For Doctors: How You Can Help Your Patients Who Are Running Out of HIV Treatment Options

By Nelson Vergel, B.S.Ch.E., M.B.A.

July 6, 2011

In a previous blog post, I reviewed the current situation for the minority of patients with HIV who have run out of treatment options.
Of the HIV medications in development with potential activity against highly resistant HIV (i.e., patients with GSS=0), two may become available within the next year: ibalizumab (formerly TNX-355), a monoclonal antibody currently under development by TaiMed Biologics, and dolutegravir (formerly GSK1349572), a second-generation integrase inhibitor made by ViiV Healthcare).
Ibalizumab has a completely new mode of action, so most patients should respond to it when using it with at least one other active agent. It is different from the entry inhibitor maraviroc (Selzentry, Celsentri) in that it blocks the CD4 receptor on T cells rather than blocking the CCR5 co-receptor. This means it could be effective against virus that uses either the CCR5 or CXCR4 co-receptor. It is a genetically engineered monoclonal antibody administered once every two weeks intravenously. TaiMed has finished its dosing phase 2b study and will be presenting the data in the near future. TaiMed is also developing a subcutaneous administration of ibalizumab; phase 3 studies should take place involving HIV-infected patients in eight to 12 months.
Dolutegravir has shown activity against many raltegravir (Isentress)-resistant viruses at a dose of 50 mg twice a day. Dolutegravir's phase 3 study, which is seeking patients with raltegravir resistance, is now enrolling nationwide. However, patients are required to have a GSS=1 to join the study. For those who do not meet the entry criteria, but need help, there may be another option: The company is planning to open an expanded access program for its drug by year's end.
However, "year's end" is not near enough for patients who are in dire need of new, active antiretrovirals. There are many patients who cannot join the phase 3 studies, and who cannot wait eight to 12 months for both drugs to become available through their respective expanded access programs.
In these extreme cases, physicians can apply for "single patient Investigational New Drug (IND)" access to either or both of these antiretrovirals. Both TaiMed and ViiV/GlaxoSmithKline have shown good faith in helping patients in deep salvage, and they are willing to provide their drugs for patients with declining health and high mortality risk.
The following steps must be followed by physicians for each drug they want to access on behalf of one of their patients.

How to Apply for Single Patient IND Access to an Investigational Drug

If the patient's HIV has evidence of resistance to all commercially available antiretrovirals and his/her viral load suggests that his/her HIV is not responding to the current drug regimen, a phenotypic resistance test needs to be performed along with a tropism test. It is important to also know if phenotypic resistance to enfuvirtide (T-20, Fuzeon) is present. Additionally, genotypic integrase mutations need to be characterized to assess the patient's potential response to dolutegravir.
Once the test results have confirmed that the patient has developed resistance to all commercially available or expanded access HIV medications, and provided the patient's health is at risk (i.e., CD4+ cell count under 100 cells/mL and declining clinical outlook), physicians can follow this procedure required by the U.S. Food and Drug Administration (FDA). (Note that the FDA has also changed its regulations to accept patient access for small groups of patients, which could save a lot of paperwork.)

1. The treating physician should call the company that is developing the investigational antiretroviral to find out if it is willing to provide the drug for free before it has been approved. (Drugs have to have gone through dosing and safety studies before they can be made available in this manner. Also, antiretroviral interaction data are valuable, although ViiV and TaiMed do not expect negative drug-drug interactions from the combination of dolutegravir and ibalizumab.)
2. After each manufacturer agrees to provide its respective investigational drug via single patient IND, the doctor should follow the procedure described on this FDA Web page to fill the required forms and get institutional review board (IRB) approval.

