Rivaroxaban, tablet, 10 mg, Xarelto®, March 2009
Public summary document for Rivaroxaban, tablet, 10 mg, Xarelto®, March 2009
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Public Summary Document
Product: Rivaroxaban, tablet, 10 mg,
                           Xarelto®
Sponsor: Bayer Australia Limited
Date of PBAC Consideration: March 2009
1. Purpose of Application
                           The submission sought a section 85 Authority required (Streamlined)
                           listing and a section 100 (s100) Private Hospital Authority
                           required listing for rivaroxaban for prevention of venous
                           thromboembolism (VTE) in a patient undergoing hip or knee
                           replacement.
                           Highly Specialised Drugs are medicines for the treatment of chronic
                           conditions, which, because of their clinical use or other special
                           features, are restricted to supply to public and private hospitals
                           having access to appropriate facilities.
2. Background
                           This was the first time rivaroxaban had been considered by the
                           PBAC.
3. Registration Status
                           Rivaroxaban was TGA registered on 24 November 2008 for the
                           prevention of venous thromboembolism (VTE) in adult patients who
                           have undergone major orthopaedic surgery of the lower limbs
                           (elective total hip replacement, treatment for up to 5 weeks;
                           elective total knee replacement, treatment for up to 2
                           weeks).
4. Listing Requested and PBAC’s View
Section 85 Authority Required (STREAMLINED)
                           For the prevention of venous thromboembolism in an adult patient
                           undergoing elective total hip replacement surgery (treatment for up
                           to 5 weeks);
                           For the prevention of venous thromboembolism in an adult patient
                           undergoing elective total knee replacement surgery, (treatment for
                           up to 2 weeks).
                           Section100 (Highly Specialised Drug)
Private hospital authority required
                           For the prevention of venous thromboembolism in an adult patient
                           undergoing elective total hip replacement surgery (treatment for up
                           to 5 weeks);
                           For the prevention of venous thromboembolism in an adult patient
                           undergoing elective total knee replacement surgery, (treatment for
                           up to 2 weeks).For PBAC’s view, see Recommendation and
                              Reasons.
5. Clinical Place for the Proposed Therapy
                           Rivaroxaban will provide an oral alternative to the currently
                           available injectable anti-thrombotic drugs used to prevent venous
                           thromboembolism (VTE) in patients who have undergone major
                           orthopaedic surgery of the lower limb (total hip or knee
                           replacement).
6. Comparator
                           The submission nominated enoxaparin as the main comparator. The
                           PBAC accepted this as appropriate.
7. Clinical Trials
                           The submission presented two randomised key trials to support the
                           listing of rivaroxaban for total hip replacement and one randomised
                           trial to support the listing of rivaroxaban for total knee
                           replacement, as follows:
Total hip replacement:
- RECORD 1: comparing rivaroxaban 10 mg for 35 days with enoxaparin 40 mg for 35 days, consistent with current best practice; and
- RECORD 2: comparing rivaroxaban 10 mg for 35 days with enoxaparin 40 mg for 12 ± 2 days
Total knee replacement:
- RECORD 3: comparing rivaroxaban 10 mg for 12 ± 2 days with enoxaparin 40 mg for 13 ± 2 days, consistent with both current and best practice.
                           The PBAC agreed that the duration of enoxaparin use in the trials
                           submitted (medians ranged from 13 to 36 days in hip replacement and
                           13 days in knee replacement) reflected the range of durations in
                           Australian practice.
                           The trials published at the time of the submission, are as follows:
                           
                        
| Trial/First author | Protocol title | PublicationCitation | 
| Direct randomised trial(s) | ||
| RECORD 1 | ||
| Eriksson, B. et al | Oral Rivaroxaban Compared with Subcutaneous Enoxaparin for Extended Thromboprophylaxis after Total Hip Arthroplasty: The RECORD1 Trial. | ASH Annual Meeting Abstracts 2007, vol. 110, no. 11, Abstract 6, 2007. | 
| Eriksson, B. et al | Rivaroxaban versus enoxaparin for thromboprophylaxis after hip arthroplasty. | New England Journal of Medicine, 358(26): 2765-2775, 2008. | 
| RECORD 2 | ||
| Kakkar A. K. et al. 2007 | Extended Thromboprophylaxis with Rivaroxaban Compared with Short-Term Thromboprophylaxis with Enoxaparin after Total Hip Arthroplasty: The RECORD 2 Trial. | ASH Annual Meeting Abstracts 2007, vol. 110, no. 11, Abstract 307. | 
| RECORD 3 | ||
| Lassen M. R, et al | Rivaroxaban - An Oral, Direct Factor Xa Inhibitor - for Thromboprophylaxis after Total Knee Arthroplasty: The RECORD3 Trial. | ASH Annual Meeting Abstracts 2007, vol. 110, no. 11, Abstract 308. | 
| Lassen M. R, et al | Rivaroxaban versus enoxaparin for thromboprophylaxis after total knee arthroplasty. | New England Journal of Medicine, 358(26): 2776-2786, 2008. | 
                           ASH=American Society of Hematology; DVT=deep vein thrombosis;
                           PE=pulmonary embolism; VTE=venous thromboembolism.
