Abstract
Over the last decade, the treatment of patients with breast cancer (BC) has been greatly impacted by the approval of multiple drugs and indications. This summary describes 30 US Food and Drug Administration (FDA) approvals of treatments for BC from 2010-2020. The trial design endpoints, results, and regulatory considerations are described for each approved indication. Of the 30 indications, 23 (76.6%) received regular and 7 (23.3%) received accelerated approval. Twenty-six approvals were granted in metastatic BC (MBC) and four in early BC. Approval decisions for the 26 MBC indications were initially supported by progression-free survival (PFS) in 21 (80.8%), overall survival (OS) or a combination of OS and PFS in two (7.7%), and objective response rate (ORR) in three (11.5%). The four approvals in early BC utilized pathologic complete response (pCR) in one (25%) and invasive disease-free survival (iDFS) in three (75%) trials. Among the 30 indications, 22 received priority review, seven were granted Breakthrough Therapy Designation, and ten applications participated in one or more pilot Oncology Center of Excellence regulatory review initiatives, including Real Time Oncology Review, Assessment Aid, and Project Orbis. FDA initiatives to advance breast cancer drug development are also described.
INTRODUCTION
During the most recent decade, several new targeted therapies, including cyclin-dependent kinase (CDK) 4/6 and poly (ADP-ribose) polymerase (PARP) inhibitors, received U.S. Food and Drug Administration (FDA) approvals, providing new options for patients with breast cancer (BC). Expedited pathways, including fast track designation, breakthrough therapy designation (BTD), priority review, and accelerated approval (AA), facilitated drug development and shortened review timelines for many of these innovative therapies, leading to the approvals of new agents to address unmet medical needs of patients with BC.1 In this review, we will describe the basis for FDA approvals of treatments for BC that were approved by the Office of Oncologic Diseases between January 1, 2010 and December 31, 2020, with a focus on endpoints and regulatory considerations as part of these approvals. This review is the second article in a two-part series detailing the changing landscape and approvals in breast and gynecological cancers over the last decade and the FDA Oncology Center of Excellence (OCE) initiatives that have supported the regulatory review of these therapeutics. Part 1 reviewed the FDA approvals for gynecologic malignancies.
DRUG APPROVALS IN BREAST CANCER
Approximately 284,200 new cases of invasive BC (281,550 women and 2,650 men) and 49,290 cases of ductal carcinoma in situ (DCIS) will be diagnosed in the U.S. in 2021, and nearly 44,130 patients (43,600 women and 530 men) will die from BC.2 The mortality trends show a decline of 41% in female BC death rate between 1989 and 2018, likely due to a combination of earlier detection through screening and a growing treatment armamentarium.2 Below, we describe approvals in early and advanced/metastatic BC including clinical trial design, endpoints, and regulatory considerations that have contributed to the expanded treatment landscape (descriptions below provide the rationale at the time of approval; see Table 1 and 2 for information included in the recent US Prescribing information).
Table 1:
Drug Approvals for Metastatic Breast Cancer (MBC): 2010-2020*
| Drug (Date of Approval) | Population Studied | Study Design (Treatment Arms) | Primary Endpoint | Select Secondary Endpoints | Approved Indication(s) | Co-approved Companion Diagnostic Device (Device Sponsor) |
|---|---|---|---|---|---|---|
| HR-Positive | ||||||
| Fulvestrant4 (RA September 9, 2010) | Postmenopausal women with HR-positive advanced breast cancer (n= 736) | DB, R (1:1) 500mg 250mg |
PFS: median 6.5 months versus 5.4 months (HR 0.80; 95% CI: 0.68-0.94) for 500mg versus 250mg | OS: median 26.4 months versus 22.3 months (HR 0.81; 95% CI: 0.69-0.96) for 500mg versus 250mg ORR: 13.8% versus 14.6% for 500mg versus 250mg |
Patients with metastatic breast cancer who have previously received at least two chemotherapeutic regimens for the treatment of metastatic disease. Prior therapy should have included an anthracycline and a taxane in either the adjuvant or metastatic setting | N/A |
| Everolimus5 (RA July 20, 2012) | HR-positive, HER2-negative breast cancer (n= 724) | DB, R (2:1) everolimus+exemestane vs. placebo + exemestane | PFS: median 7.8 months versus 3.2 months (HR 0.45; 95% CI: 0.38-0.54) | OS: Immature ORR: 12.6% vs 1.7% |
Treatment of postmenopausal women with advanced hormone receptor-positive, HER2-negative breast cancer in combination with exemestane, after failure of treatment with letrozole or anastrozole | N/A |
| Palbociclib**,8,9,10,11,12 (AA February 3, 2015, RA March 31, 2017) |
First-line for postmenopausal women (n=666) | PALOMA-2 DB, R (2:1) Palbociclib + letrozole vs. placebo + letrozole |
INV PFS: median 24.8 vs. 14.5 months (HR 0.58; 95% CI: 0.46-0.72) | OS: Not mature at time of final PFS | Patients with hormone receptor (HR)-positive, HER2-negative advanced or metastatic breast cancer in combination with: • fulvestrant in patients with disease progression following endocrine therapy • an aromatase inhibitor as initial endocrine-based therapy in postmenopausal women or in men |
N/A |
| Second-line for pre-, peri, or postmenopausal women whose disease relapsed or progressed on ET (n=521)*** | PALOMA-3 DB, R (2:1) Palbociclib + fulvestrant vs. placebo + fulvestrant |
INV PFS: median 9.5 vs. 4.6 months (HR 0.46; 95% CI: 0.36-0.59) | OS: median 34.9 vs. 28.0 months (HR 0.81; 95% CI: 0.4-1.03)**** | N/A | ||
| Ribociclib13,14,15,16,17,18 (RA March 13, 2017) Utilized AAid and RTOR |
First-line for postmenopausal women (n=668) | MONALEESA-2 DB, R (1:1) Ribociclib + letrozole vs. placebo + letrozole |
