Summary Basis of Decision for Eliquis

Review decision

The Summary Basis of Decision explains why the product was approved for sale in Canada. The document includes regulatory, safety, effectiveness and quality (in terms of chemistry and manufacturing) considerations.


Product type:

Drug
Eliquis

Apixaban, 2.5 mg, Tablet, Oral

Bristol-Myers Squibb Canada

Submission control no: 141873

Date issued: 2012-04-26

Foreword

Health Canada's Summary Basis of Decision (SBD) documents outline the scientific and regulatory considerations that factor into Health Canada regulatory decisions related to drugs and medical devices. SBDs are written in technical language for stakeholders interested in product-specific Health Canada decisions, and are a direct reflection of observations detailed within the evaluation reports. As such, SBDs are intended to complement and not duplicate information provided within the Product Monograph.

Readers are encouraged to consult the 'Reader's Guide to the Summary Basis of Decision - Drugs' to assist with interpretation of terms and acronyms referred to herein. In addition, a brief overview of the drug submission review process is provided in the Fact Sheet entitled 'How Drugs are Reviewed in Canada'. This Fact Sheet describes the factors considered by Health Canada during the review and authorization process of a drug submission. Readers should also consult the 'Summary Basis of Decision Initiative - Frequently Asked Questions' document.

The SBD reflects the information available to Health Canada regulators at the time a decision has been rendered. Subsequent submissions reviewed for additional uses will not be captured under Phase I of the SBD implementation strategy. For up-to-date information on a particular product, readers should refer to the most recent Product Monograph for a product. Health Canada provides information related to post-market warnings or advisories as a result of adverse events (AE).

For further information on a particular product, readers may also access websites of other regulatory jurisdictions. The information received in support of a Canadian drug submission may not be identical to that received by other jurisdictions.

Other Policies and Guidance

Readers should consult the Health Canada website for other drug policies and guidance documents. In particular, readers may wish to refer to the 'Management of Drug Submissions Guidance'.

1 Product and submission information

Brand name:

Eliquis

Manufacturer/sponsor:

Bristol-Myers Squibb Canada

Medicinal ingredient:

Apixaban

International non-proprietary Name:

Apixaban

Strength:

2.5 mg

Dosage form:

Tablet

Route of administration:

Oral

Drug identification number(DIN):

  • 02377233

Therapeutic Classification:

Anticoagulant

Non-medicinal ingredients:

Anhydrous lactose, microcrystalline cellulose, croscarmellose, sodium, sodium laurylsulfate magnesium stearate, lactose monohydrate, hypromellose, titanium dioxide, triacetin, yellow iron oxide

Submission type and control no:

New Drug Submission, Control Number: 141873

Date of Submission:

2010-10-05

Date of authorization:

2011-12-16
2 Notice of decision

On December 16, 2011, Health Canada issued a Notice of Compliance to Bristol-Myers Squibb Canada for the drug product, Eliquis.

Eliquis contains the medicinal ingredient apixaban which is an anticoagulant (direct factor Xa inhibitor).

Eliquis is indicated for the prevention of venous thromboembolic events (VTE) in adult patients who have undergone elective knee or hip replacement surgery. Apixaban inhibits free and clotbound factor Xa, and prothrombinase activity. Apixaban indirectly inhibits platelet aggregation induced by thrombin derived from the upstream proteases in the blood coagulation cascade.

The market authorization was based on quality, non-clinical, and clinical information submitted. The efficacy and safety of Eliquis was evaluated in three pivotal double-blind multinational Phase III studies with patients who had undergone major orthopaedic surgery. The use of Eliquis 2.5 mg twice a day (BID) was compared to the gold standard for VTE prevention, enoxaparin. In two of these studies, the non-North American regimen for enoxaparin was used, 40 mg once daily (OD). In Canada (and the United States), the recommended regimen for enoxaparin for this indication is 30 mg BID, which results in a 50% higher daily exposure to enoxaparin. In the pivotal study with the Canadian enoxaparin regimen as control, Eliquis did not meet the prespecified statistical criteria for non-inferiority. However, its use was associated with lower rates of clinically relevant bleeding. In the other two studies using the non-North American enoxaparin regimen in the control group, Eliquis showed superiority over enoxaparin, without increasing bleeding.

