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` NDA 207924/S-007
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`
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`
`
`SUPPLEMENT APPROVAL
`
`
`
`
`
`
` Eli Lilly and Company
`
`
`
`
`
` Attention: Jessie Lynn Bishop, MPH
`
` Associate Director, Global Regulatory Affairs - US
`
`
`
` Lilly Corporate Center / Drop Code 2543
`
`
`
` Indianapolis, IN 46285
`
`
`
`
`
`
`Dear Ms. Bishop:
`
`
`
`Please refer to your supplemental new drug application (sNDA) dated and received
`
`
`
`December 13, 2021, and your amendments, submitted under section 505(b) of the
`
`
`
`
`Federal Food, Drug, and Cosmetic Act (FDCA) for Olumiant (baricitinib) tablets.
`
`
`
`
`
`
`
`This Prior Approval supplemental new drug application provides for the addition of the
`
`
`
`indication for the treatment of adult patients with severe alopecia areata.
`
`
`APPROVAL & LABELING
`
`We have completed our review of this application, as amended. It is approved, effective
`
`
`
`on the date of this letter, for use as recommended in the enclosed agreed-upon
`
`labeling.
`
`
`CONTENT OF LABELING
`
`
`As soon as possible, but no later than 14 days from the date of this letter, submit the
`
`
`
`
`content of labeling [21 CFR 314.50(l)] in structured product labeling (SPL) format using
`
`
`
`the FDA automated drug registration and listing system (eLIST), as described at
`
`
`
`
`FDA.gov.1 Content of labeling must be identical to the enclosed labeling (text for the
`
`Prescribing Information and Medication Guide), with the addition of any labeling
`
`
`changes in pending “Changes Being Effected” (CBE) supplements, as well as annual
`
`
`
`
`reportable changes not included in the enclosed labeling.
`
`Information on submitting SPL files using eList may be found in the guidance for
`
`
`industry SPL Standard for Content of Labeling Technical Qs and As.2
`
`
`
`
`
`The SPL will be accessible from publicly available labeling repositories.
`
`
`
`
`
` 1 http://www.fda.gov/ForIndustry/DataStandards/StructuredProductLabeling/default.htm
`
` 2 We update guidances periodically. For the most recent version of a guidance, check the FDA Guidance
`
`
` Documents Database https://www.fda.gov/RegulatoryInformation/Guidances/default.htm.
`
`
`
`
`
`
`Reference ID: 4998371
`
`

`

`
`
`
`
`
`
`
` NDA 207924/S-007
`
` Page 2
`
`
` SENTINEL/ARIA NOTIFICATION
`
` The Food and Drug Administration Amendments Act of 2007 (FDAAA) required FDA to
`
`
` establish a national electronic system to monitor the safety of FDA-regulated medical
` products. In fulfillment of this mandate, FDA established the Sentinel System, which
`
`
` enables FDA to proactively monitor drug safety using electronic health data from
`
` multiple data sources that contribute to the Sentinel Distributed Database.
`
`
`
`
`
`FDA plans to evaluate Olumiant (baricitinib) tablets in the Sentinel System. We have
`
`
`
`determined that Sentinel’s Active Postmarket Risk Identification and Analysis System,
`
`
`established under section 505(k)(3) of the FDCA, is sufficient to identify unexpected
`
`serious risks (myocardial infarction, stroke, and thrombosis) possibly related to
`
`baricitinib dose during long-term use for alopecia areata.
`
`
`
`
`The ARIA safety assessment will be posted to the Sentinel website.3 Once there is
`
`
`sufficient product uptake to support an analysis, an analysis plan will be posted online.
`
`After the analysis is complete, FDA will also post the results on the Sentinel website.
`
`FDA will notify you prior to posting the analysis plan.
`
`
`REQUIRED PEDIATRIC ASSESSMENTS
`
`
`
`Under the Pediatric Research Equity Act (PREA) (21 U.S.C. 355c), all applications for
`
`
`
`new active ingredients (which includes new salts and new fixed combinations), new
`
`
`indications, new dosage forms, new dosing regimens, or new routes of administration
`
`
`
`are required to contain an assessment of the safety and effectiveness of the product for
`
`
`the claimed indication in pediatric patients unless this requirement is waived, deferred,
`
`or inapplicable.
`
`
`
`
`We are waiving the pediatric study requirement for ages 0 to less than 6 years because
`
`
`the studies are impossible or highly impractical.
`
`
`We are deferring submission of your pediatric study for ages 6 years to less than 18
`
`
`years for this application because this product is ready for approval for use in adults and
`
`
`the pediatric study has not been completed.
`
`
`
`Your deferred pediatric studies required by section 505B(a) of the Federal Food, Drug,
`
`and Cosmetic Act are required postmarketing studies. The status of these
`
`
`
`postmarketing studies must be reported annually according to 21 CFR 314.81 and
`
`
`section 505B(a)(4)(C) of the Federal Food, Drug, and Cosmetic Act. These required
`
`
`studies are listed below.
`
` 4289-1 Conduct a randomized, controlled trial to evaluate the safety, efficacy, and
`
` pharmacokinetics of baricitinib in the adolescent population (12 years to
`
`
`
`
`
`
`
`
` 3 https://www.sentinelinitiative.org
`U.S. Food and Drug Administration
`
`
`Silver Spring, MD 20993
`www.fda.gov
`
`
`
`
`Reference ID: 4998371
`
`

