H2R
2 weeks ago
Center of Medicare: Yep, Pine is out, shortage, etc!!!
https://www.asrs.org/content/documents/aao-asrs-to-cms-re-pine-repackaged-avastin-discontinuation_final.pdf
October 16, 2024
Meena Seshamani, MD, PhD
Deputy Administrator and Director
Center for Medicare
Mailstop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244
VIA ELECTRONIC DELIVERY
Dear Deputy Administrator Seshamani,
The American Academy of Ophthalmology (the Academy)i and the American Society of
Retina Specialists (ASRS)ii are reaching out to provide notice and background around an
upcoming shortage of repackaged Avastin (bevacizumab), which could challenge
Medicare beneficiary access to sight-saving care. On October 11, Pine Pharmaceuticals,
which as far as we know is the largest supplier of repackaged Avastin in the US,
announced that they will be discontinuing production of all Avastin products (see
Appendix A for the discontinuation notice).
At this time, the company has informed our organizations that they have no plans to reenter the market and have only 2-3 weeks of supply remaining. Our organizations have
significant concerns regarding patient access to repackaged Avastin and negative
outcomes stemming from the abrupt discontinuation. We ask that CMS notify all
Medicare contractors, including traditional MACs and Medicare advantage plans, of
this critical medication supply disruption and urge a halt to step therapy and prior
authorization requirements for alternative ophthalmic anti-VEGF therapies to avoid
treatment delays.
Repackaged bevacizumab (Avastin) is the most commonly administered intravitreal drug
worldwide, and therefore a disruption to its availability has a major impact on patients.
This disruption is particularly concerning given the market share that Pine
Pharmaceuticals has as a repackaged Avastin supplier. For ophthalmologists, particularly
retina specialists, in need of repackaged Avastin for patient care, finding alternative
suppliers that can provide timely access will be a significant challenge. Other U.S. Food
and Drug Administration (FDA)-registered 503B outsourcing facilities, such as Leiters
Health, require new customers to go through an onboarding process before new orders
can be filled, which disrupts the normal flow of supply. Additionally, states such as
California have few outsourcing facilities with a license allowing them to ship to their
state.
Repackaged bevacizumab (Avastin) is a critically important treatment option for
ophthalmology patients facing sight-threatening diseases, including age-related macular
degeneration, macular edema, neovascular glaucoma and others. Avastin was first
approved by the Food and Drug Administration (FDA) to treat different types of cancer.
Its use in ophthalmology is considered an “off-label” use. This is the fourth major
disruption to supply of repackaged Avastin in the past five years. In 2019, the efforts of
Optum (formerly Avella) to align their testing procedures with 2018 FDA final guidance,
“Mixing, Diluting, or Repackaging Biological Products Outside the Scope of an Approved
Biologics License Application,” resulted in an extensive shortage. In 2021, Optum halted
production of repackaged Avastin due to out-of-specification test results on select
batches of the product. Last year, we experienced yet another disruption to repacked
Avastin production when there was a recall at Pine Pharmaceuticals due to concerns of
the FDA regarding a potential lack of sterility assurance.
Our top priority is to ensure our patients receive the highest quality care, including timely
access to treatments like repackaged Avastin and any clinically appropriate alternative
medications. Unexpected delays in receiving intravitreal anti-VEGF therapy has been
shown to result in vision loss across multiple conditions.iii That is why our organizations
have opposed existing step therapy policies, which interfere with the patient – physician
relationship and in cases of supply instability, can create significant challenges for
ophthalmology practices. Even when drug supply is stable, step therapy requirements
are administratively burdensome on a physician and their staff as they help patients
navigate complicated and often opaque coverage determination processes. Furthermore,
payor exemption and appeals processes can be complicated and lengthy, making them
onerous for strained physician practices and patients awaiting treatment.
Given the discontinuation by a major supplier and persistent access challenges in the
compounded drug marketplace, it would be appropriate to halt step therapy and prior
authorization requirements for repackaged Avastin alternatives. Facilitating access to
alternative therapies is critical for patient care and will be a significant help to our
ophthalmology practices. Additionally, if a patient must switch therapies due to the
current repackaged Avastin shortage, we believe patients should be allowed to continue
whichever clinically appropriate therapy they have been switched to if it is effectively
treating their disease after the shortage has concluded.
