Dasatinib, tablets, 20 mg, 50 mg, 70 mg and 100 mg, Sprycel® - July 2011

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Public Summary Document

Product: Dasatinib, tablets, 20 mg, 50 mg, 70 mg and 100 mg, Sprycel®
Sponsor: Bristol-Myers Squibb Pty Ltd
Date of PBAC Consideration: July 2011

1. Purpose of Application

The submission sought to extend the current Authority required listing to include treatment of newly diagnosed patients in the chronic phase of chronic myeloid leukaemia (CML) expressing the Philadelphia chromosome or the transcript, bcr-abl tyrosine kinase, and who have a primary diagnosis of chronic myeloid leukaemia.

2. Background

At the March 2007 meeting, the PBAC recommended listing dasatinib as an Authority Required benefit for the treatment of all phases of CML in patients not responding to imatinib because of resistance or intolerance, on a cost-effectiveness basis against imatinib. Listing was effective from 1 August 2007.

At the same meeting, the PBAC rejected a submission to list dasatinib as a Section 100 (Highly Specialised Drugs Program) benefit for the treatment of acute lymphoblastic leukaemia (ALL) in adult patients expressing the Philadelphia chromosome or transcript, bcr-abl tyrosine kinase, who are resistant or intolerant to prior therapy. The PBAC was unable to form a view on the cost-effectiveness of the comparator, imatinib, in the treatment of ALL because of the absence of adequate data.

At the July 2007 meeting, the PBAC recommended the listing of dasatinib on the PBS for the treatment of patients with ALL, expressing the Philadelphia chromosome or the transcript bcr-abl kinase, who are resistant to, or whose disease has relapsed on, prior therapy. The PBAC considered that the listing of dasatinib in this small patient group was consistent with the intention of its ‘Rule of Rescue’ guidelines. Listing was effective from 1 December 2007.

3. Registration Status

Dasatinib is TGA registered for the following indications:

  • Treatment of adults aged 18 years or over with newly diagnosed Ph+ CML in the chronic phase;
  • Treatment of adults aged 18 years or over with chronic, accelerated or myeloid or lymphoid blast phase CML with resistance or intolerance to prior therapy including imatinib;
  • Treatment of adults aged 18 years or over with Ph+ ALL with resistance or intolerance to prior therapy.

4. Listing Requested and PBAC’s View

The submission sought a listing consistent with imatinib’s restriction for the chronic phase of CML and provided the following abridged restriction:

Authority Required

Initial treatment of patients in the chronic phase of chronic myeloid leukaemia expressing the Philadelphia chromosome or the transcript, bcr-abl tyrosine kinase, and who have a primary diagnosis of chronic myeloid leukaemia.

Continuing treatment of patients who have received initial treatment with dasatinib mesylate as a pharmaceutical benefit for the chronic phase of chronic myeloid leukaemia and who have demonstrated either a major cytogenetic response or less than 1% bcr-abl level in the blood in the preceding 12 months.

For PBAC’s view, see Recommendation and Reasons.

5. Clinical Place for the Proposed Therapy

CML is a rare, myeloproliferative disorder. The use of bone marrow transplantation/stem cell transplantation is the only potential curative option for patients with CML. However, this is an option for very few patients due to patient age, the presence of co-morbidities and the absence of suitably matched donors. Currently, imatinib at a dose of 400 mg/day or 600 mg/day is first line therapy for patients newly diagnosed with CML in the chronic phase. For patients who are intolerant of imatinib, fail to achieve a response or lose a previously obtained response with imatinib, dasatinib and nilotinib are second-line treatment options.

The submission proposed that the place in therapy of dasatinib is as a first line alternative therapy to imatinib (and possibly nilotinib) in chronic phase CML.

The submission stated that if dasatinib (and possibly nilotinib) becomes a first line therapy in chronic phase CML, the treatment algorithm for patients who fail to achieve a response with dasatinib is uncertain due to a paucity of evidence for using imatinib following dasatinib (or nilotinib) treatment failure.

For PBAC’s view, see Recommendation and Reasons.

