throbber
CENTER FOR DRUG EVALUATION AND
`RESEARCH
`
`APPLICATION NUMBER:
`022063Orig1s000
`
`OTHER REVIEW(S)
`
`

`

`
`
`
`PMRIPMC Development Template I
`
`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`This template should be completed by the PMRJ'PMC Development Coordinator and included for each
`
`
`
`
`
`PMRfPMC in the Action Package.
`
`
`
`NDA/BLA #
`
`
`
`Product Name:
`
`
`
`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`Mydayis (mixed salts of amphetamine product) 12.5 mg, 25 mg extended-
`
`
`release capsules
`
`
`PMR/PMC Description:
`
`
`
`
`
`
`
`
`Pharmacokinetic study in 4 toS year olds
`
`
`
`
`
`
`
`
`PMR/PMC Schedule Milestones: Final Protocol Submission:
`
`
`Study/Trial Completion:
`
`
`Final Report Submission:
`Other: N/A
`
`
`
`
`
`
`
`09/01/2017
`
`
`12/31/2018
`
`06/30/2019
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1. During application review, explain why this issue is appropriate for a PMR/PMC instead of a pre-approval
`
`
`
`
`
`
`requirement. Cheek type below and describe.
`
`
`
`
`
`
`I:I Unmet need
`
`
`I:I Life—threatening condition
`
`
`
`
`I:I Long-term data needed
`
`
`
`
`
`
`I:I Only feasible to conduct post-approval
`
`
`
`
`
`E] Prior clinical experience indicates safety
`
`
`
`
`D Small subpopulation affected
`
`
`
`1:] Theoretical concern
`
`
`E Other
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Per PeRC guidance, the Sponsor is being allowed to defer this study.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2. Describe the particular review issue and the goal of the study/clinical trial. Ifthe study/clinical trial is a
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`FDAAA PMR, describe the risk. If the FDAAA PMR is created post-approval, describe the “new safety
`information.”
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`The study will provide information on the PK profile of Mydayis in 4 toS year olds.
`
`
`
`
`
`I PMR/PMC Development Template
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`
`
`
`
`Last Updated (SIB/ZONW Page 1 of 12
`
`

`

`
`NDA 022063
`
`
`
`
`3.
`
`
`
`
`
`
`
`
`
`If the study/clinical trial is a PMR, check the applicable regulation.
`
`
`
`
`
`
`13"not a PMR, skip to 4.
`
`
`
`
`
`— Which regulation?
`
`
`
`
`I:I Accelerated Approval (subpart I-I/E)
`
`
`
`
`|:| Animal Efficacy Rule
`
`
`
`
`
`IXI Pediatric Research Equity Act
`
`
`
`
`
`I:I FDAAA required safety study/clinical trial
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`If the PMR is a FDAAA safety study/clinical trial, does it: (check all that apply)
`
`
`
`
`
`
`
`
`
`
`
`
`E] Assess a known serious risk related to the use of the drug?
`
`
`
`
`
`
`
`
`
`
`
`
`
`[I Assess signals of serious risk related to the use of the drug?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:I Identify an unexpected serious risk when available data indicate the potential for a serious risk?
`
`
`
`
`
`“
`
`
`
`
`
`
`
`
`
`
`
`
`
`If the PMR is a FDAAA safety study/clinical trial, will it be conducted as:
`
`
`
`
`
`
`
`El Analysis of spontaneous postmarketing adverse events?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study/clinical trial (me if such an analysis will not be sufficient to assess
`
`
`
`
`or identify a serious risk
`
`
`
`
`
`
`
`
`
`
`I:I Analysis using pharmacovigilance system?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study/clinical trial type if. the new pharmacovigilance system that the FDA
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`is required to establish under section 505(k)(3) has not yet been established and is thus not sufficient
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`to assess this known serious risk, or has been established but is nevertheless not sufficient to assess
`
`
`
`
`or identify a serious risk
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`E] Study: all other investigations, such as investigations in humans that are not clinical trials as defined
`
`
`
`
`
`
`
`
`
`
`below (e.g., observational epidemiologic studies), animal studies, and laboratory experiments?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study wpe if. a study will not be sufficient to identify or assess a serious
`risk
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I] Clinical trial: any prospective investigation in which the sponsor or investigator determines the
`
`
`
`
`
`
`
`
`
`
`
`
`
`method of assigning investigational product or other interventions to one or more human subjects?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`4. What type of study or clinical trial is required or agreed upon (describe and check type below)? If the study
`
`
`
`
`
`
`
`
`
`or trial will be performed in a subpopulation, list here.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`A pharmacokinetic study in the preschool subpopulation is required for a new, lower (6.25mg)
`
`
`
`
`
`
`
`dose than those studied for approval.
`
`
`
`Required
`
`
`
`
`
`
`I] Observational pharmacoepidemiologic study
`
`
`
`I:I Registry studies
`
`
`
`
`
`
`
`I:I Primary safety study or clinical trial
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:I Pharmacogenetic or pharmacogenomic study or clinical trial if required to further assess safety
`
`
`
`
`
`I:I Thorough Q-T clinical trial
`
`
`
`
`
`
`
`
`
`I:I Nonclinical (animal) safety study (e.g., carcinogenicity, reproductive toxicology)
`
`
`
`
`
`
`
`
`
`
`
`I:I Nonclinical study (laboratory resistance, receptor affinity, quality study related to safety)
`
`
`
`
`
`
`IX Pharmacokinetic studies or clinical trials
`
`
`
`
`
`
`
`
`I:I Drug interaction or bioavailability studies or clinical trials
`
`
`
`I:I Dosing trials
`
`
`
`
`
`
`
`
`
`
`
`
`5. PMR/'PMC Development Template
`
`
`
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`Last Updated 6/23/201769—34—201—762311-204—7
`
`
`
`
`Page 2 of 12
`
`
`
`

