Five Strategic Considerations for Biosimilar Commercialization By Rohit Sood, Sebastien Morisot, and Rafal Kokolus With a large number of blockbuster biologics such as Erbitux [cetuximab; ImClone, BMS] and Herceptin [trastuzumab; Genentech] expected to go offpatent in the next 5 years, the global biosimilar market is expected to reach $15 billion by 2020. More than 150 manufacturers are currently investing in biosimilar development, manufacturing, and commercialization capabilities across several key markets, including South Korea, India, China, Argentina, and in the European Union (EU). Meanwhile, advancements in technology and capabilities as well as economic necessities driving the need for less expensive medicines have created an opportunity for biosimilars in the marketplace. Biosimilar commercialization is essentially similar to commercializing a biologic, but with two key differences: the level and mix of the investment and the commercial model. Through our research and experience working with a wide range of commercial organizations in the biotechnology space, Campbell Alliance has identified five factors companies may consider as they think about commercializing biosimilars: country, category, company, competition, and customer. Country In determining the countries in which a product will be marketed, consideration must be given to different levels of IP protection, regulatory pathways, and policies on interchangeability/ automatic substitution. Figure 1a: Go-to-market considerations should include IP and local market healthcare policies Law against automatic substitution Guidelines prohibit automatic substitution Automatic substitution occuring; No regulation/law Sweden Finland NoMA encouraging interchangeability study for REMSIMA and REMICADE Norway Estonia Latvia Denmark Lithuania Ireland UK Netherlands Belgium Jan, 2014: Law change to allow automatic substitution for treatment naiive patients France Belarus Poland Germany Czech Republic Switzerland Italy Austria Ukraine Slovakia Moldova Hungary Romania Slovenia Croatia Serbia Bulgaria Cyprus Spain Portugal Greece Malta Source: Campbell Alliance Insights OBR; Published October 15, 2014; http:/http://obroncology.com/obrgreen/article/Five-Strategic-Considerations-for-Biosimilar-Commercialization OBR GREEN | OCTOBER 2014 | obroncology.com 1 In Europe, biosimilar products for growth have been available for almost a decade. To push back, manufacturers of originator drugs are using changes in manufacturing procedures and for- mulations to create new patent protections. As they begin to invest in the development of new biosimilars, manufacturers may consider engaging outside council to conduct a patent mapping exercise to Meanwhile, policies around interchangeability and automatic substitution differ by region (Figure 1a and 1b). In the EU, decisions regarding interchangeability are decided by the individual countries. Due to concerns around the traceability of adverse events, almost all EU country regulatory bodies have established rules against automatic substitution.1 However, there is some change on the horizon. Figure 1b: Markets with similar automatic substitution policies may result in varying uptake given physician behavior and dynamics 1.4 Volume Standard Units (millions) 1.2 1.0 0.8 0.6 0.4 0.2 0.0 Q1 1998 Q1 2000 Q1 2002 0.7 Q1 2004 Q1 2006 Q1 2008 Q4 2009 Q1 2006 Q1 2008 Q4 2009 Volume Standard Units (millions) 0.6 0.5 0.4 0.3 0.2 0.1 0.0 Q1 1998 Q1 2000 Q1 2002 Q1 2004 Total of All Brands First Generation Brands Source: Campbell Alliance Insights make sure that there is a development path with minimal barriers. IP mapping is vital for addressing not just the known IP implications of a product but also the potential unknown issues. Second Generation Brands Biosimilars In January, France became the first country to allow pharmacists to substitute a biosimilar for a “reference biologic.” In Germany, a large proportion of erythropoietin is apparently being purchased by dialysis clinics through a physician organization equivalent to a group purchasing organization, so physicians there appear to have direct financial incentive to use the less expensive product. In fact, German physicians run the risk of being held accountable for exceeding target cost limits in prescribing, which is driving uptake for biosimilars. Italy, Spain, and the UK have established guidance and official lists of non-substitutable medicines that include all biologics. Here, in the US, legislation regarding biosimilars varies from state to state and is constantly evolving. Virginia, Utah, and North Dakota have passed laws OBR; Published October 15, 2014; http://http://obroncology.com/obrgreen/article/Five-Strategic-Considerations-for-Biosimilar-Commercialization 2 OBR GREEN | OCTOBER 2014 | obroncology.com that permit pharmacists to dispense a biosimilar in place of a prescribed biological product only if that biosimilar meets the higher safety standards for interchangeability. Meanwhile, states like Arizona, Maryland, Mississippi, and Washington have rejected similar