6. Comparator

The submission nominated imatinib 400 mg as the comparator and imatinib 600 mg as a supportive comparator. Nilotinib 300 mg and 400 mg was also nominated as a supportive comparator (for efficacy only). The use of imatinib at a dose of 400 mg as the main comparator was considered appropriate by the PBAC.

7. Clinical Trials

The submission presented two randomised trials comparing dasatinib 100 mg with imatinib 400 mg in adult patients newly diagnosed with CML in the chronic phase (Study 056, S0325). Additional trials were presented, one comparing imatinib 400 mg with imatinib 600 mg (SPIRIT) and one comparing imatinib 400 mg with nilotinib 300 mg and nilotinib 400 mg twice daily (Saglio).

Patients within the trials were adults newly diagnosed with CML in the chronic phase for which a transplant was not viable.

The key outcome measures from the trials used by the submission were: complete cytogenetic response (CCyR), confirmed CCyR (cCCyR; a CCyR confirmed at two separate occasions at least 28 days apart by bone marrow cytogenetics); time to CCyR (the date of a CCyR is the date of the first recorded CCyR); and safety outcomes.

The submission did not provide an assessment of what could be considered a minimally clinically important difference in either cCCyR or CCyR.

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

Trial ID/ First author Protocol title / Publication title Publication citation
Direct comparison: Dasatinib v Imatinib 400 mg
Study 056 An open label, randomized, multi-centre phase III trial of dasatinib vs. standard dose imatinib (400mg) in the treatment of subjects with newly diagnosed chronic phase Philadelphia chromosome positive chronic myeloid leukaemia.
Kantarijan et al. (2010) Dasatinib versus imatinib in newly diagnosed chronic phase chronic myeloid leukaemia. New England Journal of Medicine . 2010 362:2260-2270.
Study S0325 Imatinib Mesylate or Dasatinib in Treating Patients With Chronic Phase Chronic Myelogenous Leukaemia
Radich et al. (2010) A randomized phase II trial of dasatinib 100 mg vs. imatinib 400 mg in newly diagnosed chronic myeloid leukaemia in chronic phase: the S0325 intergroup trial. Blood . 2010 116 (Abstract LBA-6)
Trials used for indirect comparison: Imatinib 600 mg
SPIRIT A Phase III Prospective Randomized Comparison of Imatinib at a Dose of 400mg in Combination With Peg-Interferon-alpha2a (Peg-IFNa2a) or Cytarabine (Ara-C)Versus Imatinib at a Dose of 600mg Versus Imatinib a Dose of 400mg for Previously Untreated Chronic Myelogenous Leukaemia (CML) in Chronic Phase
Predhomme et al. (2010) Imatinib plus Peginterferon Alfa-2a in Chronic Myeloid Leukaemia. New England Journal of Medicine 2010 363(26): 2511-2521
Trials used for indirect comparison: Nilotinib 300 mg or 400 mg
Saglio et al. (2010) A Study of Imatinib Versus Nilotinib in Adult Patients With Newly Diagnosed Philadelphia Chromosome Positive (Ph+) Chronic Myelogenous Leukaemia in Chronic Phase (CML-CP) (ENESTnd).
Nilotinib versus imatinib for newly diagnosed chronic myeloid leukaemia. New England Journal of Medicine . 2010 362(24): 2251-2259.

8. Results of Trials

Dasatinib vs. imatinib 400 mg

For Study 056, the cCCyR (one of the primary outcomes) at 12 months for imatinib 400 mg was 66.2% and 76.8% for dasatinib 100 mg daily. The PBAC noted that from a meta-analysis of the CCyR results from Study 056 and S0325 (using the modified ITT population), dasatinib is associated with a statistically significant increase in the proportion of those who achieve a CCyR when compared with imatinib 400 mg (RR = 1.19, 95% CI: 1.06, 1.33; p=0.002). However, progression free survival (PFS) and overall survival (OS) outcomes were too immature in either trial to draw any meaningful comparisons between dasatinib and imatinib 400 mg.

The following table provides the cCCyR by 12 months, by 18 months and the within 12 month results from Study 056. Additionally, results from the 056 and S0325 trials, and the meta-analysis results for CCyR at 12 months, are also included.
 