`

`
`
`
` NDA 207924/S-007
`
` Page 3
`
`
`
` less than 18 years) with severe alopecia areata. Evaluate at least 300
`
`
`
`
`
` subjects exposed to baricitinib for a minimum of 52 weeks.
`
`
`Final Protocol Submission:
`
`
`Study Completion:
`
`
`Final Report Submission:
`
`
`October 2022
`
`January 2027
`
`June 2027
`
`
`
`
`
`
`
`
`
`4289-2 Conduct a randomized, controlled trial to evaluate the safety, efficacy, and
`pharmacokinetics of baricitinib in the pediatric population (6 years to less
`
`
`
`
`
`than 12 years) with severe alopecia areata. Evaluate at least 100 subjects
`
`
`exposed to baricitinib for a minimum of 52 weeks.
`
`
`Final Protocol Submission:
`
`
`Study Completion:
`
`
`Final Report Submission:
`
`
`December 2027
`
`May 2031
`
`November 2031
`
`
`
`
`
`FDA considers the term final to mean that the applicant has submitted a protocol, the
`
`
`FDA review team has sent comments to the applicant, and the protocol has been
`
`
`
`
`revised as needed to meet the goal of the study or clinical trial.4
`
`
`
`Submit the protocol(s) to your IND 112543, with a cross-reference letter to this NDA.
`
`
`
`Reports of these required pediatric postmarketing studies must be submitted as an NDA
`
`or as a supplement to your approved NDA with the proposed labeling changes you
`believe are warranted based on the data derived from these studies. When submitting
`the reports, please clearly mark your submission "SUBMISSION OF REQUIRED
`
`PEDIATRIC ASSESSMENTS" in large font, bolded type at the beginning of the cover
`
`
`
`
`letter of the submission.
`
`
`POSTMARKETING REQUIREMENTS UNDER 505(o)
`
`
`
`
`Section 505(o)(3) of the Federal Food, Drug, and Cosmetic Act (FDCA) authorizes FDA
`
`
`to require holders of approved drug and biological product applications to conduct
`
`
`
`postmarketing studies and clinical trials for certain purposes, if FDA makes certain
`
`
`findings required by the statute.
`
`
`
`
`
`
`We have determined that an analysis of spontaneous postmarketing adverse events
`
`reported under subsection 505(k)(1) of the FDCA will not be sufficient to identify the
`
`
`unexpected serious risk of adverse maternal, fetal, and infant outcomes of women
`
`exposed to baricitinib during pregnancy.
`
`
`
`
`
`Furthermore, the active postmarket risk identification and analysis system as available
`
`
`
`under section 505(k)(3) of the FDCA will not be sufficient to assess this serious risk.
`
` 4 See the guidance for Industry Postmarketing Studies and Clinical Trials—Implementation of Section
`
`
` 505(o)(3) of the Federal Food, Drug, and Cosmetic Act (October 2019).
`
` https://www.fda.gov/RegulatoryInformation/Guidances/default.htm.
`U.S. Food and Drug Administration
`
`
`
`Silver Spring, MD 20993
`www.fda.gov
`
`
`Reference ID: 4998371
`
`

