA’s current thinking on this topic.
Contains Nonbinding Recommendations Draft — Not for Implementation 10 b. Secondary endpoints 369 370 Sponsors should consider the following secondary endpoints: 371 372 • Greater than or equal to 2-log 10 decline in serum HDV RNA 373 • HDV RNA less than LLOQ (TND) 374 • ALT normalization 375 • Histological response or change in liver stiffness 376 • Change in Model for End-Stage Liver Disease scores 377 • Change in Child-Turcotte-Pugh scores 378 379 7. Trial Procedures and Timing of Assessments 380 381 The optimal timing of the primary endpoint assessment is unknown. Sponsors should consider 382 the following for timing of assessments: 383 384 • For therapies intended to be administered indefinitely, an on-treatment assessment after a 385 predefined time period can be acceptable for efficacy. 386 387 • For therapies intended to be administered for a finite duration, FDA’s preferred endpoint 388 is an off-treatment assessment of efficacy. 389 390 8. Statistical Considerations 391 392 For recommendations and considerations on statistical analysis methods and issues, see the 393 guidance for industry Providing Clinical Evidence of Effectiveness for Human Drug and 394 Biological Products (May 1998) and the article “Statistical Considerations on Subgroup Analysis 395 in Clinical Trials” (Alosh et al. 2015). 396 397 a. Efficacy analyses 398 399 The preferred primary endpoints for phase 3 trials are described above in section III.B.6., 400 Efficacy Endpoints. Sponsors should consider the following recommendations for analyzing the 401 primary efficacy endpoint: 402 403 • The primary analysis should compare the proportion of responders across trial treatment 404 arms. This analysis determines whether effectiveness has been demonstrated. 405 406 • The analysis of the primary efficacy endpoint should be performed within important 407 subgroups based on demographic and baseline characteristics (e.g., geographic region, 408 sex, race, age group, screening HDV RNA level, HDV/HBV genotypes, baseline weight 409 and body mass index, baseline ALT, baseline fibrosis/cirrhosis, (if applicable) response 410 to previous treatment regimens). The purpose of these analyses is to explore the 411 consistency of the primary efficacy endpoint result across these subgroups. 412 413
Contains Nonbinding Recommendations Draft — Not for Implementation 11 b. Noninferiority trials 414 415 Because there are no approved therapies for the treatment of chronic HDV infection at this time, 416 a noninferiority trial design is not possible. In the future, should there be approved therapies for 417 the treatment of chronic HDV infection, noninferiority trials may be acceptable. Sponsors should 418 justify proposed noninferiority margins and discuss with DAVP.14 419 420 c. Combination regimens 421 422 Sponsors planning to evaluate a combination regimen of two or more drugs should consult 21 423 CFR 300.50 regarding combination drugs. Additional recommendations for codevelopment of 424 two new investigational drugs can be found in the guidance for industry Codevelopment of Two 425 or More New Investigational Drugs for Use in Combination (June 2013). 426 427 9. Accelerated Approval (Subpart H) Considerations 428 429 For HDV infection, no surrogate endpoints have been definitively shown to predict clinical 430 benefit. Trials aimed at demonstrating the clinical benefit of an HDV therapy would likely 431 require a prolonged follow-up period. Therefore, FDA anticipates that development programs 432 may opt to pursue accelerated approval pathways based on a surrogate endpoint reasonably 433 likely to predict clinical benefit (see section III.B.6., Efficacy Endpoints). An accelerated 434 approval pathway will require confirmation of clinical benefit through a long-term extension of 435 the original trial or a subsequent additional clinical trial or trials. Sponsors should consider 436 planning for the confirmatory trial(s) during the development of the phase 3 program. 437 438 C. Other Considerations 439 440 1. Clinical Virology Considerations 441 442 Sponsors can find general recommendations for clinical virology assessments in the guidances 443 for industry Antiviral Product Development — Conducting and Submitting Virology Studies to 444 the Agency and Chronic Hepatitis B Virus Infection: Developing Drugs for Treatment. Sponsors 445 should consider the following recommendations specific for HDV infection: 446 447 • Virologic Assessments 448 449 − For virologic assessments in clinical trials, we recommend the use of FDA-approved 450 or FDA-cleared assays, if available, and a central laboratory. If an investigational 451 assay or assays are used, the sponsor should provide performance characteristics of 452 the assay(s) determined from analytical validation studies using geographically and 453 temporally distinct isolates in addition to detailed descriptions of the methodology. 454 Viral loads should be reported in international units per milliliter (IU/mL). 455 456 14 For additional information on determining noninferiority margins, see the guidance for industry Non-Inferiority Clinical Trials to Establish Effectiveness (November 2016).