INV PFS: median NR vs. 14.7 months (HR 0.56; 95% CI: 0.43-0.72) | OS: Not mature at time of PFS analysis | In combination with: • fulvestrant for the treatment of postmenopausal women with HR-positive, HER2-negative advanced or metastatic breast cancer, as initial endocrine-based therapy or following disease progression on endocrine therapy. • an aromatase inhibitor for the treatment of pre/perimenopausal or postmenopausal women with HR-positive, HER2-negative advanced or metastatic breast cancer, as initial endocrine-based therapy. |
N/A |
| First or second line for postmenopausal women who disease has progressed on ET (n=726) | MONALEESA-3 DB, R (2:1) Ribociclib + fulvestrant vs. placebo + fulvestrant |
INV PFS: median 20.5 vs. 12.8 months (HR 0.59; 95% CI: 0.48-0.73) | OS: median NR vs. 40.0 months (HR 0.72; 95% CI: 0.57-0.92) | N/A | ||
| First-line for pre- or peri-menopausal women (n = 672) | MONALEESA-7 DB, R (1:1) Ribociclib + NSAI + goserelin vs. placebo + NSAI + goserelin |
INV PFS: median 27.5 vs. 13.8 months (HR 0.57; 95% CI: 0.44-0.74) | OS: median NR vs. 40.7 months (HR 0.70; 95% CI: 0.50-0.98) | N/A | ||
| Ribociclib-letrozole Copackaged (Co-Pack)19 | See above for MONALEESA-2 and MONALEESA-7 | MONALEESA-2 MONALEESA-7 Refer to results above |
Refer to results above | Refer to results above | As initial endocrine-based therapy for the treatment of pre/perimenopausal or postmenopausal women with HR-positive, HER2-negative advanced or metastatic breast cancer | N/A |
| Abemaciclib20,21,22,23,24 (RA September 28, 2017) |
Second line or later, women whose disease progressed on ET, prior taxane (n= 132) | MONARCH-1 SA, Abemaciclib monotherapy |
INV ORR: 19.7% (95% CI:13.3-27.5) | DoR: 8.6 months (95% CI: 5.8-10.2) |
Indicated: • as monotherapy for the treatment of adult patients with HR-positive, HER2-negative advanced or MBC with disease progression following endocrine therapy and prior chemotherapy in the metastatic setting • in combination with fulvestrant for the treatment of women with HR-positive, HER2-negative advanced or MBC with disease progression following endocrine therapy • in combination with an aromatase inhibitor as initial endocrine-based therapy for the treatment of postmenopausal women with HR-positive, HER2-negative advanced or MBC |
N/A |
| Second-line for pre-, peri-, or postmenopausal women whose disease progressed on ET (n=669)*** | MONARCH 2 DB, R (2:1) Abemaciclib + fulvestrant vs. placebo + fulvestrant |
INV PFS: median 16.4 vs. 9.3 months (HR 0.55; 95% CI: 0.45 – 0.68) | OS: median 46.7 vs. 37.3 months (HR 0.76; 95% CI: 0.61 – 0.95) | N/A | ||
| First-line for postmenopausal women (n =493) | MONARCH 3 DB, R (2:1) Abemaciclib + ET vs. placebo + ET. ET choices: letrozole or anastrozole |
INV PFS: median 28.2 vs. 14.8 months (HR 0.54; 95% CI: 0.42-0.70) | OS: Not mature at time of PFS analysis | N/A | ||
| Alpelisib25,26,27 (RA May 24, 2019) Utilized AAid and RTOR |
Postmenopausal women, and men with HR-positive, HER2-negative, PIK3CA-mutated, advanced or MBC (n=572) | SOLAR-1 DB, R (1:1) Alpelisib + fulvestrant vs. fulvestrant |
PFS PIK3CA tumor mutation: 11.0 vs. 5.7 months (HR 0.65; 95% CI: 0.50-0.85). No PFS benefit was observed in patients whose tumors did not have a PIK3CA tissue mutation (HR 0.85; 95% CI: 0.58-1.25). |
OS: Immature at time of primary PFS analysis. | In combination with fulvestrant for the treatment of postmenopausal women, and men, HR-positive, HER2-negative, PIK3CA-mutated, advanced or metastatic breast cancer as detected by an FDA-approved test following progression on or after an endocrine-based regimen. |
therascreen
PIK3CA RGQ PCR Kit* (QIAGEN GmbH). If no mutation is detected in a plasma specimen, test tumor tissue. |
| HER2-Positive | ||||||
| Pertuzumab29,30,31 (RA June 8, 2012) |
Women and men with HER2-positive MBC (n=808) | CLEOPATRA DB, R (1:1) Pertuzumab+trastuzumab + docetaxel vs. placebo + trastuzumab + docetaxel |
PFS: 18.5 vs. 12.4 months (HR 0.62; 95% CI: 0.51-0.75). | OS: 56.5 vs. 40.8 months (HR 0.68; 95% CI: 0.56-0.84). | in combination with trastuzumab and docetaxel for the treatment of patients with HER2-positive metastatic breast cancer who have not received prior anti-HER2 therapy or chemotherapy for metastatic disease | Assessment of HER2 protein overexpression and HER2 gene amplification should be performed using FDA-approved tests specific for breast cancer by laboratories with demonstrated proficiency. |
| Lapatinib32,33 (AA January 29, 2010; RA December 6, 2018) |
Postmenopausal women with HR-positive MBC (n=1286, n=219 HER2-positive) | DB, R (1:1), Lapatinib + letrozole vs. placebo + letrozole | PFS (HER2-Positive Population): 35.4 months lapatinib + letrozole arm vs. 13 months in the letrozole arm (HR 0.71; 95% CI: 0.53-0.96) | OS: Not mature | In combination with letrozole for the treatment of postmenopausal women with hormone receptor-positive metastatic breast cancer that overexpresses the HER2 receptor for whom hormonal therapy is indicated | N/A |
| Postmenopausal women who had HR-positive/HER2-positive MBC | R (1:1:1), lapatinib + trastuzumab + Aromatase Inhibitor (AI) vs. trastuzumab + AI vs. lapatinib + AI | PFS: 11 vs. 5.6 vs. 8.3 months (HR 0.85; 95% CI: 0.62-1.17) for lapatinib + trastuzumab + Aromatase Inhibitor (AI) vs. trastuzumab + AI vs. lapatinib + AI | ORR: 22.5% vs. 8.5% vs. 12.7% | |||
| T-DM134,35,36 (RA February 22, 2013) |
Women and men with HER2-positive MBC (n=991) | EMILIA OL, R (1:1) T-DM1 vs. lapatinib + capecitabine |
Co-primary endpoints PFS: 9.6 vs. 6.4 months (HR 0.65; 95% CI: 0.55-0.77). OS: 30.9 vs. 25.1 months (HR 0.68; 95% CI: 0.55-0.85). |
