Our
Position

PFENEX IS UNIQUELY SITUATED TO DELIVER A ROBUST PIPELINE OF BIOSIMILARS AND VACCINES TO PATIENTS GLOBALLY. WE ARE COMMITTED TO WORKING WITH REGULATORY AGENCIES, LEGISLATORS AND OUR PARTNERS TO CREATE AND FOSTER A SUPPORTIVE REGULATORY ENVIRONMENT THAT ENSURES PATIENT ACCESS TO NEEDED THERAPEUTICS AND VACCINES.

Naming

To support the use of biosimilars in the U.S., it is our position biosimilars should be given the same INN as the reference product. The current FDA guidance to add a suffix to traditional INNs stands to slow growth of the biosimilar market, stifle cost-reduction opportunities, and reduce patient access. We have compelling examples to demonstrate the case for same names – both the Europe biosimilar markets have successfully used the same INN for years and continue to maintain high standards of drug tracking and patient safety. Twenty-one leading industry and patient care groups – including CVS Health, Express Scripts, Kaiser Permanente, Pharmaceutical Care Management Association, and Rite Aid – as well as the Federal Trade Commission (FTC) also expressed their support for a system that supports the same INNs for biosimilars and the reference product.

Coding

It is our position that the decision to group all biosimilars to a single reference product under the same Healthcare Common Procedure Coding System (HCPCS) code, with the reference product maintaining a separate code does not support the development of a robust biosimilars market. We remain concerned that the current CMS Rule will hinder biosimilar uptake and discourage innovation by not establishing a reimbursement model for biosimilars based on an individual product’s unique average sales price (ASP). As defined by the U.S. Food and Drug Administration (FDA), biosimilars are proven to have no clinically meaningful difference in safety, purity, and potency from a reference product. Because biosimilars are comparatively developed to a given reference product, rather than other biosimilars, it is illogical to tie reimbursement to other molecular entities to which the biosimilar was not compared. As such, we believe each biosimilar product should have an individual HCPCS code, which is in accordance with the Biologics Price Competition and Innovation Act (BPCIA). It is our believe that such a policy will better ensure innovation and drive market entry, ultimately allowing the U.S. to realize the full promise of biosimilars.

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