`

`Continuation o
`
`
`n'on 4
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`El Additional data or analysis required for a previOusly submitted or expected study/clinical trial
`
`
`(provide explanation)
`
`
`
`
`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`[I Meta—analysis or pooled analysis ofprevious studies/clinical trials
`
`
`
`
`
`
`D Immunogenicity as a marker of safety
`
`
`
`
`C] Other (provide explanation)
`
`
`
`
`Agreed upon:
`
`
`
`
`
`
`
`
`
`[:I Quality study-without a safety endpoint (e.g., manufacturing, stability)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[:I Pharmacoepidemiologic study not related to safe drug use (e.g., natural history of disease, background
`
`
`
`
`rates of adverse events)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:I Clinical trials primarily designed to fin’ther define efficacy (e.g., in another condition, different disease
`
`
`
`
`
`
`
`
`
`
`severity, or subgroup) that are NOT required under Subpart HfE
`
`
`
`
`
`
`
`
`
`I: Dose—response study or clinical trial performed for effectiveness
`
`
`
`
`
`
`[:1 Nonclinical study, not safety-related (specify)
`
`El Other
`
`
`
`
`
`
`
`
`5.
`
`
`
`
`
`
`
`Is the PMR/PMC clear, feasible, and appropriate?
`
`
`
`
`
`
`
`
`
`
`
`E Does the study/clinical trial meet criteria for PMRs or PMCs?
`
`
`
`
`
`
`
`
`
`
`
`E Are the objectives clear from the description of the PMRfPMC?
`
`
`
`
`
`
`
`
`
`
`
`
`E Has the applicant adequately justified the choice of schedule milestone dates?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`E Has the applicant had sufficient time to review the PMRs/PMCS, ask questions, determine feasibility,
`
`
`
`
`
`
`and contribute to the development process?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`El Check if this form describes a FDAAA PMR that is a randomized controlled clinical trial
`
`
`
`
`
`
`
`
`
`
`
`Ifso, does the clinical trial meet thefollowing criteria?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[I There is a significant question about the public health risks of an approved drug
`
`
`
`
`
`
`
`
`
`
`
`I] There is not enough existing information to assess these risks
`
`
`
`
`
`
`
`
`
`
`E] Information cannot be gained through a different kind of investigation
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[I The trial will be appropriately designed to answer question about a drug‘s efficacy and safety, and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I] The trial will emphasize risk minimization for participants as the protocol is developed
`
`
`
`
`
`
`
`
`PMRIPMC Development Coordinator:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`E This PWPMC has been reviewedfor clarity and consistency, and is necessary tofizrlher refine the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`safety, efficacy, or optimal use ofa drug. or to ensure consistency and reliability ofdrug quality.
`
`
`
`
`(signature line for BLAS)
`
`
`
`
`
`
`
`I PMRJ'PMC Development Template
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`Last Updated 6/23,:‘20176f‘23429l36fi23429fi
`
`
`
`
`
`Page 3 of 12
`
`
`
`

