Dear Massachusetts Department of Public Health and Drug Formulary Commission

Dear Massachusetts Department of Public Health and Drug Formulary Commission,

I am writing on behalf of Egalet Corporation in regard to your request for comments in the Notice of Public Hearing, for amendments to the following regulations: 105 CMR 720.000, 105 CMR 720.000 – List of Interchangeable Drug Products. Egalet is a fully integrated specialty pharmaceutical company focused on developing, manufacturing and commercializing innovative treatments for pain and other conditions. We are active in the field of abuse-deterrent opioid development and would like to share information that you may find useful in the assessment of inclusion of our approved ARYMOTM ER and OXAYDO® drug products to your List of Interchangeable Drug Products for Abuse-Deterrent Opioids.

ARYMO ER

On January 9, 2017 Egalet received approval from the United States Food and Drug Administration (FDA)for ARYMO ER (morphine sulfate) extended-release tablets, CII, for the management of pain severe enough to require daily, around-the-clock, long-term opioid treatment and for which alternative treatment options are inadequate. ARYMO ER will be commercially available in the first quarter of 2017 and available as 15 mg, 30 mg, and 60 mg tablets. ARYMO ER is an abuse-deterrent, extended-release oral morphine formulation that is manufactured using Egalet's proprietary Guardian™ Technology. This technology combines a polymer matrix formulation with the process of injection molding to manufacture a tablet with controlled release properties and that resists physical and chemical manipulation. ARYMO ER has been shown to be bioequivalent to extended-release morphine sulfate across all dosage strengths.

To evaluate the ability of ARYMO ER to reduce the potential for misuse and abuse, a series of abuse-deterrent in vitro laboratory physical manipulation, chemical extraction, and syringeability studies were conducted. An oral pharmacokinetic study and an oral clinical abuse potential study were also conducted with manipulated ARYMO ER. Manipulation of extended-release opioid formulations to produce smaller particle sizes that allow for faster release of the opioid and prepare the drug for administration through alternative routes of administration is a common component of opioid misuse and abuse. Intravenous administration is the most common alternative route of abuse for morphine.1

In vitro physical and chemical manipulation testing of ARYMO ER demonstrated that it has increased resistance to cutting, crushing, grinding, or breaking using a variety of tools compared to morphine sulfate extended-release tablets; and when introduced to liquid, manipulated ARYMO ER tablets form a viscous hydrogel (i.e., a gelatinous mass).

In a study of recreational opioid users,the pharmacokinetic profile of orally administered manipulated ARYMO ER was characterized compared to crushed morphine sulfate extended-release and demonstrated that manipulated ARYMO ER had a lower maximum concentration and a longertime to maximum concentration. This study also demonstrated that oral administration of manipulated ARYMO ER resulted in a statistically significantly lower mean maximum drug liking score than the oral administration of crushed morphine sulfate extended-release tablets (P<0.05). The difference between manipulated ARYMO ER and crushed morphine sulfate extended-release tablets for willingness to take drug again was not statistically significant (P= 0.054); therefore, it cannot be concluded that ARYMO ER has physical and chemical properties that are expected to reduce abuse via the oral route. The in vitro data demonstrate that ARYMO ER has physical and chemical properties expected to make abuse by injection difficult. However, abuse by the intravenous, intranasal and oral routes is still possible.

Please see attached Full Prescribing Information and associated important safety information for ARYMO ER.