8. Results of Trials
The results of the trials and associated reports presented in the submission are described
                           below:
Total hip replacement
The results for the primary composite outcome, total VTE, in RECORD 1 and RECORD 2,
                           demonstrated that rivaroxaban was significantly superior in efficacy to enoxaparin
                           in the prevention of VTE in adult patients undergoing elective total hip replacement
                           over the duration of the trial (median time of 13 to 36 days). The disaggregated components
                           of this endpoint also favoured rivaroxaban. The PBAC noted the observed risk difference
                           in each of the trials (RECORD 1: -2.6%, 95%CI -3.7%, -1.5%; RECORD 2: -7.3%, 95%CI
                           -9.4%, -5.2%) was likely to be significant given the incidence of total VTE in the
                           comparator group of 3.7% and 9.3% for RECORD 1 and RECORD 2 respectively.
Total knee replacement
The results for the primary composite outcome, total VTE, in RECORD 3 demonstrated
                           that rivaroxaban was significantly superior in efficacy to enoxaparin in the prevention
                           of VTE in adult patients undergoing elective total knee replacement over the duration
                           of the trial (median time of 13 days). The observed risk difference (-9.2%, 95% CI
                           -12.4%, -5.9%) was likely to be regarded as clinically significant given the incidence
                           of total VTE in the enoxaparin treatment group was 18.9%.
The PBAC noted the results for total VTE in all three trials were heavily weighted
                           by the larger proportion of asymptomatic deep vein thrombosis (DVT) and distal DVT.
                           However, the secondary composite outcome measures, which excluded all distal DVT,
                           also supported the superior efficacy of rivaroxaban over enoxaparin in patients undergoing
                           total hip replacement (THR) and total knee replacement (TKR).
Between 30-35% of randomised participants were excluded from the analysis of the primary
                           outcome in each of the trials. The main reason for exclusion was inadequate assessment
                           (either no venography or unilateral or non-evaluable venography). Excluded participants
                           were evenly distributed between treatment groups in all of the trials and the reasons
                           for exclusion were also similar between groups. Comparison of the baseline characteristics
                           between the safety population and the primary efficacy analysis set for each trial
                           failed to detect any differential loss to follow-up between the treatment groups.
The primary outcome for all of the RECORD trials was total VTE, a composite endpoint
                           including any symptomatic or asymptomatic DVT (proximal and/or distal), non-fatal
                           pulmonary embolism (PE), and death from all causes. The PBAC noted the recommendation
                           in current international guidelines is to use a composite, including all proximal
                           DVT, symptomatic non-fatal pulmonary embolism (PE), VTE related death or death due
                           to any cause, ± symptomatic distal DVT. Asymptomatic distal DVT was not included in
                           the recommended composite endpoints in these guidelines. Although the primary composite
                           outcome in all three trials included asymptomatic distal DVT, both the disaggregated
                           components of this endpoint, and a number of secondary composite outcomes which did
                           not include all distal DVT, supported the superiority of rivaroxaban over enoxaparin
                           in all of the trials included in the submission.
The submission provided data on the incidence of treatment-emergent major bleeding
                           and a summary of other adverse events in each of the RECORD trials. The safety of
                           prolonged use of rivaroxaban has not been evaluated.
