Corifollitropin alfa, solution for injection, 100 micrograms in 0.5 mL, 150 micrograms in 0.5 mL, pre-filled syringe, Elonva®

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Product: Corifollitropin alfa, solution for injection, 100 micrograms in 0.5 mL, 150 micrograms in 0.5 mL, pre-filled syringe, Elonva®
Sponsor: Schering-Plough Pty Ltd (MSD)
Date of PBAC Consideration: November 2010

1. Purpose of Application

The submission sought a Section 100 IVF/GIFT Program listing for patients who are receiving medical treatment as described in items 13200, 13201, 13202 or 13203 of the Medicare Benefits Schedule.

2. Background

This drug had not previously been considered by the PBAC.

3. Registration Status

On 30 July 2010, corifollitropin was TGA registered for controlled ovarian stimulation for the development of multiple follicles and pregnancy in women participating in in-vitro fertilisation techniques.

4. Listing Requested and PBAC’s View

Section 100 IVF/GIFT Program
Patients who are receiving medical treatment as described in items 13200, 13201, 13202 or 13203 of the Medicare Benefits Schedule.

NOTE:
Supply of these items is through an accredited IVF/GIFT clinic. For enquiries relating to the IVF/GIFT Program, medical practitioners should contact Medicare Australia on 1800 700 270.

The PBAC did not comment on the requested restriction.

5. Clinical Place for the Proposed Therapy

Several different protocols exist for controlled ovarian stimulation for assisted reproductive technology using different combinations of drug treatments. During controlled ovarian stimulation, recombinant follicle stimulating hormone (rFSH) is administered to stimulate follicular development. rFSH administration is initiated on stimulation day one, and on average adequate follicular development is achieved by the ninth day of treatment (range 6-18 days). Human chorionic gonadotrophin can then be administered to induce final oocyte maturation.

The submission proposed that corifollitropin alfa would replace the first seven daily doses of conventional rFSH (follitropin alfa or beta), providing a reduced injection burden. This would be expected to minimise patients' apprehension and anxiety, improve patient convenience and compliance, and lessen the impact on the patient’s lifestyle.

6. Comparator

The submission nominated conventional rFSH as the comparator, focusing on follitropin beta. Follitropin beta (Puregon®) and follitropin alfa (GONAL-f®) were previously considered by the PBAC to be equivalent on a per unit basis.

The PBAC agreed that the choice of comparator, conventional rFSH, represented by follitropin beta (Puregon®), was appropriate. See Recommendations and Reasons.

7. Clinical Trials

The basis of the submission was two direct randomised comparative trials, ENGAGE and ENSURE. The ENGAGE study population consisted of 1,506 treated patients, and compared a single injection of corifollitropin alfa 150 mcg (followed by daily injections of 150-200 IU follitropin beta 1 week later) to daily injections of follitropin beta 200 IU in women greater than 60 kg and less than 90 kg in bodyweight. The ENSURE study population consisted of 396 treated patients, and compared a single injection of corifollitropin alfa 100 mcg (then daily injections of 150-200 IU follitropin beta 1 week later) to daily injections of follitropin beta 150 IU in women less than 60 kg bodyweight.

Details of the published trials presented in the submission are in the table below.

Direct randomised trials and associated reports presented in the submission

Trial ID/First author Protocol/Publication/Presentation title Publication citation

ENGAGE

Devroey P, et al.

Koper NP, et al.

Behr B, et al.

Fernandez Sanchez M, et al.

Doody K, et al.

Leader A, et al.

Alper M, et al.

A double-blind, non-inferiority RCT comparing corifollitropin alfa and recombinant FSH during the first seven days of ovarian stimulation using a GnRH antagonist protocol.

Corifollitropin alfa demonstrates similar pregnancy rates as compared to daily recombinant FSH treatment in a controlled ovarian stimulation regimen for IVF/ICSI.

Corifollitropin alfa versus recombinant FSH treatment for COS in a GnRH antagonist protocol: equal efficacy in terms of oocyte and embryo quality.

Equally high ongoing pregnancy rates with corifollitropin alfa and recombinant FSH irrespective of variations in ART procedures.

Success rates of a standardized rFSH/GnRH antagonist protocol are not affected by endogenous LH levels.

Ongoing pregnancy rates with corifollitropin alfa/ gonadotrophin-releasing hormone (GnRH) antagonist regimen are not impacted by endogenous LH levels.

Potential predictive factors of pregnancy in patients undergoing controlled ovarian stimulation (COS) in a GNRH antagonist protocol.

Human Reproduction 2009; 24(12):3063-72.

