Ezetimibe with simvastatin, tablets, 10 mg - 20 mg, Vytorin®, March 2009

Public summary document for Ezetimibe with simvastatin, tablets, 10 mg - 20 mg, Vytorin®, March 2009

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Public Summary Document

Product: Ezetimibe with simvastatin, tablets, 10 mg - 20 mg, Vytorin®
Sponsor: Merck Sharp & Dohme (Australia) Pty Ltd (and Schering – Plough Pty Ltd)
Date of PBAC Consideration: March 2009

1. Purpose of Application

The submission sought to list a new strength of ezetimibe with simvastatin and to lower the threshold dose to a daily dose of 20 mg or greater of a statin instead of the current daily dose 40 mg or greater.

2. Background

The March 2005 PBAC meeting recommended an authority required listing of ezetimibe with simvastatin (10/40 mg and 10/80 mg) on a cost-minimisation basis compared to the sum of the corresponding strengths of the individual components for use in patients with CHD or diabetes. Vytorin was first PBS-listed on 1 February 2006. The listing was expanded to other high risk patient groups at the PBAC meetings in November 2005 and November 2006.

The November 2006 meeting also considered an application to list a new strength of ezetimibe with simvastatin (10/10 mg). This was rejected on the grounds of unclear clinical need, and unnecessary proliferation of dosage forms.

This fixed strength of the combination of ezetimibe and simvastatin had not previously been considered by the PBAC.

3. Registration Status

Ezetimibe with simvastatin 10/10 mg, 10/20 mg, 10/40 mg and 10/80 mg were TGA registered on 07 January 2005 for the following:

  • Primary hypercholesterolemia - as adjunctive therapy to diet in patients with primary (heterozygous familial and non-familial) hypercholesterolemia or mixed hyperlipidemia where use of a combination product is appropriate:
  • Patients not appropriately controlled with a statin or ezetimibe alone.
  • Patients already treated with a statin and ezetimibe.
  • Homozygous Familial Hypercholesterolemia (HoFH). Patients may also receive adjunctive treatments (e.g., LDL apheresis).


4. Listing Requested and PBAC’s View


Authority Required (Streamlined)
Changes to the current listing are highlighted onBOLD
Treatment, in conjunction with dietary therapy and exercise, in patients whose cholesterol levels are inadequately controlled with an HMG CoA reductase inhibitor (statin) and who have:
(a) coronary heart disease; or
(b) diabetes mellitus; or
(c) peripheral vascular disease; or
(d) heterozygous familial hypercholesterolaemia; or
(e) cerebrovascular disease which has become symptomatic; or
(f) family history of coronary heart disease; or
(g) hypertension.

Inadequate control with a statin is defined as follows:
(1) where the patient falls into a category for which the General Statement for Lipid-Lowering Drugs includes an initial cholesterol threshold for PBS-subsidy, a cholesterol level in excess of that threshold after at least 3 months of treatment at a daily dose of 20 mg or greater of a statin, in conjunction with dietary therapy and exercise. The dose and duration of statin treatment and the cholesterol level which shows inadequate control must be documented in the patient's medical records when the ezetimibe component is initiated. The cholesterol level which shows inadequate control must be no more than 2 months old when the ezetimibe component is initiated; or
(2) where the patient falls into a category for which the General Statement for Lipid-Lowering Drugs allows PBS-subsidised treatment with a statin at any cholesterol level, a cholesterol level in excess of 4 mmol per L after at least 3 months of treatment at a daily dose of 20 mg or greater of a statin, in conjunction with dietary therapy and exercise. The dose and duration of statin treatment and the cholesterol level which shows inadequate control must be documented in the patient's medical records when the ezetimibe component is initiated. The cholesterol level which shows inadequate control must be no more than 2 months old when the ezetimibe component is initiated.

Patients with homozygous familial hypercholesterolaemia who are eligible for PBS-subsidised lipid-lowering medication (according to the criteria set out in the General Statement for Lipid-Lowering Drugs).

For PBAC’s view, see Recommendation and Reasons.
 