`

`
`
`
`
`
`
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`
` NDA 207924/S-007
`
` Page 4
`
`
` Therefore, based on appropriate scientific data, FDA has determined that you are
`
` required to conduct the following:
`
`
`
`
`
`4289-3 Conduct a Pregnancy Exposure Registry, a prospective, registry based
`
`observational exposure cohort study that compares the maternal, fetal,
`and infant outcomes of women exposed to baricitinib during pregnancy to
`
`
` an unexposed control population. The registry should be designed to
` detect and record major and minor congenital malformations, spontaneous
`
`
`
`
` abortions, stillbirths, elective terminations, small for gestational age,
` preterm birth, and any other adverse pregnancy outcomes. These
`
`
`
`
` outcomes will be assessed throughout pregnancy. Infant outcomes,
`including effects on postnatal growth and development, will be assessed
`through at least the first year of life.
`
`
`
`
`
`
`
`
`For more information, see the May 2019 FDA draft guidance for industry
`
`
`
`
`
`Post approval Pregnancy Safety Studies.
`
`
`https://www.fda.gov/regulatory-information/search-fda-guidance-
`documents/postapproval-pregnancy-safety-studies-guidance-industry
`
`
`The timetable you submitted on June 9, 2022 states that you will conduct
`
`
`
`this study according to the following schedule:
`
`
`
`
`
`
`
`
`Draft Protocol Submission:
`
`Final Protocol Submission:
`
`Interim/Other:
`
`
`
`Study/Trial Completion:
`
`
`Final Report Submission:
`
`
`December 2022
`
`June 2023
`
`
`June 2028
`
`June 2033
`
`June 2034
`
`
`
`4289-4 Conduct a pregnancy study that uses a different design from the
`
`
`
`Pregnancy Registry (for example, a retrospective cohort study using
`
`claims or electronic medical record data or a case control study) to assess
`
`
`
`
`major congenital malformations, spontaneous abortions, stillbirths, and
`
`
`small for gestational age and preterm birth in women exposed to baricitinib
`
`during pregnancy compared to an unexposed control population.
`
`
`
`
`The timetable you submitted on June 9, 2022 states that you will conduct
`
`
`
`this study according to the following schedule:
`
`
`
`Draft Protocol Submission:
`
`Final Protocol Submission:
`
`Interim/Other:
`
`
`
`Study/Trial Completion:
`
`
`Final Report Submission:
`
`
`
`December 2022
`
`June 2023
`
`June 2026
`
`June 2029
`
`June 2030
`
`
`
`U.S. Food and Drug Administration
`
`Silver Spring, MD 20993
`
`www.fda.gov
`
`
`
`Reference ID: 4998371
`
`

`

`
`
`
` NDA 207924/S-007
`
` Page 5
`
`
` FDA considers the term final to mean that the applicant has submitted a protocol, the
`
`
`
`
`
` FDA review team has sent comments to the applicant, and the protocol has been
` revised as needed to meet the goal of the study or clinical trial.5
`
`
`
`
`
`
`
`Submission of the protocols for required postmarketing observational studies to your
`
`
`
`
`IND is for purposes of administrative tracking only. These studies do not constitute
`
`clinical investigations pursuant to 21 CFR 312.3(b) and therefore are not subject to the
`
`IND requirements under 21 CFR part 312.
`
`
`
`
`Section 505(o)(3)(E)(ii) of the FDCA requires you to report periodically on the status of
`
`
`any study or clinical trial required under this section. This section also requires you to
`
`periodically report to FDA on the status of any study or clinical trial otherwise
`
`
`
`undertaken to investigate a safety issue. Section 506B of the FDCA, as well as
`
`
`
`21 CFR 314.81(b)(2)(vii) requires you to report annually on the status of any
`
`postmarketing commitments or required studies or clinical trials.
`
`
`
`
`
`FDA will consider the submission of your annual report under section 506B and
`
`
`21 CFR 314.81(b)(2)(vii) to satisfy the periodic reporting requirement under section
`
`505(o)(3)(E)(ii) provided that you include the elements listed in 505(o) and
`
`
`
`21 CFR 314.81(b)(2)(vii). We remind you that to comply with 505(o), your annual report
`
`
`
`
`
`must also include a report on the status of any study or clinical trial otherwise
`
`
`undertaken to investigate a safety issue. Failure to submit an annual report for studies
`
`or clinical trials required under 505(o) on the date required will be considered a violation
`
`
`of FDCA section 505(o)(3)(E)(ii) and could result in enforcement action.
`
`
`PROMOTIONAL MATERIALS
`
`You may request advisory comments on proposed introductory advertising and
`
`
`promotional labeling. For information about submitting promotional materials, see the
`
`
`final guidance for industry Providing Regulatory Submissions in Electronic and Non-
`
`
`Electronic Format-Promotional Labeling and Advertising Materials for Human
`
`
`
`Prescription Drugs.6
`
`You must submit final promotional materials and Prescribing Information, accompanied
`
`
`
`
`by a Form FDA 2253, at the time of initial dissemination or publication
`
`
`
`[21 CFR 314.81(b)(3)(i)]. Form FDA 2253 is available at FDA.gov.7 Information and
`
`
`
`
`
`
`
`Instructions for completing the form can be found at FDA.gov.8
`
`
`
`
`
`
`
`
` 5 See the guidance for Industry Postmarketing Studies and Clinical Trials—Implementation of Section
`
`
`
` 505(o)(3) of the Federal Food, Drug, and Cosmetic Act (October 2019).
` https://www.fda.gov/RegulatoryInformation/Guidances/default.htm.
`
`
`
` 6 For the most recent version of a guidance, check the FDA guidance web page at
` https://www.fda.gov/media/128163/download.
`
`
`
` 7 http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Forms/UCM083570.pdf
`
`
` 8 http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Forms/UCM375154.pdf
`U.S. Food and Drug Administration
`
`
`
`Silver Spring, MD 20993
`www.fda.gov
`
`
`
`
`Reference ID: 4998371
`
`

