National Coverage Analysis (NCA) Tracking Sheet

Ferrlecit®: Intravenous Iron Therapy

CAG-00046N

Issue

Ferrlecit is an injectable iron product used for the treatment of iron deficiency anemia in end-stage renal disease (ESRD) patients undergoing dialysis who are receiving supplemental erythropoeitin therapy.

National Coverage Determinations

Benefit Category

Drugs and Biologicals

Requestor Information

Requestor Name Requestor Letter
Gary D. Kozloski, Pharm.D., Schein Pharmaceutical, Inc. N/A
N/A

Important Dates

Formal Request Accepted and Review Initiated
08/12/1999
Expected NCA Completion Date
04/20/2000
Public Comment Period
09/13/1999 - 10/13/1999
Proposed Decision Memo Due Date
Proposed Decision Memo Released
Proposed Decision Memo Public Comment Period
Decision Memo Released
04/26/2000

Contacts

Lead Analysts
Poppy Kendall
Lead Medical Officers

Medicare Benefit Category Determination Date

Actions Taken

August 10, 1999

Application received.

August 12, 1999

Formal request accepted for review.

November 12, 1999

Due date, revised. HCFA has extended its original decision date to January 31, 2000 while it continues to analyze issues of coverage. Particularly, we are interested in examining and comparing the conditions and the population for which sodium ferric gluconate is reasonable and necessary when compared with dextran iron injectables or with oral iron.

January 26, 2000

Questions in need of additional evidence:

(1) Is there any evidence that shows that sodium ferric gluconate is safer then oral iron therapy? Is there any evidence that shows sodium ferric gluconate is not riskier then oral iron?

(2) What is the evidence that sodium ferric gluconate is more effective than oral iron or can a population be defined for which this is so? What is the added value of IV iron as a first-line therapy option without a trial of oral iron?

(3) Is there a definable subset of anemic ESRD patients who should not be tried on oral iron before injectable?

(4) What is the evidence supporting the statement made in the normal request that "patients with functional iron deficiency do not meet laboratory criteria for absolute iron deficiency, but demonstrate an increase in hemoglobin/hematocrit or a decrease in rHuEPO dosage with stable hemoglobin/hematocrit when parenteral iron is administered"?

February 10, 2000

2000 Schein Pharmaceuticals, Inc. submitted evidence.

March 9, 2000

2000 American Regent Laboratories, Inc. submitted evidence.

March 10, 2000

Due date revised to May 10, 2000 in light of new evidence from Schein Pharmaceuticals, Inc. and American Regent Laboratories, Inc.

April 20, 2000

Decision made to issue a positive national coverage determination for sodium ferric gluconate complex in sucrose injection for either first or second line treatment of iron deficiency anemia in patients undergoing chronic hemodialysis who are receiving supplemental erythropoeitin therapy. See Decision Memorandum dated April 20, 2000.

April 26, 2000

Letter sent to requestor informing of decision.