Eliquis (2.5 mg apixaban) is presented as tablets. The recommended dose of Eliquis for VTE prevention in patients following elective hip and knee replacement surgery is 2.5 mg twice daily. Eliquis can be taken with or without food. The initial dose should be taken 12 to 24 hours after surgery. In patients undergoing hip replacement surgery, the recommended duration of treatment is 32 to 38 days. In patients undergoing knee replacement surgery, the recommended duration of treatment is 10 to 14 days. Dosing guidelines are available in the Product Monograph.

Eliquis is contraindicated for patients who have clinically significant active bleeding; and for patients who have lesions at increased risk of clinically significant bleeding, including cerebral infarct (ischaemic or haemorrhagic) in the previous 6 months; and patients with spontaneous impairment of haemostasis. Eliquis is also contraindicated in patients who have a hepatic disease associated with coagulopathy and a clinically relevant bleeding risk; patients who have concomitant systemic treatment with strong inhibitors of both cytochrome P450 (CYP) 3A4 and P-glycoprotein; as well as patients who have a hypersensitivity to apixaban or to any of the ingredients of the formulation. Eliquis should be administered under the conditions stated in the Product Monograph taking into consideration the potential risks associated with the administration of this drug product. Detailed conditions for the use of Eliquis are described in the Product Monograph.

Based on the Health Canada review of data on quality, safety, and efficacy, Health Canada considers that the benefit/risk profile of Eliquis is favourable for the prevention of venous thromboembolic events (VTE) in adult patients who have undergone elective knee or hip replacement surgery.

3 Scientific and Regulatory Basis for Decision

3.1 Quality Basis for Decision

3.1.1 Drug Substance (Medicinal Ingredient)

General Information

Apixaban, the medicinal ingredient of Eliquis, is an anticoagulant that acts by selectively and reversibly inhibiting human coagulation factor Xa.

Factor Xa (FXa) is the common downstream effector of the intrinsic and extrinsic pathways of the coagulation cascade, and is the only mediator of thrombin formation. Thrombin acts on fibrin formation and activates platelets, making it a key mediator of thrombosis in both the venous and arterial circulation.

Manufacturing Process and Process Controls

Apixaban is manufactured via a multi-step synthesis. Each step of the manufacturing process is considered to be controlled within acceptable limits:

  • The sponsor has provided information on the quality and controls for all materials used in the manufacture of the drug substance.
  • The drug substance specifications were found to be satisfactory. Impurity limits meet International Conference on Harmonisation (ICH) requirements.
  • The processing steps have been evaluated and the appropriate ranges for process parameters have been established.
Characterization

The route of synthesis of apixaban supports the chemical structure assigned. Confirmation of the chemical structure was provided by elemental analysis and spectroscopic analysis.

Appropriate tests are adequately controlling the levels of product- and process-related impurities.

Control of Drug Substance

The drug substance specifications and analytical methods used for quality control of apixaban are considered acceptable.

Validation reports are considered satisfactory for all analytical procedures used for inprocess and release testing of the drug substance.

Batch analysis results were reviewed and all results comply with the specifications and demonstrate consistent quality of the batches produced.

The proposed packaging components are considered acceptable.

Stability

Based on the long-term, real-time, and accelerated stability data submitted, the proposed retest period for the drug substance were supported and are considered satisfactory.

3.1.2 Drug Product

Description and Composition

Eliquis film-coated tablets contain 2.5 mg of the drug substance, apixaban. The tablets are yellow and round and debossed with "893" on one side and "2½" on the other side. The tablets are supplied in blisters of 10, 20, 60, or 100 tablets.

