cumulatively Stratify by whether a Cardiovascular Adverse Event Reporting Form was received as a result of these ECHO changes or not
aKnown or suspected adverse events related to valvular heart disease or pulmonary hypertension are to be reported regardless of outcome Root cause analyses of whether periodic monitoring of ECHOs was followed per the Prescribing Information are to be included Provide an overall analysis and discussion of all cases identified from all sources (i-v) including but not limited to the following for each case drug discontinued due to cardiac toxicity pertinent clinical data ECHOs over time duration and dose of Fintepla used treatment required and clinical outcome Sources of the data (including but not limited to) i Patient Status Form ii Cardiovascular Adverse Event Reporting Form iii Spontaneous adverse event reports iv Literature searches v Social media
2 Lennox Gastaut Syndrome Foundation b Include an overall analysis and discussion on information collected on the Patient Status Form and Cardiovascular Adverse Event Reporting Form which further assess the registry data with respect to safe use Provide data in tabular format Provide a unique identifier for patients so that changes over the course of subsequent REMS reports can be tracked
i Number of reported unique cases and unique patients with changes in the ECHO or abnormal ECHO
ii Of those stratify to include for both cases and patients 1 Type of Cardiac Finding (VHD PAH Other New Abnormality) as characterized on the Cardiovascular Adverse Event Reporting Form
o Number of cases reporting specific valve involved sorted by type (mitral aortic tricuspid pulmonic)
o Classification of regurgitation on ECHO at the time the change occurred (mild moderate severe)
NDA 212102 Page 19
o Number of cases reporting Restricted Valve Motion sorted by valve type
o Number of cases reporting Valve Thickening sorted by valve type
o Number of cases reporting Patient Symptomatic
o Number of cases reporting Signs on Physical Exam
o Number of cases reporting patient is on Stiripentol
o Patient Age (Mean Range)
o Patient Age group (group by lt 2 years of age 2-5 6-11 12-17 17 and older)
o Total Dose (Mean Range)
o Daily Dose (mgkgday)
o BMI (group by Underweight Normal Overweight and Obese based on CDC definitions for children)
o Cumulative Time to Event Analysis stratified by Patient Age Total Dose (Mean Range) Daily Dose (mgkgday)
o Event Outcome stratified by age dosing symptomaticsigns to include
Number of cases requiring hospitalization
Number of cases requiring medication or interventional therapy
Number of cases reporting death
Number of cases reporting discontinuation of treatment due to CV AE
3 Of the reported cases of elevated pulmonary arterial systolic pressure (PASP gt 35 mm Hg) stratify to include
o Number of cases reporting ECHO findings of PAH sorted by Interventricular septal flattening Elevated right heartpulmonary artery pressure (pulmonary artery systolic pressure gt35 mm Hg) Other
US Food and Drug AdministrationSilver Spring MD 20993 wwwfdagov
Reference ID 4631810
NDA 212102 Page 20
o Of those with Elevated right heartpulmonary artery pressure (pulmonary artery systolic pressure gt35 mm Hg)
Mean Max and Min PASP reading (mm Hg)
o Number of cases reporting Patient Symptomatic
o Number of cases reporting Signs on Physical Exam
o Number of cases reporting patient is on Stiripentol
o Patient Age (Mean Range)
o Total Dose (Mean Range)
o Daily Dose (mgkgday)
o Cumulative Time to Event Analysis stratified by Patient Age Total Dose (Mean Range) Daily Dose (mgkgday)
o Event Outcome stratified by age dosing reporting symptomaticsigns to include
Number of cases requiring hospitalization
Number of cases requiring medication or interventional therapy
Number of cases reporting death
Number of cases reporting discontinuation of treatment due to CV AE
4 Of the Other new abnormality on ECHO (not previously reported) stratify to include
o Specified Reported Event Terms on AE Form
o Number reporting Patient Symptomatic
o Number reporting Signs on Physical Exam
o Number reporting patient is on Stiripentol
o Age (Mean Range)
o Total Dose (Mean Range)
o Daily Dose (mgkgday)
US Food and Drug AdministrationSilver Spring MD 20993 wwwfdagov
Reference ID 4631810
NDA 212102 Page 21
o Cumulative Time to Event Analysis stratified by Patient Age Total Dose (Mean Range) Daily Dose (mgkgday)
o Event Outcome stratified by age dosing reporting symptomaticsigns to include
Number of cases requiring hospitalization
Number of cases requiring medication or interventional therapy
Number of cases reporting death