Results across the direct randomised trials

 

Trial Dasatinib(%) Imatinib 400 mg(%) RR (95% CI) OR (95% CI) RD(95% CI)
cCCyR
056 12 mth a 199/259 (76.8%) 172/260 (66.2%) 1.16 (1.04, 1.30) 1.70 (1.15, 2.50) 0.11 (0.03, 0.18)
056 12 mth b 199/259 (76.8%) 177/260 (68%) 1.13 (1.01, 1.26) 1.56 (1.05, 2.29) 0.09 (0.01, 0.16)
056 18 mth c 202/259 (78.0%) 182/260 (70.0%) 1.11 (1.01, 1.24) 1.52 (1.02, 2.26) 0.08 (0.01, 0.16)
CCyR at 12 mths
056 216/259 (83.4%) 186/260 (71.5%) 1.17 (1.06, 1.28) 2.00 (1.31, 3.05) 0.12 (0.05, 0.19)
S0325 d 55/123 (45%) 40/123 (33%) 1.34 (1.00,1.90) 1.68 (1.00, 2.82) 0.12 (0.00, 0.24)
Pooled e result 271/382 (70.9%) 226/383 (59.0%) 1.19 (1.06, 1.33) 1.86 (1.34, 2.59) 0.12 (0.6, 0.18)
Chi-square heterogeneity (P) I 2 statistic 1.09 (0.30) 8.4% 0.26 (0.61) 0% 0.00 (0.96) 0%
S0325 f 55/67 (82%) 40/58 (69%) 1.19 (0.97, 1.46) 2.06 (0.89, 4.76) 0.13 (-0.02, 0.28)

Dasat = Dasatinib; Imat 400 mg = Imatinib 400 mg; RR = relative risk; OR = odds ratio; RD = relative difference; cCCyR = confirmed complete cytogenetic response; CCyR = complete cytogenetic response; mth = months
a results by 12 months
b results for achieving response within 12 months, note confirmation of response via 2nd test performed at any time including > 12mths
c results by 18 months
dmodified intention to treat population, disregards 7 patients randomised but not treated
e pooled results of CCyR at 12 months from Studies 056 and S0325 (modified intention to treat population)
f results for evaluable patients i.e. those for which cytogenetic data available
Statistically significant results are shown in bold text.

The dasatinib arm within Study 056 had a higher proportion of Asians and females compared with the imatinib 400 mg arm. The PBAC noted that a subgroup analysis conducted by Ogura et al (Blood (ASH Annual Meeting Abstracts) 2010 116: Abstract 4484) for Study 056 of Japanese patients treated with dasatinib or imatinib 400 mg achieved a greater cCCyR (90% for dasatinib and 70% for imatinib) than that observed in the overall patient group (77% for dasatinib and 66% for imatinib). The higher proportion of Asians within the dasatinib arm may have biased the results in favour of dasatinib.

Study 056 found no statistically significant differences in the number of patients who achieve an MCyR (defined as the sum of patients who achieve a CCyR or partial CyR). Furthermore, both Study 056 and S0325 reported that imatinib 400 mg is associated with a non-statistically significant increase in the number of patients with a complete haematological response compared with dasatinib.

The median time to response for dasatinib was reported within Study 056 as 3.1 months (95% CI: 3.0, 3.1) and 5.5 months (95% CI: 3.3, 5.7) for imatinib 400 mg. Patients receiving dasatinib were associated with a statistically significant faster rate (2.4 months earlier) of achieving a cCCyR than those receiving imatinib 400 mg (HR 1.5, p<0.0001).

An independent search conducted during the evaluation retrieved no relevant studies that have explored the clinical significance or the impact on PFS or OS for achieving CCyR 2.4 months earlier.

Indirect comparisons:
The table below summarises the main results from the indirect comparisons of dasatinib 100 mg once daily versus imatinib 600 mg once daily and versus nilotinib 300 mg twice daily and nilotinib 400 mg twice daily for CCyR within 12 months.
 