This procedure is hardly used by doctors in HIV care due to lack of information or concerns about its complexity. But in actuality, it's very straightforward: three simple forms, a signed patient consent form and IRB approval are needed. Many local IRBs will even expedite approval of this kind of request due to its urgency.
Also, single patient IND can be approved verbally by the FDA if the patient has an expected survival of less than 30 days (this is called emergency IND). This will allow the drug company to ship the drug in an expedited manner, but the forms I mention above will still need to be processed while drug shipment is taking place.
If you need a sample patient consent form and cover letter for IRB submission, I recommend using these, which were used in the past for access to darunavir (TMC114, Prezista) and etravirine (TMC125, Intelence) while they both were investigational drugs:

• Sample consent form (from salvagetherapies.org)
• Sample cover letter (from salvagetherapies.org)

ViiV and TaiMed can also make copies of consent forms for their drugs available if requested by the physician applying for access on behalf of his/her patient.
I welcome e-mails from physicians who need more information or would like additional help gaining access to investigational drugs for their HIV-infected patients whose virus is resistant to all currently available drugs. Please send e-mails to nelsonvergel@gmail.com.

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AIDS Activists Support the Approval of Egrifta- But With Some Conditions for Theratecnologies and Serono

17 May 2010

Paul Tran, BS Pharrn, RPh Advisors and Consultants Staff Center for Drug Evaluation and Research Food and Drug Administration 5630 Fishers Lane, HFD-21 Rockville, MD 20857

Dear Mr. Tran:

On behalf ofthe Drug Development Committee (DDC) ofthe AIDS Treatment Activists Coalition (ATAC), I am writing to urge members ofthe Endocrinologic and Metabolic Drugs Advisory Committee (EMDAC) to recommend approval of Egrifta (tesamorelin) for the treatment of HIV-associated lipohypertrophy (NDA 22-505). This letter of support is submitted free of influence, financial or otherwise, from the NDA's sponsor, Theratechnologies, or Egrifta's planned U.S. distributor, EMD Serono.

Though the exact prevalence of lipohypertrophy among HIV -positive patients is not well established-the prevalence of the broader lipodystrophy syndrome is believed to be between 18 and 81 percent of people living with HIV-it has been an established comorbidity in the HIV patient population since the mid-1990s. Indeed, it is one of the only clinically significant HIV-related manifestations for which there is no proven treatment modality approved for use.

After review of the published data, we firmly believe that Egrifta, with its moderate efficacy profile and minimal adverse effects, should receive an EMDAC approval recommendation and cleared for marketing by the Food and Drug Administration (FDA). However, we remain sensitive to the fact that there are lingering concerns and questions regarding Egrifta's long-term efficacy and safety. Thus, our support for approval hinges on the establishment of post-marketing safety and efficacy features, clearly written into the product's labeling, along with a commitment to conduct additional safety and efficacy evaluations.

ATAC. 611 Broadway, #308 . New York, NY 10012.646/284-3801. admin@atac-usa.org

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Interpretation of Efficacy Evaluations

Our initial optimism began with the successful completion of seven Phase II studies showing clear benefits-with minimal adverse events, notably a statistically significant increase in rates of glucose intolerance and diabetes mellitus-associated with 2 mg daily dosing of Egrifta.

The 26- and 52-week efficacy data from Theratechnologies' two Phase III studies, LIPO-Ol0 and CTR-l0lljCTR-l012, solidify our encouragement. The 15 percent and 11 percent reductions in visceral adipose tissue (VAT), respectively, after 26 weeks (and maintained reductions among patients treated for 52 weeks) and the differences in the intent-to-treat and per-protocol analyses with respect to the primary endpoint (a VAT reduction of ~8 percent) are proof-positive of Egrifta's potential for HIV-infected patients with lipohypertrophy. We are also heartened by Egrifta's secondary benefits, compared with placebo, including decreases in waist circumference, increases in lean body mass, preservation of subcutaneous adipose tissue (SAT) and significant improvements in triglyceride levels and other CVD-related biochemical indices.

It is disappointing that the Phase III studies lacked the design and resources needed to validate decreases in VAT as a surrogate marker for reduced cardiovascular disease (CVD) risk, in light of data indicating that VAT and increased waist circumference is a predictor of clinical and subclinical CVD in both HIV-positive and HIV-negative individuals. There is undoubtedly a need for observational and randomized, controlled studies exploring the effects of VAT -reducing agents, including Egrifta, on the absolute and relative risks of serious cardiovascular and cerebrovascular events, as well as other clinical manifestations such as sleep apnea and pancreatic, liver, pulmonary and vascular functioning.