N/A | Treatment of patients with HER2-positive, metastatic breast cancer who previously received trastuzumab and a taxane, separately or in combination. Patients should have either: • received prior therapy for metastatic disease, or • developed disease recurrence during or within six months of completing adjuvant therapy. |
• PATHWAY anti-HER-2/neu (4B5) Rabbit Monoclonal Primary Antibody assay • INFORM HER2 Dual ISH DNA Probe Cocktail (Ventana Medical Systems, Inc.) |
| T-DXd37,38,39 (AA December 20, 2019) Utilized AAid |
Adults with HER2-positive MBC who received prior T-DM1 (n = 184) | DESTINY-Breast01 SA, T-DXd monotherapy |
ORR (confirmed): 60.3% (95% CI: 52.9-67.4) | DOR: 14.8 months (95% CI:13.8-16.9). | Treatment of adult patients with unresectable or metastatic HER2-positive breast cancer who have received two or more prior anti-HER2-based regimens in the metastatic setting. | N/A |
| Neratinib40,41 (RA February 25, 2020) Utilized AAid |
Patients with HER2-positive MBC (n=621) | NALA OL, R (1:1) Neratinib + capecitabine, vs. lapatinib + capecitabine |
PFS: 5.6 vs. 5.5 months (HR 0.76; 95% CI:0.63-0.93). | OS: 21 vs. 18.7 months (HR 0.88; 95% CI: 0.72-1.07). | In combination with capecitabine, for the treatment of adult patients with advanced or metastatic HER2-positive breast cancer who have received two or more prior anti-HER2 based regimens in the metastatic setting. | N/A |
| Tucatinib42,43,44 (RA April 17, 2020) Utilized AAid, RTOR, and Orbis |
HER2-positive, unresectable locally advanced or MBC, with or without brain metastases, and prior treatment with trastuzumab, pertuzumab, and ado-trastuzumab emtansine (T-DM1) separately or in combination, in the neoadjuvant, adjuvant or metastatic setting (n=612) | HER2CLIMB R (2:1), DB, tucatinib + trastuzumab + capecitabine vs. placebo + trastuzumab + capecitabine |
PFS: 7.8 (95% CI: 7.5 – 9.6) vs. 5.6 (95% CI: 7.2 – 7.1) months (HR 0.54; 95% CI:0.42-0.71) | OS: 21.9 vs. 17.4 months (HR: 0.66; 95% CI: 0.50-0.87) PFSBrainMets: 7.6 vs. 5.4 months (HR: 0.48; 95% CI: 0.34-0.69) ORR: 40.6%-46.0) vs. 22.8% DoR: 8.3 vs. 6.3 months |
In combination with trastuzumab and capecitabine for treatment of adult patients with advanced unresectable or metastatic HER2-positive breast cancer, including patients with brain metastases, who have received one or more prior anti-HER2-based regimens in the metastatic setting | N/A |
| Margetuximab-cmkb47,48 (RA December 16, 2020) Utilized AAid |
Patients with immunohistochemistry (IHC) 3+ or in situ hybridization (ISH-amplified HER2-positive MBC who had received prior treatment with other anti-HER2 therapies (n=536) | SOPHIA OL, R (1:1) margetuximab + chemotherapy (M+C) vs. trastuzumab + chemotherapy (T+C) | PFS: 5.8 vs. 4.9 months (HR 0.76; 95% CI: 0.59-0.98) OS: Not mature |
ORR: 22% vs. 16% DoR: 6.1 vs. 6.0 months |
In combination with chemotherapy, for the treatment of adult patients with metastatic HER2-positive breast cancer who have received two or more prior anti-HER2 regimens, at least one of which was for metastatic disease | N/A |
| mTNBC | ||||||
| Atezolizumab49,50,51,52 (AA March 8, 2019) Utilized AAid Note: The drug company announced in August 2021 that this indication will be withdrawn voluntarily after consultation with FDA regarding alterations in the treatment landscape that changed risk benefit calculation.54 |
locally advanced or metastatic TNBC patients that had not received prior chemotherapy for metastatic disease (n=902) | IMpassion130 DB, R (1:1), atezolizumab + paclitaxel protein-bound vs. placebo + paclitaxel protein-bound | PFS PD-L1-pos: 7.4 vs. 4.8 months (HR 0.60; 95% CI: 0.48-0.77) OS PD-L1-pos: 25.4 vs. 17.9 months (HR 0.67; 95% CI: 0.53 −0.86) Note: OS in the PD-L1 expression ≥ 1% population was a major efficacy endpoint, but there remained no alpha to evaluate this endpoint. These results should be considered not statistically significant. |
ORR: 98% vs. 60% DoR: 9.2 vs. 6.2 months |
Treatment of patients with unresectable locally advanced or metastatic TNBC whose tumors express PD-L1 (PD-L1 stained tumor-infiltrating immune cells of any intensity covering ≥ 1% of the tumor area) | Ventana PD-L1 (SP142) Assay (Ventana Medical Systems, Inc.) |
| Pembrolizumab55,56,57,58 (AA November 13, 2020, RA July 26, 2021) Utilized AAid |
Patients with locally recurrent unresectable or metastatic TNBC, regardless of tumor PD-L1 expression, who had not been previously treated with chemotherapy in the metastatic setting (n=847) | KEYNOTE-355 DB, R (2:1) pembrolizumab + chemotherapy (paclitaxel, paclitaxel protein-bound, or gemcitabine and carboplatin) or placebo + chemotherapy | PFS: 9.7 vs. 5.6 months (HR 0.65; 95% CI: 0.49 – 0.86) | OS: Not mature ORR: 53% vs. 40% DoR: 19.3 vs. 7.3 months |
In combination with chemotherapy for the treatment of patients with locally recurrent unresectable or metastatic TNBC whose tumors express PD-L1 (CPS ≥10) | PD-L1 IHC 22C3 pharmDx (Dako North America, Inc.) |
| Sacituzumab govitecan-hziy59,60,61 (AA April 22, 2020; RA April 7, 2021) Utilized AAid, RTOR, and Orbis |
mTNBC after 2 prior therapies for metastatic disease (n=108) | IMMU-132-01 SA, sacituzumab monotherapy |
ORR: 33.3% (95% CI: 24.6-43.1) | DOR: 7.7 months (95% CI:4.9-10.8). | Treatment of adult patients with mTNBC who have received at least two prior therapies for metastatic disease. | N/A |
| Unresectable locally advanced or mTNBC after 2 prior therapies (1 of which could be in (neo)adjuvant setting if progression within 12 months. | ASCENT OL, R (1:1) Sacituzumab vs. TPC |
PFS BMNeg: Results not applicable as indication granted for ITT population | PFS ITT: 4.8 vs. 1.8 months (HR 0.43; 95% CI: 0.35-0.54) OS: 11.8 vs. 6.9 months (HR 0.51; 95% CI: 0.41-0.62). |
Treatment of adult patients with unresectable locally advanced or mTNBC who have received two or more prior systemic therapies, at least one of them for metastatic disease. |
N/A | |
| Germline BRCA-mutated (gBRCAm) HER2-negative MBC | ||||||