Summary of results of the indirect comparison, based on the proportion achieving CCyR within 12 months

Trial ID Trials of Dasatinib Trial of Imatinib 600 mg Indirect RR c (95% CI)
RR a (95% CI) Dasat n/N (%) Imat 400 n/N (%) Imat 400 n/N (%) Imat 600 n/N (%) RR b (95% CI)
056 1.17 (1.06, 1.28) 216/259 (83%) 186/260 (72%)
S0325 1.34 (1.00, 2.82) 55/123 (45%) 40/123 (33%)
Pooled d 1.19 (1.06,1.33) 261/382 (68%) 226/383 (59%)
SPIRIT Imat 600 92/159 (58%) 104/160 (65%) 1.12 (0.94, 1.34)
Indirect comparison dasatinib vs. Imatinib 600 mg 1.06 (0.86, 1.31)
Trial ID Trials of Dasatinib Trial of Nilotinib 300 mg Indirect RR c (95% CI)
RR a (95% CI) Dasat n/N (%) Imat 400 n/N (%) Imat 400 n/N (%) Nilot 300 n/N (%) RR b (95% CI)
Saglio Nilot 300 184/283 (55%) 226/282 (80%) 1.23 (1.11, 1.37)
Indirect comparison dasatinib vs. nilotinib 300 mg e 0.95 (0.83, 1.10)
Trial ID Trials of Dasatinib Trial of Nilotinib 400 mg Indirect RR c (95% CI)
RR a (95% CI) Dasat n/N (%) Imat 400 n/N (%) Imat 400 n/N (%) Nilot 400 n/N (%) RR b (95% CI)
Saglio Nilot 400 184/283 (55%) 219/281 (78%) 1.20 (1.08, 1.33)
Indirect comparison dasatinib vs. nilotinib 400 mg e 0.98 (0.85, 1.12)

CI = confidence interval; RR = relative risk; Dasat = dasatinib; Imat = Imatinib; Nilot = Nilotinib; Bold = statistically significant; CCyR = complete cytogenetic response
a dasatinib over imatinib 400 mg
b comparator over imatinib 400mg
c inferred as comparator over dasatinib
d pooled using the random effects model
e S0325 was excluded from this indirect comparison

The PBAC noted that no statistically significant differences were found in the indirect comparisons for CCyR when comparing dasatinib versus imatinib 600 mg (RR 1.06, 95%CI: 0.86, 1.31) and for the comparison of dasatinib versus nilotinib 300 mg (RR 0.95, 95%CI: 0.83, 1.10) and nilotinib 400 mg (RR 0.98, 95%CI: 0.85, 1.12). Again, the rates of PFS and OS were too immature to interpret with any meaning and no claim was made regarding the comparative efficacy of dasatinib compared with imatinib 600 mg or nilotinib on these outcomes.

The results of the indirect comparisons may have been biased in favour of dasatinib from the disproportional representation of Asian patients in the included trials. As previously discussed, the Asian subgroup within Study 056 showed a greater cCCYR response compared to the overall population. There was a higher proportion of Asian patients in Study 056 compared to the Saglio trial, and in particular, a greater disproportion of Asians within the dasatinib group compared to the common reference (imatinib 400 mg), within Study 056.

The table below presents a summary of the adverse events in Study 056 and S0325.
 

Summary of select adverse events in the direct randomised trials at 12 months

Trial Dasatinib (%) Imatinib 400 (%) RR (95% CI)
056 n = 258 n = 258
All Drug-related grade 3/4 AEs 78 (30%) 61 (24%) 1.28 (0.96, 1.70)
Thrombocytopenia (grade 3/4) 34 (13%) 21 (8%) 1.62 (0.97, 2.71)
Pleural effusion any grade 26 (10%) 0 52.0 (3.14, 849) a
Drug-related AEs any grade leading to discontinuation 13 (5%) 11 (4%) 1.18 (0.54, 2.59)
All deaths 10 (4%) 6 (2%) 1.67 (0.62, 4.52)
S0325 n = 123 n = 123
Pleural effusion any grade 14 (11%) 2 (2) 7.00 (1.63, 30.15)
Non-haematological (grade 3/4) 44 (36%) 21 (17) 2.10 (1.33, 3.31)
Thrombocytopenia (grade 3/4) 22 (18%) 10 (8) 2.20 (1.09, 4.45)
Drug related AEs any grade leading to discontinuation 18 (15%) 13 (11%) 1.39 (0.71, 2.70)
Number died 3 (2%) 4 (3%) 0.75 (0.17, 3.28)

AE = adverse event; SAE = severe adverse event; Bold = statistically significant
a imputing 0.5 case for both treatment arms

Overall, dasatinib was associated with a statistically significant increase in the incidence of grade 3/4 thrombocytopenia and pleural effusion (any grade) compared to imatinib 400 mg. Comparatively, imatinib 400 mg appeared to be associated with an increase in adverse events (AEs) any grade, with a statistically significant increase in any grade nausea, myalgia, vomiting, muscle spasms, eyelid oedema, drug-related fluid retention, superficial oedema and generalised oedema.