We hope that CMS will take whatever steps necessary within its authority to mitigate the
disruption to important sight-saving therapies. Our organizations welcome the
opportunity to work with you. If you have any questions and/or to coordinate a meeting,
please contact the Academy’s Director of Health Policy, Brandy Keys at bkeys@aao.org
or 202.587.5815, or ASRS’s Vice President of Health Policy, Allison Madson at
allison.madson[ @whosYOcaddy?.
Cc:
Cheri Rice, Deputy Director, Parts C and D, Center for Medicare
Sincerely,
Michael X. Repka, MD, MBA
Medical Director, Governmental Affairs
American Academy of Ophthalmology
Ankoor R. Shah, MD, FASRS
ASRS Practice Management
Committee Chair
i The American Academy of Ophthalmology is the largest association of eye physicians and
surgeons in the United States. A nationwide community of over 20,000 medical doctors, we
protect sight and empower lives by setting
the standards for ophthalmic education, supporting research, and advocating for our patients
and the public
ii ASRS is the largest retina organization in the world, representing over 3,000 board certified
ophthalmologists who have completed fellowship training in the medical and surgical
treatment of retinal diseases. The mission of the ASRS is to provide a collegial open forum for
education, to advance the understanding and treatment of vitreoretinal disease.
iii Song W, Singh RP, Rachitskaya AV. The Effect of Delay in Care among Patients Requiring
Intravitreal Injections. Ophthalmol Retina. 2021 Oct;5(10):975-980. doi:
10.1016/j.oret.2020.12.020. Epub 2021 Jan 1. PMID: 33395587
Appendix A: Discontinuation Notice
4
Subject: Discontinuation of Repackaged Bevacizumab
Dear Valued Customer,
We are writing to inform you of an important change in our product offerings. Effective
immediately, we are discontinuing manufacturing the below pharmaceutical products in
prefilled syringes.
ITEM DESCRIPTION
343 BEVACIZUMAB 1.25 MG/0.05 ML INJ - BD TB
963 BEVACIZUMAB 1.25MG/0.05ML INJ - SCLS MN
Prefilled syringes are designed with lubricants to ensure smooth plunger movement, which
is essential for proper function. However, any visible lubricant detected during quality
inspections necessitates the rejection of those units. Unfortunately, this has resulted in
unsustainable batch yields, which has contributed to our decision to discontinue this
product line.
We understand that the discontinuation of these syringes will cause a disruption in service,
and we want to express that this decision was not made lightly. We have truly honored the
opportunity to supply this drug for you and your patients over the last ten years and will
continue to distribute these products while our current supplies last.
We greatly appreciate your understanding and patience during this transition. Should you
have any questions or need further information, please do not hesitate to contact us at
844-218-4138 or support@pinepharmaceuticals.com.
Thank you for your understanding and continued partnership.
5
thermo
2 weeks ago
Outlook Therapeutics (OTLK) Buy, $50 PT
Capitulation from the Largest 503B Supplier of Off-Label Intravitreal Bevacizumab Bodes Well for Potential LYTENAVA Launch Next Year; Reiterate BUY
What You Should Know:
We spoke with two representatives from Pine Pharmaceuticals (Private) today, who confirmed that Pine discontinued all repackaged intravitreal bevacizumab products earlier in October. Based on our discussion with OTLK mgmt, it is believed that Pine previously accounted for 40% to 45% of all off-label intravitreal bevacizumab volume as the largest 503B supplier in the US. We view this as significant capitulation that reads through positively to the commercial potential of LYTENAVA (fka ONS-5010). We may see some indication from the FDA re: the agency's stance on compounding pharmacy regulation enforcement prior to LYTENAVA's potential launch next year, with additional clarity on tirzepatide's status (the lawsuit to follow is Outsourcing Facilities Association et al. v. FDA, docket #4:24-cv-00953-P). However, with major compounding pharmacies already bowing out of the intravitreal bevacizumab business, we think OTLK likely does not even need the FDA to clarify their stance on enforcement in order for LYTENAVA to be commercially successful.
...
Compounded bevacizumab is currently utilized by ~70% of retinal specialists in the US as 1L Tx for wet age-related macular degeneration (wAMD), yet remains subject to concerns surrounding quality and supply. We expect these concerns would be resolved with a pharmaceutical-grade, FDA-approved alternative.
...
===================
BTIG
To be clear, I'm not saying this is a buy, buy, buy moment. Financing overhang still dominates. But, once we get through that, the investment thesis looks compelling.