A summary of the treatment emergent bleeding events in the direct randomised trials
                           is shown in the table below:
                        
| Trial ID | Rivaroxaban n with event/N (%) | Enoxaparin n with event/N (%) | Risk Difference RD % (95%CI) | RR (95% CI) | 
| Total hip replacement | ||||
| RECORD 1 | ||||
| Major bleeding a | 6/2209 (0.3) | 2/2224 (<0.1) | 0.18 (-0.07,0.43) | 3.02 (0.61,15.0) | 
| Any bleeding | 133/2209 (6.0) | 131/2224 (5.9) | 0.13 (-1.26,1.52) | 1.02 ( 0.81,1.29) | 
| Clinically relevant bleeding | 70/2209 (3.2) | 56/2224 (2.5) | 0.65 (-0.33,1.63) | 1.26 (0.89,1.78) | 
| Non major bleeding | 128/2209 (5.2) | 129/2224 (5.8) | -0.01(-1.38,1.37) | 1.00 (0.79,1.27) | 
| Non major clinically relevant bleeding | 65/2209 (2.9) | 54/2224 (2.4) | 0.51(-0.44,1.47) | 1.21 (0.85,1.73) | 
| Other non major bleeding | 71/2209 (3.2) | 77/2224 (3.5) | -0.25 (-1.31,0.81) | 0.93 (0.68,1.28) | 
| Major bleeding including surgical site bleeding b | 40/2209 (1.8) | 33/2224 (1.5) | 0.33 (-0.42,1.08) | 1.22 (0.77,1.93) | 
| RECORD 2 | ||||
| Major bleeding a | 1/1228 (<0.1) | 1/1229 (<0.1) | 0.00 (-0.00 0.00) | 1.00 (0.06,5.98) | 
| Any bleeding | 81/1228 (6.6) | 68/1229 (5.5) | 1.06 (-0.82,2.95) | 1.19 (0.87,1.63) | 
| Clinically relevant bleeding | 41/1228 (3.3) | 34/1229 (2.8) | 0.57 (-0.79,1.93) | 1.21 (0.77,1.89) | 
| Non major bleeding | 80/1228 (6.5) | 67/1229 (5.5) | 1.06 (-0.81,2.94) | 1.20 (0.87,1.64) | 
| Non major clinically relevant bleeding | 40/1228 (3.3) | 33/1229 (2.7) | 0.57 (-0.77,1.91) | 1.21 (0.77,1.91) | 
| Other non major bleeding | 43/1228 (3.5) | 36/1229 (2.9) | 0.57 (-0.82,1.97) | 1.20 (0.77,1.85) | 
| Major bleeding including surgical site bleeding b | 23/1228 (1.9) | 19/1229 (1.6) | 0.33 (-0.70,1.35) | 1.21 (0.66,2.21) | 
| Total knee replacement | ||||
| RECORD 3 | ||||
| Major bleeding a | 7/1220 (0.6) | 6/1239 (0.5) | 0.09 (-0.48,0.66) | 1.18 (0.40,3.52) | 
| Any bleeding | 60/1220 (4.9) | 60/1239 (4.8) | 0.08 (-1.63,1.78) | 1.02 (0.72,1.44) | 
| Clinically relevant bleeding | 40/1220 (3.3) | 34/1239 (2.7) | 0.53 (-0.82,1.89) | 1.19 (0.76,1.87) | 
| Non major bleeding | 53/1220 (4.3) | 54/1239 (4.4) | -0.01 (-1.63,1.60) | 1.00 (0.69,1.44) | 
| Non major clinically relevant bleeding | 33/1220 (2.7) | 28/1239 (2.3) | 0.45 (-0.79,1.68) | 1.20 (0.73,1.97) | 
| Other non major bleeding | 22/1220 (1.8) | 31/1239 (2.5) | -0.70 (-1.85,0.45) | 0.72 (0.42,1.24) | 
| Major bleeding including surgical site bleeding b | 21/1220 (1.7) | 17/1239 (1.4) | 0.35 (-0.63,1.33) | 1.25 (0.67,2.37) | 
RR=relative risk.
a Primary safety outcome. This outcome does not include bleeding at the surgical site.
b Incidence of treatment emergent major bleeding events after removing the restriction
                           to extra-surgical site for those bleeding events associated with a fall in haemoglobin
                           of ≥2g/dL or for those bleeding events leading to transfusions of ≥2units of whole
                           blood or packed cells.
The incidence of major bleeding in the trials in patients undergoing THR (RECORD 1
                           & 2) was low for both drugs ( <0.1 – 0.31) and there was no statistically significant
                           difference between the rivaroxaban and enoxaparin treatment groups in either trial.
                           The PBAC noted trials were underpowered for detecting any statistically significant
                           difference in the rate of treatment-emergent major bleeding events. The PBAC also
                           noted there were insufficient data to determine accurately the comparative incidence
                           of cardiovascular events for the two drugs. Minimal information was available regarding
                           the potential effect of rivaroxaban on hepatic and renal function or the potential
                           for other rare or delayed adverse events. There were no safety data for patient groups
                           other than those undergoing elective total hip replacement and elective total knee
                           replacement.