`

`
`
`
`
`
`
`
` NDA 207924/S-007
`
` Page 6
`
`
`PATENT LISTING REQUIREMENTS
`
`
` Pursuant to 21 CFR 314.53(d)(2) and 314.70(f), certain changes to an approved NDA
`
`
` submitted in a supplement require you to submit patent information for listing in the
`
` Orange Book upon approval of the supplement. You must submit the patent information
`
` required by 21 CFR 314.53(d)(2)(i)(A) through (C) and 314.53(d)(2)(ii)(A) and (C), as
`
` applicable, to FDA on Form FDA 3542 within 30 days after the date of approval of the
`
`
`
` supplement for the patent information to be timely filed (see 21 CFR
` 314.53(c)(2)(ii)). You also must ensure that any changes to your approved NDA that
`
`
`
`
`
` require the submission of a request to remove patent information from the Orange Book
` are submitted to FDA at the time of approval of the supplement pursuant to 21 CFR
`
`
`
`
`
`
`
` 314.53(d)(2)(ii)(B) and 314.53(f)(2)(iv).
`
`
`REPORTING REQUIREMENTS
`
`We remind you that you must comply with reporting requirements for an approved NDA
`
`(21 CFR 314.80 and 314.81).
`
`
`
`As required under 21 CFR 314.80, report each adverse drug experience that is both
`
`
`serious and unexpected within 15 days from initial receipt of the information.
`
`
`
`If you have any questions, call Strother D. Dixon, Senior Regulatory Project Manager, at
`
`
`(301) 796-1015.
`
`
`
`Sincerely,
`
`
`{See appended electronic signature page}
`
`
`
`Gordana Diglisic, MD
`
`Associate Director for Therapeutic Review
`
`
`Division of Dermatology and Dentistry
`
`Office of Immunology and Inflammation
`
`Center for Drug Evaluation and Research
`
`
`
`ENCLOSURES:
`
`• Content of Labeling
`
`
`o Prescribing Information
`
`
`o Medication Guide
`
`
`
`
`
`U.S. Food and Drug Administration
`
`Silver Spring, MD 20993
`
`www.fda.gov
`
`
`
`Reference ID: 4998371
`
`

`

`Signature Page 1 of 1
`--------------------------------------------------------------------------------------------
`This is a representation of an electronic record that was signed
`electronically. Following this are manifestations of any and all
`electronic signatures for this electronic record.
`--------------------------------------------------------------------------------------------
`/s/
`------------------------------------------------------------
`
`GORDANA DIGLISIC
`06/13/2022 01:58:30 PM
`
`Reference ID: 4998371
`
`(
`
`
`
`

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