Agomelatine, tablet, 25 mg, Valdoxan® - July 2011
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Public Summary Document
Product:  Agomelatine, tablet, 25 mg,
                           Valdoxan®
Sponsor: Servier Laboratories (Australia) Pty
                           Ltd
Date of PBAC Consideration: July 2011
1. Purpose of Application
                           The re-submission sought a Restricted Benefit listing for major
                           depressive disorders.
2. Background
At the November 2010 meeting, the PBAC rejected an application for PBS-listing of
                           agomelatine because of uncertainty around the claim that agomelatine was superior
                           to venlafaxine and the resultant uncertainty in the economic analysis. The Committee
                           considered that the submission’s nomination of venlafaxine as the main comparator
                           was inappropriate, as although based on Medicare data for the period April 2009 to
                           March 2010, venlafaxine had the largest single agent share of the anti-depressant
                           market, the SSRIs (sertraline, citalopram, escitalopram, fluoxetine and fluvoxamine)
                           accounted for 54% of the total anti-depressant market. Even when the proportion of
                           use of SSRIs for indications other than major depression was taken into account, the
                           SSRIs as a group remained an appropriate comparator for agomelatine.
A copy of the Public Summary Document (PSD) from the November 2010 meeting is available.
 
                        
3. Registration Status
                           Agomelatine was TGA registered on 9 August 2010 for treatment of
                           major depression in adults including prevention of relapse.
4. Listing Requested and PBAC’s View
Restricted benefit
                           Major depressive disorders
                           The PBAC did not comment on the requested restriction.
5. Clinical Place for the Proposed Therapy
                           Major depression is a condition characterised by a persistent
                           feeling of depressed mood and loss of interest or pleasure in
                           addition to a number of other psychological and somatic
                           symptoms.
                           The submission proposed that the place in therapy of agomelatine
                           was as an alternative first-line treatment option for major
                           depression, with a different mechanism of action and adverse event
                           profile, to current pharmacological treatments.
6. Comparator
                           As in the previous submission, the re-submission nominated
                           venlafaxine as the main comparator. In response to the PBAC’s
                           request for a comparison of agomelatine with the SSRIs, the
                           re-submission also presented a comparison of agomelatine with
                           SSRIs: fluoxetine, sertraline and escitalopram.
                           The PBAC considered that the SSRIs were the more appropriate main
                           comparator.
For PBAC’s view, see Recommendation and
                              Reasons.
7. Clinical Trials
                           The re-submission presented no new trial data comparing agomelatine
                           with venlafaxine (CL3-035 and CL3-036). Publication details of
                           these trials have been previously reported in the November 2011
                           PSD.
                           The re-submission presented and meta-analysed the results of an
                           additional four randomised trials comparing agomelatine with SSRIs
                           (CL3-045, CL3-046, CL3-056 and CL3-063), and discussed the
                           systematic review and meta-analysis by Schueler et al (2011)
                           of duloxetine and venlafaxine compared to other antidepressants
                           including SSRIs in major depression. Details of the studies
                           published at the time of the submission are presented in the table
                           below.
Trials and associated reports presented in the submission
| Trial ID/first author | Protocol title/ Publication title | Publication citation | 
| Direct randomised trials (agomelatine vs SSRIs) | ||
| CL3-045 Hale A et al . | Superior antidepressant efficacy results of agomelatine versus fluoxetine in severe MDD patients: A randomized, double-blind study | International Clinical Psychopharmacology 2010; 25: 305-314 | 
| CL3-046 Kasper S et al. | Efficacy of the novel antidepressant agomelatine on the circadian rest-activity cycle and depressive and anxiety symptoms in patients with major depressive disorder: a randomized, double-blind comparison with sertraline | The Journal of Clinical Psychiatry 2010; 71(2): 109-120 | 
| Meta-analyses comparing venlafaxine/duloxetine vs SSRIs | ||
| Schueler YB et al | A systematic review of duloxetine and venlafaxine in major depression, including unpublished data. | Acta Psychiatrica Scandinavica 2011; 123: 247–65 | 
8. Results of Trials
Comparative effectiveness
Agomelatine versus venlafaxine:
The resubmission presented no new trial data comparing agomelatine with venlafaxine
                           (CL3-035 and CL3-036). The main outcome of HAM-D17 & Montgomery-Asberg depression
                           rating scale (MADRS) scores were the secondary outcomes of the agomelatine vs venlafaxine
                           trials. The primary outcomes were the Leeds Sleep Evaluation Questionnaire (CL3-035)
                           and the Sex Effects Scale score (CL3-036).