Contains Nonbinding Recommendations Draft — Not for Implementation 12 − Because HDV requires the HBV envelope protein to propagate, clinical efficacy 457 assessments should include virologic parameters for both HDV and HBV. 458 459 − Samples for HDV and HBV quantification, genotypic, and phenotypic analysis 460 should be obtained at multiple time points during treatment and follow-up. 461 462 − Where feasible, we recommend determining the genotypes/subtypes of both HDV 463 and HBV present at baseline and, hence, determine if the investigational drug exhibits 464 antiviral activity against all the HDV/HBV genotypes/subtypes represented in the 465 trial. 466 467 • Resistance Assessment 468 469 − In general, for treatment of HDV infection, virologic failure is defined as a confirmed 470 increase in HDV RNA levels of greater than or equal to 1.0 log 10 IU/mL above the 471 nadir value (assuming an initial response of at least 1.0 log10 IU/mL compared with 472 baseline) or having quantifiable HDV RNA after being less than LLOQ (TND). In 473 general, virologic nonresponse is defined as less than or equal to 1.0-log10 IU/mL 474 reduction in HDV RNA levels compared with baseline. 475 476 − Genotypic assessment of resistance should include sequencing of the HDV genome 477 and, for drugs that act through the HBV envelope protein or NTCP receptor, 478 sequencing of the HBsAg coding region where feasible. Any changes, including 479 mixtures, in the amino acid sequence of the target protein (or nucleotide sequence for 480 genome targeting drugs) present in on-treatment or follow-up samples, but not in the 481 baseline sample, can be reported as having developed during therapy. 482 483 − Phenotypic assessment of resistance should include analysis of HDV variants in cell 484 culture, if feasible, and determination of loss of susceptibility to the investigational 485 drug. 486 487 − Before submission of resistance data, contact FDA to obtain the most recent format 488 recommendations for submitting resistance datasets. 489 490 − For drugs with a host target, the frequency of polymorphisms in the target in key U.S. 491 racial groups should be reported and their effect on efficacy assessed in clinical trials. 492 493
Contains Nonbinding Recommendations Draft — Not for Implementation 13 REFERENCES 494 495 Aldabe, R, L Suárez-Amarán, C Usai, and G González-Aseguinolaza, 2015, Animal Models of 496 Chronic Hepatitis Delta Virus Infection Host-Virus Immunologic Interactions, Pathogens, 497 4(1):46–65. 498 499 Alosh, M, K Fritsch, M Huque, K Mahjoob, G Pennello, M Rothmann, E Russek-Cohen, F 500 Smith, S Wilson, and L Yue, 2015, Statistical Considerations on Subgroup Analysis in Clinical 501 Trials, Stat Biopharm Res, 7(4):286–303. 502 503 Chen, HY, DT Shen, DZ Ji, PC Han, WM Zhang, JF Ma, WS Chen, H Goyal, S Pan, and HG 504 Xu, 2019, Prevalence and Burden of Hepatitis D Virus Infection in the Global Population: A 505 Systematic Review and Meta-Analysis, Gut, 68:512–21. 