Food and Drug Administration Center for Drug Evaluation and Research Summary Minutes of the Endocrinologic and Metabolic Drugs Advisory Committee Meeting December 12, 2013 Location: FDA White Oak Campus, Building 31, The Great Room (Rm. 1503), White Oak Conference Center, 10903 New Hampshire Avenue, Silver Spring, Maryland Issue: The committee discussed the efficacy and safety of new drug application (NDA) 202293, dapagliflozin tablet, submitted by Bristol-Myers Squibb. Dapagliflozin is a sodium-glucose cotransporter 2 inhibitor developed as an adjunct to diet and exercise to improve glycemic control in adults with type 2 diabetes mellitus. These summary minutes for the December 12, 2013 Endocrinologic and Metabolic Drugs Advisory Committee meeting were approved on January 17, 2014. I certify that I attended the December 12, 2013 meeting of the Endocrinologic and Metabolic Drugs Advisory Committee meeting and that these minutes accurately reflect what transpired. ___________/S/________________ Karen Abraham-Burrell, PharmD Designated Federal Officer, AVDAC ____________/S/______________ Robert J. Smith, MD Acting Chairperson, EMDAC Page 1 of 8 The Endocrinologic and Metabolic Drugs Advisory Committee (EMDAC) meeting of the Food and Drug Administration (FDA), Center for Drug Evaluation and Research met on December 12, 2013, at the FDA White Oak Campus, Building 31, The Great Room (Rm. 1503), White Oak Conference Center, 10903 New Hampshire Avenue, Silver Spring, Maryland. Prior to the meeting, members and temporary voting members were provided copies of the background materials from the FDA and Bristol-Myers Squibb. The meeting was called to order by Robert J. Smith, MD (Acting Chairperson); the conflict of interest statement was read into the record by Karen Abraham-Burrell, PharmD (Designated Federal Officer). There were approximately 150 persons in attendance. There were four Open Public Hearing speakers. Issue: The committee discussed the efficacy and safety of new drug application (NDA) 202293, dapagliflozin tablet, submitted by Bristol-Myers Squibb. Dapagliflozin is a sodium-glucose cotransporter 2 inhibitor developed as an adjunct to diet and exercise to improve glycemic control in adults with type 2 diabetes mellitus. Attendance: EMDAC Members Present (Voting): Erica H. Brittain, PhD; Diana Hallare, MPH (Consumer Representative); William Hiatt, MD, FACP; Robert J. Smith, MD (Acting Chairperson) EMDAC Members Not Present (Voting): Vera Bittner, MD, MSPH; David Cooke, MD; Edward Gregg, PhD; Ed Hendricks, MD; Ellen Seely, MD; Charles Stanley, MD EMDAC Member Present (Non-Voting): Mads F. Rasmussen, MD, PhD Temporary Members (Voting): Barbara Berney; Antonio Tito Fojo, MD, PhD; Julia Lewis, MD; Kevin McBryde, MD; Milton Packer, MD; Abraham Thomas, MD, MPH, FACP; Peter Savage, MD; Miriam Vos, MD, MSPH; Peter Wilson, MD; Wyndham Wilson, MD FDA Participants (Non-Voting): Curtis Rosebraugh, MD; Jean-Marc Guettier, MDCM; Frank Pucino, PharmD, MPH; Eugenio Andraca-Carrera, PhD Designated Federal Officer (Non-Voting): Karen Abraham-Burrell, PharmD Page 2 of 8 Open Public Hearing Speakers: Sidney Wolfe, MD (statement read by Sammy Almashat, MD, MPHPublic Citizen Health Research Group); Robert Ratner, MD, FACP, FACE (American Diabetes Association); Bennet Dunlap (Diabetes Advocates); Diana Zuckerman, PhD (Cancer Prevention and Treatment Fund) The agenda proceeded as follows: Call to Order and Introduction of Committee Robert J. Smith, MD Acting Chairperson, EMDAC Conflict of Interest Statement Karen Abraham-Burrell, PharmD Designated Federal Officer, EMDAC FDA Introductory Remarks Jean-Marc Guettier, MDCM Acting Division Director Division of Metabolism and Endocrinology Products (DMEP) Office of Drug Evaluation (ODE-II) Office of New Drugs (OND), CDER, FDA SPONSOR PRESENTATIONS Bristol-Myers Squibb Introduction Amy Jennings, PhD Group Director, Cardiovascular/Metabolics Global Regulatory & Safety Sciences - US Bristol-Myers Squibb Medical Need for New Anti-Diabetic Treatments Harold E. Bays MD, FTOS, FACE, FNLA Medical Director/President Louisville Metabolic and Atherosclerosis Research Center Inc. (L-MARC Research Center) Louisville, Kentucky Dapagliflozin: Overview of Mode of Action and Introduction to Development Program James List, MD, PhD Vice President, Development Lead –Dapagliflozin Bristol-Myers Squibb Clinical Efficacy Shamik Parikh, MD Vice President, Global Medical Diabetes & Metabolism AstraZeneca Page 3 of 8 Safety James List, MD, PhD Dean F. Bajorin, MD Professor of Medicine Weill Cornell Medical College Attending Physician Genitourinary Oncology Service Division of Solid Tumor Oncology Memorial Sloan-Kettering Cancer Center New York, New York Clinical Perspective John Wilding, DM, FRCP Professor of Medicine & Honorary Consultant Physician Head of Department of Obesity and Endocrinology Institute of Ageing & Chronic Disease Clinical Sciences Centre University Hospital Aintree Liverpool, United Kingdom Dapagliflozin Post-Approval James List, MD, PhD Clarifying Questions BREAK FDA PRESENTATIONS Statistical Assessment of Cardiovascular Safety Eugenio Andraca-Carrera, PhD Mathematical Statistician Division of Biometrics VII Office of Biostatistics Office of Translational Sciences, CDER, FDA Clinical Efficacy and Noncardiovascular Safety Frank Pucino, PharmD, MPH Clinical Reviewer DMEP, ODE-II, OND, CDER, FDA Clarifying Questions LUNCH Open Public Hearing Questions to the Committee/Committee Discussion Page 4 of 8 BREAK Questions to the Committee/Committee Discussion (cont.) ADJOURNMENT Questions to the Committee: Cardiovascular Risk Evaluation: 1) DISCUSSION: Based on the information provided in the briefing package and the presentations at today’s meeting, please address the following with regard to the cardiovascular risk assessment for dapagliflozin. a. Comment on which data (i.e., overall population, enriched population) best inform the cardiovascular risk associated with dapagliflozin use and discuss the weight you place on the evidence provided by the subgroup of patients specifically recruited on the basis of established cardiovascular disease in Trials 18 and 19. b. Discuss whether you believe the updated cardiovascular risk data derived from Trials 18 and 19 are consistent with the overall findings reported for the pool of 21 clinical trials. c. Discuss the clinical importance you place on the observed changes in blood pressure, weight, glycemic control and lipid parameters in informing overall cardiovascular risk of dapagliflozin. d. Discuss additional concerns, if any, you may have with regard to dapagliflozin and cardiovascular risk. Committee Discussion: Some committee members commented that there was not a convincing signal for increased cardiovascular events with the use of dapagliflozin. The committee also commented that the conclusions of the studies do not fundamentally change as different individual studies, in particular studies 18 and 19 versus the overall pool of studies, are considered. With regard to the future trials, the committee agreed that data from short-term trials are less informative than data from long-term trials and consideration should be given to longer trials. The committee also made the following comments related to the overall trials presented: • There was a concern related to the overall role of censoring • There was a lack of diversity in the studies with regards to Blacks and Hispanics • Changes in blood pressure, weight, glycemic control and lipid parameters were modest Please see the transcript for details of the committee discussion. Page 5 of 8 Malignancy: 2) DISCUSSION: Based on the information provided in the briefing package and the presentations at today’s meeting, discuss your level of concern with regard to the observed association between dapagliflozin use and occurrence of cancer identified in the application. Specifically, comment on whether you believe use of dapagliflozin is associated with an increased risk of bladder cancer and explain your rationale. Committee Discussion: The committee commented that, based on the data for dapagliflozin use, the overall risk of any cancer had a relative risk of one (1) and that was reassuring that dapagliflozin is not associated with an increased overall risk of cancer. In regards to bladder cancer, the committee noted that there were ten cases of bladder cancer in the various dapagliflozin studies presented and that the data represents a potential risk, but not a convincing risk due to the small number of events. The committee members further noted that five of the ten cases of bladder cancer occurred in the first six months of treatment with