`

`
`
`
`PMR/PMC Development Template II
`
`
`
`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`This template should be completed by the PMR/PMC Development Coordinator and included for each
`
`
`
`
`
`PMR/PMC in the Action Package.
`
`
`
`
`NDA/BLA #
`
`Product Name:
`
`
`
`
`
`
`
`
`
`
`
`NDA 022063 Mydayis (mixed salts of amphetamine product) extended-
`
`
`release capsules
`
`
`PMR/PMC Description:
`
`
`
`
`
`
`
`
`
`
`Efficacy and safety study in 4 ms year olds
`
`
`
`PMR/PMC Schedule Milestones: Final Protocol Submission:
`
`
`
`
`
`
`
`Study/Trial Completion:
`
`
`Final Report Submission:
`Other: N/A
`
`
`
`
`
`
`
`09/01/2017
`
`
`12/31/2018
`
`06/30/2019
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`6. During application review, explain why this issue is appropriate for a PMR/PMC instead of a pre-approval
`
`
`
`
`
`
`requirement. Check type below and describe.
`
`
`
`
`
`
`I] Unmet need
`
`
`I:I Life-threatening condition
`
`
`
`
`I:| Long-term data needed
`
`
`
`
`
`
`D Only feasible to conduct post-approval
`
`
`
`
`
`Prior clinical experience indicates safety
`
`
`
`
`IX Small subpopulation affected
`
`
`
`I:I Theoretical concern
`
`
`C] Other
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Per PeRC guidance, the Sponsor is being allowed to defer this study.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`7. Describe the particular review issue and the goal of the study/clinical trial. If the study/clinical trial is a
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`FDAAA PMR, describe the risk. If the FDAAA PMR is created post-approval, describe the “new safety
`information.”
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Drug use data demonstrates that 4 and 5 year old children are receiving XR and IR amphetamine products
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`simultaneously. Given that information, it is likely that Mydayis, a 16 hour dosage form, will be
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`prescribed for children who received the shorter dosage forms. The study will provide data to inform
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`clinicians about the safety and efficacy of a new lower dose of Mydayis in 4 ms year olds and help guide
`
`
`
`
`
`
`
`
`
`
`
`them should they choose to prescribe the medication.
`
`
`
`
`f PMR/PMC Development Template
`
`
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`
`Last Updated 6/23/20176/23/20—1—16/2—3/20—1—1
`
`
`
`
`
`Page 4 of 12
`
`
`
`