The PBAC noted that there appeared to be no statistically significant difference in grade 3/4 adverse events between dasatinib and imatinib 600 mg.

Dasatinib appeared to be associated with statistically significantly more grade 3/4 haematological adverse events and any grade non-haematological adverse events compared to nilotinib 300 mg and 400 mg.
 

9. Clinical Claim

Dasatinib vs. Imatinib 400 mg

The submission described dasatinib as superior in terms of comparative effectiveness and having a different safety profile compared with imatinib 400 mg/day.

The PBAC accepted that although dasatinib is superior to imatinib 400 mg daily based on CCyR, the Committee did not accept that this predicts superiority for progression free survival or overall survival. The PBAC also did not accept the claim regarding the safety profile. The PBAC noted that imatinib 400 mg is associated with more drug related AEs of any grade, but that dasatinib is associated with a greater proportion of Grade 3 or 4 AEs, indicating that dasatinib might be inferior in terms of safety compared with imatinib 400 mg.

Dasatinib vs. Imatinib 600 mg

The submission described dasatinib as similar and at least no worse in terms of comparative effectiveness and having an equivalent safety profile compared with imatinib 600 mg.

Dasatinib vs. Nilotinib 300 mg or 400 mg

The submission described dasatinib as no worse in terms of comparative effectiveness and having a different safety profile compared with nilotinib 300 mg or 400 mg.

The PBAC accepted that dasatinib is no worse in terms of comparative effectiveness compared with imatinib 600 mg or nilotinib 300 mg or 400 mg as the results of the indirect comparisons support the claim for non-inferior efficacy with respect to surrogate outcomes but noted that the point estimate for dasatinib, 1.17 (1.06, 1.28) is less than nilotinib 1.23 (1.11, 1.37).

The PBAC considered the claim of equivalent safety of dasatinib over imatinib 600 mg was uncertain as there was no pre-specified inferiority margin and the comparison was indirect. The claim of a different safety profile compared with nilotinib 300 mg or 400 mg was not considered appropriate, as dasatinib was associated with more adverse events.

10. Economic Analysis

Dasatinib versus Imatinib 400 mg

A trial-based economic evaluation was presented, based on the direct randomised trial (Study 056).

The patient population in the economic model presented in the submission was adult patients newly diagnosed with CML in the chronic phase, and this was directly derived from the Trial 056. The submission did not modify the patient data, because it stated that the patients in the trial are likely to be similar to the proposed PBS population. This may not have been appropriate given the exclusion of patients with cardiovascular or other significant co-morbidities, the lower mean age of participants and the potential over-representation of Asians within Study 056 who may have better CCyR outcomes compared to the general population.

A stepped analysis was presented in which health outcomes were first presented as additional patients with a cCCyR within 13 months (Step 1), additional time with cCCyR (Step 2) and then as quality-adjusted life years gained (Step 3). The results for additional time with response and time with experiencing an AE were directly estimated from Trial 056, while the quality-adjusted life years (QALY) gained uses transformation steps relying on quality of life estimates derived from the literature.

The time horizon in the modelled economic evaluation was 13 months. The analysis did not consider longer term costs or outcomes since it was assumed that the rates of progression to the accelerated blast phases of disease, loss of response or survival did not differ between the treatment groups. This may not have been appropriate as drug treatment is over a patient’s remaining lifetime as well as the differing safety profiles of dasatinib and imatinib 400 mg with the potential for associated adverse event treatment costs to differ over the course of drug treatment.

The PBAC considered that there was no basis for the cost-effectiveness analysis based on its findings regarding comparative effectiveness and safety.