The tablet core contains the following non-medicinal ingredients: anhydrous lactose; microcrystalline cellulose; croscarmellose sodium; sodium lauryl sulphate; and magnesium stearate. The coating of the tablet contains lactose monohydrate, hypromellose, titanium dioxide, triacetin, and yellow iron oxide.

All non-medicinal ingredients (excipients) found in the drug product are acceptable for use in drugs according to the Food and Drug Regulations. The compatibility of apixaban with the excipients is demonstrated by the stability data presented on the proposed commercial formulation.

Pharmaceutical Development

Changes to the manufacturing process and formulation made throughout the pharmaceutical development are considered acceptable upon review.

Manufacturing Process and Process Controls

All manufacturing equipment, in-process manufacturing steps, and detailed operating parameters were adequately described in the submitted documentation and were found to be acceptable. The manufacturing process is considered to be adequately controlled within justified limits.

Control of Drug Product

Eliquis is tested to verify that its identity, appearance, content uniformity, assay, disintegration, and levels of degradation products, drug-related impurities, and microbiological impurities are within acceptance criteria. The test specifications and analytical methods are considered acceptable; the shelf-life and the release limits, for individual and total degradation products, are within acceptable limits.

Copies of the analytical methods and, where appropriate, validation reports were provided and are considered satisfactory for all analytical procedures used for release and stability testing of Eliquis.

Data from batch analyses were reviewed and are considered acceptable according to the specifications of the product.

Stability

Based on the real-time, long-term, and accelerated stability data submitted, the proposed 36-month shelf-life at 15-30°C for Eliquis is considered acceptable.

The compatibility of the drug product with the container closure system was demonstrated through stability studies. The container closure system met all validation test acceptance criteria.

3.1.3 Facilities and Equipment

The design, operations, and controls of the facilities and equipment that are involved in the production of Eliquis are considered suitable for the activities and products manufactured.

3.1.4 Adventitious Agents Safety Evaluation

The excipients, anhydrous lactose and lactose monohydrate, are sourced from bovine milk that is fit for human consumption and is unlikely to present any risk of transmissible spongiform encephalopathy (TSE) contamination. Magnesium stearate is of vegetable origin.

3.1.5 Conclusion

The Chemistry and Manufacturing information submitted for Eliquis has demonstrated that the drug substance and drug product can be consistently manufactured to meet the approved specifications. Proper development and validation studies were conducted, and adequate controls are in place for the commercial processes.

3.2 Non-Clinical Basis for Decision

In order to support the human use of apixaban, a comprehensive set of non-clinical studies, including pharmacodynamic, safety pharmacology, pharmacokinetic, and toxicology studies were undertaken in different rodent and non-rodent models, and humans. This non-clinical program followed the relevant ICH guidelines and the major studies were compliant to Good Laboratory Practices.

3.2.1 Pharmacodynamics

The mode of action and safety of apixaban were demonstrated through a series of in vitro and in vivo experiments. Apixaban was very selective for factor Xa (FXa) and acted at different levels by inhibiting free human FXa, FXa in the prothrombinase complex, and clot-bound FXa, as well as tissue-factor induced platelet aggregation. Apixaban also dose-dependently decreased thrombus weight in different models (rat, rabbit, and dog) of venous thrombosis. At concentrations above the recommended human dose, apixaban neither inhibited human Ether-à-go-go-Related Gene (hERG) current nor affected cardiac action potentials in vitro. Apixaban had no effect on cardiovascular parameters in vivo suggesting low potential to trigger long QT syndrome. In addition, apixaban did not affect renal and hepatic functions in vivo.

3.2.2 Pharmacokinetics

Absorption

In rats, apixaban was rapidly absorbed throughout the intestinal tract.

In dogs, a dose volume of 1 mL/kg and a particle size of 32 µm gave the best exposure. Gender differences in exposure to apixaban were reported in dogs.

Distribution

In mice, apixaban showed low to moderate serum protein binding.