`

`
`NDA 022063
`
`
`
`8.
`
`
`
`
`
`
`
`
`
`
`
`
`If the study/clinical trial is a PMR, check the applicable regulation.
`
`
`
`
`
`
`Ifnot a PMR, skip to 4.
`
`
`
`
`
`— Which regulation?
`
`
`
`
`E] Accelerated Approval (subpart H/E)
`
`
`
`
`El Animal Efficacy Rule
`
`
`
`
`
`E Pediatric Research Equity Act
`
`
`
`
`
`[I FDAAA required safety study/clinical trial
`
`
`
`
`
`—
`
`—
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`If the PMR is a FDAAA safety studylclinical trial, does it: (check all that apply)
`
`
`
`
`
`
`
`
`
`
`
`
`El Assess a known serious risk related to the use of the drug?
`
`
`
`
`
`
`
`
`
`
`
`
`
`El Assess signals of serious risk related to the use of the drug?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`El Identify an unexpected serious risk when available data indicate the potential for a serious risk?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`If the PMR is a FDAAA safety study/clinical trial, will it be conducted as:
`
`
`
`
`
`
`
`I] Analysis of spontaneous postmarketing adverse events?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study/clinical trial type if such an analysis will not be sufficient to assess
`
`
`
`
`or identify a serious risk
`
`
`
`
`
`
`
`
`
`
`I:I Analysis using pharmacovigilance system?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study/clinical trial type if: the new pharrnacovigilance system that the FDA
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`is required to establish under section 505(k)(3) has not yet been established and is thus not sufficient
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`to assess this known serious risk, or has been established but is nevertheless not sufficient to assess
`
`
`
`
`or identify a serious risk
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:] Study: all other investigations, such as investigations in humans that are not clinical trials as defined
`
`
`
`
`
`
`
`
`
`
`below (e.g., observational epidemiologic studies), animal studies, and laboratory experiments?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study type if: a study will not be sufficient to identify or assess a serious
`risk
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I: Clinical trial: any prospective investigation in which the sponsor or investigator determines the
`
`
`
`
`
`
`
`
`
`
`
`
`
`method of assigning investigational product or other interventions to one or more human subjects?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`9. What type of study or clinical trial is required or agreed upon (describe and check type below)? If the study
`
`
`
`
`
`
`
`
`
`or trial will be performed in a subpopulation, list here.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`A 4-week safety (and efficacy) trial evaluating Mydayis in 4 to 5 years old attention deficit
`
`
`
`
`hyperactivity disorder patients
`
`
`
`
`
`
`
`Required
`
`
`
`I:I Observational pharmacoepidemiologic study
`
`
`
`I:I Registry studies
`
`
`
`
`
`
`
`IZI Primary safety study or clinical trial
`
`
`
`
`
`
`
`
`
`
`
`
`
`I] Pharmacogenetic or pharrnacogenomic study or clinical trial if required to further assess safety
`
`
`
`
`
`I] Thorough Q-T clinical trial
`
`
`
`
`
`
`
`
`
`[I Nonclinical (animal) safety study (e.g., carcinogenicity, reproductive toxicology)
`
`
`
`
`
`
`
`
`
`
`
`I: Nonclinical study (laboratory resistance, receptor affinity, quality study related to safety)
`
`
`
`
`
`
`I] Pharmacokinetic studies or clinical trials
`
`
`
`
`
`
`
`
`I] Drug interaction or bioavailability studies or clinical trials
`
`
`
`I: Dosing trials
`
`
`
`
`
`
`
`
`
`
`
`I PMR/PMC Development Template
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`
`Last Updated 6/23/20176/23301—76231129l4
`
`
`
`Page 5 of 12
`
`
`
`

`

`@finuafion 0t destian 4
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`E] Additional data or analysis required for a previously submitted or expected study/clinical trial
`
`
`(provide explanation)
`
`
`
`
`
`
`
`
`
`
`
`[:I Meta-analysis or pooled analysis of previous studies/clinical trials
`
`
`
`
`
`
`E] Immunogenicity as a marker of safety
`
`
`
`
`C] Other (provide explanation)
`
`
`
`NDA 022063
`
`
`
`
`
`
`Agreed upon:
`
`
`
`
`
`
`
`
`
`D Quality study without a safety endpoint (e.g., manufacturing, stability)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`El Pharmaeoepiderniologic study not related to safe drug use (e.g., natural history of disease, background
`
`
`
`
`rates of adverse events)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[I Clinical trials primarily designed to further define efficacy (e. g., in another condition, different disease
`
`
`
`
`
`
`
`
`
`
`severity, or subgroup) that are NOT required under Subpart HE
`
`
`
`
`
`
`
`
`
`E] Dose—response study or clinical trial performed for effectiveness
`
`
`
`
`
`
`I:I Nonclinical study, not safety-related (specify)
`
`
`
`
`
`D Other
`
`
`
`
`
`
`
`
`
`10. Is the PMR/PMC clear, feasible, and appropriate?
`
`
`
`
`
`
`
`
`
`
`
`E Does the study/clinical trial meet criteria for PMRs or PMUS?
`
`
`
`
`
`
`
`
`
`
`
`IX Are the objectives clear from the description of the PMRJPMC?
`
`
`
`
`
`
`
`
`
`
`
`
`12] Has the applicant adequately justified the choice of schedule milestone dates?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`E Has the applicant had sufficient time to review the PMRSIPMCS, ask questions, determine feasibiIity,
`
`
`
`
`
`
`and contribute to the development process?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`E] Check if this form describes a FDAAA PMR that is a randomized controlled clinical trial
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ifso, does the clinical trial meet thefollowing criteria?
`
`
`
`
`
`
`
`
`
`
`
`
`
`[I There is a significant question about the public health risks of an approved drug
`
`
`
`
`
`
`
`
`
`
`
`1:] There is not enough existing information to assess these risks
`
`
`
`
`
`
`
`
`
`
`D Information cannot be gained through a different kind of investigation
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CI The trial will be appropriately designed to answer question about a drug’s efficacy and safety, and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`E] The trial will emphasize risk minimization for participants as the protocol is developed
`
`
`
`
`
`
`
`
`PMRIPMC Development Coordinator:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`This PAIR/PMC has been reviewedfor clarity and consistency, and is necessary tofiirther refine the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`safegi, eflieacy, or optimal use ofa drug, or to ensure consistency and reliability ofdrug quality.
`
`
`
`
`
`
`(signature line for BLAs)
`
`
`
`
`
`
`I PMR/PMC Development Template
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`
`
`
`Last Updated @3/20176r'i23yQO-1—161-237L20-1—7
`
`
`
`Page 6 of 12
`
`
`
`