The submission stated that the use of dasatinib in place of imatinib in the treatment of patients with CML in chronic phase is associated with an incremental cost-effectiveness ratio (ICER) in the range of $15,000 - $45,000 per QALY gained. The ICER was uncertain as there were uncertainties about the use of dasatinib and imatinib within the Australian PBS population, the estimated utility values in both treatment groups for with and without response, the disutility estimates for adverse events, the costs of treating pleural effusion within Australia, the future costs of drug therapy post 13 months and the cost of treating AEs post 13 months.

Sensitivity analyses indicated that the model was most sensitive to definition of response (with the attached utility), choice of AEs included within the model, the time horizon of the model, and uncertainty in the actual dose of dasatinib and imatinib.

For the sensitivity analyses assessing the impact of the time horizon on the ICER, a mortality rate was not applied and there was no change in the incremental QALY gain. As such, these were not genuine sensitivity analyses as only the drug cost changed.

Indirect comparison of Dasatinib versus Imatinib 600 mg

In addition to the cost effectiveness analysis presented against imatinib 400 mg, the submission also presented a cost-minimisation analysis to imatinib 600 mg, based on the claim of non-inferiority of dasatinib to imatinib 600 mg.

Equi-effective doses of dasatinib 100 mg to imatinib 600 mg were assumed.

The resulting annual cost difference between dasatinib treatment and imatinib 600 mg treatment was very sensitive to the assumed equi-effective doses. The point where dasatinib 100 mg/day becomes more expensive annually compared with imatinib is at an average daily dose of imatinib of just under 599 mg, which is higher than the 590 mg/day median imatinib dose reported in the SPIRIT trial. Including the costs for treating pleural effusion would add additional costs for dasatinib, resulting in imatinib being less expensive than dasatinib (based on the price to pharmacist).

The rationale for presenting the cost minimisation of dasatinib versus imatinib 600 mg was based on the premise that Australian patients are initiated on a dose of either 400 mg or 600 mg. This may not have been appropriate, as the recommended starting dose in the Australian PI for patients with chronic phase CML is imatinib 400 mg.

The PBAC accepted that dasatinib is non-inferior to imatinib 400 mg and nilotinib 300 mg or 400 mg and considered that a listing based on cost-minimisation with imatinib 400 mg was more appropriate with the inclusion of cost-offsets for managing the increased adverse effects, particularly the pleural effusions which are associated with dasatinib.

11. Estimated PBS Usage and Financial Implications

The submission estimated the likely total number of patients treated to be less than 10,000 in year 5.

The submission estimated a total net cost to the PBS of less than $10 million in year 5.

12. Recommendation and Reasons

The PBAC recommended listing dasatinib on the PBS as an Authority Required benefit for first-line treatment of chronic phase Philadelphia positive chronic myeloid leukaemia on a cost-minimisation basis compared with imatinib 400 mg. The PBAC considered the equi-effective doses to be dasatinib 93.88 mg and imatinib 395.77 mg based on the average doses from Study 056.

The PBAC noted that the availability of dasatinib as first-line therapy for CML would change the current treatment algorithm. The PBAC considered that it was unlikely that imatinib would be used after failure of dasatinib due to resistance as there is little evidence for this use. It is possible that imatinib might be used after dasatinib in cases of intolerance to dasatinib but the most likely scenario after failure of dasatinib is second-line nilotinib. The PBAC considered that the PBS listings for TKIs in second-line setting would need reviewing due to the change in the treatment algorithm. In future, it will be critical to distinguish between the need to change TKI because of intolerance and because of inadequate response. Second-line therapy after dasatinib should refer to the situation where there has been failure of response and should not include failure due to toxicity. Changes between TKIs should be possible in first–line therapy where there is intolerance to the first initiated TKI. The PBAC noted that further discussion will be needed with the sponsor and Stakeholders before finalisation of the restrictions for first and second-line treatment settings.

