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The Nurtec ODT Resubmission Journey: From FDA CRL to Approval 

Categories: Cell Therapy / Regulatory Rescue
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Hello Regulatory Scientists, 

Today, let’s dive into the journey of Nurtec ODT (rimegepant) from receiving an FDA Complete Response Letter (CRL) to achieving approval. This case study provides valuable insights and lessons that can guide companies developing new drugs today. 

Regulatory History and Initial Submission 

Drug: Nurtec ODT (rimegepant) 
Mechanism of Action: CGRP (calcitonin gene-related peptide) receptor antagonist, which helps alleviate migraine symptoms by blocking the activity of CGRP, a protein involved in migraine attacks 
Indication: Acute treatment of migraine with or without aura in adults 
Initial Submission Date: March 2019 

The Complete Response Letter (CRL) 

CRL Date: July 2019 
CRL Concerns: 

  1. Manufacturing Issues: The FDA raised concerns about the quality and consistency of the drug’s manufacturing process. 
  1. Stability Data: Request for additional stability data to ensure the drug’s efficacy and safety over its shelf life. 
  1. Risk Management Plan: Need for a robust risk management plan to monitor and mitigate potential adverse effects. 

Resubmission Strategy 

Biohaven Pharmaceuticals, the company behind Nurtec ODT, implemented a comprehensive strategy to address the FDA’s concerns: 

  1. Manufacturing Process Improvements: Made significant enhancements to the manufacturing process to ensure consistency and quality. 
  1. Stability Data Collection: Conducted further studies to gather more robust stability data to support the drug’s efficacy and safety over its intended shelf life. 
  1. Risk Management Plan: Developed a detailed risk management plan, including monitoring guidelines and patient education materials. 
  1. Continuous FDA Engagement: Maintained open lines of communication with the FDA to ensure alignment on the resubmission strategy and clarify any outstanding questions. 

Resubmission Date: October 2019 

Outcome 

Approval Date: February 2020 
Nurtec ODT was approved for the acute treatment of migraine with or without aura in adults, providing a new and effective option for migraine sufferers. 

Lessons Learned 

The journey of Nurtec ODT from CRL to approval highlights several key lessons for drug developers: 

  1. Manufacturing Process Improvements: Ensuring the quality and consistency of the manufacturing process is crucial. Proactive improvements and rigorous quality control measures can prevent setbacks. 
  1. Comprehensive Data Collection: Providing extensive stability data to support the drug’s efficacy and safety over its shelf life is essential to addressing FDA concerns. 
  1. Effective Risk Management: Developing and implementing a detailed risk management plan can help mitigate potential adverse effects and ensure patient safety. 
  1. Continuous FDA Engagement: Maintaining open and ongoing communication with the FDA helps align development efforts with regulatory expectations. 
  1. Proactive Quality Control: Implementing stringent quality control measures ensures the consistency and reliability of the drug’s production. 

Relevance for Current Drug Developers 

For companies developing drugs today, the Nurtec ODT case underscores the importance of strategic planning and meticulous attention to detail in the regulatory process. Here are some takeaways to help avoid a CRL and achieve first-cycle approval: 

  1. Thorough Pre-Submission Preparation: Ensure that all aspects of your submission, including manufacturing processes and stability data, meet FDA standards. 
  1. Proactive Risk Management: Identify and address potential risks early in the development process to prevent issues from arising during FDA review. 
  1. Engage with the FDA Early and Often: Regular interactions with the FDA can provide valuable guidance and help steer the development process. 
  1. Invest in Quality Data: Prioritize the collection of high-quality, detailed safety and efficacy data to support the submission. 
  1. Utilize Advisory Committees: Seek feedback from advisory committees to validate data and address potential concerns, even if formal hearings are not required. 

By learning from the Nurtec ODT resubmission experience, current drug developers can better navigate the regulatory landscape, avoid common pitfalls, and increase the likelihood of a successful first review cycle approval. 

Stay diligent and strategic, 

CERES Regulatory Services 

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Asad Khan