In a recent article in the New York Times,
Andrew Pollack quoted from The Kidney Doctor post published here.
One of the points that I made was that I am not sure that one can justify drawing a line between
ESRD patients (ie patient’s on dialysis) and patients with CKD not on dialysis.
Why?
First, let me concede that obviously dialysis
patients are different than stage 4/5 CKD patients not on dialysis in at least two
important respects. Dialysis patients usually have more severe impairment in
native kidney function. By the time patients are on dialysis, and especially
after patients have been on dialysis for a while, there is a decline in residual
renal function. Besides, dialysis patients have more complications related to kidney
disease: worse bone disease, greater deficiency in epo production, and underlying
cardiovascular disease. Data also demonstrates more evidence of inflammation –
higher baseline hsCRP, lower serum albumin, and higher baseline ferritin. These characteristics may modify the effect of ESAs on outcomes.
The other big difference is that patients with ESRD undergo
dialysis, which has systemic effects. For example, patients undergo removal of
fluid, fluxes in solute and electrolytes, and changes in hemodynamics. Dialysis
patients also tend to become more hemoconcentrated as volume is removed.
But the question is not whether there are physiologic
differences between ESRD and non-ESRD patients. The issue is whether one can comfortably assume that an ESA is safe in ESRD patients even
though there is a safety signal in a non-ESRD setting. In essence, is it
alright for the FDA to accept that approval is OK in dialysis patients “because
these patients are different” from non-dialysis CKD patients?
The answer is that, like me, the FDA is hedging it’s bets. The FDA states the benefits of the drug narrowly: “This new drug offers patients and
health care providers the convenience of receiving ESA therapy just once per
month instead of more frequent injections.” And, “Omontys [peginesatide] should not be used in patients with CKD who
are not receiving dialysis or in patients with cancer–related anemia, according
to the FDA-approved labeling. It also should not be used as a substitute for
red blood cell transfusions in patients who require immediate correction of
anemia. Omontys has not been shown to improve symptoms of anemia, physical
functioning or health-related quality of life in patients with CKD on dialysis.”
The FDA is accepting the fact that the drug appears to be
safe in dialysis patients, but, because of the PEARL data it is not sure.
Recall that in the PEARL studies, the frequency of CSE events was higher in the peginesatide group (21.6 percent) versus the comparator (17.1 percent) (HR 1.34, 90 percent CI 1.03 - 1.73). Note: CSE is the adjudicated cardiovascular composite safety endpoint of death, stroke, myocardial infarction, congestive heart failure, unstable angina, and arrhythmia).
Because of the safety signal in PEARL the FDA is requiring the drug manufacturer (Affymax) to perform additional studies in dialysis patients in the post-marketing phase.
Recall that in the PEARL studies, the frequency of CSE events was higher in the peginesatide group (21.6 percent) versus the comparator (17.1 percent) (HR 1.34, 90 percent CI 1.03 - 1.73). Note: CSE is the adjudicated cardiovascular composite safety endpoint of death, stroke, myocardial infarction, congestive heart failure, unstable angina, and arrhythmia).
Because of the safety signal in PEARL the FDA is requiring the drug manufacturer (Affymax) to perform additional studies in dialysis patients in the post-marketing phase.
Writes the Pharma Letter:
In the approval action letter, the FDA outlined”post-marketing requirements: an
observational study and a randomized controlled trial to be completed with
final reports submitted in 2018 and 2019, respectively. The objectives of the
studies are to evaluate cardiovascular safety and assess safety of long-term
use in adult patients on dialysis, in particular in the incident patient
population. In addition, the post-marketing commitment includes the initiation
of pediatric studies with target dates for completion between 2016 and 2027.
The reason that the FDA is hedging is because there have
been 4 randomized controlled trials reporting a safety signal. Of these 4
studies, 1 was in dialysis patients – the Normal Hematocrit trial, and 3 in
non-dialysis patients – CHOIR, CREATE, and TREAT.
So I am hopeful that peginesatide will truly be safer in
dialysis patients as compared to epoetin-alfa or epoetin-beta or CERA among dialysis patients, but I
doubt that will be the case. More likely, the reason that peginesatide did not demonstrate a
safety signal in EMERALD was because of either subtle differences in the enrolled study
population, or because of differences in the studies of the ESA dose or treatment algorithm that was used, or because
of differences in the Hb targets in PEARL compared to the earlier studies.
Therefore, my plan is to: 1. Not use peginesatide in non-dialysis CKD
patients and, 2. use peginesatide
in the dialysis population recognizing that it’s risk in dialysis patients is
probably no different from the other ESAs tested in both CKD and non-CKD
populations. Thus, I plan to individualize the use of the drug by identifying the Hb trigger for the patient that requires an ESA intervention, and generally using the lowest possible ESA dose.