The results of CL3-035 and CL3-036 have been previously reported in the November 2010
                           PSD.
 
                        
Agomelatine versus SSRIs:
The primary outcome for Trial CL3-045 and a secondary outcome for Trials CL3-046,
                           CL3-056 and CL3-063 was the difference in the adjusted mean change from baseline HAM-D17
                           scores. The pooled estimate for this outcome was presented as a sensitivity analysis
                           in the re-submission’s meta-analyses with difference in the last post-baseline HAM-D
                           17 score presented as primary outcome in the meta-analysis.
The adjusted mean change in HAM-D17 total scores from baseline comparing agomelatine
                           with SSRIs for those trials published is shown in the following table.
 
                        
Results of HAM-D17 total scores comparing agomelatine with SSRIs – adjusted mean change from baseline
| Trial ID | Agomelatine | SSRI | Treatment effect a SSRI-Ago (95%CI) | ||||
| n | Mean baseline (SD) | Mean change (SD) | n | Mean baseline (SD) | Mean change (SD) | ||
| Mandatory period | |||||||
| CL3-045 fluoxetine (8 wks) | 247 | 28.5 (2.7) | -17.3 (7.3) | 257 | 28.7 (2.5) | -16.0 (8.4) | 1.49 (0.20, 2.77) | 
| CL3-046 sertraline (6 wks) | 150 | 26.1 (2.8) | -15.8 (7.3) | 156 | 26.5 (3.0) | -14.4 (8.7) | 1.68 (0.15, 3.20) | 
| Optional extension period (Weeks 0 to 24) | |||||||
| CL3-045 fluoxetine | 247 | 28.5 (2.7) | -19.9 (8.3) | 257 | 28.7 (2.5) | -18.9 (9.6) | - | 
| CL3-046 sertraline | 150 | 26.1 (2.8) | -17.7 (8.4) | 156 | 26.5 (3.0) | -16.4 (10.3) | NR | 
Abbreviations: Ago, agomelatine; CI, confidence interval; HAM-D, Hamilton Depression
                           Rating scale; SD, standard deviation; SSRI, selective serotonin reuptake inhibitor;
                           wks, weeks
a adjusted for centre (random effect) and baseline as a covariate
Bolded results are statistically significant
During the mandatory period of the four trials, agomelatine was associated with larger
                           reductions in HAM-D17 scores, although the differences between agomelatine and the
                           SSRI comparator were only statistically significantly different in Trials CL3-045
                           and CL3-046. The pooled result was statistically significantly different in favour
                           of agomelatine However, considering that the nominated MCID was 1.5 points, the PBAC
                           considered it unlikely that this difference was clinically important. For the optional
                           extension analysis (to Week 24), there were no statistically significant differences
                           between agomelatine and the SSRI comparator in the two trials (CL3-045 and CL3-063)
                           reporting adjusted mean change from baseline. However, only patients who were ‘responders’
                           in the mandatory period were able to enter the optional extension period, so it could
                           be expected that the two treatments would not differ.
The pooled analyses showed that there were statistically significantly higher HAM-D17
                           responder rates (reduction of at least 50% from baseline) for agomelatine compared
                           to SSRI in both the mandatory and optional extension analyses. However, there were
                           no statistically significant differences in the proportion of HAM-D17 remitters in
                           either period.
The between-arm differences in the mean last post-baseline Clinician Global Impression
                           (CGI) severity of illness (CGI-S) and CGI global improvements (CGI-I) scores were
                           generally small and favoured agomelatine. The pooled results showed that there was
                           a statistically significant difference favouring agomelatine for both CGI-S and CGI-I
                           in the mandatory period, and for CGI-I in the optional extension analyses.
The odds of being a CGI responder were higher for agomelatine-treated patients in
                           the mandatory period, but there were no significant differences in the optional extension
                           period. There were no differences in CGI remitter rates for either the mandatory or
                           the extension period.
The re-submission presented new toxicity data comparing agomelatine with SSRIs and
                           discussed the latest Periodic Safety Update Report.
 
                        
Agomelatine versus venlafaxine:
There were statistically significant fewer discontinuations overall and discontinuations
                           due to adverse events in agomelatine treated patients.