`

`
`
`
`
`PMR/PMC Development Template III
`
`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`This template should be completed by the PMR/PMC Development Coordinator and included for each
`
`
`
`
`
`PMR/PMC in the Action Package.
`
`
`
`
`NDA/BLA #
`
`Product Name:
`
`
`
`.
`
`PMR/PMC Description:
`
`
`
`
`
`
`
`
`
`
`
`NDA 022063 Mydayis (mixed salts of amphetamine product) extended-
`
`
`release capsules
`
`
`
`
`
`
`
`
`
`
`
`Efficacy and safety study of 6.25mg dose in 6 to 12 year olds
`
`
`
`PMR/PMC Schedule Milestones: Final Protocol Submission:
`
`
`
`
`
`
`
`Study/Trial Completion:
`
`
`Final Report Submission:
`Other: N/A
`
`
`
`
`
`
`
`09/01/2017
`
`12/31/201 8
`06/30/2019
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`11. During application review, explain why this issue is appropriate for a PMR/PMC instead of a pre—approval
`
`
`
`
`
`
`requirement. Check type below and describe.
`
`
`
`
`
`
`[I Unmet need
`
`
`[I Life-threatening condition
`
`
`
`
`[I Long-term data needed
`
`
`
`
`
`
`I] Only feasible to conduct post-approval
`
`
`
`
`IE Prior clinical experience indicates safety
`
`
`
`
`I] Small subpopulation affected
`
`
`
`D Theoretical concern
`
`
`El Other
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Pro-approval review of Mydayis 12.5 and 25mg doses demonstrate high exposure levels and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`adverse reactions of severe insomnia and decreased appetite in 6 to 12 year olds. Mydayis will be
`
`
`
`
`
`
`
`
`
`
`
`
`
`approved with a limitation of use; use in less than 12 years is not recommended.
`
`
`
`Therefore, safety of a new, lower 6.25mg dose should be evaluated in that age group.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`12. Describe the particular review issue and the goal of the study/clinical trial. If the study/clinical trial is a
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`FDAAA PMR, describe the risk. Ifthe FDAAA PMR is created post-approval, describe the “new safety
`information.”
`
`
`
`
`
`
`See question 11.
`
`
`
`
`
`
`l PMR/PMC Development Template
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`
`
`Last Updated 6/23/20176/33QQJ46/23/29—1—2
`
`
`
`Page 7 of 12
`
`
`
`