5. Clinical Place for the Proposed Therapy

Vytorin 10/20 mg would provide an alternative therapy in patients whose cholesterol is not controlled on 20 mg of a statin or greater.

6. Comparator

The submission nominated simvastatin 40 mg, atorvastatin 20 mg and 40 mg and rosuvastatin 20 mg as the main comparators i.e., up-titration of statin dose from statin 20 mg or switching to a more potent statin which was considered appropriate by the PBAC.

7. Clinical Trials

The submission presented five randomised trials comparing Vytorin 10/20 or ezetimibe 10 mg/simvastatin 20 mg with simvastatin 40 mg and atorvastatin 20 mg in patients with hypercholesterolemia where patients were being treated in the second-line setting (i.e., randomised to treatment after a run-in period on statin 20 mg). Three of the five trials conducted in the second-line setting randomised patients to ezetimibe/simvastatin or up-titration of statin following inadequate control on a stable statin dose and the remaining two trials randomised patients to ezetimibe/simvastatin or up-titration of statin regardless of lipid control.

The submission also presented four randomised trials comparing Vytorin 10/20 or ezetimibe 10 mg/simvastatin 20 mg with atorvastatin 40 mg and rosuvastatin 20 mg in patients with hypercholesterolemia where patients were treated in the first-line setting i.e., randomised to treatment after a run-in period on placebo.

The studies published at the time of the submission, are as follows:

Trial/First author Protocol title Publication citation
Trials of EZ10/20 as versus relevant comparator(s) where treatment was received as 2nd Line therapy
Barrios et al Lipid-altering efficacy of switching from atorvastatin 10 mg/day to ezetimibe/simvastatin 10/20 mg/day compared to doubling the dose of atorvastatin in hypercholesterolaemic patients with atherosclerosis or coronary heart disease. Int J Clin Pract 2005; 59:1377-86.
EASEGO (Roeters et al) The efficacy of statin monotherapy up titration versus switching to ezetimibe/simvastatin: Curr Med Res Opin 2008; 24:685-94.
Protocol 700
Bobs et al Co-administration of ezetimibe with simvastatin. J Am Coll Cardiol 2003; 41(6, Suppl. A): 227A-227A.
Constance et al Efficacy of ezetimibe/simvastatin 10/20 and 10/40 mg compared with atorvastatin 20 mg in patients with type 2 diabetes mellitus. Diabetes Obes Metab 2007; 9:575-84.
Protocol 021
Gaudiani et al Efficacy and safety of ezetimibe co-administered with simvastatin in thiazolidinedione-treated type 2 diabetic patients. Diabetes, Obesity and Metabolism. 7(1): 88-97, 2005.
Gaudiani et al Efficacy and safety of ezetimibe co-administered with simvastatin versus simvastatin alone in thiazolidinedione-treated type 2 diabetes mellitus. Journal of the American College of Cardiology 43(5, Suppl. A): 479A-479A (#1084-169) March 2004 (in Soc. Proc.).
Trial/First author Protocol title Publication citation
Trials of EZ10/20 as versus relevant comparator(s) where treatment received as 1st Line therapy for where a second line comparison was not available
Protocol 051 (VYVA study)
Ballantyne et al Attainment of optimal National Cholesterol Education Program Adult treatment panel III treatment goals in high risk patients: dose comparison of VYTORIN (ezetimibe/simvastatin) and atorvastatin. Journal of the American College of Cardiology, 45 (3, Suppl.A) 423A-423A, 2005.
Ballantyne et al Dose comparison study of the combination of ezetimibe and simvastatin (VYTORIN) versus atorvastatin in patients with hypercholesterolemia: the VYTORIN versus Atorvastatin (VYVA) study. American Heart Journal 149(3): 464-73, 2005.
Ballantyne et al Evaluation of the safety and efficacy of the ezetimibe/simvastatin combination tablet versus atorvastatin in patients with hypercholesterolemia. XV International Symposium on Drugs Affecting Lipid Metabolism, 24-27 October 2004, Venice Italy, Abstract p124.
Abate et al Ezetimibe/simvastatin versus atorvastatin for patients who have diabetes mellitus and hypercholesterolemia. Diabetologia 48(Suppl. 1) A392-A393 (#1087) August 2005.
Ballantyne et al Ezetimibe/simvastatin versus atorvastatin for patients who have diabetes mellitus and hypercholesterolemia. Diabetes 54 (Suppl. 1): A235-A235 (#962-P) June 2005.
Protocol 077 (VYTAL)
Goldberg et al Ezetimibe/simvastatin vs atorvastatin in patients with type 2 diabetes mellitus and hypercholesterolemia: The VYTAL study. Mayo Clin Proc 2006;81:1579-88.
Guyton et al Lipoprotein and apolipoprotein ratios in the VYTAL trial of ezetimibe/simvastatin compared with atorvastatin in type 2 diabetes. J Clin Lipidology 2008;2:19-24. J Clin Lipidology 2008;2:19-24.
Weinstock et al Effect of ezetimibe/simvastatin vs atorvastatin on lowering levels of LDL-C and non-HDL-C, ApoB, and hs-CRP in patients with type 2 diabetes. J Clin Lipidology 2008;2:25-35.
COMPELL (McKenney et al) Comparative effects on lipid levels of combination therapy with a statin and extended-release niacin or ezetimibe versus a statin alone (the COMPELL study). Atherosclerosis 2007;192:432-7.
Protocol 058
Catapano et al Lipid-altering efficacy of the ezetimibe/simvastatin single tablet versus rosuvastatin in hypercholesterolemic patients. Curr Med Res Opin 2006; 22:2041-53.
Abate et al LDL-C lowering efficacy of the ezetimibe/simvastatin single tablet compared with atorvastatin or rosuvastatin in elderly patients with hypercholesterolemia. J. Am. Geriatric Society 54(4, Suppl.):S163-S163 (#D22) 2006.