The PBAC noted that the submission presented two randomised trials comparing dasatinib 100 mg with imatinib 400 mg in adult patients newly diagnosed with CML in the chronic phase (Study 056, S0325) and described dasatinib as superior in terms of comparative effectiveness and having a different safety profile compared with imatinib 400 mg. For Study 056, the cCCyR (one of the primary outcomes) by 12 months for imatinib 400 mg was 66.2% and 76.8% for dasatinib 100 mg daily. The PBAC noted that from a meta-analysis of the CCyR results from Study 056 and S0325 (using the modified ITT population), dasatinib is associated with a statistically significant increase in the proportion of those who achieve a CCyR when compared with imatinib 400 mg (RR = 1.19, 95% CI: 1.06, 1.33; p=0.002). However, progression free survival (PFS) and overall survival (OS) outcomes were too immature in either trial to draw any meaningful comparisons between dasatinib and imatinib 400 mg.

The PBAC noted that there was no statistically significant difference between dasatinib and imatinib 400 mg with regards to complete haematological response and it is uncertain whether the increase in CCyR (a surrogate outcome) found for dasatinib versus imatinib 400 mg, without a difference in MCyR, would result in an improvement in final outcomes, PFS and OS. Based on this, the PBAC accepted that although dasatinib was superior to imatinib 400 mg daily based on CCyR, the Committee did not accept that this predicts superiority for PFS or OS. The PBAC also did not accept the claim regarding the safety profile. The PBAC noted that imatinib 400 mg was associated with more drug related AEs of any grade, but that dasatinib was associated with a greater proportion of Grade 3 or 4 AEs, indicating that dasatinib might be inferior in terms of safety compared with imatinib 400 mg. Consequently, the PBAC was not prepared to recommend the listing of dasatinib on a cost effectiveness basis compared with imatinib 400 mg.

Indirect comparisons of dasatinib 100 mg once daily versus imatinib 600 mg once daily and versus nilotinib 300 mg twice daily and nilotinib 400 mg twice daily for CCyR within 12 months were presented in the submission. The PBAC noted that no statistically significant differences were found in the indirect comparisons for CCyR when comparing dasatinib versus imatinib 600 mg (RR 1.06, 95%CI: 0.86, 1.31) and for the comparison of dasatinib versus nilotinib 300 mg (RR 0.95, 95%CI: 0.83, 1.10) and nilotinib 400 mg (RR 0.98, 95%CI: 0.85, 1.12). Again, the rates of PFS and OS were too immature to interpret with any meaning and no claim was made regarding the comparative efficacy of dasatinib compared with imatinib 600 mg or nilotinib on these outcomes.

The PBAC accepted that dasatinib is no worse in terms of comparative effectiveness compared with imatinib 600 mg or nilotinib 300 mg or 400 mg as the results of the indirect comparisons support the claim for non-inferior efficacy with respect to surrogate outcomes but noted that the point estimate for dasatinib, 1.17 (1.06, 1.28) is less than nilotinib 1.23 (1.11, 1.37). However, dasatinib appears to be associated with statistically significantly more grade 3/4 haematological adverse events and any grade non-haematological adverse events compared to nilotinib 300 mg and 400 mg. Therefore, the claim of a different safety profile compared with nilotinib 300 mg or 400 mg was not considered appropriate, as dasatinib is associated with more adverse events.

The PBAC noted that there appears to be no statistically significant difference in grade 3/4 adverse events between dasatinib and imatinib 600 mg. However, the claim of equivalent safety of dasatinib over imatinib 600 mg is uncertain as there is no pre-specified inferiority margin and the comparison is indirect.

The PBAC considered that there was no basis for the cost-effectiveness analysis based on the above conclusions. However, the PBAC accepted that dasatinib is non-inferior to imatinib 400 mg and nilotinib 300 mg or 400 mg and considered that a listing based on cost-minimisation with imatinib 400 mg was more appropriate with the inclusion of cost-offsets for managing the increased adverse effects, particularly the pleural effusions which are associated with dasatinib.

The PBAC acknowledged and noted the consumer comments received in its consideration of dasatinib.

Dasatinib is not included on the PBS medicines for prescribing by nurse practitioners.

Recommendation: DASATINIB, tablet, 20 mg, 50 mg, 70 mg, 100 mg

Amend the current restriction as follows:

Restriction: To be finalised

Maximum quantity: 60 (20 mg, 50 mg, 70 mg)
30 (100 mg)
Repeats: 5 (all strengths)

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 sponsor has no comment.