THE PERSONALIZED MEDICINE REPORT - 2017 Opportunity, Challenges, and the Future
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THE PERSONALIZED MEDICINE REPORT 2017 · Opportunity, Challenges, and the Future
The Personalized Medicine Coalition gratefully acknowledges graduate students at Manchester University in North Manchester, Indiana, and at the University of Florida, who updated the appendix of this report under the guidance of David Kisor, Pharm.D., Director, Pharmacogenomics Education, Manchester University, and Stephan Schmidt, Ph.D., Associate Director, Pharmaceutics, University of Florida. The Coalition also acknowledges the contributions of its many members who offered insights and suggestions for the content in the report.
CONTENTS INTRODUCTION 5 THE OPPORTUNITY 7 Benefits 9 Scientific Advancement 17 THE CHALLENGES 27 Regulatory Policy 29 Coverage and Payment Policy 35 Clinical Adoption 39 Health Information Technology 45 THE FUTURE 49 Conclusion 51 REFERENCES 53 APPENDIX 57 Selected Personalized Medicine Drugs and Relevant Biomarkers 57
HISTORICAL PRECEDENT For more than two millennia, medicine has maintained its aspiration of being personalized. In ancient times, Hippocrates combined an assessment of the four humors — blood, phlegm, yellow bile, and black bile — to determine the best course of treatment for each patient. Today, the sequence of the four chemical building blocks that comprise DNA, coupled with telltale proteins in the blood, enable more accurate medical predictions.
The Personalized Medicine Report 5 INTRODUCTION When it comes to medicine, one size does not fit all. Treatments that help some patients are ineffective for others (Figure 1),1 and the same medicine may cause side effects in only certain patients. Yet, bound by the constructs of traditional disease, and, at the same time, increase the care delivery models, many of today’s doctors still efficiency of the health care system by improving prescribe therapies based on population averages. quality, accessibility, and affordability. As a result, health care systems around the world Health care is in the midst of a transformation continue to deliver inefficient care that fails to away from one-size-fits-all, trial-and-error help significant portions of the patient population. medicine and toward this new, targeted approach Enter personalized medicine. Personalized that utilizes patients’ molecular information to medicine, also called precision or individualized inform health care decisions. Completing that medicine, is an evolving field in which physicians transformation, however, will require a collabora- use diagnostic tests to identify specific biological tive effort in the U.S. and abroad to keep up with markers, often genetic, that help determine which the pace of progress in science and technology. medical treatments and procedures will work best A myriad of nuanced regulatory and reimburse- for each patient. By combining this information ment challenges as well as complexities regarding with an individual’s medical records, circumstances, the clinical adoption of new medical norms and and values, personalized medicine allows doctors standards, in particular, continue to make it and patients to develop targeted treatment difficult for health care systems around the world and prevention plans. Personalized health care has to capitalize on innovative science and a growing the capacity to detect the onset of disease body of knowledge pointing to a new era in the at its earliest stages, pre-empt the progression of history of medicine.
6 Introduction FIGURE 1: ONE SIZE DOES NOT FIT ALL Percentage of the patient population for which a particular drug in a class is ineffective, on average. ANTI-DEPRESSANTS 38% SSRIs ASTHMA DRUGS 40% DIABETES DRUGS 43% ARTHRITIS DRUGS 50% ALZHEIMER’S DRUGS 70% CANCER DRUGS 75% Reproduced with permission from: Spear, BB, Heath-Chiozzi, M, Huff, J. Clinical application of pharmacogenetics. Trends in Molecular Medicine. 2001;7(5): 201-204.
The Personalized Medicine Report 7 THE OPPORTUNITY
8 The Opportunity “The power in tailored therapeutics is for us to say more clearly to payers, providers, and patients: ‘this drug is not for everyone, but it is for you.’ That is exceedingly powerful.” — John C. Lechleiter, Ph.D. former Chairman, President, and CEO, Eli Lilly and Company
The Personalized Medicine Report 9 BENEFITS Personalized medicine benefits patients and the In some areas, early genetic testing can save health system by: lives. For example, women with certain BRCA1 • Shifting the emphasis in medicine from reaction or BRCA2 gene variations have up to an 85 to prevention percent lifetime chance of developing breast • Directing targeted therapy and reducing trial- cancer, compared to a 13 percent chance among and-error prescribing the general female population.2, 3, 4 Women with • Reducing adverse drug reactions harmful BRCA1 and BRCA2 mutations also have up to a 39 and 17 percent chance, respectively, • Revealing additional targeted uses for medicines of developing ovarian cancer, compared with a and drug candidates 1.3 percent chance among the general female • Increasing patient adherence to treatment population.2 The BRCA1 and BRCA2 genetic • Reducing high-risk invasive testing procedures tests can guide preventive measures, such as • Helping to control the overall cost of health care prophylactic surgery, chemoprevention, and more frequent mammography. Shifting the Emphasis in Medicine from Personalized medicine also opens the door Reaction to Prevention to early intervention for patients with familial hypercholesterolemia, which is characterized Personalized medicine introduces the ability to by a mutation in the LDL receptor gene. These uncover molecular markers that signal disease risk patients can take drugs that block the PCSK9 or presence before clinical signs and symptoms gene (known as PCSK9 inhibitors) to reduce appear, offering an opportunity to focus on their cholesterol levels and potentially decrease prevention and early intervention rather than on their risk of developing coronary artery disease. reaction at advanced stages of disease.