OXAYDO

We note that the Massachusetts Department of Public Health and the Drug Formulary Commission have previously performed an evaluation of OXAYDO (oxycodone HCL) tablets, CII, and concluded that they were not a chemically equivalent substitute for any opioids with heightened public health risk. However, OXAYDO is the only FDA approved immediate-release opioid with features designed to discourage abuse and is indicated for the management of acute and chronic pain severe enough to require an opioid analgesic and for which alternative treatments are inadequate. OXAYDO contains the aversive inactive ingredient, sodium lauryl sulfate, that may cause nasal burning and throat irritation when Oxaydo is manipulated and snorted. In a study of recreational opioid users, six times more patients reported they would not take OXAYDO again compared with immediate-release oxycodone (30% of subjects exposed to OXAYDO responded that they would not take the drug again compared to 5% exposed to immediate-release oxycodone). In pharmacokinetic evaluations, OXAYDO achieved FDA standards for bioequivalence to the reference listed drug product, immediate-release oxycodone. Based on these data we believe that OXAYDO demonstrates features that discourage intranasal abuse and demonstrate its suitability as an Interchangeable Drug Product.

Please see attached Full Prescribing Information and associated important safety information for OXAYDO.

CONCLUSION

We appreciate that the Massachusetts Department of Public Health and the Drug Formulary Commission recognize the value of abuse-deterrent opioid formulations and provided this opportunity for comment. We believe that ARYMO ER and OXAYDO can be a significant part of a multifaceted solution to the epidemic of opioid misuse and abuse. If you have any questions or require any additional information, please contact us.

Sincerely,

Gwendolyn Niebler, DO

Sr. Vice-President, Clinical Research and Medical Affairs

Email:

ATTACHMENTS

ARYMO ER Full Prescribing Information

OXAYDO Full Prescribing Information

REFERENCES

Butler SF, Black RA, Cassidy TA, et al. Abuse risks and routes of administration of different prescription opioid compounds and formulations. Harm Reduction J 2011;8:29.

460 E. Swedesford Road – Suite 1050 – Wayne, PA 19087 – +610-833-4200

Lejrvej 37-39, DK-3500 – Værløse , Denmark - +45 44 47 80 80

HIGHLIGHTS OF PRESCRIBING INFORMATION

These highlights do not include all the information needed to use ARYMO™ ERsafely and effectively. See full prescribing information for ARYMO ER.

ARYMO™ ER (morphine sulfate) extended-release tablets, for oral use CII

Initial U.S. Approval: 1941

WARNING: ADDICTION, ABUSE, and MISUSE; LIFE-THREATENING RESPIRATORY DEPRESSION; ACCIDENTAL INGESTION; NEONATAL OPIOID WITHDRAWAL SYNDROME; and RISKS FROM CONCOMITANT USE WITH BENZODIAZEPINES OR OTHER CNS DEPRESSANTS
See full prescribing information for complete boxed warning.

ARYMO ER exposes users to risks of addiction, abuse, and misuse, which can lead to overdose and death. Assess each patient’s risk before prescribing, and monitor regularly for these behaviors and conditions. (5.1)
Serious, life-threatening or fatal respiratory depression may occur. Monitor closely, especially upon initiation or following a dose increase. Instruct patients to swallow ARYMO ER tablets whole to avoid exposure to a potentially fatal dose of morphine. (5.2)
Accidental ingestion of ARYMO ER, especially in children, can result in fatal overdose of morphine. (5.2)
Prolonged use of ARYMO ER during pregnancy can result in neonatal opioid withdrawal syndrome, which may be life-threatening if not recognized and treated. If prolonged opioid use is required in a pregnant woman, advise the patient of the risk of neonatal opioid withdrawal syndrome and ensure that appropriate treatment will be available. (5.3)
Concomitant use of opioids with benzodiazepines or other central nervous system (CNS) depressants, including alcohol, may result in profound sedation, respiratory depression, coma, and death. Reserve concomitant prescribing for use in patients for whom alternative treatment options are inadequate; limit dosages and durations to the minimum required; and follow patients for signs and symptoms of respiratory depression and sedation. (5.4, 7)

______INDICATIONS AND USAGE______

ARYMO ER is an opioid agonist indicated for the management of pain severe enough to require daily, around-the-clock, long-term opioid treatment and for which alternative treatment options are inadequate. (1)