506 507 Erhardt, A, W Gerlich, C Starke, U Wend, A Donner, A Sagir, T Heintges, and D Haussinger, 508 2006, Treatment of Chronic Hepatitis Delta with Pegylated Interferon-Alpha2b, Liver Int, 509 26(7):805–810. 510 511 Farci, P, T Roskams, L Chessa, G Peddis, AP Mazzoleni, R Scioscia, G Serra, ME Lai, M Loy, L 512 Caruso, V Desmet, RH Purcell, and A Balestrieri, 2004, Long-Term Benefit of Interferon Alpha 513 Therapy of Chronic Hepatitis D: Regression of Advanced Hepatic Fibrosis, Gastroenterology, 514 126(7):1740–1749. 515 516 Fattovich, G, S Boscaro, F Noventa, E Pornaro, D Stenico, A Alberti, A Ruol, and G Realdi, 517 1987, Influence of Hepatitis Delta Virus Infection on Progression to Cirrhosis in Chronic 518 Hepatitis Type B, J Infect Dis, 155(5):931–935. 519 520 Heidrich, B, C Yurdaydin, G Kabacam, BA Ratsch, K Zachou, B Bremer, GN Dalekos, A 521 Erhardt, F Tabak, K Yalcin, S Gurel, S Zeuzem, M Cornberg, CT Bock, MP Manns, and H 522 Wedemeyer, 2014, Late HDV RNA Relapse After Peginterferon Alpha-Based Therapy of 523 Chronic Hepatitis Delta, Hepatology, 60(1):87–97. 524 525 Patel, EU, CL Thio, D Boon, DL Thomas, and AAR Tobian, 2019, Prevalence of Hepatitis B 526 and Hepatitis D Virus Infections in the United States, 2011–2016, Clin Infect Dis, 69(4):709– 527 712. 528 529 Romeo, R, E Del Ninno, M Rumi, A Russo, A Sangiovanni, R de Franchis, G Ronchi, and M 530 Colombo, 2009, A 28-Year Study of the Course of Hepatitis Delta Infection: A Risk Factor for 531 Cirrhosis and Hepatocellular Carcinoma, Gastroenterology, 136(5):1629–1638. 532 533 Tang, LSY, E Covert, E Wilson, and S Kottilil, 2018, Chronic Hepatitis B Infection: A Review, 534 JAMA, 319(17):1802–1813. 535 536 Wedemeyer, H, C Yurdaydin, GN Dalekos, A Erhardt, Y Cakaloglu, H Degertekin, S Gurel, S 537 Zeuzem, K Zachou, H Bozkaya, A Koch, T Bock, HP Dienes, and MP Manns, 2011, 538
Contains Nonbinding Recommendations Draft — Not for Implementation 14 Peginterferon Plus Adefovir Versus Either Drug Alone for Hepatitis Delta, N Engl J Med, 539 364(4):322–331. 540 541 Winer, BY, E Shirvani-Dastgerdi, Y Bram, J Sellau, BE Low, H Johnson, T Huang, G 542 Hrebikova, B Heller, Y Sharon, K Giersch, S Gerges, K Seneca, MA Pais, AS Frankel, L 543 Chiriboga, J Cullen, RG Nahass, M Lutgehetmann, JE Toettcher, MV Wiles, RE Schwartz, and 544 A Ploss, 2018, Preclinical Assessment of Antiviral Combination Therapy in a Genetically 545 Humanized Mouse Model for Hepatitis Delta Virus Infection, Sci Transl Med, 10(447): 546 eaap9328. 547 548 Wranke, A and H Wedemeyer, 2016, Antiviral Therapy of Hepatitis Delta Virus Infection — 549 Progress and Challenges Towards Cure, Curr Opin Virol, 20:112–118. 550 551 Yurdaydin, C, Z Abbas, M Buti, M Cornberg, R Esteban, O Etzion, EJ Gane, RG Gish, JS 552 Glenn, S Hamid, T Heller, C Koh, P Lampertico, Y Lurie, M Manns, R Parana, M Rizzetto, S 553 Urban, and H Wedemeyer, on behalf of Hepatitis Delta International Network (HDIN), 2019, 554 Treating Chronic Hepatitis Delta: The Need for Surrogate Markers of Treatment Efficacy, J 555 Hepatol, 70(5):1008–1015. 556
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