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      Bioequivalence between innovator and generic tacrolimus in liver and kidney transplant recipients: A randomized, crossover clinical trial

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          Abstract

          Background

          Although the generic drug approval process has a long-term successful track record, concerns remain for approval of narrow therapeutic index generic immunosuppressants, such as tacrolimus, in transplant recipients. Several professional transplant societies and publications have generated skepticism of the generic approval process. Three major areas of concern are that the pharmacokinetic properties of generic products and the innovator (that is, “brand”) product in healthy volunteers may not reflect those in transplant recipients, bioequivalence between generic and innovator may not ensure bioequivalence between generics, and high-risk patients may have specific bioequivalence concerns. Such concerns have been fueled by anecdotal observations and retrospective and uncontrolled published studies, while well-designed, controlled prospective studies testing the validity of the regulatory bioequivalence testing approach for narrow therapeutic index immunosuppressants in transplant recipients have been lacking. Thus, the present study prospectively assesses bioequivalence between innovator tacrolimus and 2 generics in individuals with a kidney or liver transplant.

          Methods and findings

          From December 2013 through October 2014, a prospective, replicate dosing, partially blinded, randomized, 3-treatment, 6-period crossover bioequivalence study was conducted at the University of Cincinnati in individuals with a kidney ( n = 35) or liver transplant ( n = 36). Abbreviated New Drug Applications (ANDA) data that included manufacturing and healthy individual pharmacokinetic data for all generics were evaluated to select the 2 most disparate generics from innovator, and these were named Generic Hi and Generic Lo. During the 8-week study period, pharmacokinetic studies assessed the bioequivalence of Generic Hi and Generic Lo with the Innovator tacrolimus and with each other. Bioequivalence of the major tacrolimus metabolite was also assessed. All products fell within the US Food and Drug Administration (FDA) average bioequivalence (ABE) acceptance criteria of a 90% confidence interval contained within the confidence limits of 80.00% and 125.00%. Within-subject variability was similar for the area under the curve (AUC) (range 12.11–15.81) and the concentration maximum (C max) (range 17.96–24.72) for all products. The within-subject variability was utilized to calculate the scaled average bioequivalence (SCABE) 90% confidence interval. The calculated SCABE 90% confidence interval was 84.65%–118.13% and 80.00%–125.00% for AUC and C max, respectively. The more stringent SCABE acceptance criteria were met for all product comparisons for AUC and C max in both individuals with a kidney transplant and those with a liver transplant. European Medicines Agency (EMA) acceptance criteria for narrow therapeutic index drugs were also met, with the only exception being in the case of Brand versus Generic Lo, in which the upper limits of the 90% confidence intervals were 111.30% (kidney) and 112.12% (liver). These were only slightly above the upper EMA acceptance criteria limit for an AUC of 111.11%. SCABE criteria were also met for the major tacrolimus metabolite 13-O-desmethyl tacrolimus for AUC, but it failed the EMA criterion. No acute rejections, no differences in renal function in all individuals, and no differences in liver function were observed in individuals with a liver transplant using the Tukey honest significant difference (HSD) test for multiple comparisons. Fifty-two percent and 65% of all individuals with a kidney or liver transplant, respectively, reported an adverse event. The Exact McNemar test for paired categorical data with adjustments for multiple comparisons was used to compare adverse event rates among the products. No statistically significant differences among any pairs of products were found for any adverse event code or for adverse events overall. Limitations of this study include that the observations were made under strictly controlled conditions that did not allow for the impact of nonadherence or feeding on the possible pharmacokinetic differences. Generic Hi and Lo were selected based upon bioequivalence data in healthy volunteers because no pharmacokinetic data in recipients were available for all products. The safety data should be interpreted in light of the small number of participants and the short observation periods. Lastly, only the 1 mg tacrolimus strength was utilized in this study.

          Conclusions

          Using an innovative, controlled bioequivalence study design, we observed equivalence between tacrolimus innovator and 2 generic products as well as between 2 generic products in individuals after kidney or liver transplantation following current FDA bioequivalence metrics. These results support the position that bioequivalence for the narrow therapeutic index drug tacrolimus translates from healthy volunteers to individuals receiving a kidney or liver transplant and provides evidence that generic products that are bioequivalent with the innovator product are also bioequivalent to each other.

          Trial registration

          ClinicalTrials.gov NCT01889758.

          Abstract

          In a randomized 3-treatment crossover clinical trial, Rita Alloway of the University of Cincinnati and colleagues establish bioequivalence between 3 versions of the drug tracolimus (a brand name and 2 disparate generics) in kidney and liver transplant recipients.