10 The Opportunity Directing Targeted Therapy and Reducing Other personalized medicine tests measure Trial-and-Error Prescribing prognostic markers that help indicate how a disease may develop in an individual when a In many disease areas, diagnostic tests enable disorder is already diagnosed. Two complex tests, physicians to identify the most effective treat- Oncotype DX® and MammaPrint®, for example, ment for a patient immediately by testing use prognostic markers to help physicians target for specific molecular characteristics, thus the best course of treatment for breast cancer avoiding the frustrating and costly practice of patients. Oncotype DX® can determine whether trial-and-error medicine. Medicines that target women with certain types of breast cancer those molecular characteristics often improve are likely to benefit from chemotherapy.8, 9, 10 outcomes and reduce side effects. One of the MammaPrint® can detect which early-stage breast most common applications of this practice has cancer patients are at risk of distant recurrence been for women with breast cancer. About following surgery.11 Both tests place patients into 30 percent of breast cancer cases are character- risk categories that inform physicians and patients ized by over-expression of a cell-surface protein of whether the cancer may be treated success- called human epidermal growth factor receptor 2 fully with hormone therapy alone, as opposed (HER2). For breast cancer patients who express to some combination of hormone therapy and this molecule, adding an antibody drug like chemotherapy, which is associated with an addi- trastuzumab (Herceptin®) to their chemotherapy tional financial burden and toxic effects. Similar regimen can reduce their recurrence risk by prognostic tests for prostate and colon cancer 52 percent.5, 6 Molecular diagnostic tests for HER2 patients have also been developed.12, 13, 14 are used to identify the patients who will benefit from receiving Herceptin® and other drugs that target HER2, such as lapatinib (Tykerb®). Reducing Adverse Drug Reactions Treatments targeting genetic variants involved in Another category of personalized medicine tests, the molecular pathway of disease, such as BRAF called pharmacogenomic tests, help predict what in melanoma and ALK and EGFR in non-small medications at what doses will be safest for indi- cell lung cancer, represent a remarkable improve- viduals based on their genetic makeup. Doing so is ment over trial-and-error medicine, and we are important. According to several studies, about 5.3 moving toward an era in which we treat all cancer percent of all hospital admissions are associated cases with a targeted course of treatment with adverse drug reactions (ADRs).15 Many ADRs (Figure 2).7 are attributed to variations in genes that code for
The Personalized Medicine Report 11 FIGURE 2: F ORGING A PATH TO PERSONALIZED CANCER CARE TACKLING TUMORS: Percentage of patients whose tumors are driven by certain genetic mutations that could be targets for specific drugs, by types of cancer. 73% Melanoma 56% Thyroid 51% Colorectal 43% Endometrial 41% Lung 41% Pancreatic 32% Breast 31% Other gynecological 29% Genitourinary 25% Other gastrointestinal 21% Ovarian 21% Head and neck Reproduced with permission from: Winslow, R. Major shift in war on cancer. Wall Street Journal. June 5, 2011. Accessed September 13, 2016 at http://www.wsj.com/articles/SB10001424052702304 432304576367802580935000.
12 The Opportunity drug-metabolizing enzymes, such as cytochrome The use of genetic markers to facilitate safer P450 (CYP450).16, 17 These variants cause drugs and more effective drug dosing and selection to be metabolized either faster or slower than takes on added significance at the population normal. As a result, some individuals have trouble level. For example, adverse reactions to the HIV inactivating a drug and eliminating it from their drug efavirenz (Stocrin®/Sustiva®) can occur at bodies, leading to systemic overexposure to the standard dosing due to the presence of a genetic drug, while others eliminate the drug too rapidly mutation (the CYP2B6*6 allele) in an enzyme that before it has had a chance to work. Thus, these metabolizes the medicine. This results in slower genetic variations should be considered when metabolism of the drug and is found significantly determining dose. more often in patients of African heritage than Pharmacogenomic testing can help guide those of European heritage.22 Lowering the the safe application of medicines in many health drug dose in individuals with this allele can help areas, including heart disease, hematologic reduce adverse effects and increase treatment disorders, HIV and other infectious diseases, compliance. Similarly, the HLA-B*5701 mutation is cancer adjunct therapy, anesthesiology, derma- associated with severe and life-threatening hyper- tology, gastroenterology, neurology, psychiatry, sensitivity to the HIV drug abacavir (Ziagen®/ and rheumatology. One of the first applications Epzicom®).23 The HLA-B*5701 mutation is present of pharmacogenomics was for patients that in approximately five percent of HIV patients in had been prescribed the drug warfarin, used the U.S. to prevent blood clots. Genetic variations in a drug-metabolizing enzyme (CYP2C9) and Revealing Additional Targeted Uses for an enzyme that activates vitamin K (VKORC1) Medicines and Drug Candidates complicate the safe use of warfarin.18, 19 Dosing is typically adjusted for the individual patient Molecular testing can also help identify the most through multiple rounds of trial-and-error, during appropriate uses for therapies that were initially which the patient may be at risk for excessive targeted to the general population. The lung bleeding or further blood clots. FDA now recom- cancer drug gefitinib (Iressa®), for example, did mends genotyping for all patients before warfarin not demonstrate a survival advantage in a general treatment, which allows for more precise dosing. population of lung cancer patients in clinical trials, Although the data are still evolving, early evidence and was withdrawn from the market in 2005 suggests that genetic testing in advance of after initially being granted accelerated approval prescribing warfarin helps patients avoid serious in 2003. However, continued clinical research and possibly fatal adverse effects.20, 21