Apixaban was transported by permeability-glycoprotein (P-gp) and breast cancer resistance protein (BCRP) transporters and its transport was not saturated at concentrations up to 100 µM.

After oral administration in rats, apixaban was widely distributed with the highest concentration found in the gastrointestinal (GI) tract followed by adrenal glands, liver, thyroid, and urinary bladder. The lowest concentration was found in the brain.

Oral administration of apixaban to pregnant mice and rats resulted in embryonic exposure of approximately 9-10% of the maternal exposure values. Apixaban was detected in all foetal tissues and blood. In addition, apixaban was detected in the umbilical cord plasma in rabbits. Apixaban was also found in the milk of lactating rats after oral administration.

Metabolism

In mice, rats, and dogs, there was little metabolism of apixaban (<13% of apixaban was metabolized). In rabbits, after oral and intravenous (IV) administration, apixaban was extensively metabolized, with apixaban representing <10% of the recovered sample.

Metabolism of apixaban occurred in the liver and not in the kidney. The metabolism pathway included O-demethylation, sulphate conjugation, hydroxylation, mono-oxidation, and hydrolysis.

Only 6 metabolites were formed after incubating apixaban with human hepatocytes. The major metabolite M1, the sulphate conjugate of O-demethyl apixaban, did not contribute to apixaban's pharmacological activity.

When studied with pooled human liver microsomes, apixaban was metabolized mainly by the cytochrome P450 (CYP) enzymes CYP3A4/3A5. Minor contributions of CYP1A2, CYP2C8, CYP2C9, CYP2C19, and CYP2J2 were reported. Apixaban neither induced nor inhibited the activity of many CYP enzymes.

Only 6 metabolites were formed after incubating apixaban with human hepatocytes. The major metabolite M1, the sulphate conjugate of O-demethyl apixaban, did not contribute to apixaban's pharmacological activity.

When studied with pooled human liver microsomes, apixaban was metabolized mainly by the cytochrome P450 (CYP) enzymes CYP3A4/3A5. Minor contributions of CYP1A2, CYP2C8, CYP2C9, CYP2C19, and CYP2J2 were reported. Apixaban neither induced nor inhibited the activity of many CYP enzymes.

Excretion

In mice, dogs, and rats, apixaban was the main drug-related component excreted. Low recoveries of apixaban were reported in rabbits.

Following oral administration in rats, mice, dogs, and rabbits, apixaban was mainly excreted through the faeces. There were small and very minor contributions of the renal and biliary routes. In rats, apixaban was also directly excreted into the intestine.

3.2.3 Toxicology

Single-Dose Toxicity

Apixaban had a low order of acute toxicity. Single-oral doses in mice (≤4,000 mg/kg), rats (≤4,510 mg/kg), or dogs (≤1,500 mg/kg) produced no mortality and were welltolerated.

Repeat-Dose Toxicity

In mice, rats, and dogs following repeat-dosing, apixaban was clinically well-tolerated, and there were no target organs of toxicity identified. The highest doses tested in the chronic toxicity studies were the no-observed-adverse-event-level (NOAEL) doses of 600 mg/kg/day and 100 mg/kg/day in the 6-month rat and the 1-year dog studies, respectively. Mild to moderate prolongations of prothrombin time (PT) and activated partial thromboplastin time (aPTT) occurred in the repeat-dose oral and IV studies, representing effects consistent with the pharmacology of FXa inhibition. Bleeding times were also increased in rats and dogs (evaluated only in 3-month oral studies). In general, overt haemorrhages were not evident in association with the prolongations of PT and aPTT. At the highest doses tested (600 mg/kg/day in rats, 100 mg/kg/day in dogs), no target organs of toxicity, including the liver were identified. There was no overt bleeding or haemorrhage and the drug exposure area under the curve (AUC) values in rats and dogs were 30 times and 114 times, respectively, the AUC at the recommended human dose of 5 mg [2.5 mg twice a day (BID)].

