Miglustat, capsule, 100 mg, Zavesca® - November 2011
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Public Summary Document
Product:  Miglustat, capsule, 100 mg,
                           Zavesca®
Sponsor: Actelion Pharmaceuticals Australia Pty
                           Ltd
Date of PBAC Consideration: November 2011
1. Purpose of Application
                           The re-submission requested inclusion in the Life Saving Drugs
                           Program (LSDP) for the treatment of progressive neurological
                           manifestations in adults and paediatric patients with Niemann-Pick
                           type C (NP-C) disease.
                           Through the LSDP, the Australian Government provides subsidised
                           access, for eligible patients, to expensive and potentially life
                           saving drugs for very rare life-threatening conditions. Before a
                           drug is made available on the LSDP, it must generally be accepted
                           by the Pharmaceutical Benefits Advisory Committee (PBAC) as
                           clinically necessary and effective, but not recommended for
                           inclusion on the Pharmaceutical Benefits Scheme due to unacceptable
                           cost-effectiveness.
                           Subsidised access through the LSDP is granted in accordance with
                           specified eligibility criteria and subject to certain conditions:
                           
                        
Life Saving Drugs Program Criteria and Conditions (PDF 17 KB)
2. Background
                           At the July 2010 meeting, the PBAC rejected an application to
                           include miglustat on the PBS for the treatment of NP-C disease on
                           the basis of uncertain clinical efficacy and a very high and
                           uncertain cost effectiveness ratio. The PBAC considered that
                           miglustat for the treatment of NP-C disease did not meet the
                           criteria for the LSDP, and hence was not suitable for consideration
                           of inclusion in the LSDP.
See July 2010 Public Summary Document for full
                              details.
3. Registration Status
                           Miglustat was TGA registered on 3 February 2010 for the treatment
                           of progressive neurological manifestations in adult and paediatric
                           patients with NP- C disease.
4. Listing Requested and PBAC’s View
Authority required
                           Treatment of progressive neurological manifestations in adults and
                           paediatric patients with Niemann-Pick disease Type C disease.
For PBAC’s view, see Recommendation and
                              Reasons.
5. Clinical Place for the Proposed Therapy
                           NP-C disease is a very rare inherited disorder that is progressive,
                           debilitating, degenerative and ultimately fatal, affecting the
                           liver, lungs, bone marrow and brain. The neurological
                           manifestations are caused by the accumulation of lipids primarily
                           in the brain.
                           Treatment for NP-C disease is currently palliative only and depends
                           on the needs of the individual, the symptoms and the clinical
                           manifestations.
                           The submission proposed that miglustat will provide a pharmacologic
                           intervention that may interrupt disease progression.
6. Comparator
                           The submission nominated standard medical management comprising of
                           palliative care.
                           At the July 2010 meeting, the PBAC considered that placebo plus
                           standard medical management (standard care) was the appropriate
                           comparator, noting that miglustat would be used in addition to,
                           rather than replacing, standard care.
7. Clinical Trials
The previously submitted trials were:
- Randomised controlled trial OGT918-007a and its extension study (OGT918-007a(ext));
 - Paediatric sub-study of the above trial (OGT918-007p) and its extension study (OGT918-007p(ext));
 - Stage I survey; and
 - Two case-series and 19 case reports.
 
The new data presented in the submission were from:
- Three videofluoroscopy swallowing studies (VFSSs) of up to six patients (Australian, Italian and Taiwanese); and
 - Other patient case series data: UK data, Spanish and Portuguese data, and Italian data;
 - Survival analysis of patients treated with miglustat compared with an untreated cohort compiled from several patient sources.
 