The Personalized Medicine Report 13 revealed benefits in patients who test positive toma and anaplastic large cell lymphoma.33, 34 for epidermal growth factor mutations. FDA FDA has fast-tracked regulatory review for these approved Iressa® as a first-line treatment for this expanded indications, which some observers subset of patients in 2015. believe is a precursor to an era in which the agency Gene and protein analyses have also led to an approves all personalized medicines faster based evolution in the way tumors are evaluated and on the increased likelihood that a molecularly classified. With an increasing body of knowledge targeted drug will be safe and effective. about the underlying genomic alterations and the expression of relevant biomarkers, tumor clas- Increasing Patient Adherence sification is shifting away from tissue of origin and to Treatment toward molecular taxonomy, which is having a profound effect on the way that oncology treat- Patient non-adherence with treatment leads to ment decisions are made. For example, trial results adverse health effects and increased overall health suggest that expression of the PD-L1 biomarker, care costs. When personalized therapies prove which has been widely observed in cancers from more effective or present fewer side effects, multiple tissues of origin, can help doctors make patients may be more likely to comply with their more informed decisions about the use of some treatment regimens. The greatest impact could be novel immune checkpoint inhibitors.24 This has led in the treatment of chronic diseases, for which non- to expanded approvals for immune checkpoint adherence commonly exacerbates the condition. inhibitors like pembrolizumab (Keytruda®), which For example, inherited forms of hypercholes- was initially approved in 2014 for melanoma.25 terolemia (high cholesterol) can increase the risk FDA revised Keytruda’s label in 2015 for use in of myocardial infarction before the age of 40 by non-small cell lung cancer and has fast-tracked more than 50-fold in men and 125-fold in women. review for its use in other indications.26, 27 Similarly, Knowledge of a genetic predisposition for hyper- FDA has also approved the use of nivolumab cholesterolemia provides patients with a powerful (Opdivo®) for multiple indications.28, 29, 30, 31, 32 incentive to make lifestyle changes and manage Likewise, early studies indicate that crizotinib their condition with drugs. Patients with a genetic (Xalkori®), already approved to treat specific forms diagnosis have shown more than 86 percent of non–small cell lung cancers, including those that adherence to their treatment program after two are EML4-ALK-positive, is also effective against years, compared to 38 percent prior to testing.35 other types of tumors containing ALK alterations, such as aggressive forms of pediatric neuroblas-
14 The Opportunity FIGURE 3: A NEW TREATMENT PARADIGM Without Personalized Medicine: Some Benefit, Some Do Not Patients Therapy Some patients benefit, some patients do not benefit, and some patients experience adverse effects With Personalized Medicine: Each Patient Receives the Right Medicine Patients Biomarker Diagnostics Therapy Each patient benefits from individualized treatment Adapted with permission from: PhRMA. A New Treatment Paradigm. Accessed September 13, 2016 at http://chartpack.phrma.org/personal-medicines-in-development-chartpack/a-new-treatment- paradigm/personalized-medicine-can-improve-efficiencies-within-the-health-care-system.
The Personalized Medicine Report 15 Avoiding Invasive Testing Procedures system can help decrease costs associated with many embedded inefficiencies, such as trial-and- Molecular tests that simply require a blood sample error dosing, hospitalizations due to adverse drug can also sometimes replace invasive and uncom- reactions, late-stage health condition diagnoses, fortable tissue biopsies. For example, Allomap®, and reactive treatment. Personalized medicine can a multi-gene expression test, detects whether also play an important role in the implementation the immune system of heart transplant recipients of value-based payment and delivery models, which is rejecting the new organ.36 Approximately 25 can help coordinate patient care and reduce costs. percent of heart transplant patients experience As an example, data suggest that pharmacoge- a rejection, which can prove fatal. To monitor for nomic testing associated with the management rejection, heart tissue biopsies are performed as of dosing of the blood thinning drug warfarin can frequently as once a week after the transplant, eliminate costs associated with hospitalizations and then every few months thereafter for several for bleeding or thromboembolism. The Mayo years. This invasive procedure requires inserting a Clinic and the pharmacy benefits manager Medco tube into a vein in the neck and threading it to the put the model to the test in a 3,600-subject heart to obtain the biopsy, which is uncomfortable prospective study. Hospitalization rates for heart for patients and has risks associated with injury to patients were reduced by about 30 percent when the vein and heart. Patients who are monitored for genetic information was available to doctors rejection using Allomap® have equivalent outcomes prescribing the drug.39 Additionally, breast cancer as those who receive heart tissue biopsies, but therapy guided by the Oncotype DX® test has without the associated risks and complications.37, 38 been estimated to provide a net cost savings of $2,256 per patient tested, based on a reduction Helping to Control the Overall in chemotherapy use with an incremental cost- Cost of Health Care effectiveness ratio of $1,944 per life year saved.40 By introducing innovative science that can create Another study found a $604 million annual efficiencies and sustainability, personalized medi- savings among all patients when treatment with cine also has the potential to reduce health care panitumumab (Vectibix®) or cetuximab (Erbitux®) costs worldwide. As noted, incorporating personal- was limited to patients with metastatic colorectal ized medicine into the fabric of the health care cancer whose KRAS gene was not mutated.41
16 The Opportunity “It’s not really ‘should we do this.’ We have to do this. We don’t get to decide what the biology of these diseases are, we just have to work with it.” — Barbara Weber, M.D. Interim Chief Medical Officer, Neon Therapeutics
The Personalized Medicine Report 17 SCIENTIFIC ADVANCEMENT The scientific tools necessary to realize the for the Study of Drug Development showed that benefits of personalized medicine are already at 42 percent of the drugs in the development pipe- our disposal. line now include biomarkers in their research and PMC counts 132 personalized medicines, that development design. The survey also suggested is, drugs that point to specific biomarker(s) in that biopharmaceutical manufacturers have nearly their labels to direct use, currently on the market doubled their investment in personalized medicine (Figure 4; Appendix), and recent estimates by the over the past five years, and that these companies genetic testing data company Concert Genetics expect investment to increase by another 33 indicate that there are now no fewer than 65,000 percent over the next five years (Figure 7). genetic tests available (Figure 5). Analysts peg the Scientific developments in genomic market value for drugs reliant on companion diag- sequencing, how an individual’s biology impacts nostics (CDx) at over $25 billion in 2015 (Figure 6). disease susceptibility, immunotherapy, gene These numbers are likely to continue growing. therapy, and CRISPR-Cas9 gene editing are laying A recent survey conducted by the Tufts Center the groundwork for a new era in medical discovery.
18 The Opportunity FIGURE 4: COMING OF AGE Number of Personalized Medicines Has Increased Steadily Since 2008* 132 106 81 36 5 2008 2010 2012 2014 2016 Personalized Medicine Coalition. The Case for Personalized Medicine (eds. 1–4). 2008–2014; Personalized Medicine Coalition. Applications: Therapies. Accessed October 31, 2016 at http://www.personalizedmedi- cinecoalition.org/Education/Therapies. *Methodological notes: The number of personalized medicines was calculated by combining informa- tion from former editions of PMC’s Case for Personalized Medicine (2008–2014) with 2016 data from FDA’s Table of Pharmacogenomic Biomarkers in Drug Labeling, accessed October 31, 2016 at http://www.fda.gov/Drugs/ScienceResearch/ResearchAreas/Pharmacogenetics/ucm083378. htm and CPIC’s Genes-Drugs tables, accessed October 31, 2016 at https://cpicpgx.org/genes-drugs/. A complete list of the 132 drugs counted as of October 2016 is available at http://www.personalized- medicinecoalition.org/Education/Therapies and in the Appendix of this report.
The Personalized Medicine Report 19 Genomic Sequencing Human Biology and Disease Susceptibility: It took $1 billion and 13 years to sequence the first The Role of DNA, RNA, Epigenetics, draft of the human genome. Since then, sequencing and Proteins technology has evolved from the manual Sanger Understanding the role of genetic variation in method using radioactive labels to automated disease has also become a central part of medical sequencing that employs color-coded fluores- research. Most scientists believe that many cent dyes. As a result, the cost of sequencing an common human ailments, such as heart disease, entire genome has declined at a rate that exceeds diabetes, and cancer, are significantly influenced Moore’s law (Figure 8). The results reflect a general by numerous rare genetic variations present within trend in the industry and an important transition a single genome. Thus, one person might not carry around mid-2007 brought on by next-generation the same set of variants as another, even if both sequencing technology. have the same disease. These rare variants are, as The cost to sequence a human genome today, National Institutes of Health (NIH) Director Francis at approximately $1,000,42 is comparable to the Collins termed them, the “dark matter” in genetic cost of other medical tests and procedures, and patterns that remain undiscovered. new innovations may continue to drive sequencing Thanks to the Human Genome Project and costs down. Current estimates suggest that in subsequent advancements in sequencing tech- ten years the cost will be $100.43 Additional costs nology, the scientific community is now more and time are necessary, however, for analysis and equipped than ever to make sense of this “dark annotation in a clinical setting. matter.” It is now possible to simultaneously interrogate hundreds of thousands of sites in
20 The Opportunity FIGURE 5: PROGRESS BY THE THOUSANDS 65,839 Total Singles Panels Genetic Testing Products Now on the Market (as of September 2016) (Cumulative growth) 65,839 APR MAY JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEP More Than 5,500 New Genetic Testing Products Came to Market Between April 2015 and September 2016* Data provided by: Concert Genetics. Available at concertgenetics.com. *Methodological notes: Concert Genetics began publishing the first reliable data on the number of genetic testing products available in January of 2016. PMC has published a list of 127 genetic tests com- monly associated with the 132 personalized medicines listed in the Appendix of this document at http:// www.personalizedmedicinecoalition.org/Education/Tests.
The Personalized Medicine Report 21 an individual’s DNA to find associations between There is also a growing understanding of a given disease and genetic variation. In 2015, genomic changes that can alter the chemistry and U.S. President Barack Obama launched the structure of DNA without altering its sequence. Precision Medicine Initiative (PMI), an effort to These “epigenetic” changes can occur in response build a national research cohort of one million to environmental factors, and influence whether or more Americans who volunteer their genetic certain genes are turned “on” or “off.” Epigenetic information for research aimed at finding more factors have been linked to a number of health effective ways to improve health and treat disease. conditions, including heart disease, diabetes, and The project is poised to fill a tremendous gap cancer. The NIH has developed the Roadmap in our understanding of human genetic variation Epigenomics Project to study the role of epi- by making thousands and ultimately a million genetics in human diseases.46 genome sequences securely available for scientific In addition, scientists are working to standardize interrogation. existing proteomic technologies such as mass But advances in personalized medicine are not spectrometry, leading to more robust identification confined to analysis of DNA. In fact, analyzing of protein biomarkers, which indicate the presence messenger RNA transcripts, the immediate or absence of disease apart from the risk predic- downstream mediator of the genome, can some- tion of genetic analysis. Entirely new approaches times detect gene expression in ways that DNA to protein biomarker detection47 are promising to analysis cannot. RNA sequencing analysis repre- make proteomics as “simple” as genetic analysis, sents an expanding share of the next-generation ushering in an era when diseases can be diagnosed — sequencing marketplace.44, 45 and treated — in their earliest stages.
22 The Opportunity Immunotherapy Gene Therapy Researchers and pharmaceutical companies are Medical researchers are also developing ways also developing highly personalized treatment to introduce genetic material directly into cells approaches that use the patient’s own immune to treat or prevent disease. Gene therapy, for system to help fight cancer. These “immuno- example, may allow scientists to “knock out” or therapies” work in different ways. Some provide replace a mutated gene that causes illness, or to a general boost to the body’s immune system. introduce a healthy copy of a gene to restore the Others help train the immune system to attack function of a needed protein. The European Union specific cancer cells by inhibiting a tumor’s ability has approved the first gene therapy, alipogene to use a substance called PD-L1 to put the “brakes” tiparvovec (Glybera®),50 and several gene thera- on immune cells. Novel immune checkpoint pies have advanced to phase III trials in the U.S.51 inhibitors like Keytruda® and Opdivo®, for example, Although the clinical efficacy of these treatments block the ability of PD-L1 to bind with its receptor, has not yet been established,52 proponents believe PD-1, which normally acts as a type of “off-switch” the therapies will begin to carve out a niche as the that helps keep a patient’s immune system from number of potential targets for these treatments attacking cancer cells. These therapies have been continues to increase. approved for the treatment of melanoma, non- small cell lung cancer, kidney cancer, and Hodgkin lymphoma.48, 49 They are also being studied for use against many other types of cancer.
The Personalized Medicine Report 23 FIGURE 6: MARKETED THERAPEUTICS RELIANT ON A CDx GENERATED ~$25 BILLION IN THERAPEUTIC REVENUES IN 2015 Biopharma worldwide marketed CDx drug revenue segmentation (2015)* Percent of revenues ~$25B ~$25B ~$25B 100 Other**** Other*** Therapy selection/ 80 monitoring Opdivo (BMS) Tarceva (Roche)** Perjeta (Roche) Erbitux (BMS) 60 Sprycel (BMS) Tasigna (Novartis) Oncology 40 Therapy selection Gleevec (Novartis) 20 Herceptin (Roche) 0 Drug (Company) Therapeutic area Test purpose * 2015 revenues are actual or analyst estimates; PHC products include those with labels that require/recommend CDx tests for candidacy ** Includes all Tarceva revenues, not just those from first-line treatment for EGFR+ non-small cell lung cancer patients *** Other includes Alecensa, Aristada, Blincyto, Bosulif, Cholbam, Cotellic, Gilotrif, Ibrance, Iressa, Kadcyla, Lonsurf, Lynparza, Mekinist, Nucala, Orkambi, Praluent, Repatha, Rexulti, Selzentry, Tafinlar, Tagrisso, Tykerb/Tyverb, Vectibix, Victrelis, Xalkori, Zelboraf, and Zykadia drug revenues **** Other includes infectious disease, neurology, cardiology, pediatrics, respiratory, and gastroenterology therapeutic areas Republished with permission from: L.E.K. Consulting. “Marketed Therapeutics Reliant on a CDx Generated ~$25B in Therapeutic Revenues in 2015,” PowerPoint presentation, updated January 27, 2016.
24 The Opportunity FIGURE 7: THE BIOPHARMACEUTICAL INDUSTRY IS COMMITTED TO PERSONALIZED MEDICINE Drug development pipelines are full of targeted treatments that offer new hope for patients. 42% 73% of all drugs in of oncology drugs development are in development are personalized medicines personalized medicines Personalized Medicines • 2% of all compounds and 73% of oncology compounds in the pipeline have 4 the potential to be personalized medicines • Biopharmaceutical companies nearly doubled their R&D investment in personalized medicines over the past five years, and expect to increase their investment by an additional 33 percent in the next five years • iopharmaceutical researchers also predict a 69% increase in the number of B personalized medicines in development over the next five years Tufts Center for the Study of Drug Development. Personalized medicine gains traction but still faces multiple challenges. Impact Report. 2015;17(3).
The Personalized Medicine Report 25 CRISPR/Cas9 Gene Editing The potential of germ-line genetic modifica- tion, however, has raised ethical concerns about A new tool called CRISPR/Cas9 gene editing is the appropriate use of the technology. These also generating excitement in personalized medi- concerns are sure to lead to ethical debates going cine. The discovery of CRISPR (clustered regularly forward. Nonetheless, CRISPR/Cas9’s application interspaced short palindromic repeats) and to treatment of diseases targeting somatic cells in CRISPR-associated (Cas) genes has allowed for adult patients will likely have a significant impact the development of efficient and reliable ways to on medical technology, as will many of the other make precise changes to the genomes of living cells. trends described here. Gene editing using the CRISPR/Cas9 technology may allow for the correction of disease-causing mutations in humans.53 The potential application of this technology for personalized treatment strate- gies spans a wide spectrum of health conditions, from congenital blindness to cancer. “[B]etween 2012 and 2016 we have invented technologies that allow us to change human genomes intentionally and permanently … We can now ‘read’ human genomes, and we can ‘write’ human genomes in a manner inconceivable just three or four years ago.” —S iddhartha Mukherjee, M.D., D.Phil. author, The Gene: An Intimate History
26 The Opportunity FIGURE 8: THE RAPIDLY DECREASING COST OF SEQUENCING HUMAN GENOMES This graph shows the average cost of sequencing a genome for sequencing technology projects funded by the National Human Genome Research Institute over time. The data capture the dramatic decline in sequencing costs through 2015, and the cost has continued to drop. $100M $10M Moore’s Law COST PER GENOME $1M $100K $10K $1K 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 National Human Genome Research Institute. The Cost of Sequencing a Human Genome. Accessed September 13, 2016 at http://www.genome.gov/sequencingcosts.
The Personalized Medicine Report 27 THE CHALLENGES
28 The Challenges “We are pleased to see substantial progress and look forward to continuing our efforts to advance biomarkers, which will help bring additional, important new therapies to patients in need.” — Janet Woodcock, M.D. Director, Center for Drug Evaluation and Research, FDA
The Personalized Medicine Report 29 REGULATORY POLICY Scientific progress is driving an increase in the The landscape for regulation of personalized number of personalized medicine products and medicine, however, is still emerging, and the lack services subject to regulatory review. In fact, of a clear regulatory pathway for personalized nearly one of every four drugs FDA approved medicine diagnostics continues to discourage from 2014 – 2016 was a personalized medicine, investment in the field. Among the topics under and personalized medicines accounted for 27 continued discussion are FDA’s proposed over- percent of new drug approvals in 2016. Those sight policies related to laboratory-developed numbers are a sharp increase from 2005, when tests (LDTs) and next-generation sequencing personalized medicines accounted for just 5 technologies. In contrast, the agency’s well- percent of new drug approvals (Figure 9). The developed position on the codevelopment of agency has responded to the growing demand for personalized medicine products has removed an regulatory clarity by issuing draft guidance docu- obstacle to the field’s progress. ments (Figure 10). The 21st Century Cures Act, which Congress passed in 2016, encourages the Regulatory Oversight of LDTs agency to modernize its paradigm for considering The emergence of personalized medicine tests “real-world evidence,” the patient experience, that inform clinical decision-making and guide and molecular pathways as they relate to clinical drug selection and dosage has led FDA to trial designs. The year 2017 will also mark the fifth re-examine its approach to regulating diagnostics. reauthorization of the Prescription Drug User Fee Traditionally, diagnostic tests have fallen into two Act (PDUFA), which includes several provisions main categories: diagnostic kits and LDTs. The that will offer clarity in areas such as biomarker former are products containing all the reagents qualification, patient-focused drug development, and materials needed to run the test, and are and the use of innovative clinical trial designs.
30 The Challenges FIGURE 9: PERSONALIZED MEDICINE AT FDA: THEN AND NOW Personalized medicines accounted for just 5 percent of the new molecular entities FDA approved in 2005. In 2016, they accounted for more than 25 percent. 2005 2016 5% 27% of the new molecular of the new molecular entities approved by FDA entities approved by FDA were personalized were personalized
The Personalized Medicine Report 31 regulated by FDA as medical devices. Only a small surrounding the future of the regulatory landscape portion of personalized medicine diagnostics falls for LDTs continues to discourage investment in under this category; most are LDTs, only a handful innovative molecular diagnostics. of which are FDA-approved. The clinical laboratories that perform LDTs are Regulatory Oversight of NGS-Based subject to the Clinical Laboratory Improvement Diagnostic Tests Amendment (CLIA) rules administered and implemented by the Centers for Medicare and FDA is also working to understand how to regulate Medicaid Services (CMS).54 Clinical laboratories diagnostics that incorporate next-generation can obtain CLIA certification directly from CMS, sequencing (NGS) technology, which yield insights typically through state agencies that survey labs from entire sets of genes. While current regula- for compliance with CLIA requirements. A lab tory concepts are applicable for the regulation of can also seek accreditation by one of the inde- conventional diagnostics that measure a limited pendent accreditation organizations approved number of endpoints associated with a disease by CMS, which include the College of American or condition, diagnostic tests that use NGS Pathologists (CAP), among others. Although FDA technology can examine millions of DNA variants has historically claimed jurisdiction to regulate at a time, and therefore require a more flexible LDTs, the agency has also historically refrained oversight approach. from actively regulating these tests, under a policy FDA is developing a new approach to regulat- it describes as “enforcement discretion.” ing NGS tests that the agency says will allow In July of 2014, however, FDA outlined a draft timely access to tools that have adequate analyti- framework for the agency’s oversight of LDTs. cal and clinical performance. Through 2016, only Following publication, many organizations one NGS instrument (Illumina MiSeqDx™) and concluded that a legislative solution would be two accompanying assays for the diagnosis of required to adequately address concerns raised by cystic fibrosis (Illumina MiSeqDx,™ Cystic Fibrosis the different sectors of the laboratory community. 139 Variant and Clinical Sequencing Assays) have FDA’s efforts to finalize its own guidance docu- been FDA-approved. Because it was impractical ment culminated only in a non-binding discussion to detect every possible variant that might exist in paper published in January 2017. The uncertainty a genomic sequence, analytical test performance
32 The Challenges FIGURE 10: POLICY AND GUIDANCE DOCUMENTS FROM THE U.S. FDA 2005 Pharmacogenomic Data Submissions (final guidance) 2007 Pharmacogenomic Tests and Genetic Tests for Heritable Markers (final guidance) 2007 In Vitro Diagnostic Multivariate Index Assays (draft guidance) 2008 E15 Definitions for Genomic Biomarkers, Pharmacogenomics, Pharmacogenetics, Genomic Data, and Sample Coding Categories (final guidance) 2011 E16 Guidance on Biomarkers Related to Drug or Biotechnology Product Development: Context, Structure, and Format of Qualifications Submissions (final guidance) 2012 Enrichment Strategies for Clinical Trials to Support Approval of Human Drugs and Biological Products (draft guidance) 2013 Clinical Pharmacogenomics: Premarket Evaluation in Early-Phase Clinical Studies and Recommendations for Labeling (final guidance) 2013 Clinical Pharmacogenomics: Premarket Evaluation in Early-Phase Clinical Studies and Recommendations for Labeling (final guidance) 2014 Qualification Process for Drug Development Tools (final guidance) 2014 In Vitro Companion Diagnostic Devices (final guidance) 2014 Framework for Regulatory Oversight of Laboratory Developed Tests (LDTs) (draft guidance) 2014 FDA Notification and Medical Device Reporting for Laboratory Developed Tests (LDTs) (draft guidance) 2016 Use of Standards in FDA Regulatory Oversight of Next Generation Sequencing (NGS)-Based In Vitro Diagnostics (IVDs) Used for Diagnosing Germline Diseases (draft guidance) 2016 Use of Public Human Genetic Variant Databases to Support Clinical Validity for Next Generation Sequencing (NGS)-Based In Vitro Diagnostics (draft guidance) 2016 Principles for Codevelopment of an In Vitro Companion Diagnostic Device with a Therapeutic Product (draft guidance) 2017 Discussion Paper on Laboratory Developed Tests (LDTs) (discussion paper) U.S. Food and Drug Administration. Search for FDA Guidance Documents. Accessed January 31, 2017 at http://www.fda.gov/RegulatoryInformation/Guidances/default.htm.