Abstract O-207. Fertility and Sterility 90(Suppl. 1):S75. ASRM 64th Annual Meeting San Francisco, CA. November 8-12, 2008

Abstract O-003 Oral. Human Reproduction 24 (Suppl 1):i1−2. ESHRE 25th Annual Meeting, Amsterdam, the Netherlands 28 June - 1 July 2009.

Abstract O-005 Oral. Human Reproductio n 24 (Suppl 1):i2−3. ESHRE 25th Annual Meeting, Amsterdam, the Netherlands 28 June - 1 July 2009.

Abstract O-255 Oral. Human Reproduction 24 (Suppl 1):i102. ESHRE 25th Annual Meeting, Amsterdam, the Netherlands 28 June - 1 July 2009.

Fertility and Sterility 92(3):S3-S4. ASRM 65th Annual Meeting Atlanta, Georgia October 17-21, 2009.

Abstract O-234 Oral. Fertility and Sterility 92(3):S68-S69. ASRM 65th Annual Meeting, Atlanta, Georgia October 17-21, 2009.

ENSURE Obruca A, et al.

Hillensjo T, et al.

Ledger W, et al.

Corifollitropin alfa for ovarian stimulation in IVF: a randomized trial in lower-body-weight women.

A comparison of corifollitropin vs. recombinant FSH in a GnRH antagonist protocol for controlled ovarian stimulation in women weighing 60 kg or less.

Two doses of corifollitropin alfa allow for similar exposure and ovarian response in patients weighing ≤ 60 kg and > 60 kg.

Reproductive BioMedicine Online, 2010; 21(1):66−76.

Abstract O-004 Oral. Human Reproduction 24(Suppl 1):i2. ESHRE 25th Annual Meeting, Amsterdam, the Netherlands 28 June - 1 July 2009.

Abstract O-282 Oral. Human Reproduction 24(Suppl 1):i114. ESHRE 25th Annual Meeting, Amsterdam, the Netherlands 28 June - 1 July 2009.

ESHRE = European Society of Human Reproduction and Embryology; ASRM = American Society for Reproductive Medicine; BMI = body mass index; GnRH = Gonadotropin releasing hormone COS = Controlled ovarian stimulation; LH = luteinizing hormone; ET = Embryo transfer; ICSI = Intracytoplasmic sperm injection; IVF = In vitro fertilisation; rFSH = Recombinant follicle stimulating hormone (follitropin beta).

For PBAC’s view, see Recommendation and Reasons.
 

8. Results of Trials

Both ENGAGE and ENSURE studies assessed equivalence in terms of the number of oocytes retrieved (the co-primary endpoint in ENGAGE and the primary endpoint in ENSURE). In both studies, a lower margin of minus 3 oocytes and an upper margin of plus 5 oocytes were applied for the difference in the number of oocytes retrieved between the treatment groups. The rationale provided for this margin was as follows: A reduction of three or more oocytes between the corifollitropin alfa and follitropin beta treatment arms was considered by the submission to be clinically relevant because three oocytes are usually required to produce one good quality embryo for transfer (or freezing). Anticipating an average yield of 12–13 oocytes with the applied follitropin beta doses in the reference group, an excess of more than five oocytes (giving a total of 18) would be undesirable due to the increased risk of developing OHSS (subjects with more than 18 oocytes are known to have an increased risk of OHSS). The rationale was considered appropriate.

ENGAGE (Study 38819 – body weight greater than 60 kg and less than 90 kg):
Results for the primary outcome of ongoing pregnancy rate (presence of at least one foetus with heart activity at least 10 weeks after embryo transfer as assessed by ultrasound scan or Doppler) are summarised in the table below.

Primary endpoint: Results of ongoing pregnancy rate in ENGAGE (Study 38819: body weight > 60 kg)

Result Corifollitropin alfa 150 mcg n/N (%) Follitropin beta 200IU n/N (%) Risk difference (95% CI) p-value
Ongoing pregnancy rates Per attempt a (ITT) 294/756(38.9) 286/750 (38.1) 0.9 (-3.9, 5.7) p = 0.71
Per embryo transfer b (Subset of the ITT pop) 294/672 (43.8) 286/704 (40.6) 3.1 (-2.0, 8.2) p = 0.24
Per attempt a (PP) 291/739 (39.4) 733/282 (38.5) 1.1 (-3.8, 6.0) p = 0.67
Per embryo transfer b (Subset of the PP pop) 291/659 (44.2) 282/687 (41.0) 3.1 (-0.2, 8.3) p = 0.24

a If a subject did not reach a certain stage in IVF treatment, zero values were imputed (e.g. if the particular subject did not have oocyte retrieval, then the number of oocytes, number of embryos etc. was set to zero and the pregnancy outcome was set to not pregnant)
b ‘Per stage’ analyses were restricted to subjects who reached a specific IVF stage, in this case only women who had embryo transfer.