          Author summary

          Why was this study done?
          • Consensus documents developed by professional transplantation societies worldwide have cautioned the use of generic immunosuppressants such as tacrolimus in individuals with a solid organ transplant. Reasons have included repeated switching between innovator (that is, “brand” products) and generics and among different generics, especially when not controlled by physicians.

          • There was uncertainty in the transplant community as to whether tacrolimus generics that are bioequivalent to the innovator are also bioequivalent to each other.

          • For market approval, generic drug products of the narrow therapeutic index drug tacrolimus had to be studied only in healthy individuals and not in the much more complex organ transplant population.

          What did the researchers do and find?
          • We performed a randomized, prospective, 3-treatment, 6-period, crossover, replicate dose study in individuals with a kidney or liver transplant.

          • Thirty-five individuals with a kidney transplant and 36 individuals with a liver transplant receiving tacrolimus were studied to compare the tacrolimus time concentration profiles of 3 different products in their blood: namely, Innovator (Prograf), Generic Hi (Sandoz), and Generic Lo (Dr. Reddy) 1.0 mg tacrolimus capsules.

          • Generic products were selected based upon pharmacokinetic data from healthy volunteer studies since bioequivalence data were not available in individuals with an organ transplant.

          • We observed bioequivalence based on average bioequivalence and scaled average bioequivalence criteria in individuals after kidney or liver transplant between tacrolimus innovator and the 2 generics on the US market as well as between the 2 generics.

          What do these findings mean?
          • Similar tacrolimus exposure is expected in individuals with a kidney or liver transplant when receiving Prograf, Sandoz generic, or Dr. Reddy’s generic tacrolimus.

          Related collections

          Most cited references31

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          Clinical Pharmacogenetics Implementation Consortium (CPIC) Guidelines for CYP3A5 Genotype and Tacrolimus Dosing.

          Tacrolimus is the mainstay immunosuppressant drug used after solid organ and hematopoietic stem cell transplantation. Individuals who express CYP3A5 (extensive and intermediate metabolizers) generally have decreased dose-adjusted trough concentrations of tacrolimus as compared with those who are CYP3A5 nonexpressers (poor metabolizers), possibly delaying achievement of target blood concentrations. We summarize evidence from the published literature supporting this association and provide dosing recommendations for tacrolimus based on CYP3A5 genotype when known (updates at www.pharmgkb.org).
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            Comparing generic and innovator drugs: a review of 12 years of bioequivalence data from the United States Food and Drug Administration.

            In the US, manufacturers seeking approval to market a generic drug product must submit data demonstrating that the generic formulation provides the same rate and extent of absorption as (ie, is bioequivalent to) the innovator drug product. Thus, most orally administered generic drug products in the US are approved based on results of one or more clinical bioequivalence studies. To evaluate how well the bioequivalence measures of generic drugs approved in the US over a 12-year period compare with those of their corresponding innovator counterparts. This retrospective analysis compared the generic and innovator bioequivalence measures from 2070 single-dose clinical bioequivalence studies of orally administered generic drug products approved by the Food and Drug Administration (FDA) from 1996 to 2007 (12 y). Bioequivalence measures evaluated were drug peak plasma concentration (C(max)) and area under the plasma drug concentration versus time curve (AUC), representing drug rate and extent of absorption, respectively. The generic/innovator C(max) and AUC geometric mean ratios (GMRs) were determined from each of the bioequivalence studies, which used from 12 to 170 subjects. The GMRs from the 2070 studies were averaged. In addition, the distribution of differences between generic means and innovator means was determined for both C(max) and AUC. The mean +/- SD of the GMRs from the 2070 studies was 1.00 +/- 0.06 for C(max) and 1.00 +/- 0.04 for AUC. The average difference in C(max) and AUC between generic and innovator products was 4.35% and 3.56%, respectively. In addition, in nearly 98% of the bioequivalence studies conducted during this period, the generic product AUC differed from that of the innovator product by less than 10%. The criteria used to evaluate generic drug bioequivalence studies support the FDA's objective of approving generic drug formulations that are therapeutically equivalent to their innovator counterparts.
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              Mechanisms of clinically relevant drug interactions associated with tacrolimus.