 
                        
Agomelatine versus SSRIs:
In the pooled analyses, there were statistically significantly fewer agomelatine-treated
                           patients discontinuing overall and due to adverse events compared to SSRI-treated
                           patients during the mandatory period. However, there were no statistically significant
                           differences in discontinuation rates during the optional extension period, with the
                           point estimates favouring SSRIs.
For PBAC’s comments on these results, see Recommendation and Reasons.
 
                        
9. Clinical Claim
                           The re-submission stated that the conclusion and the claim had not
                           changed from the November 2010 submission i.e. agomelatine was
                           non-inferior in terms of efficacy and superior in terms of
                           discontinuation from treatment to the primary comparator
                           venlafaxine.
                           The PBAC reaffirmed that substantiation of a claim of
                           non-inferiority to venlafaxine would first require demonstration of
                           superiority over the SSRIs.
                           The re-submission also described agomelatine as superior in terms
                           of comparative efficacy and superior in terms of comparative safety
                           over SSRIs. This was not accepted by the PBAC.
                           The PBAC considered that the evidence provided in the submission
                           was not sufficient to support the claim that agomelatine was
                           superior in terms of comparative efficacy and safety to the SSRIs.
                           See Recommendation and Reasons.
10. Economic Analysis
                           The re-submission presented a cost minimisation analysis against
                           venlafaxine. The re-submission presented an updated model which was
                           still based on the clinical claim that fewer discontinuations would
                           occur with agomelatine compared to venlafaxine. These fewer
                           discontinuations were assumed to translate to better adherence, a
                           claim that has not previously been accepted by PBAC.
                           From the updated model, the incremental cost per quality adjusted
                           life-year (QALY) gained was less than $15,000 for the base-case,
                           which included liver function tests (LFTs) costs.
11. Estimated PBS Usage and Financial Implications
                           The re-submission’s estimate of the likely number of patients
                           treated per year was between 50,000 and 100,000 in Year 5, at a net
                           cost per year to the PBS of less than $10 million in Year 5.
12. Recommendation and Reasons
                           The PBAC reaffirmed that, as agomelatine is the first in a new
                           class of antidepressants, substantiation of a claim of
                           non-inferiority to venlafaxine firstly requires demonstration of
                           superiority over the SSRIs. The PBAC considered that the SSRIs were
                           the more appropriate main comparator for agomelatine as agomelatine
                           will be used in the first line treatment of depression. The PBAC
                           further considered that the evidence provided in the submission was
                           not sufficient to support the claim that agomelatine was superior
                           in terms of comparative efficacy and safety to the SSRIs.
                           The PBAC expressed a number of concerns with the trial data
                           comparing agomelatine with the SSRIs as a secondary clinical
                           comparator. There were concerns surrounding the selective exclusion
                           of 5 earlier trials (CL3-014, CL3-022, CL3-023, CL3-024 and
                           CL3-030). The impact of excluding potentially relevant trials was
                           uncertain. The sponsor in its Pre Sub-Committee Response explained
                           that these trials lacked the methodological improvements seen in
                           subsequent studies and used a fixed dose regimen rather than the
                           titrating dose regimen applied in clinical practice. However, the
                           key trial CL3-036 in the submission comparing agomelatine 50 mg
                           with venlafaxine 150 mg was also a fixed dose trial and was not
                           excluded on this basis. Of the four included trials, the PBAC noted
                           that both SSRI comparators in two trials (CL3-045 and CL3-046) may
                           have been inadequately dosed. In addition, the fluoxetine dose in
                           trial CL3-045 could be titrated from 20 mg up to 40 mg from week 4,
                           whereas the agomelatine dose could be titrated up from 25 mg to 50
                           mg at week 2, which could favour agomelatine.
                           The PBAC noted that the nominated main depression outcomes (HAM-D17
                           and CGI) used in the resubmission were not the primary outcomes for
                           trials CL3-046 (rest/activity cycle), CL3-056 (polysomnographic
                           sleep efficiency index) and CL3-063 (global satisfaction on sleep
                           score), although the HAM-D17 total score was the primary outcome
                           for CL3-045.