Non-inferiority of corifollitropin alfa to follitropin beta, in terms of the primary outcome of ongoing pregnancy rates (presence of at least one foetus with heart activity at least 10 weeks after embryo transfer as assessed by ultrasound scan or Doppler), was demonstrated in both per attempt and per stage analyses and in both intention-to-treat (ITT) and per protocol analyses.

The per embryo transfer (or per stage) analysis of ongoing pregnancy rates favoured corifollitropin alfa over the comparator. This was because the number of events or the numerator did not change between the per attempt analysis and the per embryo transfer analysis (294 events in the corifollitropin alfa arm and 286 events in the follitropin beta arm) whilst the reduction in magnitude of the denominator (as a consequence of exclusion from the analysis) in the corifollitropin treatment arm (756 to 672 – a difference of 84 subjects), was larger than that in the follitropin beta arm (750 to 704 – a difference of 46 subjects).

Equivalence of corifollitropin alfa to follitropin beta, in terms of the co-primary endpoint of number of oocytes retrieved, was demonstrated in both per attempt and per stage analyses and in both ITT and per protocol analyses.

ENSURE (Study 107012 – body weight less than or equal to 60 kg):
Results for the primary outcome of number of oocytes retrieved are summarised in the table below.

Primary endpoint: Number of cumulus-oocyte-complexes (per attempt and per stage) by treatment group in ENSURE (Study 107012: body weight less than or equal to 60 kg)

Outcome Corifollitropin alfa 100 mcg Follitropin beta 150 IU RD (95% CI) P value
Number of Oocytes Retrieved (ITT) Per attempt a N (subjects) Mean (SD) Median (range) 268 13.3 (7.3) 12.0 (0, 46) 128 10.6 (5.9) 10.0 (0, 33) 2.5 [1.2, 3.9] p <0.001
Number of Oocytes Retrieved Per Stage b N (subjects) Mean (SD) Median (range) 266 13.4 (7.3) 12.0 (0, 46) 127 10.7 (5.9) 10.0 (0, 33) 2.6 [1.2, 3.9] p <0.001

a If a subject did not reach a certain stage in IVF treatment, zero values were imputed (e.g. if the particular subject did not have oocyte retrieval, then the number of oocytes or number of embryos etc. was set to zero and the pregnancy outcome was set to not pregnant)
b ‘Per stage’ analyses were restricted to subjects who reached a specific IVF stage, in this case only women with oocyte retrieval.
CI = confidence interval; ITT = intention to treat; RD = risk difference

Equivalence between corifollitropin alfa and follitropin beta, in terms of the primary outcome of number of oocytes retrieved was demonstrated.

For women with body weight less than or equal to 60 kg, the percentage of ongoing pregnancy rates (the secondary outcome of ENSURE) did not support the non-inferiority of 100 mcg corifollitropin alfa. The ENSURE trial lacked power to detect a difference in this outcome measure. However, the difference of 9% and the lower margin of -19% which favoured the comparator appeared substantial and included clinically relevant differences. Although the submission noted that “analyses of the ongoing pregnancy rates on a ‘per attempt’ basis showed that the estimated differences between the corifollitropin alfa and follitropin beta treatment groups were not statistically significant”, the analysis of the secondary outcome of ongoing pregnancy rates (presence of at least one foetus with heart activity at least 10 weeks after embryo transfer as assessed by ultrasound scan or Doppler) lacked power to detect a difference.

Overall, the proportion of adverse events and serious adverse events reported in ENGAGE was higher than that reported in ENSURE. Adverse events were similar between the treatment arms in both studies except for serious adverse events, which slightly favoured the comparator arms in both studies. Adverse events leading to discontinuation in the ENGAGE study also favoured the comparator arm (16 (2.1%) versus 3 (0.4%)). The risk of discontinuing due to an adverse event in the corifollitropin treatment arm was therefore almost 5 times the risk in the comparator arm. Although the submission commented that these were rare events, it should be noted that the trial excluded patients with a high risk of hyperstimulation; therefore, higher rates may be observed in the target PBS population.

The adverse event of most concern to PBAC for corifollitropin alfa was OHSS. The table below summarises OHSS events observed in the key trials.