Limitations of Use

Because of the risks of addiction, abuse, and misuse with opioids, even at recommended doses, and because of the greater risks of overdose and death with extended-release opioid formulations, reserve ARYMO ER for use in patients for whom alternative treatment options (e.g., non-opioid analgesics or immediate-release opioids) are ineffective, not tolerated, or would be otherwise inadequate to provide sufficient management of pain. (1)
ARYMO ER is not indicated as an as-needed (prn) analgesic. (1)

______DOSAGE AND ADMINISTRATION______

To be prescribed only by healthcare providers knowledgeable in use of potent opioids for management of chronic pain. (2.1)

A single dose of ARYMO ER greater than 60mg, or a total daily dose greater than 120mg, are only for use in patients in whom tolerance to an opioid of comparable potency has been established. (2.1)
Patients who are opioid tolerant are those receiving, for one week or longer, at least 60mg oral morphine per day, 25 mcg transdermal fentanyl per hour, 30 mg oral oxycodone per day, 8 mg oral hydromorphone per day, 25 mg oral oxymorphone per day, 60 mg oral hydrocodone per day, or an equianalgesic dose of another opioid. (2.1)
Use the lowest effective dosage for the shortest duration consistent with individual patient treatment goals (2.1).
Individualize dosing based on the severity of pain, patient response, prior analgesic experience, and risk factors for addiction, abuse, and misuse. (2.1)
For opioid-naïve and opioid non-tolerant patients, initiate with 15 mg tablets orally every 8 or 12 hours. (2.2)
Do not abruptly discontinue ARYMO ER in a physically dependent patient. (2.4)
Instruct patients to take tablets one at a time, with enough water to ensure complete swallowing immediately after placing in the mouth. (2.1, 5.9)

______DOSAGE FORMS AND STRENGTHS______

Extended-release: 15 mg, 30 mg, 60 mg (3)

______CONTRAINDICATIONS______

Significant respiratory depression (4)
Acute or severe bronchial asthma in an unmonitored setting or in the absence of resuscitative equipment (4)
Concurrent use of monoamine oxidase inhibitors (MAOIs) or use within 14 days (4)
Known or suspected gastrointestinal obstruction, including paralytic ileus (4)
Hypersensitivity to morphine (4)

______WARNINGS AND PRECAUTIONS______

Risk of Life-Threatening Respiratory Depression in Elderly, Cachectic, and Debilitated Patients, and in Patients with Chronic Pulmonary Disease: Monitor closely, particularly during initiation and titration. (5.5, 5.6)
Adrenal Insufficiency: If diagnosed, treat with physiologic replacement of corticosteroids, and wean patient off of the opioid. (5.7)
Severe Hypotension: Monitor during dose initiation and titration. Avoid use of ARYMO ER in patients with circulatory shock. (5.8)
Risks of Use in Patients with Increased Intracranial Pressure, Brain Tumors, Head Injury, or Impaired Consciousness: Monitor for sedation and respiratory depression. Avoid use of ARYMO ER in patients with impaired consciousness or coma. (5.9)

•Risk of Obstruction in Patients who have Difficulty Swallowing or have Underlying GI Disorders that may Predispose them to Obstruction: Consider use of an alternative analgesic. (5.10)

______ADVERSE REACTIONS______

Most common adverse reactions: constipation, nausea, and sedation (6.1)

To report SUSPECTED ADVERSE REACTIONS, contact Egalet US Inc. at 1-800-518-1084 or FDA at 1-800-FDA-1088 or

______DRUG INTERACTIONS______

Serotonergic Drugs: Concomitant use may result in serotonin syndrome. Discontinue ARYMO ER if serotonin syndrome is suspected. (7)

Mixed Agonist/Antagonist and Partial Agonist Opioid Analgesics: Avoid use with ARYMO ER because they may reduce analgesic effect of ARYMOER or precipitate withdrawal symptoms. (5.11, 7)