                           During the mandatory period of the four trials, agomelatine was
                           associated with larger reductions in HAM-D17 scores, although the
                           differences between agomelatine and the SSRI comparator were only
                           statistically significantly different in Trials CL3-045 and
                           CL3-046. The pooled result (SSRI-agomelatine) was statistically
                           significantly different in favour of agomelatine However, the PBAC
                           considered that the differences were unlikely to be clinically
                           important, given the pre-defined MCID for change from baseline in
                           HAM-D17 score was 1.5. For the optional extension analysis (to Week
                           24), the PBAC noted that there were no statistically significant
                           differences between agomelatine and the SSRI comparator in the two
                           trials (CL3-045 and CL3-063) reporting adjusted mean change from
                           baseline. There were statistically significantly more HAM-D17
                           responders (reduction of at least 50% from baseline) among
                           agomelatine-treated patients, but no statistically significant
                           differences in HAM-D17 remitter rates
                           The PBAC noted that there were inconsistencies in the CGI results.
                           The difference in mean CGI-I (global improvement) was statistically
                           significantly in favour of agomelatine for the mandatory and
                           optional extension periods, but was only statistically significant
                           in the mandatory period for CGI-S (severity of illness). The PBAC
                           considered that the small differences reported were unlikely to be
                           clinically important. The odds of being a CGI responder were higher
                           for agomelatine-treated patients in the mandatory period, but there
                           were no significant differences in the optional extension period.
                           There were no differences in CGI remitter rates for either the
                           mandatory or the extension period.
                           There was some evidence supporting the lower discontinuation rates
                           associated with agomelatine in the mandatory period, but not the
                           optional extension period of the SSRI trials.
                           The PBAC concerns regarding a claim of superiority based on
                           discontinuation rates remain:
                           Discontinuation rates cannot be assumed to be persistence rates.
                           Multiple factors can affect adherence and persistence.
                           Intention-to-treat analyses already account for the differential
                           discontinuation rates in the efficacy outcomes; and
                           A proportion of discontinuing patients will go on to another
                           antidepressant in clinical practice.
                           The resubmission presented no new trial data comparing agomelatine
                           with venlafaxine (CL3-035 and CL3-036). The main outcome of HAM-D17
                           & Montgomery-Asberg depression rating scale (MADRS) scores were
                           the secondary outcomes of the agomelatine vs venlafaxine trials.
                           The primary outcomes were the Leeds Sleep Evaluation Questionnaire
                           (CL3-035) and the Sex Effects Scale score (CL3-036).
                           For Trial CL3-035, there was no statistically significant
                           difference between agomelatine and venlafaxine at the end of the
                           mandatory period (6 weeks) in the mean last post-baseline HAM-D17
                           scores. Again, the PBAC considered interpretation of these results
                           was limited by the potential under-dosing of venlafaxine in this
                           trial. For Trial CL3-036, there were no statistically significant
                           differences in the mean last post-baseline MADRS scores at Week 6
                           between agomelatine- and venlafaxine-treated patients. There were
                           no statistically significant differences in HAM-D17/MADRS responder
                           and remitter rates between agomelatine and venlafaxine for the
                           individual trials and the pooled analyses during the mandatory
                           period. The PBAC considered that interpretation of the pooled data
                           was limited by the use of different depression measurement scales,
                           the differences in dosing schedules and the differences in trial
                           durations.
                           The submission presented a cost minimisation analysis against
                           venlafaxine. As in the previous submission, the PBAC noted
                           uncertainties regarding both the equi-effective doses of
                           agomelatine and venlafaxine and the updated model which was still
                           based on the clinical claim that fewer discontinuations would occur
                           with agomelatine compared to venlafaxine. These fewer
                           discontinuations were assumed to translate to better adherence, a
                           claim that has not previously been accepted by PBAC.
                           As noted above, the PBAC considered that the SSRIs were the more
                           appropriate main comparator for agomelatine, the first in a new
                           class of antidepressants, as agomelatine will be used in the first
                           line treatment of depression and is more likely to substitute for
                           SSRIs than the more expensive SNRIs in clinical practice. The
                           estimates in Section E of the submission supported this
                           assumption.
                           The PBAC rejected the submission on the basis that superior
                           clinical effectiveness and safety over SSRIs had not been
                           demonstrated.
                           The PBAC also acknowledged and noted the consumer comments received
                           in its consideration of agomelatine.
Recommendation:
Reject
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
Servier has met with the PBAC Chairman and is working towards achieving a PBS-listing in a timely manner for agomelatine.