Number of cases reporting discontinuation of treatment due to CV AE
c Include an overall summary and discussion of whether the data warrants further detailed assessment labeling changes andor communication
12The requirements for assessments of an approved REMS under section 505-1(g)(3) include with respect to each goal included in the strategy an assessment of the extent to which the approved strategy including each element of the strategy is meeting the goal or whether one or more such goals or such elements should be modified
We remind you that in addition to the REMS assessments submitted according to the timetable in the approved REMS you must include an adequate rationale to support a proposed REMS modification for the addition modification or removal of any goal or element of the REMS as described in section 505-1(g)(4) of the FDCA
We also remind you that you must submit a REMS assessment when you submit a supplemental application for a new indication for use as described in section 505-1(g)(2)(A) This assessment should include
a) An evaluation of how the benefit-risk profile will or will not change with the new indication
b) A determination of the implications of a change in the benefit-risk profile for the current REMS
US Food and Drug AdministrationSilver Spring MD 20993 wwwfdagov
Reference ID 4631810
NDA 212102 Page 22
c) If the new proposed indication for use introduces unexpected risks A description of those risks and an evaluation of whether those risks can be appropriately managed with the currently approved REMS
d) If a REMS assessment was submitted in the 18 months prior to submission of the supplemental application for a new indication for use A statement about whether the REMS was meeting its goals at the time of the last assessment and if any modifications of the REMS have been proposed since that assessment
e) If a REMS assessment has not been submitted in the 18 months prior to submission of the supplemental application for a new indication for use Provision of as many of the currently listed assessment plan items as is feasible
f) If you propose a REMS modification based on a change in the benefit-risk profile or because of the new indication of use submit an adequate rationale to support the modification including Provision of the reason(s) why the proposed REMS modification is necessary the potential effect on the serious risk(s) for which the REMS was required on patient access to the drug andor on the burden on the health care delivery system and other appropriate evidence or data to support the proposed change Additionally include any changes to the assessment plan necessary to assess the proposed modified REMS If you are not proposing a REMS modification provide a rationale for why the REMS does not need to be modified
If the assessment instruments and methodology for your REMS assessments are not included in the REMS supporting document or if you propose changes to the submitted assessment instruments or methodology you should update the REMS supporting document to include specific assessment instrument and methodology information at least 90 days before the assessments will be conducted Updates to the REMS supporting document may be included in a new document that references previous REMS supporting document submission(s) for unchanged portions Alternatively updates may be made by modifying the complete previous REMS supporting document with all changes marked and highlighted Prominently identify the submission containing the assessment instruments and methodology with the following wording in bold capital letters at the top of the first page of the submission
NDA 212102 REMS ASSESSMENT METHODOLOGY(insert concise description of content in bold capital letters eg ASSESSMENT METHODOLOGY PROTOCOL SURVEY METHODOLOGIES AUDIT PLAN DRUG USE STUDY)
An authorized generic drug under this NDA must have an approved REMS prior to marketing Should you decide to market sell or distribute an authorized generic drug
US Food and Drug AdministrationSilver Spring MD 20993 wwwfdagov
Reference ID 4631810
NDA 212102 Page 23
under this NDA contact us to discuss what will be required in the authorized generic drug REMS submission
We remind you that section 505-1(f)(8) of FDCA prohibits holders of an approved covered application with elements to assure safe use from using any element to block or delay approval of an application under section 505(b)(2) or (j) A violation of this provision in 505-1(f) could result in enforcement action
Prominently identify any submission containing the REMS assessments or proposed modifications of the REMS with the following wording in bold capital letters at the top of the first page of the submission as appropriate
