There is no question that developing new medications in children is
fraught with challenges, particularly for rare conditions including
pediatric venous thromboembolism (VTE). This is due to both logistical
and ethical considerations which are nicely described in a document on
the Food & Drug Administration (FDA) website.[1] Furthermore,
gaining an approval from the FDA for pediatric use requires a functional
partnership between pharmaceutical companies (Pharma), academia, and the
regulators/officers at the FDA. When this relationship works well, novel
agents can be made available to children that have the assurance of
efficacy and safety which is in the best interest of all involved
parties, especially patients. The licensure of emicizumab for the
prevention of bleeding in hemophilia A patients is one excellent example
in which a serious unmet need for a rare disease was addressed in a
timely manner (~18 months from the start of a phase 3
trial to approval), and where the labelled indication even includes the
word “newborn” with respect to the included age groups. [2,3]
Unfortunately, this is not the case with respect to anticoagulants in
children, and there is plenty of blame to go around including Pharma,
academia (myself included), but also the FDA. I know this all too well
as I have had a front seat view having served as an advisor to the FDA
on this very topic in 2011 as well as on several other occasions
involving specific discussions regarding fondaparinux and rivaroxaban.
Although the authors and investigators of this report [4] are to be
commended for the significant effort it took to achieve an FDA-approved
indication, one can’t help but feel that with respect at least to
injectable anticoagulants that “the ship has sailed.” What do I mean
by this? Enoxaparin is the most commonly used low molecular weight
heparin (LMWH) and anticoagulant in children with fondaparinux also
gaining more use with the prime advantage being that it is a once-a-day
option. Despite dalteparin (a less commonly used LMWH) now being
licensed for children [5], I doubt it will ever supersede enoxaparin
in prescriptions nor does it have the advantages of fondaparinux,
particularly once daily dosing.
How did we arrive at such an unenviable situation? Certainly, it is
nobody’s fault that enoxaparin does not have a pediatric
indication—the author’s clearly explained the fact that enoxaparin
came to the market prior to the Pediatric Research Equity Act (PREA),
and at this point, despite the sheer volume of data on the pediatric use
of enoxaparin, it will likely never be licensed for children. This is
not the case, however, for fondaparinux which has been in regulatory
limbo with respect to pediatric use for nearly 15 years. This, despite
the fact that there is more published data on fondaparinux than
dalteparin including a similarly (to dalteparin) designed, prospective,
dose-finding, pharmacokinetic, efficacy and safety study [6-8], and
the fact that the Pharma companies (the compound has changed hands a few
times) have been in discussions with the FDA repeatedly. Unlike with
dalteparin, the FDA has placed numerous and pointless hurdles upon the
responsible Pharma for capricious reasons succeeding only in potentially
putting children at increased risk of harm by, for example, requiring a
dose-finding study when the dose of fondaparinux is already
well-established. This is the antithesis of what the FDA should be
doing. This unending process of which I have played a significant part
as an academician has been nothing short of befuddling. While the FDA
clearly went to great lengths to work with the sponsor to have
dalteparin approved for children, they owe the pediatric hematology
community an explanation on what has gone so wrong with fondaparinux.
So, where does this leave us currently and what would I recommend
pediatric hematologists do with the data from this report [4] and
the licensure of dalteparin for children? Importantly, off-label use in
the pediatric setting is quite common typically ranging around 50%
depending on the setting [9] so there is no need for any pediatric
treater to fret over prescribing anticoagulants as such. Thus, if you
are comfortable using enoxaparin or fondaparinux based on the available
data, the collective pediatric experience and your personal experience,
then I would advocate that you continue to do so until there are better
options (more on that later). If, however, you prefer to prescribe
medications per the prescribing information (to the extent possible) and
you find the data from this study compelling, then certainly you may
choose dalteparin as your anticoagulant of choice for your pediatric
patients with VTE.
Above I discussed the current situation, however on a strongly positive
note, there has been outstanding cooperation between Pharma,
academicians and the FDA when it comes to the development of the direct
oral anticoagulants (DOACs) which without a doubt will dramatically
change the management of pediatric VTE. While I have been privy to
discussions with the FDA regarding rivaroxaban and have served on the
steering committee for the rivaroxaban and edoxaban studies, I am also
aware of the productive discussions with respect to dabigatran and
apixaban. This trilateral collaboration is the epitome of what PREA is
for, and in the coming year or two, it is highly likely that several
DOACs will be licensed for use in children and will also lead to the
availability of pediatric-friendly formulations.
In conclusion, the approval of dalteparin is on the one hand far too
little and too late to be of any meaningful clinical use, yet it does
set an example of what fruitful pediatric drug development can look like
in hematology/oncology (and other specialties as well) particularly for
rare diseases. It is incumbent upon the academic community not to
request, but in fact to demand that Pharma fund proper studies (not just
ones that “check the box”), and that the FDA review data in a fair and
reasonable manner such that the future will be filled with more examples
like dalteparin and fewer debacles like fondaparinux.
References
- https://www.fda.gov/drugs/drug-information-consumers/drug-research-and-children
[Accessed September 9, 2020]
- Young G, Liesner R, Chang , Sidonio R, Oldenburg J, Jimenez-Yuste V,
Mahlangu J, Kruse-Jarres R, Wang M, Uguen M, Doral MY, Wright LY,
Schmitt C, Levy GG, Shima M, Mancuso ME. A multicenter, open-label,
phase 3 study of emicizumab prophylaxis in children with hemophilia A
with inhibitors. Blood 2019; 134: 2127-2138.
- https://www.accessdata.fda.gov/drugsatfda_docs/label/2017/761083s000lbl.pdf
[Accessed September 9, 2020]
- Merino M, Richardson N, Reaman G, Ande A, Zvada S, Liu C, Hariharan S,
De Claro A, Farrell A, Pazdur R. FDA approval summary: Dalteparin for
the treatment of venous thromboembolism in pediatric patients. Pediatr
Blood Cancer 2020 (in press).
- https://www.accessdata.fda.gov/drugsatfda_docs/label/2019/020287s072lbl.pdf
[Accessed September 9, 2020]
- Young G, Yee DL, O’Brien SH, Khanna R, Barbour A, Nugent DJ.
FondaKIDS: A prospective pharmacokinetic and safety study of
fondaparinux in children between 1 and 18 years of age. Pediatr Blood
Cancer 2011; 57: 1049-1054.
- Ko RH, Michieli C, Lira JL, Young G. FondaKIDS II: Long-term follow-up
data of children receiving fondaparinux for treatment of venous
thromboembolic events. Thromb Res 2014; 134: 643-647.
- Shen X, Wile R, Young G. FondaKIDS III: A long-term retrospective
cohort study of fondaparinux for treatment of venous thromboembolism
in children. Pediatr Blood Cancer 2020; 67:e28295.
- Yackey K, Stukus K, Cohen D, Kline D, Zhao S, Stanley R. Off-label
prescribing practices in pediatrics: An update. Hosp Pediatr 2019;
9:186-193.