8. Results of Trials

The outcome from the randomised second-line trials that was used in the modelled economic evaluation was the percentage mean change in Total Cholesterol:High Density Lipoprotein-C (TC:HDL-C) ratios. The results of the meta-analyses of the second-line randomised trials are presented below:

Results of mean change in TC:HDL-C ratio from baseline to end point changes across the direct randomised trials (second-line setting)

Trial ID V10/20 or E10/S20 S40 or A20 End point (weeks) WMD (95% CI)
n/N (%) Mean (SD) n/N (%) Mean (SD)
Second-line setting: Patients randomised to Vytorin 10/20 or up-titration of statin following inadequate control on a stable statin dose
Barrios (V10/20 v A20) 215/221 (97.3) -20.90 (14.66) 207/214 (96.7) -11.70 (14.39) 6 -9.20 (-11.97, -6.43)
EASEGO (V10/20 v A20 or S40) 157/178 (88.2) -13.50 (18.68) 174/189 (92.1) -6.10 (17.87) 12 -7.40 (-11.35, -3.45)
Pooled result (inadequate control) Chi-square for heterogeneity: P=0.46 I 2 statistic with 95% uncertainty interval=0% -8.61 (-10.87, -6.34)
Second-line setting: Patients randomised to Vytorin 10/20 or up-titration of statin following run-in on a stable statin dose (not necessarily inadequately controlled)
Constance (E10/S20 v A20) 219/220 (99.5) -15.31 (19.82) 218/219 (99.5) -5.90 (19.81) 6 -9.41 (-13.13, -5.69)
Protocol 021 (E10/S20 v S40) 103/104 (99.0) -13.40 (22.27) 107/110 (97.3) 0.10 (17.42) 24 -13.50 (-18.92, -8.08)
Pooled result (control not determined) Chi-square for heterogeneity: P=0.19 I 2 statistic with 95% uncertainty interval=42.5% -10.96 (-14.85, -7.07)
Pooled result (all trials) Chi-square for heterogeneity: P=0.36 I 2 statistic with 95% uncertainty interval=6.0% -9.37 (-11.27, -7.47)

V10/20=Vytorin 10/20, S40=simvastatin 40 mg, A20=atorvastatin 20 mg,
E10/S20=ezetimibe 10 mg/simvastatin 20 mg, SD=standard deviation, WMD=weighted mean difference