Mutagencity

Apixaban was not mutagenic in the in vitro bacterial reverse mutation (Ames) assay, not clastogenic in vitro (cytogenetics assay in Chinese hamster ovary cells) or in vivo (1-month in vivo/in vitro cytogenetics study in rat peripheral blood lymphocytes), and showed no evidence of genotoxicity in a micronucleus study in rats.

Carcinogenicity

Apixaban was not carcinogenic in mice that were given ≤3,000 mg/kg or in rats that were given ≤600 mg/kg for 2 years. There were no treatment-related non-neoplastic pathologic changes in either species. The AUC values were ≤30 times the AUC levels obtained at the recommended human dose.

Reproductive and Developmental Toxicity

Apixaban at doses ≤600 mg/kg had little effect on maternal, foetal, and litter parameters when female rats were exposed to apixaban from premating to early organogenesis. However, when apixaban was given during implantation to parturition, at doses ≥200 mg/kg/day (36 times the AUC at the human therapeutic dose), apixaban decreased the mating and fertility indices in first filial (F1) generation females. Apixaban had no effect on the reproductive performance of F1-generation males. However, these indices are within historical ranges of fertility and hence changes in fertility are unlikely to be seen in humans suggesting that apixaban is safe in terms of reproductive and developmental toxicity.

3.2.4 Summary and Conclusion

The non-clinical studies for this drug submission are considered acceptable. The nonclinical pharmacology and toxicology program for Eliquis (apixaban) demonstrated that the compound is relatively safe for the present short-term indication. Adequate statements are in place in the Product Monograph to address the identified safety concerns.

3.3 Clinical basis for decision

3.3.1 Pharmacodynamics

The clinical studies showed a direct linear relationship between the anti-FXa activity and the plasma apixaban concentration. The pharmacodynamic effects included the prolongation of blood clotting tests such as PT, International Normalized Ratio (INR) and aPTT, as well as inhibition of FXa activity and ex vivo thrombin generation.

Single IV doses of apixaban up to 5 mg were safe and well-tolerated in healthy subjects.

Apixaban at oral doses of 10 mg once a day (QD) and 50 mg QD for 3 days had no effect on QTc interval and were safe and well-tolerated in healthy subjects.

3.3.2 Pharmacokinetics

Absorption

Apixaban was rapidly absorbed with maximum plasma concentrations (Cmax) appearing 3 to 4 hours after tablet intake. Intake with food did not affect apixaban exposure (AUC) or Cmax at the 10 mg dose. Apixaban demonstrated linear pharmacokinetics with doseproportional increases in exposure for oral doses up to 10 mg.

The absolute bioavailability of apixaban was approximately 50% for doses up to 10 mg.

Distribution

The volume of distribution at steady state was approximately 21 litres.

Average plasma protein binding in humans was approximately 87%.

Metabolism

Unchanged apixaban was the main drug-related circulating component in plasma representing 66-72% of the sample. No active circulating metabolites were present.

O-demethylation and hydroxylation at the 3-oxopiperidinyl moiety were the major sites of biotransformation. Apixaban was metabolized mainly by CYP3A4/3A5 enzymes. Minor contributions of CYP1A2, CYP2C8, CYP2C9, CYP2C19, and CYP2J2 enzymes were reported.

Excretion

After IV administration, apixaban had a total clearance (CL) and renal clearance (RCL) of 3.3 L/h and 0.9 L/h, respectively.

Faecal and urinary excretion accounted for 46.7-56.0% and 24.5-28.8%, respectively, of the dose. In urine and faeces, apixaban was the main drug-related component (21.5-34.5% of the dose); all other metabolites accounted for ≤5.09% of the dose. Biliary excretion was only a minor elimination pathway (2.44% of the dose).