For PBAC’s comments on these results, see Recommendation and Reasons.
 
                        
9. Clinical Claim
                           The submission claimed that rivaroxaban was superior in terms of
                           comparative effectiveness and equivalent in terms of comparative
                           safety over enoxaparin for prevention of VTE in patients undergoing
                           elective total hip replacement and elective total knee
                           replacement.
For PBAC’s view, see Recommendation and
                              Reasons.
10. Economic Analysis
                           A modelled economic evaluation was presented. The type of economic
                           evaluation presented was a cost-utility analysis with a 5.25 years
                           time horizon.
                           The outcomes used in the economic evaluation were years of life
                           (YoL) gained and quality-adjusted life-years (QALYs) gained. An
                           individual patient level simulation was used to generate the
                           results.
                           The model based on RECORD 1 was driven by the transition
                           probabilities in the extrapolation period and consequent costs of
                           diagnosis and treatment of long-term complications, as well as
                           their utilities. Risks of recurrent VTE and of post-thrombotic
                           syndrome (PTS) after symptomatic DVT were not derived from the
                           population for whom PBS listing is sought. Utilities values were
                           derived from varied population using varied methods.
                           Compared with the model based on RECORD 1, the model based on
                           RECORD 2 was more significantly driven by age-stratified VTE rates
                           and the long term extrapolations.
                           The trial-based economic evaluation using RECORD 1 and RECORD 2
                           resulted in an incremental cost-effectiveness ratio (ICER) of up to
                           $75,000 per QALY dependent on the inclusion of symptomatic,
                           asymptomatic, recurrent VTE, PTS and pulmonary embolism (PE)
                           complications. The ICER for RECORD 1 and RECORD 2 dropped to
                           between $15,000 - $45,000 and less than $15,000, respectively,
                           following the inclusion of the risk reduction for recurrent VTE and
                           long-term complications in the economic evaluation.
                           With respect to RECORD 3, the preliminary economic evaluation
                           resulted in an ICER of between $105,000 – $200,000 per QALY.
                           However, in the stepped economic evaluation, an ICER in the range
                           of $15,000 - $45,000 accounting for a risk reduction in the
                           conversion of asymptomatic to symptomatic VTE within 90-days post
                           surgery in the economic evaluation was calculated. Rivaroxaban was
                           more effective and less costly than enoxaparin if the risk of
                           post-thrombotic syndrome (PTS) in the long term for asymptomatic
                           patients, and pulmonary embolism (PE) case fatality rate in the
                           long term were accounted for in the economic model.
                           The economic evaluation showed that the utility values and the
                           conversion from asymptomatic to symptomatic VTE and its long-term
                           complications appeared to drive the model in demonstrating the
                           greater effectiveness and lower cost of rivaroxaban over
                           enoxaparin.
                           In all three models, the incremental gains in years of life and
                           quality-adjusted life-years were minimal, which resulted in an ICER
                           sensitive to small changes in both costs and effectiveness.
                           Sensitivity analyses indicated that the model was sensitive to the
                           proportion of people who needed home nursing to assist with
                           enoxaparin injection, as well as the transition probabilities
                           between VTE and its long term extrapolations, all of which were
                           subject to uncertainty.
                           The time horizon played an important role in the ICER calculation.
                           In the model based on each of the RECORD trials, the incremental
                           cost/YoL and incremental cost/QALY decreased dramatically from Year
                           0.25 to Year 5.25, even in the absence of extrapolation of long
                           term events.
11. Estimated PBS Usage and Financial Implications
                           The submission estimated the likely number of patients/year
                           expected to receive rivaroxaban for total hip and knee replacement
                           would be between 50,000 – 100,000 in Year 5, with a financial
                           cost/year to the PBS of < $10 million.
                           The submission’s estimates however were considered an
                           approximation due to uncertainty regarding the expected rate of
                           uptake of rivaroxaban and the current level of use of enoxaparin
                           for this indication.
12. Recommendation and Reasons
                           The PBAC recommended listing of rivaroxaban tablet 10 mg for the
                           prevention of venous thromboembolism in adult patients undergoing
                           elective total replacement of the hip or knee on the basis of
                           uncertain but overall acceptable cost-effectiveness compared with
                           enoxaparin. Listing under section 100 was not recommended as
                           rivaroxaban does not meet all five selection criteria. The maximum
                           quantities should align with the pack sizes and the Therapeutic
                           Goods Administration (TGA)-recommended durations of use (five weeks
                           for hip replacement and two weeks for knee replacement) to minimise
                           wastage. The PBAC noted that the quantities to be subsidised by the
                           PBS would differ according to whether the therapy is initiated in
                           the public hospital setting or the private hospital setting.