There is, however, much to be said for patient reported outcomes of both studies. These data cannot be overstated given the disfiguring and stigmatizing effects of lipodystrophy. Increases in VAT have clearly been shown to be associated with psychological distress, impaired quality of life measurements, reduced willingness to commence antiretroviral (ARV) therapy and poorer adherence among those on ARV treatment.

As is clearly documented in the published data, Egrifta treatment is associated with significant improvements in patient ratings of belly and body appearance distress, along with improvements in physician ratings of belly profile. These comprehensive data are unmatched by any other lipohypertrophy-reversing strategy explored thus far.

ATAC. 611 Broadway, #308 . New York, NY 10012.646/284-3801. admin@atac-usa.org

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Interpretation of Safety Evaluations

Unlike the last hormonal agent (Serostim; recombinant human growth hormone) reviewed and ultimately rejected by the FDA for the treatment of lipohypertrophy, the 52-week data from Egrifta's two Phase III studies are encouraging with respect to safety. Indeed, they establish that Egrifta's moderate efficacy outweighs Egrifta's minimal adverse effects.

Rates of injection site reactions, including localized hypersensitivity, appear to be more common among Egrifta-treated patients compared with placebo recipients. These rates, however, are dwarfed by those associated with another injectable agent, Fuzeon (enfuvirtide), used by people living with HIV.

While there also appeared to be slightly larger rates of growth hormone-related adverse events, such as arthralgia and edema, among patients receiving Egrifta compared with placebo, the reported percentages do not compare with the high rates of growth hormone­related events seen in Phase III clinical trials of Serostim.

Phase II and Phase III studies have consistently documented that Egrifta has an extremely limited effect on glycemic measures and did not appear to significantly increase the risk of glucose intolerance or diabetes mellitus. In fact, as is documented in the available data, patients with diet-controlled diabetes can receive Egrifta without an increased risk of untoward effects. Though an increased risk of glucose intolerance or diabetes cannot be ruled out completely and should be studied further, the risk-at least over 52 weeks of treatment-is minimal when balanced against the drug's moderate efficacy.

Egrifta's highly variable effect on insulin-like growth factor 1 (IGF-l) in a significant number of patents is not without potential concern. While we understand that these variations have not been associated with any clinically meaningful adverse effects, we believe that additional, long-term data are necessary to confirm these initial findings.

Another concern is the development of anti-tesamorelin IgG antibodies in a sizeable number of study participants. Though we are aware of data concluding that antibody production to this peptide is not associated with any clinically meaningful decreases in efficacy or increased rates of adverse events, we have not yet seen research exploring whether anti-tesamorelin IgG antibodies have an effect on endogenous growth hormone production after drug cessation. We are also unaware of data exploring the potential of these antibodies to shunt treatment responses to Egrifta in the event the drug is stopped and then restarted. These data, if not already compiled and analyzed, are necessary.

As with virtually every agent that has been considered by the FDA for an HIV indication, we are not without concerns regarding the long-terms safety of Egrifta. Knowing that the drug

ATAC. 611 Broadway, #308 . New York, NY 10012.646/284-3801. admin@atac-usa.org

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will need to be continued-perhaps indefinitely-to maintain reductions in VAT, we firmly believe that the product's labeling should feature prominent safety-related instructions for clinicians and patients, notably the need for regular glycemic and IGF -1 testing, along with cancer screenings, with recommendations to terminate Egrifta therapy when appropriate.

We also believe that a recommendation for Egrifta's approval be met with a commitment from the sponsor to conduct a long-term post-marketing study-either observational or randomized in design, following patients for at least three to four years-to collect data regarding the long-term safety of Egrifta.

Further Recommendations

In addition to our request for long-term safety data via a post-marketing study, we advocate for the following:

1)     Phase IV evaluations of Egrifta-associated VAT reductions on the risk of CVD. Though Theratechnologies should not be required to evaluate Egrifta in studies employing myocardial infarction or ischemic stroke as endpoints as a condition for approval, we believe that post-marketing studies exploring associations between VAT reductions and softer measures ofCVD-such as vascular function-should be required.