Details of the studies published at the time of submission are shown in the table below:
| Trial ID/First Author | Protocol title/ Publication title | Publication citation | 
|---|---|---|
| RCT data | ||
| Trial OGT 918-007a | ||
| Patterson MC et al 2007 | Miglustat for treatment of Niemann-Pick C disease: a randomised controlled study. | Lancet Neurology 2007; 6(9): 765-772. | 
| RCT extension data | ||
| Study OGT 918-007p | ||
| Patterson MC et al 2007 | Miglustat for treatment of Niemann-Pick C disease: a randomised controlled study. | Lancet Neurology 2007; 6(9): 765-772. | 
| Study OGT 918-007a (ext) | ||
| Wraith JE et al 2009 | Miglustat in adult and juvenile patients with Niemann-Pick disease type C: Long-term data from a clinical trial. | Molecular Genetics and Metabolism, epub 30 December 2009. | 
| Study OGT 918-007p (ext) | ||
| Patterson MC et al 2010 | Long-term miglustat therapy in children with Niemann-pick disease Type C. | Journal of Child Neurology 2010; 25: 300-305. | 
| Videofluoroscopy data | ||
| Italian case studies Feracotta S et al 2011 | The videofluoroscopic swallowing study shows a sustained improvement of dysphagia in children with Niemann-Pick disease type C after therapy with miglustat . | American Journal of Medical Genetics, Part A 2011; 155: 540-547. | 
| Brushini D et al 2008 | Efficacy of Miglustat on Dysphagia in Four Niemann Pick Patients . | Journal of Inherited Metabolic Disease 2008; 31 (Sup 1):123. | 
| Taiwanese case studies Chien YH et al 2007 | Treatment of Niemann-Pick disease type C in two children with miglustat: Initial responses and maintenance of effects over 1 year. | JIMD Short Reports #063 (2007) DOI 10.1007/S 10545-007-0630-Y. | 
| Other patient data | ||
| UK data Jacklin E et al 2010 | Review of 11 patients with NPC1 treated with miglustat. | Molecular Genetics and Metabolism. 2010; 99: S22. | 
| Spanish and Portuguese data Pineda M et al 2010 | Clinical experience with miglustat therapy in paediatric patients with Niemann–Pick disease type C: A case series . | Molecular Metabolism. 2010; 99: 358-366. | 
| Italian data Fecarotta S et al 2009 | Efficacy of miglustat on the neurological involvement in Italian patients with Niemann-Pick disease type C. | Molecular Genetics and Metabolism 2009; 98: 70 (Abstract). | 
| Pineda M et al 2009 | Miglustat in patients with Niemann-Pick disease Type C (NP-C): a multicenter observational retrospective cohort study. | Molecular Genetics and Metabolism 2009; 98 (3):243-249. | 
| Sedel F 2010 | Changing the disease course: Disease modifying treatment for Niemann-Pick type C. | European Neuropsycho-pharmacology. 2010; 20(Sup 3): S639. | 
NP-C = Niemann-Pick disease Type C; RCT = randomised
                              controlled trial
8. Results of Trials
The instruments used in the three videofluoroscopy case studies included the Dysphagia
                           Severity Scale, Han Functional Dysphagia Scale, Penetration/Aspiration Scale, and
                           Melbourne Health VFSS Rating Scale.
Overall, the results from the VFSSs showed a high degree of variation across subjects.
The re-submission did not provide information regarding whether the swallowed material
                           used in the assessment of swallowing function was consistent across studies or across
                           patients. Due to a lack of pre-treatment assessment for most of the patients (and/or
                           a control group), it could not be determined whether the observed changes in swallowing
                           function during the treatment period were due to natural disease progression or resulted
                           from the use of miglustat. Given that the rate of progression of neurological symptoms
                           in NP-C, including swallowing function, can vary over the course of the disease, and
                           there may also be temporary periods of spontaneous improvement, the lack of baseline
                           data and/or a control group severely hindered interpretation of the swallowing study
                           results.
Additional patient data:
The data are based on a small number of patients, with large intra- and inter-individual
                           variability in rates of disease progression. The utility of the results was further
                           limited by the potential for observer bias.
Longitudinal analysis of survival data:
A significantly lower risk of mortality was reported in the miglustat cohort than
                           in the untreated cohort (hazard ratio: 0.16 [0.063, 0.391]), based on 10 years of
                           patient data after the onset of neurological symptoms for both groups.
The Kaplan-Meier survival curves for the treated and untreated cohort of patients
                           with NP-C are shown below:
Kaplan-Meier survival curves for treated and untreated cohort of patients with NP-C

The survival curves of the two cohorts diverge within the first 3 years after the
                           onset of neurological involvement.
The Pre-Sub-Committee Response (PSCR) stated that the data used in the survival analysis
                           are real world data of patients and that these patients are reflective of the likely
                           patient population to receive miglustat if funded on the LSDP.
The survival curves, time from miglustat treatment initiation compared with time from
                           symptom onset in the control arm, are shown in the figure below:
 
                        

For PBAC’s view of these results, see Recommendation and Reasons.
No new toxicity data from clinical studies were presented in the re-submission.
 