The results of the meta-analysis of the first-line randomised trials for mean Low Density Lipoprotein-C (LDL-C) percentage change and TC:HDL-C ratios are shown below:

Results of mean LDL-C percentage change from baseline to end point changes across the direct randomised trials (first-line setting)

Trial ID (comparison) V10/20 or E10/S20 A40 or R20 End Point (weeks) WMD (95% CI)
n/N (%) Mean (SD) n/N (%) Mean (SD)
Protocol 051 (V10/20 v A40) 233/238 (97.9) -50.60 (14.02) 232/237 (97.9) -48.30 (14.77) 6 -2.30 (-4.92, 0.32)
Protocol 077 (V10/20 v A40) 238/247 (96.3) -53.60 (14.17) 241/254 (98.4) -50.90 (14.26) 6 -2.70 (-5.25, -0.15)
Pooled result Chi-square for heterogeneity: P=0.83 I 2 statistic with 95% uncertainty interval=0% -2.51 (-4.33, -0.68)
COMPELL (E10/S20 v R20) 72/77 (93.5) -53.00 (12.99) 73/76 (96.1) -50.00 (13.08) 8 -3.00 (-7.24, 1.24)
Protocol 058 (V10/20 v R20) 476/492 (96.7) -51.50 (11.13) 478/495 (96.6) -52.30 (12.27) 6 0.80 (-0.69, 2.29)
Pooled result Chi-square for heterogeneity: P=0.10 I 2 statistic with 95% uncertainty interval=63.2% -0.56 (-4.13, 3.01)

V10/20=Vytorin 10/20, E10/S20=ezetimibe 10 mg/simvastatin 20 mg, A40=atorvastatin 40 mg, R20=rosuvastatin 20 mg, SD=standard deviation, WMD=weighted mean difference.

Results of mean change in TC:HDL-C ratio from baseline to end point changes across the direct randomised trials (first-line setting)

Trial ID (comparison) V10/20 or E10/S20 A40 or R20 End point (weeks) WMD (95% CI)
n/N (%) Mean (SD) n/N (%) Mean (SD)
Protocol 051 (V10/20 v A40) 233/238 (97.9) -40.00 (11.68) 232/237 (97.9) -37.10 (11.66) 6 -2.90 (-5.02, -0.78)
Protocol 077 (V10/20 v A40) 238/247 (96.3) NR 241/254 (98.4) NR 6 NC
Pooled result Chi-square for heterogeneity: P=NA I 2 statistic with 95% uncertainty interval=NA NC
COMPELL (E10/S20 v R20) 72/77 (93.5) -43.00 (8.66) 73/76 (96.1) -40.00 (8.72) 8 -3.00 (-5.83, -0.17)
Protocol 058 (V10/20 v R20) 476/492 (96.7) -40.30 (10.02) 478/495 (96.6) -41.40 (10.04) 6 1.10 (-0.17, 2.37)
Pooled result Chi-square for heterogeneity: P=0.01 I 2 statistic with 95% uncertainty interval=85.0% -0.75 (-4.75, 3.25)

V10/20=Vytorin 10/20, E10/S20=ezetimibe 10 mg/simvastatin 20 mg, A40=atorvastatin 40 mg, R20=rosuvastatin 20 mg, SD=standard deviation, WMD=weighted mean difference, NR=not reported, NC=not calculable, NA=not applicable.

The PBAC noted patients treated with Vytorin 10/20 or ezetimibe 10 mg and simvastatin 20 mg concomitantly experience statistically significantly greater percentage mean reductions in TC:HDL-C compared with simvastatin 40 mg or atorvastatin 20 mg in the second-line treatment setting. In the first-line setting patients treated with Vytorin 10/20 or ezetimibe 10 mg/simvastatin 20 mg experienced statistically significantly greater reductions in LDL-C, and TC:HDL-C ratio (and statistically significantly greater increases in HDL-C) than those treated with atorvastatin 40 mg. No statistically significant differences in any of the reported outcomes was observed between patients treated with Vytorin 10/20 or ezetimibe 10 mg/simvastatin 20 mg and those treated with rosuvastatin 20 mg.