Incidence and severity of ovarian hyperstimulation syndrome (OHSS) in the controlled trials

OHSS Categories ENGAGE ENSURE
Corifollitropin alfa 150 mcg (N=755) Follitropin beta 200 IU (N=751) Corifollitropin alfa 100 mcg (N=268) Follitropin beta 150 IU (N=129)
OHSS AE n (%) 53 (7.0) 47 (6.3) 18 (6.7) 6 (4.7)
Discontinuation due to OHSS AE 12 (1.6) 1 (0.1) 0 (0.0) 0 (0.0)
OHSS SAE n (%) 14 (1.9) 9 (1.2) 7 (2.6) 0 (0.0)
Discontinuation due to OHSS SAE 4 (0.5) 0 (0.0) 0 (0.0) 0 (0.0)
OHSS Grade
Grade 1 (mild) 22 (2.9 %) 27 (3.6 %) 9 (3.4 %) 4 (3.1 %)
Grade 2 (moderate) 17 (2.3 %) 10 (1.3 %) 5 (1.9 %) 1 (0.8 %)
Grade 3 (severe) 14 (1.9 %) 10 (1.3 %) 4 (1.5 %) 1 (0.8 %)
Total 53 (7.0 %) 47 (6.3 %) 18 (6.7 %) 6 (4.7 %)

AE = Adverse event; SAE = Serious adverse event.
Source: Extracted from the clinical study reports of ENGAGE and ENSURE

For PBAC’s view, see Recommendation and Reasons.

It was noted that the key trials excluded women with a past history of ovarian hyper-response (or OHSS), polycystic ovary syndrome (PCOS) or a basal antral follicle count of greater than 20. The fact that these exclusion criteria were applied in the trial suggested that the non-titratable dose of corifollitropin alfa may place these patients at an increased risk of OHSS. This was supported by contraindications to its use in the corifollitropin alfa Product Information. There was high uncertainty regarding whether the relative adverse effect of treatment, in terms of OHSS, will remain constant across different levels of population risk. The submission noted that in practice, clinicians are most likely to select patients who are normal responders, similar to the populations in the clinical trials. Nonetheless, the data should be interpreted with caution until robust evidence indicates otherwise.

Maternal and foetal adverse events observed in Trial 38821 (follow up of ENGAGE) indicated that there were no significant differences between the corifollitropin alfa and follitropin beta treatment arms. Similarly, no significant differences in maternal and foetal adverse events were observed in Trial 107014 (follow up study of ENSURE). However, in Trial 107014, there was a trend towards an increased risk of serious adverse events leading to a fatal outcome in the corifollitropin alfa arm compared to the follitropin beta arm in Trial 107014 (2.3% versus 0.0%). Furthermore, in this same follow-up study, the proportion of foetuses with serious adverse events was higher in the corifollitropin alfa treatment arm (6.9%) compared to the follitropin beta treatment arm (5.6%). The submission noted that live births were not specifically documented

,

however, some data have been published recently (Boostanfar, P et al (2010) (Abstract O-119: European Society of Human Reproduction and Embryology June 2010): For 541 patients with ongoing pregnancies from the ENGAGE trial, consistent with the ongoing pregnancy rates after fresh embryo transfer (ET) (38.9% and 38.1% for the corifollitropin alfa and rFSH groups, respectively), equally high live birth rates per started cycle of 35.6% and 34.4% were observed in the corifollitropin alfa and rFSH treatment groups, respectively.

9. Clinical Claim The submission claimed corifollitropin alfa to be non-inferior in terms of comparative effectiveness and non-inferior in terms of comparative safety over follitropin beta.

The PBAC agreed that the submission’s claim that corifollitropin alfa is non-inferior in terms of comparative effectiveness and safety over follitropin beta appears reasonable only in women who are most likely to respond well and least likely to “hyper-respond”. See Recommendation and Reasons.
 

10. Economic Analysis

The submission presented a cost minimisation analysis. The equi-effective doses were as follows:
Based on the ENGAGE study of patients greater than 60 kg and less than 90 kg, corifollitropin alfa 150 mcg as a single dose over 7 days and follitropin beta 200 IU as daily doses over 7 days are equi-effective; and
Based on the ENSURE study of patients with a body weight less than or equal to 60 kg, corifollitropin alfa 100 mcg as a single dose over 7 days and follitropin beta 150 IU as daily doses over 7 days are equi-effective.

11. Estimated PBS Usage and Financial Implications

The financial cost per year to the PBS was estimated in the submission to be less than $10 million in Year 5. Whilst a cost minimisation approach was taken in the economic evaluation, the listing of corifollitropin alfa was estimated to result in an increased cost to the PBS, primarily driven by the pricing structure proposed in the submission. Furthermore, the submission failed in the financial estimates to account for the fact that patients using follitropin 150 IU daily who are dispensed 1 x 300 IU and 1 x 900 IU pens will have one day’s treatment remaining for day 8. By assuming that the costs from day 8 onwards are identical for corifollitropin and follitropin, the submission favoured corifollitropin

For PBAC’s view, see Recommendation and Reasons.