2)     Required Phase IV studies exploring the effects of Egrifta-associated VAT reductions on other clinical outcomes, including fatigue, gallbladder disease, liver disease, osteoarthritis, pulmonary function and sleep apnea.

3)     Required Phase IV studies exploring Egrifta in combination with exercise and/or diet modification to determine if VAT can be synergistically decreased.

4)     A required Phase IV gender-balanced clinical trial evaluating the safety and efficacy of Egrifta in HIV-positive women with lipohypertrophy compared with men.

5) The approved labeling should spell out the indication for Egrifta treatment, along with indicators of effectiveness while receiving therapy, to ensure that the risk­benefit ratio is maintained for each patient. Though slice CT scans were used to measure VAT reductions in the Phase III clinical trials, these will not likely be practical in the clinical setting. Waist circumference, waist-to-hip ratio and basic psychological/body image assessments are much more feasible and should be employed by clinicians when considering patients for Egrifta and while monitoring their progress (or lack thereof), at regular time points, for as long as treatment is continued.

ATAC. 611 Broadway, #308 . New York, NY 10012.646/284-3801. admin@atac-usa.org

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6)     Approve Egrifta as a medical/reconstructive modality. We strongly urge against reviewing, approving, or labeling Egrifta as a cosmetic treatment. Though Egrifta­associated VAT reductions have not yet been established as a marker of reduced CVD risk, its effects on patients' body-image perceptions, sense of well being and quality of life is substantial. This is no different than breast reconstruction following a mastectomy-an unquestioned medical approach to minimize the negative psychological effects stemming from vital but disfiguring treatment.

In conclusion, we sincerely hope that EMDAC panelists will appreciate that the approval of Egrifta, with its favorable efficacy and safety profiles, is supported by this coalition of AIDS treatment activists that has closely followed the development of this agent, carefully scrutinized the published data and-perhaps most importantly-remains eager to see this option made available to address this long-standing unmet medical need.

Respectfully submitted,

Tim Horn Drug Development Committee AIDS Treatment Activists Coalition

cc:

Mary Parks, MD Director, Division of Metabolism and Endocrinology Products

Richard Klein Office of Special Health Concerns

Kimberly Struble, PharmD Division of Antiviral Drug Products

ATAC. 611 Broadway, #308 . New York, NY 10012.646/284-3801. admin@atac-usa.org

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The Forgotten Minority: HIV+ Patients With No Available HIV treatment Options

Most successful HIV medication combinations require 3 medications that are fully active, but a small portion of long term survivors with long treatment history and accumulated HIV resistance mutations do not have the luxury of constructing a viable regimen to save their lives.

Several potent antiretrovirals (ARVs) in the past 4 years have enabled many patients with multidrug resistance (MDR) to suppress their HIV viral load.

Due to several factors, there is still a relatively small number of patients that have developed resistance or toxicity to the new ARV’s

To protect them from functional monotherapy, these patients are not allowed in pre- approval studies.

Some HIV ARV’s in phase II studies may potentially help those patients, but combining them after their respective approvals may take at least 3 or 4 years.

Some of these patients may be at risk of clinical decline and death if no viable regimen is available for them before 2012

We do not know how many of these patients there are in the U.S.

I performed a physician survey with the help of some researchers and activists to find out how many patients may be present in the U.S. with HIV multidrug resistance in deep salvage (one or zero active medications to treat their HIV).

These figures summarize our findings (click on figures to enlarge):

These are the HIV medications in current development. The ones with an asterisk are the ones that may work for patients with no options left.

The closest ones to approval are Taimed's ibalizumab ( an IV once every two weeks) which may be two years away from approval, and GSK's integrase inhibitor GSK572 (2-3 years) . Avexa recently stopped the development of   Apricitabine and Myriad may follow suit with their maturation inhibitor. A combination of at least two compounds will probably not be feasible until 2013.  Efforts towards creating an expanded access program using multiple investigational agents is currently under way but it may not be a possibility until 2011.  All companies and the FDA are welcoming the concept in its early stages.  I will provide an update during the last quarter of 2010.

I wish we could help patients who need help now.

Nelson Vergel