| Olaparib63,64,65 (RA, January 12, 2018) |
gBRCAm HER2-negative MBC (n=302) | OlympiAD OL, R (2:1) olaparib vs. TPC (capecitabine, vinorelbine, or eribulin) | PFS: 7.0 vs. 4.2 months (HR 0.58; 95% CI: 0.43 – 0.80) | ORR: 52% (95% CI: 44-60) vs. 23% (95% CI: 13 - 35) OS: 19.3 vs. 17.1 months (0.90; 95% CI: 0.66 - 1.23) |
Treatment of adult patients with deleterious or suspected deleterious gBRCAm, HER2-negative MBC who have been treated with chemotherapy either in the neoadjuvant, adjuvant, or metastatic setting. Patients with HR-positive breast cancer should have been treated with a prior endocrine therapy or be considered inappropriate for endocrine therapy. | BRACAnalysis CDx (Myriad Genetic Laboratories, Inc.) |
| Talazoparib66,67 (RA, October 16, 2018) |
gBRCAm HER2-negative locally advanced or MBC (n=431) | EMBRACA OL, R (2:1) talazoparib vs. TPC (capecitabine, eribulin, gemcitabine, or vinorelbine) | PFS: 8.6 vs. 5.6 months (HR 0.54; 95% CI: 0.41 – 0.71) | ORR: 50.2% (95% CI: 43.4- 57.0) vs. 18.4% (95% CI: 11.8 - 26.8) Median DoR 6.4 (95% CI: 5.4 - 9.5) vs. 3.9 (95% CI: 3.0 – 7.6) months |
Treatment of adult patients with deleterious or suspected deleterious germline breast cancer susceptibility gene (BRCA)-mutated (gBRCAm) human epidermal growth factor receptor 2 (HER2)-negative locally advanced or metastatic breast cancer. | BRACAnalysis CDx (Myriad Genetic Laboratories, Inc.) |
| MBC, Regardless of Subtype | ||||||
| Eribulin6 (RA November 15, 2010) |
Locally recurrent or MBC (n= 762) | OL, R (2:1) Eribulin vs. TPC |
OS: median 13.1 months versus 10.6 months (HR 0.81; 95% CI: 0.66-0.99) for eribulin versus TPC | ORR: 11% (95% CI: 8.6-14.3) DoR: 4.2 months (95% CI: 3.8-5.0) |
Patients with metastatic breast cancer who have previously received at least two chemotherapeutic regimens for the treatment of metastatic disease. Prior therapy should have included an anthracycline and a taxane in either the adjuvant or metastatic setting | N/A |
Data in the table reflects updated information from the recent product USPI, as dated in the references
First indication for palbociclib in combination with letrozole as initial endocrine-based therapy in postmenopausal women was based on PALOMA-1. This indication was expanded in 2017 to include any aromatase inhibitor and converted to regular approval based on results of PALOMA-2.
Premenopausal and perimenopausal women were eligible if they also received goserelin.
Not statistically significant.
R: Randomized; OL: Open-label; DB: Double-blind; TPC: Treatment of Physicians Choice; ET: endocrine therapy; INV: investigator; PFS: progression-free survival; OS: overall survival; NR: not reached; NSAI: non-steroidal aromatase inhibitor; AAid: Assessment Aid; RTOR: Real-Time Oncology Review; PIK3CA: Phosphatidylinositol-4,5-Bisphosphate 3-Kinase Catalytic Subunit Alpha; SA: single-arm; BMNeg: brain metastases negative; ITT: intention-to-treat
Table 2:
Drug Approvals in Early Breast Cancer: 2010-2020*
| Setting | Drug (Trial Supporting Approval) | Approval | Indication | Primary Endpoint | Diagnostic Device specified in USPI |
|---|---|---|---|---|---|
| Neoadjuvant | Pertuzumab68 (NeoSphere) (n= 417) Supportive trials: TRYPHAENA (n= 225) and BERENICE (n= 401) |
AA; September 2013 (converted to RA December 2017) | Use in combination with trastuzumab and chemotherapy as neoadjuvant treatment of patients with HER2-positive, locally advanced, inflammatory, or early-stage breast cancer (either greater than 2 cm in diameter or node positive) as part of a complete treatment regimen for early breast cancer. | pCR ITT (ypT0/is ypN0): 39.3% (95% CI: 30.0-49.2) vs. 21.5% (95% CI: 14.1-30.5) | Assessment of HER2 protein overexpression and HER2 gene amplification should be performed using FDA-approved tests specific for breast cancer |
| Adjuvant | Neratinib75 (ExteNET) (n= 2840) | RA; July 2017 | As a single agent, for the extended adjuvant treatment of adult patients with early stage HER2-positive breast cancer, to follow adjuvant trastuzumab-based therapy. | iDFS: iDFS at 24 months 94.2% vs. 91.9% (HR 0.66; 95% CI: 0.49-0.90 | N/A |
| Pertuzumab69,66 (APHINITY) (n= 4804) | RA; December 2017 | Use in combination with trastuzumab and chemotherapy as adjuvant treatment of patients with HER2-positive early breast cancer at high risk of recurrence | iDFS: iDFS at 3 years 93.5 vs. 92.5% (HR 0.83; 95% CI: 0.68 – 1.00) | Assessment of HER2 protein overexpression and HER2 gene amplification should be performed using FDA-approved tests specific for breast cancer | |
| Ado-Trastuzumab Emtansine/T-DM172,73 (KATHERINE) (n= 1486) Utilized AAid and RTOR |
RA; May 2019 | The adjuvant treatment of patients with HER2-positive early breast cancer who have residual invasive disease after neoadjuvant taxane and trastuzumab-based treatment | iDFS: iDFS at 3 years 88.3 vs. 77.0% (HR 0.50; 95% CI: 0.39-0.64) | Patients should be selected based on an FDA-approved companion diagnostic for T-DM1 (1) PATHWAY anti-HER-2/neu (4B5) Rabbit Monoclonal Primary Antibody assay (2) INFORM HER2 Dual ISH DNA Probe Cocktail assay (Ventana Medical Systems, Inc.) |
Data in the table reflects updated information from the recent product USPI, as dated in the references
AA – Accelerated Approval
RA – Regular Approval
pCR – pathological complete response
ITT – intention-to-treat
ypT0/is ypN0 - absence of invasive cancer in the breast and lymph nodes (FDA preferred definition)
iDFS – invasive disease-free survival
Advanced/Metastatic Breast Cancer (MBC)
Hormone Receptor (HR)-positive and HER2-negative MBC:
The most common subtype of BC is HR-positive, HER2-negative.3 For patients with HR-positive, HER2-negative MBC, hormonal therapy is the backbone of first-line standard of care treatment. FDA-approved hormonal agents have demonstrated improvements in response rate and time to progression. Table 1 describes initial drug approvals of hormonal and chemotherapeutic agents.4,5,6 However, most patients who initially benefit from hormone therapy develop resistance during treatment.7 In the past decade, novel drug classes such as CDK4/6 inhibitors (CDK4/6i) have been developed and approved, demonstrating improved PFS and eventually OS in patients with HR-positive, HER2-negative MBC. Combinations of endocrine therapy and CDK4/6i represent the new standard of care in both the first and second line setting in advanced HR-positive, HER2-negative breast cancer. Alpelisib was the first phosphoinositide 3-kinase (PI3K) inhibitor to be approved for BC, on the basis of improved PFS for patients with HR-positive, PIK3CA mutated breast cancer in the second- and later-line settings. In total, three CDK 4/6i and one PI3K inhibitor have been approved (Table 1).
-
Palbociclib8,9,10,11: In 2015, FDA granted AA to the first CDK4/6i for treatment of patients with HR-positive, HER2-negative advanced or MBC in combination with letrozole as initial endocrine-based therapy in postmenopausal women. The AA was based on a randomized, open-label phase I/II PALOMA-1 trial that compared palbociclib plus letrozole with letrozole alone in postmenopausal women with HR-positive, HER2-negative BC who had not received prior systemic treatment for advanced disease. PALOMA-1 trial demonstrated a substantial improvement in median PFS however given the small trial size and potential uncertainty surrounding the results an AA was granted. This indication was expanded in 2017 to include in combination with any aromatase inhibitor (AI) and converted to regular approval (RA) based on consistent results from a larger randomized PALOMA-2 trial in the same setting.
In 2016, palbociclib received RA in combination with fulvestrant based on the results of randomized, double-blind trial PALOMA-3. In 2019, FDA expanded the approved indications for palbociclib in combination with an AI or fulvestrant, to include men. Given the rarity of BC in males, this expansion of indications was mainly based on the use of trial data from the PALOMA trials and supported by real-world data of men from electronic health records and insurance claims.12
Ribociclib13,14,15,16,17,18: In 2017, ribociclib in combination with an AI received RA for the treatment of postmenopausal women based on a randomized, double-blind, placebo-controlled trial MONALEESA-2. The indication was expanded in 2018 in combination with an AI for pre/perimenopausal women based on results from a randomized, double-blind, placebo-controlled trial MONALEESA-7. Ribociclib was also approved in combination with fulvestrant for postmenopausal women with HR-positive, HER2-negative advanced or MBC, as initial endocrine-based therapy or following disease progression on endocrine therapy based on results from a randomized double-blind, placebo-controlled MONALEESA-3 trial demonstrating a significant median PFS. In 2017, ribociclib and letrozole as a co-package was approved.19
Abemaciclib20,21,22,23,24: In 2017, abemaciclib in combination with fulvestrant received RA for women with HR-positive, HER2-negative advanced or MBC based on MONARCH-2, a placebo-controlled, randomized trial. In addition, abemaciclib was approved as monotherapy for women and men with HR-positive, HER2-negative advanced or MBC with disease progression following endocrine therapy and prior chemotherapy in the metastatic setting. The approval as monotherapy was based on MONARCH-1, a single-arm trial which demonstrated a significant objective response rate (ORR) median duration of response (DoR). In 2018, abemaciclib received RA in combination with an AI for the treatment of postmenopausal women with HR-positive, HER2-negative advanced or MBC based on randomized, double-blinded, placebo-controlled MONARCH-3 trial, which demonstrated a significant improvement of median PFS of abemaciclib compared to placebo.
Alpelisib25,26,27: In 2019, alpelisib, an oral alpha-specific PI3K inhibitor, received RA in combination with fulvestrant for HR-positive, HER2-negative, PIK3CA-mutated, advanced or MBC as detected by an FDA-approved test following progression on or after an endocrine-based regimen. The approval was based on SOLAR-1, a randomized, double-blind, placebo-controlled trial and was the first PI3K inhibitor receiving FDA approval for breast cancer. The median PFS was significant in the PIK3CA tumor-mutated population. No PFS benefit was observed in patients whose tumors did not have a PIK3CA mutation, therefore, the indication was limited to the PIK3CA-mutated population. OS data were immature at the time of the primary PFS analysis. Of note, only 6% of trial participants had received an AI plus CDK inhibitor and no patients had prior fulvestrant plus CDK4/6i prior to receiving alpelisib plus fulvestrant. However, although this subset was small with wide confidence interval intervals, the PFS results favored the use of alpelisib. This was further supported by interim results of the BYLieve trial, in which a cohort treated with prior AI and CDK4/6i benefitted from treatment with alpelisib plus fulvestrant.28
HER2-positive MBC:
HER2-positive MBC represents approximately 15% of all BC subtypes with a 5-year relative survival rate ranging from 37-44% depending on HR status.3 Approval of novel agents including subcutaneous formulations that can be administered faster have expanded the treatment options available to patients with HER2-positive MBC (Table 1). Prior to these approvals, trastuzumab had shown improvement in survival and represented a significant treatment advance for patients with this subtype of breast cancer. Lapatinib was also approved as an oral therapy option in 2007. However, there remained a need for further effective therapies once there was disease progression or resistance.