laws. Numerous other states have legislation that is expected to be considered. Category Biosimilars are a relatively new and evolving category with several moving parts, including regulatory pathways and substitution policies. An opportunity exists to weave a cohesive communication story to raise awareness on biosimilars and set expectations on the value of the category to patients and the healthcare system. The Medical Affairs organization and medical science liaisons (MSLs) have an important role to play in raising market awareness of a biosimilar product. The C-suite will also need to get involved in establishing credibility of a product and the supply by participating in conferences and congresses to talk about the assets and the level of investment a company is making in the category. The value proposition of a biosimilar product will be a less important consideration because it should mirror the reference product. However, it will be necessary to articulate what a company is bringing to the table aside from just the lower cost in order to appeal to the full range of stakeholders. Cost will be important to payers, but physicians and patients will also be interested in efficacy and safety data and the support services offered. Because these products are not the equivalent of generics, a constant relationship and maintenance will be necessary after launch to make sure potential adverse events are monitored (similar to branded products) and physicians and patients are getting the hand holding they need. Company Manufacturer commitment, credibility, and corporate equity are critical for biosimilar acceptance. Based on research done by Campbell Alliance, stakeholders’ familiarity with a manufacturer has a major influence on the decision whether to prescribe the product or not. In a survey of prescribers, a rheumatologist in France noted, “If I know the company and it’s what they do, of course I would be more comfortable.” An oncologist in the US expressed that, “It would give me peace of mind if the product is coming from a big player like Amgen or Genentech.” Without the benefit of experience with a manufacturer, prescribers and payers will want to see information that helps them understand why they should use a product from this company. If a manufacturer were able to demonstrate repeated success with producing biosimilars as effective and safe as originators, this would be a trusted standard. Competition A significant number of competitors are interested in capitalizing on the opportunity with biosimilars. Separation exists between niche players and big pharma. Mapping and addressing originator messaging and policy initiatives will be critical. The competition for biosimilar manufacturers is not limited to originator products or other biosimilars targeting the same pathways. Biosimilar manufacturers must be keenly attuned to the availability or ongoing development of second-generation biologics that could compete directly against them. Second-generation biologics are part of the lifecycle management armamentarium for biotechnology companies, and they build upon the demonstrated track record of an available molecule, by improving its efficacy and safety (e.g., Roche’s Kadcyla is an antibody drug conjugate evolution of the blockbuster Herceptin). The ability of a second-generation manufacturer to shift the standard of care paradigm and convert patients from the original to the improved molecule will significantly limit the need for a biosimilar mimicking the original product. As a result, the market potential for a biosimilar manufacturer facing this situation will be restricted to a subset of a larger space dominated by a second-generation product. Conversely, lack of successful conversion from an originator product to a secondgeneration product will create opportunities for biosimilar manu- OBR; Published October 15, 2014; http:/http://obroncology.com/obrgreen/article/Five-Strategic-Considerations-for-Biosimilar-Commercialization OBR GREEN | OCTOBER 2014 | obroncology.com 3 facturers to drive utilization, gain market share from their originator competitor(s), and establish a strong presence in their space. When developing a biosimilar of an originator product that utilizes a device, such as a pre-filled syringe, biosimilar manufacturers will be challenged to develop their own device to match. Device design and development requires very different capabilities and skill sets, and biosimilar manufacturers that are considering developing their own devices need to have those capabilities in house. It will also be necessary to get the device approved by the regulatory authorities. In the US, FDA mandates the 510(k) regulatory pathway for the approval of any new device. In the EU, meanwhile, medical devices need to comply with the appropriate legislative directive, depending on the type of device it is. Customers Finally, the customer landscape is a complex mosaic involving physicians, payers, regulators, and advocacy groups. These camps have mixed views on biosimilars in general. Stakeholders have