                        
9. Clinical Claim
                           The re-submission described miglustat as superior to placebo in
                           terms of effectiveness in patients with NP-C. 
                           Based on the data presented in the resubmission, the PBAC did not
                           accept the clinical claim that miglustat is superior to placebo in
                           terms of effectiveness. The PBAC also reaffirmed its previous
                           conclusion from July 2010 that miglustat is not as safe as
                           placebo.
10. Economic Analysis
                           An updated modelled economic evaluation was not presented.
                           At the July 2010 PBAC meeting, the PBAC accepted that miglustat is
                           unlikely to be cost-effective.
11. Estimated PBS Usage and Financial Implications
                           The submission estimated the likely number of patients/year to be
                           less than 10,000 in the first 5 years.
                           The net financial cost to the PBS was estimated by the submission
                           to be less than $10 million in Year 5.
                           The estimates were uncertain as the prevalence and incidence of
                           NP-C disease in the Australian population is uncertain, and
                           therefore so are the number of patients likely to be treated.
12. Recommendation and Reasons
                           The PBAC noted that NP-C disease is highly heterogeneous in nature
                           and characterised by a widely varying life expectancy and wide
                           variability in age of onset and clinical presentations. The PBAC
                           acknowledged the scarceness of clinical data for the use of
                           miglustat in the treatment of patients with NP-C disease given the
                           rarity of NP-C disease.
                           However, based on the data presented in the resubmission, the PBAC
                           did not accept the clinical claim that miglustat is superior to
                           placebo in terms of effectiveness. The PBAC also reaffirmed its
                           previous conclusion that miglustat is not as safe as placebo.
                           The PBAC noted the new clinical data presented in the
                           re-submission, which comprised three videofluoroscopy swallowing
                           studies (VFSSs) of up to six NP-C patients (Australian, Italian and
                           Taiwanese), other NP-C patient case series data (UK data, Spanish
                           and Portuguese data, and Italian data), and a survival analysis of
                           NP-C patients treated with miglustat compared with an untreated
                           N-PC cohort sourced from elsewhere.
                           Regarding the VFSSs, the PBAC considered that the evidence provided
                           was not sufficient to support the validity and reliability of the
                           four scales used in the studies. Additionally, given the lack of
                           blinded outcome assessment there is potential for
                           investigator/assessor bias in the assessment of the subjective
                           outcome of swallowing function.
                           The PBAC noted that the results of the three VFSSs did not show
                           consistent improvement or stabilisation across treated patients in
                           swallowing function/dysphagia scores and there was no information
                           on a control group of either untreated NP-C patients or consistent
                           results prior to treatment. The PBAC considered it is therefore
                           unknown from these results whether miglustat mitigates disease
                           progression as measured by dysphagia.
                           Regarding the NP-C patient case series data, the PBAC noted that
                           the composite scales used to measure NP-C disease severity in the
                           UK, Spanish and Portuguese patients have not been validated. The
                           data are based on a small number of patients, with large intra- and
                           inter-individual variability in rates of disease progression. The
                           utility of the results is further limited by the potential for
                           observer bias.
                           Regarding the longitudinal analysis of survival data presented in
                           the re-submission, the PBAC noted that a significantly lower risk
                           of mortality was reported in the miglustat cohort than in the
                           untreated cohort (hazard ratio: 0.16 [0.063, 0.391]), based on 10
                           years of patient data after the onset of neurological symptoms for
                           both groups. The survival data on both cohorts were pooled from a
                           variety of patient sources, but there was no explanation of how
                           these patients were selected. The comparability of the two cohorts
                           in terms of potential confounding factors, eg age of neurological
                           symptom onset, was not assessed in the re-submission. The PBAC
                           noted that the survival curves of the two cohorts diverged within
                           the first 3 years after the onset of neurological involvement.
                           However, the observed lower mortality in the treated cohort may
                           have resulted from less severe or slower natural disease
                           progression of NP-C in the treated patients rather than miglustat
                           therapy. 
                           The PBAC noted that the Pre Sub-Committee Response re-created
                           survival curves looking at time from symptom onset in the control
                           group compared with time from treatment initiation in the miglustat
                           group. It states that the divergence of the survival curves from
                           the time of treatment initiation is again significant (test
                           p=0.0192). The PBAC considered that the interpretation of the
                           survival data remains unclear; given that patient baseline
                           characteristics were unmatched and that, due to more extensive
                           right-censoring in the miglustat cohort, the most reliable data
                           were at the top of the curves, before they diverge. Although the
                           applicant has emphasised the representativeness of patients in the
                           miglustat cohort to patients taking miglustat “in the real
                           world”, the PBAC’s concern is the comparability of the
                           two cohorts in terms of all aspects that might influence survival
                           of NP-C patients, so that the reported statistically significant
                           difference between the survival of the two cohorts can be
                           confidently attributed to miglustat or not. This concern is not
                           addressed either by assessing the effect of age on survival across
                           all treated and untreated patients, or by restricting the survival