Pertuzumab29,30,31: In 2012, FDA granted pertuzumab, a monoclonal antibody against HER2, RA in combination with trastuzumab and docetaxel for treatment of patients with HER2-positive MBC who have not received prior anti-HER2 therapy or chemotherapy for metastatic disease. Approval was based on CLEOPATRA, a randomized double-blind, placebo-controlled trial in patients with HER2-positive MBC who received trastuzumab and docetaxel combined with either placebo or pertuzumab. A significant improvement in the primary endpoint of PFS was seen for the addition of pertuzumab. The final OS analysis also showed a statistically significant improvement in favor of the pertuzumab arm. This approval represented the first approval after trastuzumab after a gap of greater than 10 years for an antibody targeting HER2 that showed a survival benefit when combined with trastuzumab.
Lapatinib32,33: In 2010, this oral tyrosine kinase inhibitor of HER2 (initial approval in 2007) was granted AA for use with letrozole for the treatment of postmenopausal women with HR-positive MBC that overexpresses the HER2 receptor for whom hormonal therapy is indicated. Approval was based on a double-blind, placebo-controlled trial that demonstrated a significant median PFS improvement in the HER2-positive population. No benefit was noted in the HER2-negative population included in the trial. This indication was converted to RA in 2018, based on clinically meaningful and statistically significant improvement in PFS observed in EGF114299/LAP016A2307 trial.
Ado-trastuzumab emtansine (T-DM1)34,35,36: In 2013, FDA granted RA to T-DM1, an antibody drug conjugate (ADC) targeting HER2 as monotherapy for the treatment of patients with HER2-positive, MBC who previously received trastuzumab and a taxane, separately or in combination. The approval was based on an open-label phase 3 EMILIA trial that randomized patients to receive T-DM1 or lapatinib plus capecitabine. T-DM1 demonstrated a significant improvement in PFS and OS compared to lapatinib plus capecitabine. In addition to the clinically meaningful survival benefit demonstrated, this was also the first ADC granted FDA approval for HER2-positive breast cancer.
Fam-trastuzumab deruxtecan-nxki (T-DXd)37,38,39: In 2019, T-DXd an ADC targeting HER2, received AA for the treatment of patients with unresectable or metastatic HER2-positive BC who have received two or more prior anti-HER2-based regimens in the metastatic setting. Efficacy was evaluated in DESTINY-Breast01, a single-arm trial with HER2-positive, unresectable or MBC patients, who had received two or more prior anti-HER2 therapies. A clinically meaningful confirmed ORR and median DoR was the basis of approval. At the time of AA, treatment options for HER2-positive patients after two lines of therapy were limited, and the results demonstrated significant improvements over available therapies for a heavily pretreated population.
Neratinib40,41: In 2020, neratinib, an oral TKI targeting HER2, received RA in combination with capecitabine for patients with HER2-positive advanced or MBC who have received two or more prior anti-HER2 based regimens in the metastatic setting. The approval was based on NALA, an open-label trial in which patients with HER2-positive MBC were randomized to neratinib and capecitabine or lapatinib and capecitabine. A significant improvement in median PFS was demonstrated. Although median PFS data was similar between arms, the 12- and 24-month PFS analyses and Hazard Ratio favored the neratinib arm. Prior to this approval, neratinib was only approved in the early breast cancer setting and now offered another option for heavily pretreated patients in the metastatic setting.
Tucatinib42,43,44: In 2020, tucatinib, an oral TKI targeting HER2, received RA in combination with trastuzumab and capecitabine, for adult patients with advanced unresectable or metastatic HER2-positive BC, including patients with brain metastases, who have received one or more prior anti-HER2-based regimens in the metastatic setting. Efficacy was demonstrated in HER2CLIMB, a randomized, double-blind, placebo-controlled trial which enrolled HER2-positive MBC patients who had received prior treatment with trastuzumab, pertuzumab, and T-DM1. Median PFS and OS were significant for tucatinib, trastuzumab, and capecitabine compared to the control arm of trastuzumab and capecitabine. In the subgroup of patients with brain metastases at baseline, the median PFS on the tucatinib arm was significant compared to the control arm. This approval was the first to include the treatment of brain metastases in the indication and was the first new molecular entity to be reviewed under OCE’s Project Orbis.45,46
Margetuximab-cmkb47,48: In 2020, margetuximab, a monoclonal antibody targeting HER2 was granted RA in combination with chemotherapy, for the treatment of patients with HER2-positive MBC who have received two or more prior anti-HER2 regimens, at least one of which was for metastatic disease. Efficacy and safety were evaluated in SOPHIA, a randomized, open-label trial of patients HER2-positive MBC who had received prior treatment with other anti-HER2 therapies. Patients were randomized to margetuximab plus chemotherapy or trastuzumab plus chemotherapy. Median PFS in the margetuximab arm was significantly improved compared to the control arm. Despite the small magnitude of improvement in median PFS; since trastuzumab plus chemotherapy was an active control in the trial, there was a reasonable assurance that margetuximab plus chemotherapy, at minimum, confers the same amount of benefit, if not more, as trastuzumab plus chemotherapy. Since regular approval does not require demonstration of superiority over available therapies, it was acceptable to grant regular approval to margetuximab-cmkb. Subgroup information for efficacy in various genotypes was not included in the USPI as the FDA considered these exploratory analyses as these were not statistically prespecified.
Metastatic Triple Negative Breast Cancer (TNBC):
TNBC represents approximately 10% of BCs and has the lowest 5-year survival rate of approximately 11.5% for metastatic disease among all subtypes.3 In the last decade the first therapies specifically for TNBC were approved including 3 AAs, 2 of which were the first immunotherapy approvals for BC, as well as an ADC (Table 1).