dapagliflozin and this is a much shorter time than would be anticipated if tumorogenesis were to occur due to use of this drug. In addition, it was noted that eight of the ten cases were noninvasive; if dapagliflozin were a tumor promoter one would expect to see more invasive cancers. There was a consensus among the committee that the data presented do not warrant a requirement for further studies on bladder cancer risk prior to approval; however, postmarketing studies are recommended. Regarding breast cancer risk with the use of dapagliflozin; the committee agreed that an evaluation of studies for breast cancer risk should be conducted in the post-marketing phase. Please see the transcript for details of the committee discussion. Liver Toxicity: 3) DISCUSSION: Based on the information provided in the briefing package and the presentations at today’s meeting, discuss your level of concern with regard to dapagliflozin use and drug-induced liver injury. Specifically comment on whether you believe use of dapagliflozin is associated with an increased risk of drug-induced liver injury and explain your rationale. Committee Discussion: Overall, the committee did not have substantial concerns about liver disease occurring with dapagliflozin use as the data presented did not appear to provide a significant risk signal for liver disease. However, the committee recommended monitoring for liver disease post-marketing. Please see the transcript for details of the committee discussion. Page 6 of 8 4) VOTE: In accordance with FDA’s Guidance for Industry titled “Diabetes Mellitus – Evaluating Cardiovascular Risk in New Anti-diabetic Therapies to Treat Type 2 Diabetes”, has the Applicant provided sufficient evidence that dapagliflozin, relative to comparators, has an acceptable cardiovascular risk profile? a. If you voted “Yes” to question #4, please provide your rationale. b. If you voted “No” to question #4, please provide your rationale. Vote: Yes= 10 No = 4 Abstain = 0 Committee Discussion: The majority of the committee members agreed that the Applicant provided sufficient evidence that dapagliflozin, relative to comparators, has an acceptable cardiovascular risk profile. The committee members who voted “No” indicated that some of the results from the subgroups raised concerns, and several noted that the data was not sufficient. Please see the transcript for details of the committee discussion. 5) VOTE: Based on the information included in the briefing materials and presentations today, do the benefits of dapagliflozin use outweigh identified risks and support marketing of dapagliflozin as an adjunct to diet and exercise to improve glycemic control in adults with type 2 diabetes mellitus? a. If you voted “Yes” to question #5, please provide your rationale and whether you recommend any additional studies post-approval. b. If you voted “No” to question #5, please provide your rationale and discuss what additional data are necessary to support approval. Vote: Yes= 13 No = 1 Abstain = 0 Committee Discussion: The majority of the committee members agreed that the benefits of dapagliflozin use outweigh identified risks and support marketing of dapagliflozin as an adjunct to diet and exercise to improve glycemic control in adults with type 2 diabetes mellitus. Some of the committee members who voted “Yes” commented that the cancer risk does not rise to the level of non-approval. On the other hand, the committee member who voted “No” commented that dapagliflozin does appear to increase the risk of cancer, infections and cardiovascular events. There was a consensus that post-marketing studies should be conducted and the committee members made the following suggestions for long-term considerations: • Monitor kidney function and drug-induced liver injury via post-marketing studies • Monitor occurrence of bladder cancer via post-marketing studies • Conduct follow-up studies to determine whether a lower dose might be appropriate in the elderly • Review the DECLARE study once it is complete Page 7 of 8 • Conduct studies that provide information on dapagliflozin use and diabetic neuropathy with proteinuria • Perform longer follow-up studies to evaluate breast cancer risk Please see the transcript for details of the committee discussion. The meeting was adjourned at approximately 4:47 p.m. Page 8 of 8