              The clinical management of tacrolimus, a macrolide used as immunosuppressant after transplantation, is complicated by its narrow therapeutic index in combination with inter- and intraindividually variable pharmacokinetics. As a substrate of cytochrome P450 (CYP) 3A enzymes and P-glycoprotein, tacrolimus interacts with several other drugs used in transplantation medicine, which also are known CYP3A and/or P-glycoprotein inhibitors and/or inducers. In clinical studies, CYP3A/P-glycoprotein inhibitors and inducers primarily affect oral bioavailability of tacrolimus rather than its clearance, indicating a key role of intestinal P-glycoprotein and CYP3A. There is an almost complete overlap between the reported clinical drug interactions of tacrolimus and those of cyclosporin. However, in comparison with cyclosporin, only few controlled drug interaction studies have been carried out, but tacrolimus drug interactions have been extensively studied in vitro. These results are inconsistent and are of poor predictive value for clinical drug interactions because of false negative results. P-glycoprotein regulates distribution of tacrolimus through the blood-brain barrier into the brain as well as distribution into lymphocytes. Interaction of other drugs with P-glycoprotein may change tacrolimus tissue distribution and modify its toxicity and immunosuppressive activity. There is evidence that ethnic and gender differences exist for tacrolimus drug interactions. Therapeutic drug monitoring to guide dosage adjustments of tacrolimus is an efficient tool to manage drug interactions. In the near future, progress can be expected from studies evaluating potential pharmacokinetic interactions caused by herbal preparations and food components, the exact biochemical mechanism underlying tacrolimus toxicity, and the potential of inhibition of CYP3A and P-glycoprotein to improve oral bioavailability and to decrease intraindividual variability of tacrolimus pharmacokinetics.
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                Author and article information

                Contributors
                Role: ConceptualizationRole: Data curationRole: Formal analysisRole: Funding acquisitionRole: InvestigationRole: MethodologyRole: Project administrationRole: ResourcesRole: SupervisionRole: VisualizationRole: Writing – original draftRole: Writing – review & editing
                Role: ConceptualizationRole: Data curationRole: Formal analysisRole: Funding acquisitionRole: MethodologyRole: Project administrationRole: ResourcesRole: SoftwareRole: SupervisionRole: ValidationRole: VisualizationRole: Writing – review & editing
                Role: Formal analysisRole: InvestigationRole: MethodologyRole: ResourcesRole: SoftwareRole: SupervisionRole: ValidationRole: Writing – review & editing
                Role: Formal analysisRole: SoftwareRole: ValidationRole: Writing – review & editing
                Role: Formal analysisRole: MethodologyRole: ResourcesRole: SoftwareRole: SupervisionRole: ValidationRole: Writing – review & editing
                Role: Formal analysisRole: MethodologyRole: SoftwareRole: ValidationRole: Writing – review & editing
                Role: MethodologyRole: Project administrationRole: SoftwareRole: SupervisionRole: Writing – review & editing
                Role: Data curationRole: Writing – review & editing
                Role: Data curationRole: Formal analysisRole: InvestigationRole: Writing – review & editing
                Role: Data curationRole: MethodologyRole: ResourcesRole: ValidationRole: Writing – review & editing
                Role: Data curationRole: Formal analysisRole: MethodologyRole: ResourcesRole: SoftwareRole: SupervisionRole: Writing – review & editing
                Role: ConceptualizationRole: Data curationRole: Formal analysisRole: Funding acquisitionRole: InvestigationRole: MethodologyRole: Project administrationRole: ResourcesRole: SupervisionRole: Writing – original draftRole: Writing – review & editing
                Role: Academic Editor
                Journal
                PLoS Med
                PLoS Med
                plos
                plosmed
                PLoS Medicine
                Public Library of Science (San Francisco, CA USA )
                1549-1277
                1549-1676
                14 November 2017
                November 2017
                : 14
                : 11
                : e1002428
                Affiliations
                [1 ] Division of Nephrology and Hypertension, Department of Internal Medicine, University of Cincinnati College of Medicine, Cincinnati, Ohio, United States of America
                [2 ] Division of Clinical Pharmacology, Cincinnati Children’s Hospital Medical Center, Cincinnati, Ohio, United States of America
                [3 ] Department of Pediatrics, University of Cincinnati College of Medicine, Cincinnati, Ohio, United States of America
                [4 ] Division of Biostatistics, Cincinnati Children’s Hospital Medical Center, Cincinnati, Ohio, United States of America
                [5 ] Office of Research and Standards, Office of Generic Drugs, Center for Drug Evaluation and Research, U.S. Food & Drug Administration, Silver Spring, Maryland, United States of America
                [6 ] Division of Transplantation, Department of Surgery, University of Cincinnati College of Medicine, Cincinnati, Ohio, United States of America
                [7 ] iC42 Clinical Research and Development, University of Colorado Anschutz Medical Campus, Aurora, Colorado, United States of America
                Royal Derby Hospital, UNITED KINGDOM
                Author notes

                I have read the journal's policy and the authors of this manuscript have the following competing interests: RRA serves on the following corporate advisory committees: SangStat Medical Corporation Pharmacy Advisory Board, Biogen Pharmaceutical Corporation, Anti-CD40 Ligand Scientific Advisory Board, Protein Design Labs, Abbott Pharmaceutical Corporation, Tristar Enterprises, Inc. Clinical Trials Committee, Fujisawa Clinical Pharmacy Advisory Board, Roche Clinical Pharmacy Advisory Board, Sanofi Genzyme Advisory Board and Speakers Bureau, and Veloxis Speakers Bureau, with Research Grants with Novartis and Bristol Myers Squibb. UC reports research grants with Astellas, BioRad, Biosensors, Biotronik, HepQuant, Novartis, Roche Diagnostics, Siemens Healthcare, Thermo-Fisher, Fujirebio, Veloxis, and Waters.

                Author information
                http://orcid.org/0000-0003-4835-9197
                http://orcid.org/0000-0002-8471-9826
                http://orcid.org/0000-0003-4280-0842
                http://orcid.org/0000-0003-1070-9315
                http://orcid.org/0000-0002-6413-4820
                Article
                PMEDICINE-D-17-00206
                10.1371/journal.pmed.1002428
                5685573
                29135993
                485b1b71-26a4-4119-8ddd-45791c7d87d2

                This is an open access article, free of all copyright, and may be freely reproduced, distributed, transmitted, modified, built upon, or otherwise used by anyone for any lawful purpose. The work is made available under the Creative Commons CC0 public domain dedication.

                History
                : 19 January 2017
                : 6 October 2017
                Page count
                Figures: 3, Tables: 5, Pages: 22
                Funding
                Funded by: funder-id http://dx.doi.org/10.13039/100000038, U.S. Food and Drug Administration;
                Award ID: U01FD004573
                Award Recipient :
                Funded by: funder-id http://dx.doi.org/10.13039/100006108, National Center for Advancing Translational Sciences;
                Award ID: 1UL1TR001425-01
                Award Recipient :
                On April 27, 2012, the FDA released RFA entitled Pharmacokinetic Studies of Tacrolimus in Patients 9U01 ( https://grants.nih.gov/grants/guide/rfa-files/RFA-FD-12- 021.html). Our team was awarded this U01 funded by the United States National Institutes of Health and the Food and Drug Administration: Office of Generic Drugs (U01 FD004573). The funders had no role in study design or data collection and analysis, decision to publish or preparations of the manuscript except that draft guidance documents (Food and Drug Administration. Draft Guidance on Tacrolimus 2014 [cited 2015 December 2]. Available from: http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM406344.pdf.) for analysis of average and scaled average bioequivalence were followed and the Food and Drug Administration independently performed confirmatory analyses of the primary endpoint and dissolution testing and provided comments on the manuscript.
                Categories
                Research Article
                Medicine and Health Sciences
                Surgical and Invasive Medical Procedures
                Digestive System Procedures
                Liver Transplantation
                Medicine and Health Sciences
                Surgical and Invasive Medical Procedures
                Transplantation
                Organ Transplantation
                Liver Transplantation
                Biology and Life Sciences
                Anatomy
                Renal System
                Kidneys
                Medicine and Health Sciences
                Anatomy
                Renal System
                Kidneys
                Medicine and Health Sciences
                Pharmacology
                Pharmacokinetics
                Medicine and Health Sciences
                Surgical and Invasive Medical Procedures
                Transplantation
                Organ Transplantation
                Renal Transplantation
                Medicine and Health Sciences
                Surgical and Invasive Medical Procedures
                Urinary System Procedures
                Renal Transplantation
                Research and Analysis Methods
                Research Design
                Clinical Research Design
                Adverse Events
                Medicine and Health Sciences
                Pharmacology
                Pharmacokinetics
                Drug Metabolism
                Medicine and Health Sciences
                Pharmaceutics
                Drug Therapy
                Drug Administration
                Biology and Life Sciences
                Biochemistry
                Metabolism
                Metabolites
                Custom metadata
                Data are available from Rachel Akers at the University of Cincinnati, Data Management Center, for researchers who meet the criteria for access to confidential data. Data are from the Pharmacokinetic Studies of Tacrolimus in Transplant Patients whose authors may be contacted at Rachel.akers@ 123456cchmc.org .

                Medicine
                Medicine

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