No significant differences in any adverse event outcomes reported were observed between Vytorin 10/20 or ezetimibe 10 mg/simvastatin 20 mg and its comparators (simvastatin 40 mg, atorvastatin 20 mg and 40 mg and rosuvastatin 20 mg).

9. Clinical Claim

The submission claimed that Vytorin 10/20 was superior in terms of effectiveness compared with simvastatin 40 mg, atorvastatin 20 mg and atorvastatin 40 mg and equi-effective compared with rosuvastatin 20 mg. This was accepted by the PBAC.

The submission’s claim that Vytorin 10/20 is non-inferior in terms of safety to all its nominated comparators was also accepted as reasonable.

10.Economic Analysis

The submission presented a cost-minimisation analysis of Vytorin (V)10/20 and rosuvastatin 20 mg and a stepped economic evaluation for each of the other comparators i.e., V10/20 versus Simvastatin (S)40, V10/20 v Atorvastatin (A)20, V10/20 versus A40.

The model was a Markov model with four health states dependent on the presence or absence of Coronary Heart Disease (CHD) or Cardiovascular Disease (CVD) and the cause of death.

The model transformed TC:HDL ratios to CHD events, deaths due to CVD and mortality and estimates LYG and QALY.

The incremental cost-effectiveness ratios (ICER) per Quality-Adjusted Life-Year (QALY) gained over 20 years for Vytorin 10/20 versus simvastatin 40 mg was estimated to be in the range of $15,000 - $45,000.

For PBAC’s view see Recommendation and Reasons.

11. Estimated PBS Usage and Financial Implications

The submission estimated the likely number of packs dispensed per year to be at a cost to the PBS of between $10 – $ 30 million in Year 5.

The PBAC considered this was a likely underestimate of the financial implications.

12. Recommendation and Reasons

The PBAC considered that the choices of up titration of statin dose from statin 20 mg or switching to a more potent statin as the main comparators were appropriate.

The PBAC agreed that although the requested restriction would place Vytorin 10/20 as a second-line treatment, the results of trials in first line use were relevant, given that the outcome of interest is the effect on LDL and then modelling survival benefits from this in an appropriate (though different) population. The PBAC agreed that the effect on LDL is not modified by whether use is first- or second- line, although the size of any effect on survival would be.

Therefore, in terms of effect on LDL (and TC:HDL-C ratio), the PBAC accepted the submission’s claim that Vytorin 10/20 daily is superior in terms of effectiveness compared with simvastatin 40 mg, atorvastatin 20 mg and atorvastatin 40 mg and equi-effective compared with rosuvastatin 20 mg daily. The submission’s claim that Vytorin 10/20 is non-inferior in terms of safety to all its nominated comparators was also accepted as reasonable.

The submission presented a cost-minimisation analysis of Vytorin 10/20 and rosuvastatin 20 mg and a stepped economic evaluation is presented for each of the other comparators (i.e., Vytorin10/20 versus simvastatin 40 mg, Vytorin 10/20 versus atorvastatin 20 mg, Vytorin 10/20 versus atorvastatin 40 mg). The PBAC noted rosuvastatin is the least prescribed of the three PBS-listed statins.

The submission presented the same model that has been previously considered by the PBAC. The outcome from the randomised second-line trials that was used in the modelled economic evaluation was the percentage mean change in TC-HDL-C ratios.

The PBAC considered the time horizon of the model (70 years) to be unreasonable, particularly given the age and health status of the population in the modelled evaluation. Patients have an average age of 71 years at baseline in the model, and the mortality rates applied to this population may be underestimated, and thus the incremental effect on survival overestimated. The Incremental Cost Effectiveness Ratio (ICER) increased from the lower range of between $15,000 - $45,000 to the upper range of between $45,000 - $75,000 as the time horizon decreased.

The PBAC considered a 20-year time horizon was more appropriate given the age and health status of the population in the modelled evaluation, and the resulting ICER per QALY in the $15,000 - $45,000 range to be high.