Special Populations
Hepatic Impairment

In a study comparing 16 subjects with mild and moderate hepatic impairment (classified as Child Pugh A and B, respectively) to 16 healthy control subjects, the single-dose pharmacokinetics and pharmacodynamics of apixaban 5 mg were not altered in subjects with hepatic impairment. Changes in anti-FXa activity and INR were comparable between patients with mild to moderate hepatic impairment and healthy subjects. No dose adjustment is required in patients with mild or moderate hepatic impairment; however, given the limited number of patients studied, caution is advised when using Eliquis in this population. Patients with severe hepatic impairment were not studied. Therefore, apixaban is not recommended in patients with severe hepatic impairment.

Renal Impairment

Apixaban exposure gradually increased with increased degrees of renal impairment. Renal impairment did not affect the relationship between apixaban plasma concentration and anti-FXa activity or INR. No dose adjustment is necessary in patients with mild or moderate renal impairment. Limited clinical data in patients with severe renal impairment indicate that apixaban plasma concentrations are increased; therefore, apixaban is to be used with caution in these patients because of a potential higher risk of bleeding.

Drug Interactions

Co-administration of apixaban with ketoconazole (400 mg once a day), a strong inhibitor of CYP3A4 and P-gp, led to a 2-fold increase in mean apixaban AUC and a 1.6-fold increase in apixaban Cmax. Therefore, the use of Eliquis is contraindicated in patients receiving concomitant systemic treatment with strong inhibitors of both CYP3A4 and Pgp.

Strong inducers of both CYP3A4 and P-gp should be co-administered with caution.

3.3.3 Clinical Efficacy

The efficacy and safety of Eliquis was evaluated in three pivotal double-blind multinational Phase III studies with 11,659 patients who had undergone major orthopaedic surgery (total hip replacement or total knee replacement). The three pivotal studies were part of the ADVANCE (Clinical Research trial to evaluate Apixaban Dosed orally Versus ANtiCoagulation with injectable Enoxaparin) 1, 2 and 3 clinical studies programme. The use of Eliquis 2.5 mg BID was compared to the gold standard for the prevention of venous thromboembolic events (VTE), enoxaparin. In two of the studies (ADVANCE-2 and ADVANCE-3), the non-North American regimen for enoxaparin was used, 40 mg once daily (OD). In Canada (and for knee replacement in the United States), the recommended regimen for enoxaparin for this indication is 30 mg BID, which results in a 50% higher daily exposure to enoxaparin. Only one of the Phase III studies (ADVANCE-1) used the latter dose of enoxaparin as the active control. A total of 3,195 patients were randomized in the ADVANCE-1 study.

All three studies had the same primary efficacy endpoint, the composite of all VTE and all-cause death. All VTE included symptomatic and asymptomatic distal or proximal deep vein thrombosis (DVT), and non-fatal pulmonary embolism (PE). In order to detect asymptomatic DVT, bilateral ascending venography at the end of the treatment period was mandatory.

In the two studies that used the non-North American regimen for enoxaparin (40 mg OD) as the active control, Eliquis showed superiority over enoxaparin, without increasing bleeding. In the ADVANCE-3 study, the rate of the primary endpoint was 1.39% for Eliquis and 3.86% for enoxaparin. In the ADVANCE-2 study, the total VTE and allcause death, was 15.06% for Eliquis and 24.37% for enoxaparin.

In the pivotal study with the Canadian enoxaparin regimen as a control (ADVANCE-1), Eliquis did not meet the pre-specified statistical criteria for non-inferiority. However, its use was associated with lower rates of clinically relevant bleeding. In the ADVANCE-1 study, the total VTE and all-cause death endpoint was 8.99% for Eliquis and 8.85% for enoxaparin. A plausible explanation for the failure of Eliquis in ADVANCE-1 with enoxaparin 30 mg BID as the active control, compared to its success in ADVANCE-2 and ADVANCE-3, is the obvious difference in enoxaparin daily dose. The dose of enoxaparin 30 mg BID represents a 50% higher daily dose compared to 40 mg OD. Whether this higher enoxaparin dose translates into higher efficacy is not very welldocumented, but seems reasonable when one looks at the results of other documented studies that suggest a greater effectiveness of enoxaprin 30 mg BID compared to 40 mg OD. In these studies, the 30 mg BID regimen prevented more thrombo-embolic events than 40 mg OD, but also caused more bleeding complications.