                           analyses to patients who have been included in published
                           data.
                           The PBAC noted the articles in the re-submission reporting on
                           dysphagia and aspiration pneumonia in patients with
                           neurodegenerative disorders or stroke. A total of 12 cohort studies
                           were identified. A low to moderate degree of heterogeneity in study
                           results was observed across the studies (I2: 23%,
                           Chi2 p-value: 0.21). The overall estimate of the odds
                           ratio (OR) of aspiration pneumonia in patients with dysphagia is
                           14.12 (95% CI: [13.95, 14.38]). The PBAC considered that, although
                           dysphagia may increase the risk of aspiration pneumonia in patients
                           with stroke and neurodegenerative disorders, the applicability to
                           NP-C patients is less clearly established.
                           The PBAC noted the literature search used to identify studies
                           providing data on aspiration pneumonia (or pneumonia) and
                           mortality. The results of a meta-analysis of the identified six
                           cohort studies which examined the relationship between aspiration
                           pneumonia and mortality, using a Mantel-Haenszel fixed-effects
                           model indicated an increased risk of mortality was observed in
                           patients experiencing aspiration pneumonia, with pooled OR of 3.23
                           (95%: [2.46, 4.25]), which is not as strong a signal as the OR of
                           aspiration pneumonia in patients with dysphagia. Results showed a
                           high degree of consistency across studies (I2: 0%,
                           Chi2 p-value: 0.64). However, none of the six identified
                           studies were in patients with NP-C (3 in stroke patients, 1 in
                           patients with epilepsy, 1 in patients with Parkinson’s
                           disease, and 1 in a population with a variety of neurodegenerative
                           disorders). Therefore, the PBAC again considered that the
                           applicability of these results to NP-C patients is uncertain.
                           The PBAC noted that no evidence was presented to allow an
                           assessment of the benefits of early intervention with miglustat for
                           pediatric patients and how this may alter disease progression and
                           life expectancy, given that the presentation of NP-C disease is
                           different in children compared to adults.
                           The PBAC therefore rejected the re submission for the inclusion of
                           miglustat in the Life Saving Drugs Program (LSDP) for the treatment
                           of progressive neurological manifestations in adults and paediatric
                           patients with Niemann-Pick type C (NP-C) disease on the basis that
                           the clinical evidence presented failed to show that miglustat meets
                           eligibility criterion 4 and 5 of the LSDP. 
                           In relation to the new clinical evidence in the re-submission to
                           address criterion 5 of the LSDP, the PBAC did not accept that the
                           several sets of case series presenting dysphagia results (including
                           the VFSSs) provided a convincing basis to conclude that miglustat
                           is clinically effective for this outcome. The PBAC also did not
                           accept that the comparison of survival across treated and untreated
                           patients enabled a conclusion of clinical effectiveness because it
                           could not assess the comparability of the two cohorts for other
                           aspects that might influence survival and so could not exclude
                           sources of confounding. For these reasons, together with the
                           extremely high cost per patient per year the PBAC re-affirmed its
                           previous decisions not to recommend listing on the PBS and not to
                           accept that miglustat meets eligibility criterion 4 of the
                           LSDP.
                           In relation to the new clinical evidence in the re-submission to
                           address criterion 4 of the LSDP, the PBAC did not accept the
                           comparison of survival for the reasons already identified in
                           relation to criterion 5. The PBAC also did not accept that the
                           chain of argument presented in the re-submission (i.e., from a
                           treatment effect of miglustat on dysphagia to a treatment effect of
                           miglustat on extending a patient’s lifespan via a reduction
                           in aspiration pneumonia) was sufficiently established. Based on
                           data in other diseases, the association between dysphagia and
                           aspiration pneumonia is more strongly established than between
                           aspiration pneumonia and death. However, the applicability of these
                           associations to NP-C patients is uncertain. More importantly, a
                           clear treatment effect of miglustat on dysphagia, the first link in
                           this chain of argument, was not accepted for the reasons already
                           identified in relation to criterion 5. Overall, the PBAC
                           re-affirmed its previous decision not to accept that miglustat
                           meets eligibility criterion 4 of the LSDP.
                           The PBAC expressed the view that, although the new clinical
                           evidence provided for its consideration was not sufficient to
                           change its previous conclusions, comparing survival curves across
                           treated and untreated cohorts which are otherwise similar in terms
                           of characteristics with known prognostic value would be
                           informative. Identifying patients who would be most likely to gain
                           an extension in their lifespan from treatment may also be
                           informative.
                           The PBAC also noted that, relevant to criterion B2 for the LSDP,
                           the cost per patient for treating NP-C disease is double that for
                           treating Gaucher disease under the LSDP based on the relevant
                           recommended doses being double in NP-C disease compared with
                           Gaucher disease and an identical cost per pack.
                           The PBAC also acknowledged and noted the consumer comments on this
                           item.
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
Actelion acknowledges the difficulties in meeting the LSDP criteria in a very rare condition such as Niemann-Pick Disease Type C. Actelion remains committed to working with the PBAC and LSDP to ensure that patients with Niemann-Pick Disease Type C have funded access to treatment.