______USE IN SPECIFIC POPULATIONS______

Pregnancy: May cause fetal harm. (8.1)
Lactation: Not recommended. (8.2)

See 17 for PATIENT COUNSELING INFORMATION and Medication Guide

Revised: 01/2017

FULL PRESCRIBING INFORMATION: CONTENTS*

1Indications and Usage

2Dosage and administration

2.1Important Dosage and Administration Instructions

2.2Initial Dosing

2.3Titration and Maintenance of Therapy

2.4Discontinuation of ARYMO ER

3Dosage Forms and Strengths

4Contraindications

5Warnings and Precautions

5.1Addiction, Abuse, and Misuse

5.2Life-Threatening Respiratory Depression

5.3Neonatal Opioid Withdrawal Syndrome

5.4Risks from Concomitant Use with Benzodiazepines or Other CNS Depressants

5.5Life-Threatening Respiratory Depression in Patients with Chronic Pulmonary Disease or in Elderly, Cachectic, or Debilitated Patients

5.6Interaction with Monoamine Oxidase Inhibitors

5.7 Adrenal Insufficiency

5.8Severe Hypotension

5.9Risks of Use in Patients with Increased Intracranial Pressure, Brain Tumors, Head Injury, or Impaired Consciousness

5.10Difficulty in Swallowing and Risk for Obstruction in Patients at Risk for a Small Gastrointestinal Lumen

5.11Risks of Use in Patients with Gastrointestinal Conditions

5.12Increased Risk of Seizures in Patients with Seizure Disorders

5.13Withdrawal

5.14Risks of Driving and Operating Machinery

6Adverse Reactions

6.1Clinical Trial Experience

6.2Post-Marketing Experience

7Drug Interactions

8Use in Specific Populations

8.1Pregnancy

8.2Lactation

8.3Females and Males of Reproductive Potential

8.4Pediatric Use

8.5Geriatric Use

8.6Hepatic Impairment

8.7Renal Impairment

9Drug Abuse and Dependence

9.1Controlled Substance

9.2Abuse

9.3Dependence

10Overdosage

11Description

12Clinical Pharmacology

12.1Mechanism of Action

12.2Pharmacodynamics

12.3Pharmacokinetics

13Nonclinical Toxicology

13.1Carcinogenesis, Mutagenesis, Impairment of Fertility

16How Supplied/Storage and Handling

17Patient Counseling Information

*Sections or subsections omitted from the full prescribing information are not listed.

FULL PRESCRIBING INFORMATION

WARNING: ADDICTION, ABUSE, and MISUSE; LIFE-THREATENING RESPIRATORY DEPRESSION; ACCIDENTAL INGESTION;NEONATAL OPIOID WITHDRAWAL SYNDROME; and RISKS FROM CONCOMITANT USE WITH BENZODIAZEPINES OR OTHER CNS DEPRESSANTS

Addiction, Abuse, and Misuse
ARYMO™ ER exposes patients and other users to the risks of opioid addiction, abuse, and misuse, which can lead to overdose and death. Assess each patient’s risk prior to prescribing ARYMO ER, and monitor all patients regularly for the development of these behaviors or conditions [see Warnings and Precautions (5.1)].
Life-Threatening Respiratory Depression
Serious, life-threatening, or fatal respiratory depression may occur with use of ARYMOER. Monitor for respiratory depression, especially during initiation of ARYMO ER or following a dose increase. Instruct patients to swallow ARYMO ER tablets whole; crushing, chewing, or dissolving ARYMO ER tablets can cause rapid release and absorption of a potentially fatal dose of morphine [see Warnings and Precautions (5.2)].
Accidental Ingestion
Accidental ingestion of even one dose of ARYMO ER, especially by children, can result in a fatal overdose of morphine [see Warnings and Precautions (5.2)].
Neonatal Opioid Withdrawal Syndrome
Prolonged use of ARYMO ER during pregnancy can result in neonatal opioid withdrawal syndrome, which may be life-threatening if not recognized and treated, and requires management according to protocols developed by neonatology experts. If opioid use is required for a prolonged period in a pregnant woman, advise the patient of the risk of neonatal opioid withdrawal syndrome and ensure that appropriate treatment will be available[see Warnings and Precautions (5.3)].
Risks From Concomitant Use With Benzodiazepines Or Other CNS Depressants
Concomitant use of opioids with benzodiazepines or other central nervous system (CNS) depressants, including alcohol, may result in profound sedation, respiratory depression, coma, and death [see Warnings and Precautions (5.4), Drug Interactions (7)].

