天价基因疗法存在人为“数据完整性”问题!FDA展开调查:不排除政府和刑事处罚

来源: 医药魔方/yiyaomofang
诺华旗下AveXis公司开发的基因疗法Zolgensma在今年5月24日赢得了FDA的批准,用于治疗两个编码运动神经元生存蛋白(SMN)的SMN1等位基因上携带突变的2岁以下脊髓性肌肉萎缩症(SMA)患者,并定出了212万美元的天价(见:基因疗法Zolgensma定价212万美元,可5年分期付款)。

但是这款天价明星药物近日遭遇了不小的麻烦。


8月6日,FDA发布声明称:曾于6月28日收到负责生产ZolgensmaAveXis公司的通知,告知其提交审核的BLA申请资料中的动物模型测试数据存在一处“数据操控(data manipulation)”的问题。FDA在获悉这一情况后进行了谨慎的评估,认为这小部分药品测试数据只是用来支持Zolgensma的开发和生产工艺,并不影响其在人体临床试验上的有效性和安全性结果,因此目前对于保留Zolgensma的上市资格仍持有较大信心。

不过FDA依然指出:用于产品开发和生产的动物模型测试数据完整性问题是一个很严肃的问题,FDA会慎重处理这个问题。而且FDA获知,AveXis公司在FDA对Zolgensma做出批准决定前就已知晓这一问题,但是直到FDA做出批准决定以后才向FDA上报企业如实向FDA提交完整的数据资料非常重要,因为法律赋予了FDA保护公民健康的职责。因此,FDA决定对此问题展开彻底调查(completed inspection,详见阅读原文)。FDA将在职能范围内对AveXis进行调查,根据调查结果不排除采取政府和刑事处罚的可能性

在FDA的监管体系下,FDA是基于药企提交的上市申请资料进行科学审评并做出审批决定。提交完整、准确的数据是药企的基本职责,如果企业未如实提交,将面临法律的制裁。

诺华在2018年初以87亿美元代价收购了AveXis,后者刚刚上市的Zolgensma治疗SMA只需注射一次,对于Biogen的明星产品Spinraza产生了巨大威胁。因此FDA之后的调查结果和决定也必会受到利益相关方的高度关注。

以下为FDA声明原文:



Statement on data accuracy issues with recently approved gene therapy


For Immediate ReleaseAugust 06, 2019
Statement FromDirector - Center for Biologics Evaluation and Research (CBER),Dr. Peter Marks M.D. PhD.


As a public health agency, we believe that it is critical to facilitate the development of innovative safe and effective medical products, like the cellular and gene therapy products that have shown enormous potential to treat previously untreatable diseases. As part of the approval process for biological products, the agency reviews extensive information submitted by manufacturers, including details of how the product is made in a reproducible manner, how it has been tested in animals, and how it has been investigated in human clinical trials to demonstrate its safety and efficacy. 

It is the manufacturer’s responsibility to submit complete and accurate information in marketing applications for evaluation by the FDA. If we become aware of a concern with data submitted to the agency as part of our review of a product application, it is in the best interest of patients, their caregivers, and the public that we disclose such information, to the extent permitted by law.

On May 24, the FDA approved Zolgensma, a gene therapy product intended to treat children less than two years of age with spinal muscular atrophy (SMA) with bi-allelic mutations in the survival motor neuron 1 gene — the most severe form of SMA. SMA is a leading genetic cause of infant mortality. Subsequently, on June 28, following the FDA’s approval of the product, the agency was informed by AveXis Inc., the product’s manufacturer, about a data manipulation issue that impacts the accuracy of certain data from product testing performed in animals submitted in the biologics license application (BLA) and reviewed by the FDA. 

The FDA is carefully assessing this situation and remains confident that Zolgensma should remain on the market. Out of the large amount of submitted information reviewed by the agency, our concerns at this time are limited to only a small portion of the product testing data that was contained in the marketing application. This product testing data was used by the manufacturer to support the development of its production process for the product. These data do not change the agency’s positive assessment of the information from the human clinical trials that were conducted as part of the development program. The totality of the evidence demonstrating the product’s effectiveness and its safety profile continues to provide compelling evidence supporting an overall favorable benefit-risk profile. However, the integrity of the product testing data used in the development of the product’s manufacturing process is still a matter that we are continuing to evaluate and take very seriously.

Ensuring truthful, complete and accurate data in product applications is a critical component of industry’s responsibility as they work to demonstrate the safety, purity, and potency of biological products. The submission of such truthful, complete and accurate data is also critical for the FDA to be able to protect the public health, and the law requires it. We are carefully assessing the issue of the manipulation of the product testing data used in the production process and are conducting a thorough assessment of the information from a recently completed inspection.  In part, this will allow us to determine the implications for the FDA’s scientific review of the information in the BLA and will allow us to amend our publicly posted BLA reviews, as appropriate.

We are also aware that AveXis became aware of the issue of the data manipulation that created inaccuracies in their BLA before the FDA approved the product, yet did not inform the FDA until after the product was approved.The agency will use its full authorities to take action, if appropriate, which may include civil or criminal penalties.

We recognize that parents of, and health care professionals for, children with SMA may have questions or concerns about this information. Parents and health care professionals may contact the FDA at (800) 835-4709 or AveXis for more information. The FDA will continue to provide updates related to this statement as we learn more.

As with all biological products, health care professionals and patients (or for Zolgensma, their caregivers) should be aware of both the product’s benefits and risks. The most common side effects of Zolgensma are elevated liver enzymes and vomiting. Zolgensma has a boxed warning that acute serious liver injury can occur. Health care professionals and caregivers should refer to the product package insert for additional risk information.

The FDA, an agency within the U.S. Department of Health and Human Services, protects the public health by assuring the safety, effectiveness, and security of human and veterinary drugs, vaccines and other biological products for human use, and medical devices. The agency also is responsible for the safety and security of our nation’s food supply, cosmetics, dietary supplements, products that give off electronic radiation, and for regulating tobacco products.