numerous questions relative to quality, reliability, and confidence in biosimilars. Issues like indication extrapolation are a concern when a biosimilar of a drug with multiple indications has not been tested in the full range of indications. Gastroenterologists in the US and Europe, for example, have stated that they will not prescribe biosimilar infliximab in Crohn’s disease or in patients with ulcerative colitis if clinical trials have only been conducted in rheumatoid arthritis.2 Based on research conducted by Campbell Alliance, prescribers are interested in biosimilars. Among a group of surveyed prescribers, a general practitioner in the UK expressed, “I have no real experience with biosimilars yet, but I’m interested. Real cost savings. I’m broadly positive.” Similarly, a general practitioner in Germany noted, “Insurance will try to make it popular to prescribe biosimilars like they do with generics, which is okay.” Less positively, a surveyed oncologist in the UK wondered, “If you can’t replicate [the originator drug] 100%, then how can you get [the biosimilar] to perform 100%?” A US oncologist echoed a similar concern, asking, “Are they really as good?” To overcome stakeholder skepticism around biosimilarity, it will be necessary to obtain advocacy for the product, educating opinion leaders to alleviate confusion around product nomenclature, and providing medical education around the product attributes and how it compares with the reference drug. Appealing to payers is the first hurdle, because without assurance of reimbursement, physicians will be reluctant to prescribe. Payers acknowledge that biosimilars are comparable with their biologic counterparts but not necessarily equivalent, thereby warranting a close inspection of the biosimilar’s clinical, comparative, and market data (if available) to determine appropriateness. In addition, payers acknowledge that a biosimilar could be chemically different but functionally the same as the biologic, leading to several unknowns regarding “tolerable variance.” Another important aspect of development in the biosimilar market is physician comfort with the idea of prescribing the agent. Ultimately, a physician’s decision to sit with a patient to discuss the option of using a biosimilar will vary by therapeutic area, specialty, and the patient dynamic. Physicians may be more willing to start a new patient on a biosimilar versus switching a patient from a reference drug to a biosimilar. Physicians tend to have strong preferences for which treatments they use for which patients. Unless they truly understand the clinical and economic implications of biosimilars, they will most likely limit their use of biosimilars with patients. And of course, they will be limited by the automatic substitution policy in place. A certain level of patient education may also be necessary. Patients may be reluctant to switch to a different product that does not offer the same quality of patient support—such as patient assistance programs for specialized products—and they may not be fully aware of biosimilars that have not been on the market as long as branded referenced products. OBR; Published October 15, 2014; http://http://obroncology.com/obrgreen/article/Five-Strategic-Considerations-for-Biosimilar-Commercialization 4 OBR GREEN | OCTOBER 2014 | obroncology.com On the other hand, patients will value products with an efficacy similar (or better than) that of their current treatment, with no added side effects. Most importantly, out-of-pocket payments for both non-insured and insured patients will likely be reduced if switching to a biosimilar-based treatment. Conclusion Despite the challenges, biosimilars can be an attractive opportunity for companies looking to enter a therapeutic area or for existing players looking to bolster their current position. Because biosimilar development leverages the scientific evidence established by the reference product, initial development steps involving target identification and validation are eliminated, decreasing the risk of failures and the development time. Provided that manufacturers can demonstrate comparability, biosimilars can be developed with less time, investment, and risks than is associated with standard biologic development pathways. About the Contributors Rohit Sood is Head of Global Launch Excellence, Campbell Alliance. He can be reached at r s o o d @ c a mp b e l l a l l i a n c e. c o m . Sebastien Morisot is Engagement Manager, Campbell Alliance. He can be reached at [email protected]. Rafal Kokolus is Senior Engagement Manager, Campbell Alliance. He can be reached at [email protected]. Article References: 1. 2. http://www.eahp.eu/page/biosimilars-do-not-look-mirror. Accessed 8/12/14. http://bio-trends.com/News-and-Events/Press-Releases/ TNF-alpha-inhibitors-093013. Accessed 8/12/14 OBR; Published October 15, 2014; http:/http://obroncology.com/obrgreen/article/Five-Strategic-Considerations-for-Biosimilar-Commercialization OBR GREEN | OCTOBER 2014 | obroncology.com 5
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