12. Recommendations and Reasons

The PBAC agreed that the choice of comparator, conventional rFSH, represented by follitropin beta (Puregon®), is appropriate although noting there is wide variation in the dosing regimen of follitropin beta in fertility clinics in Australia and that this adds some uncertainty to the submission’s clinical and economic analyses.

The PBAC further agreed that the submission’s claim that corifollitropin alfa is non-inferior in terms of comparative effectiveness and safety over follitropin beta appears reasonable only in women who are most likely to respond well and least likely to “hyper-respond”. Notwithstanding that the ENSURE trial was not powered to detect differences in pregnancy rates, but was powered to detect differences in the number of oocytes retrieved and that non-inferiority was demonstrated on the basis of this outcome, the Committee considered uncertainty remains regarding the comparative effectiveness of corifollitropin alfa relative to follitropin beta in terms of ongoing pregnancy rates. In the ENSURE trial corifollitropin alfa treatment was associated with fewer ongoing pregnancy rates than follitropin beta (risk difference -9.2%; 95% CI: -18.9 - 0.5%) with the lower margin of the 95% confidence interval including clinically relevant differences.

Additional clinical uncertainty arose because the women participating in the ENSURE and ENGAGE studies may not have been representative of the women likely to be treated under the IVF/GIFT program, in terms of age, weight and underlying risk factors for ovarian hyperstimulation syndrome (OHSS). The higher ages and weights of Australian patients mean that corifollitropin alfa could be less effective in Australian clinical practice. Additionally patients with underlying risks for OHSS may not be as rigorously excluded from treatment as they were from the clinical trials.

The adverse event of most concern to PBAC for corifollitropin alfa was OHSS, particularly as, unlike current rFSH therapies, the clinician does not have the option to adjust the dose of corifollitropin alfa (or even cease treatment) for baseline risk of OHSS or on the appearance of OHSS symptoms. Although there was no statistically significant differences in the rates of OHSS for corifollitropin alfa vs. follitropin beta in ENGAGE (7.0% versus 6.3%, p = 0.55) or ENSURE (6.7% versus 4.7%, p = 0.42), it is usually the case that such analyses lack adequate power. An analysis by Tarlatzis et al (2010) of the combined incidence of OHSS in the ENGAGE, ENSURE and TRUST studies referred to in the pre-PBAC response also lacked adequate power and did not adjust for early or late classification of OHSS.

Furthermore, in both ENSURE and ENGAGE there was a trend towards an increased risk and severity of OHSS in the corifollitropin alfa treatment arms compared with the follitropin beta treatment arms. Overall, OHSS was reported more frequently as a serious adverse event in the corifollitropin alfa group compared to the follitropin beta group in both trials (2.6% versus 0.0% in ENSURE and 1.9% versus 1.2% in ENGAGE). Additionally OHSS that led to study discontinuation was higher in the corifollitropin alfa treatment arm (1.6%) compared to the follitropin beta treatment arm (0.1%) of ENGAGE. Overall PBAC remained unconvinced that corifollitropin alfa is not associated with a higher risk of OHSS compared to follitropin beta.

The PBAC agreed that providing the claim of comparable (non-inferior) efficacy and safety can be supported in a future submission, the appropriate approach to cost-minimisation is to calculate a price for each strength of corifollitropin alfa proposed for listing. The price of 150 mcg corifollitropin alfa should be based on 200 IU of follitropin beta daily for 7 days; and the price of 100 mcg corifollitropin should be based on 7 days of 150 IU of follitropin beta.

The PBAC noted that uncertainty remains with respect to the submission’s utilisation estimates, and uncertainty about the number of packs of the comparator which would be replaced if corifollitropin alfa is listed, particularly as some patients using follitropin beta would be provided with sufficient drug at the first dispensing to last 8 rather than 7 days as assumed by the submission.

The PBAC therefore rejected the application to list corifollitropin on the basis of uncertainty about the claim that it is non-inferior in terms of comparative effectiveness and safety to follitropin beta, and the uncertainty in the cost-minimisation analysis resulting from this clinical uncertainty and from the pricing structure proposed by the sponsor.

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

MSD is committed to working with the PBAC in order to address any uncertainties that the Committee might have, in order to ensure access of corifollitropin alfa for patients who are undergoing controlled ovarian stimulation.