Another aspect of the three pivotal studies that needs to be considered concerns the differences in timing of the first dose of anticoagulant in relationship with the actual surgery. In the ADVANCE-2 and ADVANCE-3 studies, enoxaparin was started as its label indicates, that is 9-15 hours before surgery, while Eliquis was started 12-24 hours post-surgery. One might expect from these differences that enoxaparin would come outmore effective because of a longer duration of DVT protection, but with more perioperative bleeding events. Yet Eliquis turned out to be more effective, without raising the overall incidence of major and clinically relevant non-major (CRNM) bleeding. In the ADVANCE-1 study, both Eliquis and enoxaparin were started 12 to 24 hours postsurgery.

In conclusion, Eliquis 2.5 mg BID given 12-24 hours after surgery was more efficacious than enoxaparin 40 mg QD initiated 9-15 hours before surgery, and approached the efficacy of enoxaparin 30 mg BID initiated 12-24 hours after surgery, without worsening bleeding, and in comparison with enoxaparin 30 mg BID Eliquis appeared to lower major and CRNM bleeding.

3.3.4 Clinical Safety

The safety of Eliquis 2.5 mg BID was evaluated in the Phase II dose-finding study and the three Phase III studies (ADVANCE 1, 2, and 3). In total, 5,924 patients were exposed to Eliquis after undergoing major orthopaedic surgery of the lower limbs (elective hip replacement or elective knee replacement) and treated for up to 38 days.

The adverse event (AE) profile of Eliquis in the four VTE prevention studies was similar to that of enoxaparin 40 mg OD administered with a pre-surgery dose, and also similar to that of enoxaparin 30 mg BID administered post-surgery only. The frequencies of common AEs (reported for >1% of patients) in the Eliquis group and enoxaparin group were similar. The common adverse reactions (occurring at a rate of ≥1%) were nausea, anaemia, contusion, and haemorrhage.

The death rate in the four VTE pooled studies was low and consistent with similar recent studies of new anticoagulants.

As expected, deep vein thrombosis (DVT) and pulmonary embolism (PE) were the most common serious adverse events (SAEs). The incidence of DVT was numerically less in the Eliquis groups versus the enoxaparin groups, but the incidence of PE was numerically higher in two of the studies, in particular in the pivotal study using the Canadian enoxaparin regimen as the active control (ADVANCE-1 study). The apparent imbalance may be caused by the low numbers in the study population. However, it is also possible that the relatively higher incidence of PE in that study merely reflects the slightly lesser efficacy of Eliquis 2.5 mg BID versus enoxaparin 30 mg BID.

Major bleeding, the composite of major and CRNM bleeding, and all bleeding occurred with similar frequency in the two pivotal studies, ADVANCE-2 and ADVANCE-3, where patients were treated with Eliquis 2.5 mg BID or enoxaparin 40 mg OD. In the ADVANCE-1 study with enoxaparin 30 mg BID as the active comparator, the risks of major bleeding, CRNM bleeding, and all bleeding were lower in the patients treated with Eliquis 2.5 mg BID.

Clinical studies with Eliquis in a patient population receiving double antiplatelet therapy revealed a significantly elevated bleeding risk (5 cases were fatal) when Eliquis 5 mg BID was added, compared to the addition of placebo to the double antiplatelet therapy. A warning for this SAE appears in the Eliquis Product Monograph.

Adverse events (AEs) of special interest included myocardial infarction, stroke, thrombocytopaenia, elevated liver enzymes, and neurologic AEs. The event rates for all of these AEs were low and similar in the Eliquis and enoxaparin groups. Data on liver safety, based on the four clinical studies as well as from various other finished and ongoing studies, do not indicate that Eliquis has the potential for hepatotoxicity. Health Canada will follow up on the data emerging from the ongoing studies, and will follow post-marketing data on liver safety, as well as on neurologic disease in the completed and ongoing studies.