Atezolizumab49,50,51,52: Atezolizumab, an anti-PD-1 monoclonal antibody, in combination with paclitaxel protein-bound was granted AA in 2019 for the treatment of patients with unresectable locally advanced or metastatic TNBC whose tumors express PD-L1 (PD-L1 stained tumor-infiltrating immune cells of any intensity covering ≥ 1% of the tumor area). This approval was based on PFS from IMpassion130, a double-blinded, placebo-controlled, randomized trial. There was a modest improvement in PFS favoring the atezolizumab arm. At the time of final PFS analysis, the first interim analysis for OS was not statistically significant in the ITT population, therefore, OS was not formally tested in the PD-L1 positive population although a difference of approximately 7.5 months was seen in the second interim analysis. Given the modest magnitude of the PFS benefit and the immaturity of OS results at the time of approval, the PFS result for the PD-L1 population appeared reasonably likely to predict clinical benefit at a time when therapies for TNBC were limited and was appropriate for AA as opposed to RA for this indication. A subsequent confirmatory trial comparing atezolizumab in combination with paclitaxel vs. paclitaxel did not verify benefit and indicated a potential detriment in survival thus the label was changed to reflect this information and recommend against use with paclitaxel combination. This approval was discussed at the FDA Oncology Drugs Advisory Committee (ODAC) in April 2021, with committee members voting in favor of maintaining the indication while discussions continued regarding the plans to confirm clinical benefit.53 However, the regular approval of pembrolizumab plus chemotherapy for metastatic TNBC, that occurred after the advisory committee meeting, altered the treatment landscape and changed the risk benefit calculation. Therefore, in consultation with FDA, it was announced by the drug company that the indication for atezolizumab in metastatic TNBC will be voluntarily withdrawn.54
Pembrolizumab55,56: In 2020, pembrolizumab, an anti-PD-1 monoclonal antibody, was granted AA in combination with chemotherapy for the treatment of patients with locally recurrent unresectable or metastatic TNBC whose tumors express PD-L1 (CPS ≥10). Approval was based on KEYNOTE-355, a double-blind, placebo-controlled trial that randomized patients to receive pembrolizumab or placebo in combination with different chemotherapy treatments. The main efficacy outcome of PFS was tested in the subgroup of patients with CPS ≥10. Median PFS for this CPS cut-off was significant in the pembrolizumab plus chemotherapy arm compared to the placebo arm. The OS was not statistically significant at the time of approval but on subsequent analyses was announced as significantly improving OS in the CPS ≥ 10 group.57 This indication was converted to RA based on results from the KEYNOTE-522, a randomized, double-blind, placebo-controlled trial of pembrolizumab in combination with neoadjuvant chemotherapy followed by surgery and continued adjuvant treatment with single agent pembrolizumab.58
Sacituzumab govitecan-hziy59,60,61: In 2020, sacituzumab, an ADC directed against Trop-2, was granted AA for patients with metastatic TNBC who received at least two prior therapies for metastatic disease. Efficacy was demonstrated in IMMU-132-01, a single-arm trial enrolling patients with metastatic TNBC who received at least two prior treatments for metastatic disease. The primary efficacy outcomes were ORR and DoR. PFS and OS results from the ASCENT trial verified the clinical benefit of sacituzumab in patients with metastatic TNBC and supported conversion to RA in 2021. Based on results and eligibility of the confirmatory trial, the indication was also modified with the RA to allow earlier use in the metastatic setting.
Germline BRCA-mutated (gBRCAm) HER2-negative MBC:
Approximately 55-72% of women with a germline BRCA1 mutation and 45-69% of those with a germline BRCA2 mutation will develop BC in their lifetime.62 Two poly (ADP-ribose) polymerase (PARP) inhibitors are currently approved for gBRCAm, HER2-negative MBC (Table 1). Prior to these approvals there were no drugs specifically approved for these germline mutations in BC.
Olaparib63,64,65: In 2018, olaparib, was the first PARP inhibitor granted RA for the treatment of patients with deleterious or suspected deleterious gBRCAm, HER2-negative MBC who have been treated with chemotherapy either in the neoadjuvant, adjuvant, or metastatic setting. Approval was based on OlympiAD, an open-label trial that randomized patients to olaparib or physician’s choice of chemotherapy. The primary endpoint of median PFS was significant for olaparib compared to chemotherapy.
Talazoparib66,67: In 2018, talazoparib, a PARP inhibitor, was granted RA for patients with deleterious or suspected deleterious gBRCAm, HER2-negative locally advanced or MBC. Approval was based on EMBRACA, an open-label trial randomizing patients with gBRCAm HER2-negative locally advanced or MBC to receive talazoparib or physician’s choice of chemotherapy. The median PFS was significant in the talazoparib compared to chemotherapy.