                           The PBAC agreed that subcutaneous enoxaparin was the appropriate
                           main comparator, and that the duration of its use in the trials
                           submitted (medians ranged from 13 to 36 days in hip replacement and
                           13 days in knee replacement) reflected the range of durations in
                           Australian practice.
                           The primary outcome analysed in the randomised trials was a
                           composite measure which was dominated by a relatively large number
                           of asymptomatic events detected by venography that had no direct
                           patient relevance (especially asymptomatic distal deep vein
                           thromboses). Across the trials, there were 30% to 35% of patients
                           who were not assessed for this primary outcome mainly due to
                           problems with venography, but loss to follow-up was similar across
                           the arms of each trial. Thus the conclusion for superior
                           effectiveness rested on a reckoning that the composite outcome
                           results reflected the results for each of the rarer and directly
                           patient-relevant types of events included in the composite
                           outcome.
                           The PBAC was concerned that the point estimates for
                           treatment-emergent bleeding, although not statistically
                           significant, tended to favour enoxaparin over rivaroxaban. This is
                           of concern because of the potential of increasing clinically
                           important bleeding; the exclusion of surgical site bleeding from
                           the definition of “major bleeding” unless also
                           associated with haemoglobin changes and/or requiring transfusion;
                           the paucity of evidence available in the extended assessment of
                           harms; the likelihood that these trials were underpowered to detect
                           this outcome; and the lack of an accepted asymptomatic endpoint or
                           measure that is more commonly occurring and can predict these rare
                           events.
                           The PBAC noted that, despite concerns with the use of (a) utilities
                           from across multiple sources, and (b) transition probabilities
                           between events derived from non-surgical patients, the economic
                           evaluation was relatively robust to these sources of uncertainty.
                           The incremental cost-effectiveness ratio was most sensitive to the
                           time horizon, reflected by the large reduction in the ICER from the
                           0.25-year duration of follow-up in the trials to the 5.25-year
                           duration of the modelled economic evaluation. This reflects the
                           sensitivity of the economic evaluation both to small differences in
                           the major clinical outcomes of pulmonary emboli and deaths and also
                           to the justified inclusion of recurrent venous thrombotic events
                           and the post-thrombotic syndrome.
                           The PBAC concluded that oral rivaroxaban 10 mg once daily was more
                           effective, but possibly less safe, than subcutaneous enoxaparin 40
                           mg once daily in the restrictions requested for PBS listing and
                           across the range of durations of use of enoxaparin currently used
                           in Australia. The Committee recommended listing on the basis of
                           uncertain but overall acceptable cost-effectiveness.
                           The PBAC suggested that the NPS consider providing a RADAR suitable
                           for consumers as well as a RADAR suitable for health
                           professionals.
Recommendation:
                           RIVAROXABAN, tablet, 10 mg, 15 tablet pack, 30 tablet pack
                           Restriction:
Authority Required
                           Prevention of venous thromboembolism in a patient undergoing total
                           hip replacement.
                           Max Qty: 10, 1(15 tablet pack), 1(30 tablet pack)
                           Repeats: 1(10 tablets), 1(15 tablet pack), nil (30 tablet
                           pack)
                           NOTE:
                           No applications for increased maximum quantity and/or repeats will
                           be authorised for the 30 tablet packAuthority
                              Required
                           Prevention of venous thromboembolism in a patient undergoing total
                           knee replacement.
                           Max Qty: 10, 1(15 tablet pack)
                           Repeats: nil
                           NOTE:
                           No applications for increased maximum quantities and/or repeats
                           will be authorised.
13. Context for Decision
                           The PBAC helps decide whether and, if so, how medicines should be
                           subsidised in Australia. It considers submissions in this context.
                           A PBAC decision not to recommend listing or not to recommend
                           changing a listing does not represent a final PBAC view about the
                           merits of the medicine. A company can resubmit to the PBAC or seek
                           independent review of the PBAC decision.
14. Sponsor’s Comment
                           Bayer is pleased with the positive PBAC recommendation and
                           encourages anyone interested in further discussing the data to
                           contact the company. Bayer does not agree with the PBACs conclusion
                           regarding safety. A published meta-analysis of the RECORD 1-3
                           trials is now available (post-PBAC) which (addresses this issue
                           and) supports the companies claim of similar safety.