No clinically relevant flags were raised for bleeding events or other SAEs within the following population subgroups: age; gender; race; weight; body mass index; level of renal impairment; number of risk factors for VTE; or type of (unilateral of bilateral) orthopaedic surgery.

3.4 Benefit/Risk Assessment and Recommendation

3.4.1 Benefit/Risk Assessment

The clinical studies in this drug submission demonstrated the superiority of Eliquis 2.5 mg BID to the gold standard for VTE prevention, enoxaparin, when the latter is dosed at the non-North American regimen of 40 mg OD. However, in comparison with enoxaparin 30 mg BID, the Canadian dose regimen, Eliquis 2.5 mg BID did not reach non-inferiority, and was in fact slightly less effective. The absolute difference in risk of the primary endpoint (asymptomatic and symptomatic DVT, nonfatal pulmonary embolism and death from any cause) between Eliquis 2.5 mg BID and enoxaparin 30 mg BID was 0.11% [95% confidence interval (CI) -2.22% to 2.44%]. This means there is a risk of causing a primary endpoint event in 1 patient out of 1,000, due to the slightly weaker efficacy of Eliquis versus that of enoxaparin. The 95% CI indicates that this risk is 24 patients per 1,000 at worst, but there is also room for the possibility of Eliquis actually being better than enoxaparin by preventing 22 primary endpoints per 1,000 patients treated.

Eliquis showed an advantage in the number of major bleeding events versus the Canadian enoxaparin regimen of 30 mg BID that was almost statistically significant: 11 cases (0.7%) versus 22 cases (1.4%). The difference in risk was -0.81% [95% CI -1.49 to 0.14; probability (p) = 0.053]. The composite safety endpoint of major and clinically relevant non-major bleeding occurred in 46 patients (2.9%) in the Eliquis group and in 68 patients (4.3%) in the enoxaparin group; the adjusted difference in event rates was -1.46% (95% CI -2.75 to 0.17, p = 0.03). Thus, by using Eliquis 2.5 mg BID rather than enoxaparin 30 mg BID, 14-15 per 1,000 less patients would experience a major or clinically relevant non-major bleeding. Based on the 95% CI, this estimate would be 27-28 per 1,000 fewer patients at best, while there would be at worst 2 per 1,000 more patients in the Eliquis group versus the enoxaparin group.

Eliquis is administered orally BID, and enoxaparin is administered subcutaneously BID. The relative ease of using Eliquis may be expected to translate into a compliance advantage, preventing DVT and its sequelae.

Overall, the demonstrated superiority of Eliquis versus the non-North American enoxaparin regimen of 40 mg OD, the demonstrated efficacy and safety of Eliquis 2.5 mg BID relative to the Canadian gold standard enoxaparin 30 mg BID in major orthopaedic surgery patients, combined with the expectation of increased compliance due to the oral versus subcutaneous route of administration, is expected to make Eliquis a useful tool in the prevention of venous thromboembolism following major orthopaedic surgery.

3.4.2 Recommendation

Based on the Health Canada review of data on quality, safety and efficacy, Health Canada considers that the benefit/risk profile of Eliquis is favourable for the prevention of VTE in adult patients who have undergone elective knee or hip replacement surgery. The New Drug Submission complies with the requirements of sections C.08.002 and C.08.005.1 and therefore Health Canada has granted the Notice of Compliance pursuant to section C.08.004 of the Food and Drug Regulations.

4 Submission Milestones

Submission Milestones: Eliquis

Submission MilestoneDate
Submission filed:2010-10-05
Screening
Screening Acceptance Letter issued:2010-11-26
Review
Biopharmaceutics Evaluation complete:2011-06-10
Quality Evaluation complete:2011-12-09
Clinical Evaluation complete:2011-12-14
Labelling Review complete:2011-12-09
Notice of Compliance issued by Director General:2011-12-16