NDABLA 212102 REMS ASSESSMENT
NEW SUPPLEMENT FOR NDA 212102S-000CHANGES BEING EFFECTED IN 30 DAYSPROPOSED MINOR REMS MODIFICATION
or
NEW SUPPLEMENT FOR NDA 212102S-000PRIOR APPROVAL SUPPLEMENTPROPOSED MAJOR REMS MODIFICATION
or
NEW SUPPLEMENT FOR NDA 212102S-000PRIOR APPROVAL SUPPLEMENT PROPOSED REMS MODIFICATIONS DUE TO SAFETY LABELING CHANGES SUBMITTED IN SUPPLEMENT XXX
or
NEW SUPPLEMENT (NEW INDICATION FOR USE)FOR NDA 212102S-000REMS ASSESSMENT
PROPOSED REMS MODIFICATION (if included)
Should you choose to submit a REMS revision prominently identify the submission containing the REMS revisions with the following wording in bold capital letters at the top of the first page of the submission
REMS REVISION FOR NDA 212102
US Food and Drug AdministrationSilver Spring MD 20993 wwwfdagov
Reference ID 4631810
NDA 212102 Page 24
To facilitate review of your submission we request that you submit your proposed modified REMS and other REMS-related materials in Microsoft Word format If certain documents such as enrollment forms are only in PDF format they may be submitted as such but the preference is to include as many as possible in Word format
SUBMISSION OF REMS DOCUMENT IN SPL FORMAT
FDA can accept the REMS document in Structured Product Labeling (SPL) format If you intend to submit the REMS document in SPL format as soon as possible but no later than 14 days from the date of this letter submit the REMS document in SPL format using the FDA automated drug registration and listing system (eLIST)
For more information on submitting REMS in SPL format please email FDAREMSwebsitefdahhsgov
REQUESTED PHARMACOVIGILANCE
We request that you perform postmarketing surveillance for cases of valvular heart disease and pulmonary arterial hypertension in patients exposed to Fintepla Submit individual reports as 15-day expedited reports to your NDA and directly to the Division of Neurology 2 Include comprehensive summaries and analyses of these events quarterly as part of your required postmarketing safety reports (eg periodic safety update reports [PSURs]) In the analysis of each case provide an assessment of causality with documentation of risk factors and results of all assessments that support the diagnosis (eg ECHO reports pulmonary hemodynamic parameters) or the causality along with information about dose and dose titration duration of Fintepla therapy time of event in relation to duration of therapy associated signs and symptoms concomitant therapies treatment given for the event and outcome of each event
PROMOTIONAL MATERIALS
You may request advisory comments on proposed introductory advertising and promotional labeling For information about submitting promotional materials see the final guidance for industry Providing Regulatory Submissions in Electronic and Non-Electronic FormatmdashPromotional Labeling and Advertising Materials for Human Prescription Drugs6
As required under 21 CFR 31481(b)(3)(i) you must submit final promotional materials and the Prescribing Information at the time of initial dissemination or publication accompanied by a Form FDA 2253 Form FDA 2253 is available at FDAgov7 Information and Instructions for completing the form can be found at FDAgov8
6 For the most recent version of a guidance check the FDA guidance web page at httpswwwfdagovmedia128163download 7 httpwwwfdagovdownloadsAboutFDAReportsManualsFormsFormsUCM083570pdf 8 httpwwwfdagovdownloadsAboutFDAReportsManualsFormsFormsUCM375154pdf US Food and Drug AdministrationSilver Spring MD 20993 wwwfdagov
Reference ID 4631810
NDA 212102 Page 25
REPORTING REQUIREMENTS
We remind you that you must comply with reporting requirements for an approved NDA (21 CFR 31480 and 31481)
If you have any questions call Stephanie N Parncutt MHA Senior Regulatory Health Project Manager at (301) 796-4098 or email at StephanieParncuttfdahhsgov
Sincerely
See appended electronic signature page
Nick Kozauer MD Acting Director Division of Neurology 2 Office of Neuroscience Center for Drug Evaluation and Research
ENCLOSURE(S) x Content of Labeling
o Prescribing Information o Medication Guide o Instructions for Use
x REMS
US Food and Drug AdministrationSilver Spring MD 20993 wwwfdagov
Reference ID 4631810
--------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------
------------------------------------------------------------
(
Signature Page 1 of 1
This is a representation of an electronic record that was signed electronically Following this are manifestations of any and all electronic signatures for this electronic record
s
NICHOLAS A KOZAUER 06252020 064349 PM
Reference ID 4631810