Reserve concomitant prescribing of ARYMOER and benzodiazepines or other CNS depressants for use in patients for whom alternative treatment options are inadequate.
Limit dosages and durations to the minimum required.
Follow patients for signs and symptoms of respiratory depression and sedation.

1Indications and Usage

ARYMO ER is indicated for the management of pain severe enough to require daily, around-the-clock, long-term opioid treatment and for which alternative treatment options are inadequate.

Limitations of Use

Because of the risks of addiction, abuse, and misuse with opioids, even at recommended doses, and because of the greater risks of overdose and death with extended-release opioid formulations [see Warnings and Precautions (5.1)], reserve ARYMO ER for use in patients for whom alternative treatment options (e.g., non-opioid analgesics or immediate-release opioids) are ineffective, not tolerated, or would be otherwise inadequate to provide sufficient management of pain.
ARYMO ER is not indicated as an as-needed (prn) analgesic.

2Dosage and administration

2.1Important Dosage and Administration Instructions

ARYMO ER should be prescribed only by healthcare professionals who are knowledgeable in the use of potent opioids for the management of chronic pain.

A single dose of ARYMO ER greater than 60mg, or a total daily dose greater than 120mg, are only for use in patients in whom tolerance to an opioid of comparable potency has been established. Patients who are opioid tolerant are those receiving, for one week or longer, at least 60mg oral morphine per day, 25 mcg transdermal fentanyl per hour, 30 mg oral oxycodone per day, 8 mg oral hydromorphone per day, 25 mg oral oxymorphone per day, 60 mg oral hydrocodone per day, or an equianalgesic dose of another opioid.

Use the lowest effective dosage for the shortest duration consistent with individual patient treatment goals [see Warnings and Precautions (5)].
Initiate the dosing regimen for each patient individually, taking into account the patient’s severity of pain, patient response, prior analgesic treatment experience, and risk factors for addiction, abuse, and misuse [see Warnings and Precautions (5.1)].
Monitor patients closely for respiratory depression, especially within the first 24-72 hours of initiating therapy and following dosage increases with ARYMO ER and adjust the dosage accordingly [see Warnings and Precautions (5.2)].

Instruct patients to take ARYMO ER tablets whole, one tablet at a time, with enough water to ensure complete swallowing immediately after placing in the mouth [see Patient Counseling Information (17)]. Instruct patients not to pre-soak, lick, or otherwise wet the tablet prior to placing in the mouth [see Warnings and Precautions (5.10)]. Cutting, breaking, crushing, chewing, or dissolving ARYMO ER tablets will result in uncontrolled delivery of morphine that could lead to overdose and death [see Warnings and Precautions (5.1)].

ARYMO ER is administered orally every 8 or 12 hours.

2.2Initial Dosing

Use of ARYMO ER as the First Opioid Analgesic (opioid-naïve patients)

Initiate treatment with ARYMO ER with 15 mg tablets orally every 8 or 12 hours.

Use of ARYMO ER in Patients who are not Opioid Tolerant (opioid-non-tolerant patients)

The starting dose for patients who are not opioid tolerant is ARYMO ER 15 mg orally every 8 or 12hours.

Use of higher starting doses in patients who are not opioid tolerant may cause fatal respiratory depression [see Warnings and Precautions (5.2)].