`

`
`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`
`
`13. If the study/clinical trial is a PMR, check the applicable regulation.
`
`
`
`
`
`
`Ifnot a PMR, skip to 4'.
`
`
`
`
`
`— Which regulation?
`
`
`
`
`I:I Accelerated Approval (subpart HE)
`
`
`
`
`D Animal Efficacy Rule
`
`
`
`
`
`E Pediatric Research Equity Act
`
`
`
`
`
`El FDAAA required safety study/clinical trial
`
`
`
`
`
`—
`
`—
`
`
`
`
`
`
`
`
`
`
`
`
`
`If the PMR is a FDAAA safety study/clinical trial, does it: (check all that apply)
`
`
`
`
`
`
`
`
`
`
`
`
`[:I Assess a lmown serious risk related to the use of the drug?
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:I Assess signals of serious risk related to the use of the drug?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[I Identify an unexpected serious risk when available data indicate the potential for a serious risk?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`If the PMR is a FDAAA safety study/clinical trial, will it be conducted as:
`
`
`
`
`
`
`
`[I Analysis of spontaneous postmarketing adverse events?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study/clinical trial,r type if: such an analysis will not be sufficient to assess
`
`
`
`
`or identify a serious risk
`
`
`
`
`
`
`
`
`
`
`[I Analysis using pharmacovigilance system?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study/clinical trial type if: the new pharmacovigilance system that the FDA
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`is required to establish under section 505 (k)(3) has not yet been established and is thus not sufficient
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`to assess this known serious risk, or has been established but is nevertheless not sufficient to assess
`
`
`
`
`or identify a serious risk
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[:I Study: all other investigations, such as investigations in humans that are not clinical trials as defined
`
`
`
`
`
`
`
`
`
`
`below (e. g., observational epidemiologic studies), animal studies, and laboratory experiments?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study type if: a study will not be sufficient to identify or assess a serious
`risk
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[I Clinical trial: any prospective investigation in which the sponsor or investigator determines the
`
`
`
`
`
`
`
`
`
`
`
`
`
`method of assigning investigational product or other interventions to one or more human subjects?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`14. What type of study or clinical trial is required or agreed upon (describe and check type below)? If the study
`
`
`
`
`
`
`
`
`
`or trial will be performed in a subpopulation, list here.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`' A 4-week safety (and efficacy) trial evaluating 6.25mg Mydayis in 6 to 12 years old attention
`
`
`
`
`
`deficit hyperactivity disorder patients
`
`
`
`
`Required
`
`
`
`I:I Observational phannacoepidemiologic study
`
`
`
`I:I Registry studies
`
`
`
`
`
`
`
`IE Primary safety study or clinical trial
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:I Pharmacogenetic or pharrnacogenomic study or clinical trial if required to further assess safety
`
`
`
`
`
`I: Thorough Q-T clinical trial
`
`
`
`
`
`
`
`
`
`El Nonclinical (animal) safety study (e.g., carcinogenicity, reproductive toxicology)
`
`
`
`
`
`
`
`
`
`
`
`I:I Nonclinical study (laboratory resistance, receptor affinity, quality study related to safety)
`
`
`
`
`
`
`I:I Pharmacokinetic studies or clinical trials
`
`
`
`
`
`
`
`
`I:I Drug interaction or bioavailability studies or clinical trials
`
`
`
`I:I Dosing trials
`
`
`
`
`
`
`
`
`
`
`
`
`I PMRJIPMC Development Template
`
`
`
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`
`Last Updated 6/23/2017'6i123i12Q4—716.123M-‘LlQ-l—il
`
`
`
`
`Page 8 of 12
`
`

`

`Continuation 0
`
`
`esrion 4
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`El Additional data or analysis required for a previously submitted or expected study/clinical trial
`
`
`(provide explanation)
`
`
`
`
`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`I] Meta-analysis or pooled analysis of previous studies/clinical trials
`
`
`
`
`
`
`D Immunogenicity as a marker of safety
`
`
`
`
`I:I Other (provide explanation)
`
`
`
`
`
`
`Agreed upon:
`
`
`
`
`
`
`
`
`
`I:] Quality study Without a safety endpoint (e.g., manufacturing, stability)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`El Pharmacoepidemiologic study not related to safe drug use (e.g., natural history of disease, background
`
`
`
`
`rates of adverse events)
`_
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[I Clinical trials primarily designed to further define efficacy (e.g., in another condition, different disease
`
`
`
`
`
`
`
`
`
`
`severity, or subgroup) that are NOT required under Subpart HfE
`
`
`
`
`
`
`
`
`
`I:I Dose-response study or clinical trial performed for effectiveness
`
`
`
`
`
`
`I:I Nonclinical study, not safety-related (specify)
`
`
`
`
`
`
`D Other
`
`
`
`
`
`
`
`
`
`
`15. Is the PMR/PMC clear, feasible, and appropriate?
`
`
`
`
`
`
`
`
`
`
`
`E Does the study/clinical trial meet criteria for PMRs or PMCs'!
`
`
`
`
`
`
`
`
`
`
`
`E Are the objectives clear from the description of the PMRfPMC?
`
`
`
`
`
`
`
`
`
`
`
`
`E Has the applicant adequately justified the choice of schedule milestone dates?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Has the applicant had sufficient time to review the PMRs/PMCS, ask questions, determine feasibility,
`
`
`
`
`
`
`and contribute to the development process?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:I Check if this form describes a FDAAA PMR that is a randomized controlled clinical trial
`
`
`
`
`
`
`
`
`
`
`
`
`Ifso, does the clinical trial meet thefollowing criteria?
`
`
`
`
`
`
`
`
`
`
`
`
`
`1:] There is a significant question about the public health risks ofan approved drug
`
`
`
`
`
`
`
`
`
`
`
`D There is not enough existing information to assess these risks
`
`
`
`
`
`
`
`
`
`
`D Information cannot be gained through a different kind ofinvestigation
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`D The trial will be appropriately designed to answer question about a drug’s efficacy and safety, and
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`El The trial will emphasize risk minimization for participants as the protocol is developed
`
`
`
`
`
`
`
`
`
`
`PMRJPMC Development Coordinator:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`E This PWPMC has been reviewedfor clarity and consistency, and is necessary tofiirther refine the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`safety. eflz‘cacy, or optimal use ofa drug or to ensure consistency and reliability ofdrug quality.
`
`
`
`
`
`
`(signature line for BLAS)
`
`
`
`
`
`
`
`] PMR/PMC Development Template
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`
`
`
`
`Last Updated 6123/2017W Page 9 of 12
`
`
`
`
`
`

