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Biosimilar Interchangeability: Why FDA Designation Matters Less Than You Think

State pharmacy laws, not FDA designations, determine whether biosimilars actually get dispensed.

By RxInsider Editorial · Feb 28, 2025 · 780 words · via JD Supra
Biosimilar Interchangeability: Why FDA Designation Matters Less Than You Think

Image: JD Supra

The FDA granted interchangeable status to Cyltezo (adalimumab-adbm) in October 2021, making it the first interchangeable biosimilar in the US. Three years later, interchangeability has proven to be a commercial non-factor. Cyltezo holds less than 3% market share despite its regulatory distinction.

The disconnect between regulatory status and market reality comes down to channel economics. In the physician-administered (Part B) space, biosimilar adoption is driven by ASP-based reimbursement and 340B spread, not interchangeability. Practices and hospitals choose biosimilars when the acquisition cost advantage creates margin. Interchangeability is irrelevant because these products are prescribed by brand name.

In the pharmacy-dispensed (Part D) space, interchangeability theoretically enables automatic substitution. But PBM formulary management already controls which products get dispensed. If a PBM's preferred formulary lists a specific biosimilar, that product gets dispensed regardless of interchangeability status. The formulary, not the FDA designation, is the gatekeeper.

Manufacturers pursuing interchangeability face 18-24 months of additional development time and $50-80 million in switching study costs. The strategic question is whether that investment generates incremental market share. Current evidence suggests it does not.

Tags
biosimilarinterchangeabilityFDACyltezo
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