The PBAC noted the submission estimated the financial cost per year of listing would be in the $10 – $30 million range by year 5 of listing. This was considered a likely underestimate as the submission considered only substitution from simvastatin 40 mg, atorvastatin 20 mg, atorvastatin 40 mg, rosuvastatin 20 mg and pravastatin 40 mg and does not consider potential substitution from concomitant use of ezetimibe 10 mg and 20 mg of other statins. As these patients will be switching from two therapies (where two co-payments were made) to a single combination therapy, with a single co-payment, the costs to the PBS are likely to increase in cases of this substitution. It was also noted that the total cost of statin medications on the PBS in the 12 months to June 2008 was in excess of $900 million.

The PBAC recalled that it had previously accepted cost-minimisation claims for the listing of lipid lowering drugs on the basis of the extent of LDL cholesterol reduction. The PBAC also recalled when ezetimibe had been recommended for listing in June 2003, listing was recommended on the basis of pricing being related to the extent of LDL cholesterol reduction with ezetimibe compared with the statins. The PBAC did not accept the submission’s claim of cost-effectiveness at the requested price compared with atorvastatin, particularly in the absence of clinical endpoint data showing improved outcomes in terms of mortality or cardiovascular events.

Further, in July 2005, the PBAC had again indicated its concern with respect to the lack of direct clinical end-point data available for lipid lowering drugs during its consideration of atorvastatin. In July 2005, following the presentation of further data, the PBAC advised that the only basis for judging whether the price relativity could be further increased would be an incremental cost-effectiveness analysis based on major cardiovascular events measured directly in randomised trials rather than based on predictions modeled from surrogate outcomes.

The comment in the recent article, Amid Lingering Questions, FDA Reprieves LDL Cholesterol–Lowering Medication, Mitka M, JAMA. 2009; 301(8):813-815, that the hopes for providing evidence that ezetimibe/simvastatin affects clinical outcomes such as myocardial infarction or death rests on results from the ongoing Improved Reduction of Outcomes Vytorin Efficacy International Trial (IMPROVE-IT), which has a completion date of 2012, was noted. The PBAC noted that despite the FDA acceptance of LDL lowering as a surrogate endpoint, there was ongoing unease in the medical community concerning the translation of these data into overall mortality and morbidity benefits.

The PBAC noted that not only was it required to take into account effectiveness, comparative effectiveness and cost-effectiveness during its decision making process, but also other relevant factors such as financial cost to the PBS, and community need for a product.

The Committee considered that, were ezetimibe with simvastatin 10/20 mg (Vytorin) to be recommended for listing, the health benefits derived from its availability would be similar to the health benefits associated with up-titration of a statin. However, while both statins and ezetimibe lower lipid levels, the mortality benefits of statins has been demonstrated, and up-titration with a statin was the preferred approach. The current restriction allows for ezetimibe to be introduced only where inadequate lipid lowering had occurred at a dose of 40 mg or greater of a statin, or where the statin dose is lowered to 20 mg per day or discontinued due to the development of clinically important product-related adverse events.

Therefore, the PBAC rejected the application on the basis of a lack of clinical need, given the availability of statins to provide a similar health benefit, that in terms of a cost-effectiveness evaluation the listing would provide currently available benefits at a higher cost, and the listing would place an additional significant financial burden on the PBS.

The PBAC noted that the submission meets the criteria for an Independent Review.

Recommendation:
Reject

13. Context for Decision

The PBAC helps decide whether and, if so, how medicines should be subsidised in Australia. It considers submissions in this context. A PBAC decision not to recommend listing or not to recommend changing a listing does not represent a final PBAC view about the merits of the medicine. A company can resubmit to the PBAC or seek independent review of the PBAC decision.

14. Sponsor’s Comment

The sponsors acknowledge the PBAC's acceptance of the clinical efficacy and safety profile of Vytorin 10/20 and they will continue to work with the PBAC to identify patient groups in which the use of Vytorin 10/20 is considered appropriate.

A number of outcomes studies are currently under way and these trials should provide data that demonstrate that lowering cholesterol with Vytorin results in improved outcomes in terms of mortality and cardiovascular events.