`

`
`
`
`PMR/PMC Development Template IV
`
`
`
`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`This template should be completed by the PMR/PMC Development Coordinator and included for each
`
`
`
`
`
`PMR/PMC in the Action Package.
`
`
`
`
`NDA/BLA #
`
`Product Name:
`
`
`
`
`
`
`
`
`
`
`
`NDA 022063 Mydayis (mixed salts of amphetamine product) extended-
`
`
`release capsules
`
`
`PMR/PMC Description:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Long-term safety study, at least 1 year in length, in 4 to 5 year olds
`
`
`
`
`
`
`
`
`PMR/PMC Schedule Milestones: Final Protocol Submission:
`
`
`Study/Trial Completion:
`
`
`
`Final Report Submission:
`Other:
`
`
`
`
`09/01/2018
`
`12/31/2019
`06/30/2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`16. During application review, explain why this issue is appropriate for a PMIUPMC instead of a pre-approval
`
`
`
`
`
`
`requirement. Check type below and describe.
`
`
`
`
`[:I Unmet need
`
`
`
`D Life—threatening condition
`
`
`
`
`1:] Long-term data needed
`
`
`
`
`
`
`[:I Only feasible to conduct post-approval
`
`
`
`
`
`El Prior clinical experience indicates safety
`
`
`
`
`Small subpopulation affected
`
`
`
`El Theoretical concern
`
`
`C] Other
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Per PeRC guidance, the Sponsor is being allowed to defer this study.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`17. Describe the particular review issue and the goal of the study/clinical trial. If the study/clinical trial is a
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`FDAAA PMR, describe the risk. If the FDAAA PMR is created post-approval, describe the “new safety
`information.”
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`It is unclear if the 6- month long-term open-label study (Study 308) will provide enough data to measure
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`grovvth suppression (as assessed by change in height and weight) during 6 months time. The duration of the
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`long-term safety study needs to be of Sufficient length to assess effects on growth in the proposed
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`population (i.e- a minimum of 1 year). We also request a 6 month interim analysis to be provided to the
`
`
`
`
`Division.
`
`
`
`
`
`
`I PMR/PMC Development Template
`
`
`
`
`
`
`Last Updated 6/23/20176R9/20—146/B/20H
`
`
`
`
`Page 10 of 12
`
`
`
`Reference ID: 4119537
`Reference ID: 4119537
`
`