Early Breast Cancer (EBC)
In the past 2 decades, there has been a significant improvement in clinical outcomes of patients with HER2-positive BC.68 Table 2 summarizes approvals from 2010-2020 in the neoadjuvant and adjuvant settings. The approval of pertuzumab in 2013 represented the first regulatory approval based on pathologic complete response (pCR) supported by a totality of evidence from the metastatic setting.69 Invasive disease-free survival (iDFS) results from the APHINITY trial verified the clinical benefit of pertuzumab and supported conversion to RA in 2017. Although the benefit in iDFS was small, it was considered meaningful in the high-risk patient population and thus the indication was broadened to include pertuzumab for treatment in the adjuvant setting for patients at high-risk of recurrence.70,71
In 2012, the FDA proposed the use of pCR rate as a new regulatory end point to aid in expediting the development of therapies for high-risk early breast cancer that was considered reasonably likely to predict improvement with long-term endpoints. An advantage of pCR is that it can be assessed at the time of breast surgery and patients achieving pCR have better prognosis than those with residual disease. However, pCR rate has not been validated at the trial level as a surrogate for event-free or OS. As the magnitude of pCR benefit that may translate into a meaningful long-term benefit is unknown, and there is need for supportive totality of data for such an approval, lack of pCR can alternatively be used as an enrollment criteria to enrich a trial for a high-risk population that might benefit more from escalated therapy in the adjuvant setting. This strategy would also reduce the risk of additional treatment toxicity for patients that may be at a lower risk of recurrence. Therefore, residual disease could act as a biomarker for selection of patients with early breast cancer at high-risk of recurrence and allow testing of new therapies in a more targeted population72,73 The approval of T-DM1 in 2019 for postoperative treatment of those with residual invasive BC after neoadjuvant therapy represented such an indication.74,75 FDA has encouraged use of response to neoadjuvant therapy as a prognostic biomarker in order to enrich clinical trials for patients at the highest risk of recurrence.76 The approval of neratinib in 2017 based on ExteNET trial offered an additional treatment option for patients with HER2-positive EBC for extended adjuvant treatment.77,78
DISCUSSION
BC management for certain subtypes has been greatly improved over the past decades with approval of multiple novel drug classes and agents.79 Between 2010-2020, 30 indications received FDA approval for treatment of BC, including four in the neoadjuvant and adjuvant settings and 26 in metastatic disease (Figure 1). For these 30 indications, 23 (76.6%) received RA and 7 (23.3%) were granted AA. Of the seven AA, five confirmed benefit (one in April 2021 and one in July 2021) and were subsequently converted to RA, one AA was voluntarily withdrawn in August 2021 and one is pending verification of benefit. AA allows for marketing of potentially transformative therapies years earlier based on earlier endpoints other than survival or irreversible morbidity. Additional trials may be required to confirm benefit and if trial(s) do not confirm benefit, or are substantially delayed, the indication may be withdrawn.80 This was the case in 2011, when FDA withdrew bevacizumab’s indication for use in combination with paclitaxel for the treatment of HER2-negative MBC.81In 2008, bevacizumab was granted AA based on an improvement in PFS without significant improvement in OS. AA was accompanied with post marketing requirement for confirmatory studies (AVADO and RIBBON1) to verify and describe the clinical benefit. These trials did not verify benefit and the company did not voluntarily withdraw thus an open public hearing was held and ultimately the FDA commissioner issued a final decision withdrawing the approval in November 2011.82 The indication for atezolizumab was announced for voluntary withdrawn in 2021 due to changes in the treatment landscape (Table 1).54
Figure 1: FDA Approval in Breast Cancer 2010-2020.

(Figure represents indication granted at time of approval.)
Among the 26 MBC indication approvals, only one was for a chemotherapy with the remaining for targeted or immune-therapies; six were granted in HER2-positive, 13 in HR-positive, HER2-negative, three in TNBC, two in gBRCAm BC, and one for HR-positive, HER2-positive BC (Figure 1). The majority of these approval decisions were supported by primary efficacy endpoints of PFS in 21 (80.8%), followed by OS or a combination of OS and PFS in two (7.7%), and ORR in three (11.5%). PFS was the most commonly used primary endpoint for approval in MBC and is a radiographic measurement. As noted, PFS has supported both RA and AA depending on the uncertainty and impact of the results. PFS allows for a smaller sample size and a shorter duration of follow-up compared to OS and is not confounded by subsequent therapies which can be a challenge in breast cancer. OS is always analyzed along with PFS and must not numerically favor the control arm. Many of the approvals initially approved using PFS subsequently demonstrated OS benefit. In EBC, one approval utilized pCR and three used iDFS to demonstrate a favorable benefit-risk profile. Among the 30 indications, 22 received priority review, seven were granted BTD, and ten participated in one or more novel OCE initiatives, including Real Time Oncology Review, Assessment Aid, and Orbis.83,84,45
Over the past decade, a deeper understanding of BC has emerged, which has led to the development of effective treatments targeting specific BC subtypes and increased use of precision oncology. Development of CDK4/6i, PI3Ki, PARP inhibitors, immune checkpoint inhibitors (ICI), ADCs and HER2 targeting agents in the last decade have provided treatment options for unique subsets of patients. For HR-positive, HER2-negative disease, CDK4/6i in combination with an AI or fulvestrant are now the preferred first-line therapy and after initial approval some of the CDK4/6i trials have demonstrated an OS benefit (Table 1). HER2-positive BC has similarly seen a rapid development of novel therapies that has helped in part to greatly improve outcomes for patients with this subtype of BC. Despite the initial slow development of ICI in BC, FDA granted two AA for ICI in combination with chemotherapy for PD-L1-positive TNBC. Of the two, one indication has been converted to RA in July 2021.58 The FDA also granted approvals for subcutaneous formulations of trastuzumab monotherapy and combination of trastuzumab and pertuzumab to provide additional options for patients receiving these regimens while substantially reducing infusion time, which is an important consideration during the ongoing COVID-19 pandemic.85,86
Broadening of eligibility criteria allows more patients access to clinical trials, and also produces trial results that are more representative of the actual population that will receive these therapies.87 FDA has released multiple guidances encouraging broadening trial enrollment including a guidance encouraging enrollment of men into breast cancer clinical trials, and another guidance on inclusion of premenopausal women into breast cancer clinical trials.88,89 Last year, FDA released a guidance on clinical trial inclusion of patients with stable and active brain metastases which was reflected in the first FDA approval specifying patients with brain metastases in the indication statement for tucatinib in HER2-positive MBC.46
In addition to encouraging broadened eligibility criteria, the importance of novel endpoints in breast cancer has also been explored in the past few years. Although only one approval was supported by pCR as an endpoint, we have seen the use of lack of pCR (or residual disease post neoadjuvant therapy) emerge as a potential enrichment biomarker for future use and the pCR guidance has been updated to include this potential for trial design.73,74 In the future other novel biomarkers or endpoints such as circulating tumor DNA in this residual disease space will be explored.90
CONCLUSION
Breast cancer outcomes have improved for many patients with early-stage and metastatic breast cancer over the last decade due to dozens of newly approved therapies. FDA expedited programs such as priority review, BTD, and AA, as well as OCE new initiatives, including Real Time Oncology Review, Assessment Aid, and Orbis have allowed for more efficient review and timely approval. However, despite the progress of the last decade, there is continued need for expanded eligibility criteria in clinical trials and development of therapies for patients with treatment-resistant or refractory BC. Looking toward the next decade, further advances in targeted therapies and combinations, predictive and prognostic biomarkers, and improving patient experience and tolerability will hopefully continue to address these unmet medical needs.
Footnotes
Publisher's Disclaimer: Disclaimer: Dr. Shaily Arora completed this work while employed at the U.S. Food and Drug Administration and is currently affiliated with AstraZeneca.
Disclosure of Potential Conflicts of Interest: The authors report no financial interests or relationships with the commercial sponsors of any products discussed in this report.
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