The Personalized Medicine Report 33 for the MiSeqDx™ system was demonstrated (Herceptin®) was approved six months apart from for a representative number of subsets of types the diagnostic test (HercepTest™) in 1998. In 2014, of variants in multiple sequencing contexts. The FDA released its final In Vitro Companion Diagnostic agency is considering extending this subset-based Devices Guidance, which helped clarify its method approach for other NGS platforms alongside other for conducting simultaneous reviews of a drug and approaches for the establishment of analytic valid- its companion diagnostic.56 The guidance describes ity and clinical significance. conditions under which a targeted drug might In 2014, FDA issued a discussion document be approved ahead of a corresponding diagnostic seeking public input on these novel regulatory test. While these guidelines were in develop- approaches, and in 2016 the agency released two ment, FDA, Health Canada, and the European draft guidance documents describing potential Medicines Agency had, in several cases, either processes for analytic standards development and mandated or recommended that biomarker testing FDA-recognized public genome database develop- be performed prior to prescribing certain drugs. ment. Although the landscape remains ambiguous, Recognizing that the class of companion thera- many members of the personalized medicine peutics/diagnostics is likely to grow, FDA has also community now believe the processes outlined in begun publishing a table of genomic biomarkers the documents reflect FDA’s willingness to adapt that it considers valid in guiding the clinical use of to the changing landscape of medicine. approved drugs.57 In mid-2016, FDA published an additional Codevelopment draft guidance document on codevelopment called Principles for Codevelopment of an In Vitro According to FDA, “a companion diagnostic is Companion Diagnostic Device with a Therapeutic an in vitro diagnostic or an imaging tool that Product. The document explains how therapeutic provides information that is essential for the safe and diagnostic partners should engage with the and effective use of a corresponding therapeutic agency when codeveloping products, removing product.”55 The need for a clear regulatory path for one regulatory hurdle to the parallel regulation companion diagnostics has been a great concern of targeted therapeutics and their companion for personalized medicine since the first thera- diagnostic tests. peutic product with an accompanying diagnostic
34 The Challenges “[The top challenges facing personalized medicine are] reimbursement, reimbursement, and reimbursement.” — Alexis Borisy Partner, Third Rock Ventures
The Personalized Medicine Report 35 COVERAGE AND PAYMENT POLICY Regulatory approval of personalized medicine cuts. In addition to limiting patient access, these products and services is critically important for decisions may inadvertently discourage continued advancing the field. However, it is only part of the research and development in personalized story. Coverage and payment policies — both in medicine. Bringing personalized medicine to the public and private sectors — play an equally patients will depend on policymakers appreciating important role in ensuring patient access and the value of this new paradigm as they consider encouraging continued innovation. health technology and value assessment frame- Health care policy leaders have contended works, procedural changes to the reimbursement that in order “to stimulate the development of a landscape, and value-based payment models. more robust diagnostics pipeline and to harness the benefits of personalized medicine in patient- Evidence Requirements centered care delivery, policymakers must create As discussed, personalized medicine offers many an environment that encourages increased benefits to patients, including an improved investment in diagnostics, enables new advances capacity to prevent disease, more effective treat- in patient care that are safe, accurate and reliable, ments, improved side-effect profiles, and reduced and establishes a viable pathway toward patient use of invasive testing procedures. By ensuring access.”58 However, under pressure to address that only patients who will benefit from a partic- rising health care costs, policymakers and payers ular intervention receive it, personalized medicine are increasingly considering policies that may can also make the health care system more result in across-the-board coverage and payment
36 The Challenges efficient. In assessing the value of personalized decision support tools, have the potential to medicine products and services, however, payers encourage the use of personalized medicine if they look for convincing evidence of their clinical and incorporate explicit mechanisms for capturing economic impact.59 There is significant ambiguity the value of the field. Many of the frameworks, regarding how that evidence should be developed however, have been criticized for failing to account and disseminated. Widespread insurance coverage for the heterogeneity of treatment effects. For of diagnostic tests, for example, will likely require example, in 2016, the Institute for Clinical and practice-based evidence demonstrating value. Economic Review (ICER), a nonprofit organization Obtaining the real-world data necessary for gener- that uses available evidence to examine the value ating this evidence, however, is difficult unless the of therapeutics based on a conceptual framework products and services in question are covered by that combines its estimation of the clinical and insurance policies. These realities have led to a economic value of a particular drug with several challenging conundrum in demonstrating the value other factors, issued a value assessment deter- proposition for personalized medicine. A solution is mination on drugs for multiple myeloma that was not yet apparent. largely based on population averages.60 Patient groups responded negatively to the report, noting Value Assessment Frameworks a lack of consideration of the clinical benefit of a drug to certain patients. As the Multiple Over the past several years, “value assessment Myeloma Research Foundation pointed out in its frameworks” have emerged as tools for supporting letter to ICER, “the promise of precision medicine health care decision-making by quantifying the is that each patient is unique and will consequently value of treatments, and these frameworks have respond to treatment differently based on begun to influence coverage and payment deci- their particular genetic profile and further under- sions. The frameworks, like other evidence-based standing of the biology of their disease.”61
The Personalized Medicine Report 37 The Changing Reimbursement Landscape Medicare Clinical Diagnostic Laboratory Tests for Diagnostics Payment System,” which was part of the Protecting Access to Medicare Act (PAMA), implemented Significant challenges also exist in establishing re-pricing and reporting requirements62 that payment rates for diagnostic tests that appro- further exacerbated the downward pressure on priately reflect the value they bring to care. Until utilization of these technologies. The rule lacks recently, payments for diagnostic and molecular mechanisms that capture the value of targeted tests, the backbone of personalized medicine, treatment, and may therefore threaten progress. were predictable and standardized, relying on payments based on “stacked codes.” However, recently, a number of coding and payment Value-Based Payment Models policy changes have led to significant changes CMS and private payers are also proposing new, in reimbursement for molecular diagnostic tests. “value-based” payment models, also known CMS’ decision, for example, to use “gapfill” as “alternative payment models” (APMs), that methodology, which allows regional contractors seek to drive improvements in care quality and to set prices for laboratory and molecular efficiency. Understanding the changes and diagnostic tests, coupled with other payment potential consequences these APMs will have on decisions, has resulted in decreased payment personalized medicine tests, pharmaceuticals, rates for many personalized medicine tests. This, and companion diagnostics is essential to ensure in turn, has placed a consistent downward pres- continued progress in personalized medicine sure on physicians and laboratories interested in and improvements to patient care. APMs should using novel, high-value molecular diagnostics encourage physicians to tailor care based on an to inform treatment decisions. individual’s genetics and other factors. The 2016 Clinical Laboratory Fee Schedule (CLFS) final rule entitled “Medicare Program:
38 The Challenges “I always tell my patients that genetic knowledge is power. It is not about good news or bad news, it is about understanding the underlying cause of disease and using it to tailor a road map of prevention.” — Charis Eng, M.D., Ph.D. Founding Chair, Genomic Medicine Institute, Cleveland Clinic
The Personalized Medicine Report 39 CLINICAL ADOPTION Despite rapid scientific and technological genomic-based research to health care.67, 68, 69 advancement, the health care system has been The Personalized Medicine Coalition (PMC) relatively slow to integrate personalized medicine also assembled a Health Care Working Group to into clinical practice.63 Survey data shows, for develop a road map for integration of personalized example, that only four out of 10 consumers medicine into health care,70 and the Interna- are aware of personalized medicine, and only 11 tional Consortium on Personalized Medicine (IC percent of patients say their doctor has discussed PerMed) has identified an index of barriers for or recommended personalized medicine treat- clinical adoption.71 ment options to them.64 Recent surveys have also Integrating personalized medicine into health shown that most health care organizations do care requires: increasing awareness and under- not have formalized plans to leverage advances standing of personalized medicine concepts in genomics and data analytics to personalize amongst the public and health care workforce; patient care, and are unprepared to implement placing a greater emphasis on patient perspec- personalized medicine programs.65, 66 Behind this tives; recognizing the value of molecular pathways lag in clinical adoption are novel challenges that in guiding care; building new infrastructure health care delivery systems are encountering as and information management processes; and they adapt to the new requirements, practices, reshaping health care delivery to ensure access to and standards associated with the field. personalized medicine technologies and services. Recently, a number of efforts to understand To successfully integrate personalized medicine how to best encourage the efficient clinical into health care, providers will need to implement adoption of personalized medicine have been a range of programs and processes (Figure 11) in launched. The National Academy of Medicine, for each of these areas. example, has issued several reports on translating
40 The Challenges Education and Awareness Pharmacists have also taken a proac- tive approach to education and awareness. Perhaps the greatest challenge to integrating Pharmacogenomics is now a required element personalized medicine into health care is a lack of every doctor of pharmacy curriculum in the of education and awareness among patients and U.S.,79 graduate programs in pharmacogenomics throughout the health care delivery community. and precision medicine are now common,80, 81 and Freely available educational resources are being certification programs are available regionally developed by a number of organizations72, 73, 74, 75, 76 and nationally.82, 83, 84, 85 that are presented in multiple formats based on the needs of different stakeholders. However, they must be accurate, trusted, and updated regularly. Patient Empowerment PMC, which represents all sectors of the health care The involvement of patients in their own treat- community, continues to work with personalized ment decisions and protection of their molecular medicine’s stakeholders to develop a content-rich information from being used in ways that would website that can serve as the most reliable source cause them concern, and, perhaps, long-term for personalized medicine knowledge.77 repercussions, such as discrimination, job loss, or Although many community education strategies loss of health insurance coverage, are also critical are clear, building awareness and knowledge will for the clinical adoption of personalized medicine. not be easy, especially among physicians and other Many health and research organizations in health care providers. In recognition of this reality, the public and private sectors are reconsidering the Genomic Medicine Institute at Cleveland Clinic current policies related to patient privacy and and others host accredited genetics education consent for the use of molecular information.86, 87 symposia for practicing health care providers. The Programs are being developed that will establish Mayo Clinic’s Center for Individualized Medicine the necessary partnerships among industry educates members of the health care team suppliers, providers, and patients and their families and patients about personalized medicine and to ensure that patient data are presented in ways its implications in practice through professional that are meaningful to each of these groups while development courses, conferences, and ongoing ensuring privacy. For example, biopharmaceu- education that is integrated into practice.78 These tical development and commercial outsourcing programs, however, reach only a fraction of the services company Quintiles has initiated a Global available population. Data Protection Program, which has issued global
The Personalized Medicine Report 41 FIGURE 11: PRINCIPLES FOR INTEGRATING PERSONALIZED MEDICINE INTO HEALTH CARE 1. Health care providers, payers, employers, and policymakers, as well as patients and their families, need to have a better understanding of personalized medicine concepts and technologies. 2. Policies and practices related to patient engagement, privacy, data pro- tections, and other ethical, legal, and societal issues regarding the use of individual molecular information must ensure appropriate consent and be acceptable to patients. 3. Best practices must be established for the collection and dissemination of evidence needed to demonstrate clinical utility of personalized medicine and ensure the recognition of its value to care. 4. Effective health care delivery infrastructure and data management systems should be developed and applied so that individual patient and clinical support information is comprehensive, useful, and user-friendly, and so that it can be used to guide clinical decisions. 5. Best practices for health care delivery approaches, processes, and program operations that ensure access to personalized medicine must be established and implemented.
42 The Challenges corporate policies for the “protection of personal Payers also need to understand financial information” and “data confidentiality” related and risk reduction endpoints within the body of to patient and proprietary information exchange evidence, along with patient survival and disease between industry and providers.88 progression information. Strategies for addressing Perhaps most importantly, practitioners are these challenges have begun to emerge. Forums recognizing that they need to regularly involve between payers and product developers, for patients in health care decision-making.89 Some example, may facilitate a better understanding of providers are developing genetic counseling the evidence requirements necessary for positive service policies to ensure that patients, early in coverage determinations. In 2015, the Molecular their care, are able to understand their individual Evidence Development Consortium (MED-C) was molecular information and its implications, so that launched to help bridge the gap between payers, they can make informed decisions regarding its providers, and industry in demonstrating the value disclosure and use before problems arise.90, 91, 92 of personalized treatment strategies by providing These developments are encouraging. a forum to discuss and develop plans to gather molecular data on individual patients along with Value Recognition thorough information about their treatments and clinical outcomes.95 While many stakeholders believe that personalized medicine provides benefits to patients and the health care system, payers and providers are still Infrastructure and often reluctant to change policies and practices Information Management without having convincing evidence of its clinical Effectively managing the massive amount of and economic value.93 To help build the evidence information associated with personalized medicine base for personalized medicine, regional Medicare and coordinating programmatic processes and contractor Palmetto GBA initiated the MolDx services related to its use are also major areas of Program in 2011 to establish unique identifiers need. Health care providers emphasize the need for molecular diagnostic tests to help facilitate for data management processes that are straight- claims processing and track utilization, as well forward, user-friendly, and save time for the health as to establish clinical utility expectations and to care workforce. Institutional personalized medicine complete technical assessments of published test program policies and processes also need to be data to determine clinical utility and coverage.94 coordinated across research and clinical programs.
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