`

`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`18. If the study/clinical trial is a PIVIR, check the applicable regulation.
`
`
`
`
`
`
`Ifnot 0 PAIR, skip to 4.
`
`
`
`
`
`~ Which regulation?
`
`
`
`
`[j Accelerated Approval (subpart HIE)
`
`
`
`
`El Animal Efficacy Rule
`
`
`
`
`
`Pediatric Research Equity Act
`
`
`
`
`
`[I FDAAA required safety study/clinical trial
`
`
`
`
`
`—
`
`-
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`If the PMR is a FDAAA safety study/clinical trial, does it: (check all that apply)
`
`
`
`
`
`
`
`
`
`
`
`
`[:I Assess a known serious risk related to the use of the drug?
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:I Assess signals of serious risk related to the use of the drug?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`El Identify an unexpected serious risk When available data indicate the potential for a serious risk?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`If the PMR is a FDAAA safety study/clinical trial, will it be conducted as:
`
`
`
`
`
`
`
`D Analysis of smntaneous mstmarketing adverse events?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study/clinical trial {we if: such an analysis will not be sufficient to assess
`
`
`
`
`or identify a serious risk
`
`
`
`
`
`
`
`
`I:I Analysis using phannacovigilance system?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study/clinical trial type if the new pharmacovigilance system that the FDA
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`is required to establish under section 505(k)(3) has not yet been established and is thus not sufficient
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`to assess this known serious risk, or has been established but is nevertheless not sufficient to assess
`
`
`
`
`or identify a serious risk
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I] Study: all other investigations, such as investigations in humans that are not clinical trials as defined
`
`
`
`
`
`
`
`
`
`
`below (e.g., observational epidemiologic studies), animal studies, and laboratory experiments?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Do not select the above study {me if: a study will not be sufficient to identify or asseSS a serious
`risk
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[I Clinical trial: any prospective investigation in which the sponsor or investigator determines the
`
`
`
`
`
`
`
`
`
`
`
`
`
`method of assigning investigational product or other interventions to one or more human subjects?
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`19. What type of study or clinical trial is required or agreed upon (describe and check type below)? Ifthe study
`
`
`
`
`
`
`
`
`
`or trial will be performed in a subpopulation, list here.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`A long—term open-label safety study to evaluate growth suppression.
`
`
`
`
`
`
`
`Required
`
`
`
`E] Observational pharmacoepidemiologic study
`
`
`
`I] Registry studies
`
`
`
`
`
`
`
`E Primary safety study or clinical trial
`
`
`
`
`
`
`
`
`
`
`
`
`
`[:1 Pharmacogenetic or pharmacogenoruic study or clinical trial if required to firrther assess safety
`
`
`
`
`
`E] Thorough Q—T clinical trial
`
`
`
`
`
`
`
`
`
`[:I Nonclinical (animal) safety study (e.g., carcinogenicity, reproductive toxicology)
`
`
`
`
`
`
`
`
`
`
`
`I:I Nonclinical study (laboratory resistance, receptor affinity, quality study related to safety)
`
`
`
`
`
`
`[I Pharmacokinetic studies or clinical trials
`
`
`
`
`
`
`
`
`E] Drug interaction or bioavailability studies or clinical trials
`
`
`
`I:I Dosing trials
`
`
`
`
`
`
`
`
`
`
`| PMR/PMC Development Template
`Reference ID: 4119537
`Reference ID: 4119537
`
`
`
`
`
`Last Updated 6/23/2017me
`
`
`
`
`Page 11 of 12
`
`
`
`

`

`Continuation o
`
`
`estion 4
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`El Additional data or analysis required for a previously submitted or expected study/clinical trial
`
`
`(provide explanation)
`
`
`
`NDA 022063
`
`
`
`
`
`
`
`
`
`
`
`
`El Meta-analysis or pooled analysis of previous studies/clinical trials
`
`
`
`
`
`
`El Immunogenicity as a marker of safety
`
`
`
`
`D Other (provide explanation)
`
`
`
`
`
`
`Agreed upon:
`
`
`
`
`
`
`
`
`
`I:I Quality study without a safety endpoint (e.g., manufacturing, stability)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:I Pharmacoepidemiologic study not related to safe drug use (e.g., natural history of disease, background
`
`
`
`
`rates of adverse events)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I:I Clinical trials primarily designed to fiirther define efficacy (e.g., in another condition, different disease
`
`
`
`
`
`
`
`
`
`
`severity, or subgroup) that are NOT required under Subpart I-L’E
`
`
`
`
`
`
`
`
`
`I:I Dose-response study or clinical trial performed for effectiveness
`
`
`
`
`
`
`[I Nonclinical study, not safety—related (specify)
`
`
`
`
`
`
`I:I Other
`
`
`
`
`
`
`
`
`
`
`20. Is the PMR/PMC clear, feasible, and appropriate?
`
`
`
`
`
`
`
`
`
`
`
`[Z Does the study/clinical trial meet criteria for PMRs or PMCs?
`
`
`
`
`
`
`
`
`
`
`
`IE Are the objectives clear from th

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket