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Report
Biosimilar R&D Co.
Budget
Cost of Obtaining FDA Marketing
Approval
Date: 12/09/15
Page 1 of 20
Title
Page
Figure 1
Figure 2
Table 1
Figure 3
Direct/Indirect Costs
Table 2
Figure 4
Table 3
WBS Dictionary
Table 4
Figure 5
Budget Schedule
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
Table 11
10
Figure 6
10
Table 12
10
Table 13
10
Table 14
11
Table 15
11
Table 16
11
Table 17
11
Table 18
12
3-5
8-9
Page 2 of 20
1.0
EXECUTIVE SUMMARY
The objective of this project is to estimate the budget for an R&D organization that is
attempting to achieve FDA marketing approval for a biosimilar. The total budget for this 10year project was estimated to be $224.063 million. The following figures and tables are a
breakdown of the project costs.
In conclusion, this cost model is a good starting point in identifying the major cost drivers
and plan to achieve FDA marketing approval for a biosimilar, but further refinements
(quotes/actuals) are needed to reduce the estimate uncertainty.
Page 3 of 20
2.0
INTRODUCTION
The objective of this project is to estimate the budget for an R&D organization that is
attempting to achieve FDA marketing approval for a biosimilar. The estimate will include the
research and development of a biosimilar that will require pre-clinical testing, clinical trials
for comparability purposes, and approval by the FDA and also, the operation of a facility to
produce, manufacture, and test the biosimilar.
The estimate will be used to learn and understand the process of achieving FDA-approval for
a biosimilar and to determine potential cost drivers.
The cost model designed as part of this project is expected to address most of the budgetary
items (some exclusions were made) that should be considered when attempting to develop
a biosimilar for FDA approval. This is a general model, so once a particular biologic is
identified quotes or actuals for the required materials and clinical trial costs by therapeutic
area can be included to further refine the accuracy of the model.
3.0
As can be seen in Figure 4, the Work Breakdown Structure (WBS) is made up of 31 bottom
level work elements (highlighted yellow). Each of the WBS elements are defined in Table 3.
WBS
Code
Element Name
1.1
GMP Facility
1.1.1
Lease
1.1.2
Clean Rooms
1.2
1.2.1
1.2.2
Manufacturing Process
Definition
All phases and items required to develop, test, and achieve FDA marketing
approval for a biosimilar.
The facility where the R&D, Manufacturing, and QA testing for the
biosimilar will take place.
The cost to lease a facility of 10,000 ft2 in Florida.
The manufacturing suites and filler cover at various air quality
classifications.
The R&D phase of the organization, which is made up of the items listed
and also includes the optimization and scale-up of the manufacturing
process and establishment of procedures.
The genetic modification of a cell line, which is considered the starting
point for successful protein production.
The procurement of the manufacturing equipment and the establishment
of the upstream and downstream manufacturing process.
Page 4 of 20
Lev
el
WBS
Code
Element Name
1.2.3
Quality Specifications
1.3
Manufacturing
1.3.1
The upstream of the manufacturing process, in which the cell line is given
a media mix to allow for a consistent protein production.
1.3.2
1.3.3
1.4
Quality Assurance
1.4.1
The tests required for incoming raw materials that are used as part of the
manufacturing process.
1.4.2
In-Process Testing
Definition
The procurement of the laboratory equipment, the characterization of the
biosimilar and innovator drug, and the establishment of the raw material,
in-process, and release tests.
The Manufacturing phase/department of the organization.
The tests that characterize the drug at various stages of the manufacturing
process to confirm its quality and characteristics.
The tests required on the finished product to confirm its quality and
efficacy to allow for its release. The stability tests confirm that the drug is
stable and maintains its quality characteristics over a long period of time
(i.e. 2 years).
1.4.3
1.5
1.5.1
Preclinical Program
The lab tests and animal studies that need to be completed before testing
the biosimilar in humans.
1.5.1.1
The lab tests that compare the structure and function of the biosimilar with
the innovator drug.
1.5.1.2
Animal Studies
1.5.2
Clinical Program
1.5.2.1
1.5.2.2
1.5.2.3
The large study that may be required by the FDA after approval to further
monitor the safety and efficacy of the biosimilar.
1.6
The biosimilar user fees that indicate communication with the FDA and are
required to receive FDA approval.
1.6.1
1.6.2
The biosimilar application, which will include the CMC package, Preclinical
data/results, and the Clinical trial data/results.
1.6.3
1.6.4
1.7
1.7.1
1.7.2
1.7.3
1.7.4
1.7.5
1.8
Overhead
The main tests that are used to demonstrate biosimilarity to the FDA.
The comparison of the toxicity, safety, and efficacy of the biosimilar with
the innovator drug in animal models.
The clinical studies which require the testing of the biosimilar in human
subjects.
The multiple early trials, including one pivotal study, to compare the safety
of the biosimilar with the innovator drug.
The pivotal large study that will compare the safety and efficacy of the
biosimilar with the innovator drug. I believe it needs to only show noninferiority to the innovator drug.
Page 5 of 20
Lev
el
WBS
Code
1.8.1
1.8.2
1.8.3
1.8.4
1.8.5
G&A
1.8.6
Legal Support
4.0
Element Name
Definition
The material burden for the materials in the R&D phase.
The material burden for all of the materials in the QA phase/department.
The material burden for all of the materials in the R&D phase.
The expected maintenance and qualification costs for the facility and
equipment and the validation of the processes.
The general and administrative fees/costs.
The lawyers that may be necessary for potential clinical trial issues and
patent issues/disputes with the innovator drug company.
ASSUMPTIONS/GROUND RULES
The assumptions/ground rules for this cost estimating exercise, as well as the WBS elements
affected by and the rationale for these assumptions are listed in Table 4. (Note: These
assumptions/ground rules can probably be expanded upon).
Table 4: Cost Estimate Assumptions/Ground Rules
Ground Rules / Assumptions
WBS Element(s)
Affected
Rationale
All
N/A
1.1
1.2 - 1.4
1.2
1.3, 1.4
1.5.2
5.0
The budget schedule for this project is shown in Figure 5. The top row of data shows the
project cost per year and the total cost per element is shown in the right column. The green
boxes indicate the milestone starting year for the element and the red boxes indicate the
milestone completion year for the element. The elements that have orange boxes in the FY
Page 6 of 20
2025 column, were considered for the calculation of Recurring Cost ($16.885 million per
year, assuming 4 lots produced), except for WBS element 1.5.2.3, which is a Post-Approval
study, and half of its cost was put toward the budget of FY 2025.
GMP Facility
$24.553
10.96%
$34.590
15.44%
Manufacturing
$52.393
23.38%
Quality Assurance
$30.066
13.42%
$64.962
28.99%
Page 7 of 20
$3.336
1.49%
$14.164
6.32%
The Total Costs for each year of this 10-year project is shown in Figure 2. I need to more
research regarding how an R&D organization should be allocating its fund to determine
whether this is a successful trend or if the costs should be distributed in some other fashion
across the schedule. The last 3 years of the project have the highest total cost of the project,
which is to be expected since they include Phase 3 and 4 clinical trial costs.
The Project Cost Type Breakdown is shown in Table 1. The ratio of Labor to Material costs
over this 10-year project is approximately 28% to 72%, respectively. As can be seen in the
table, the subcontracted material costs, which is mainly from the Preclinical and Clinical
Programs, makes up approximately 30% of the total budget, which is a good sign as per our
Cost Estimating textbook, which notes that it is not cost-effective to subcontract more than
60 percent of an organizations work.
The Direct/Indirect costs of the project are shown in Figure 3. If we exclude the Comparative
Testing (WBS 1.5), the Direct to Indirect costs is close to a 60% to 40%, which is shown in
Table 6. This is much closer to that 50/50 split we expect to see for a business.
Table 6: Direct/Indirect Costs (excluding WBS 1.5)
Direct
Indirect
$96.319
$65.791
59.42%
40.58%
The Fixed vs. Variable costs is the same as the Non-recurring vs. Recurring costs reported in
Section 1.0.
I did not include Travel or Marketing/Sales Support as part of the budget, but those two
elements should probably be included if considering the generation of a Fee/Profit.
Further configuration of the cost model is needed in order to organize the costs in the
following manner: controllable vs. non-controllable, engineered vs. managed, R&D and
administrative.
6.0
Each cost element is summarized in this section and in the models Excel file. The cost
elements are defined in Table 3. The estimating methodology employed and data acquired
for each element is noted in the Excel file. A breakdown of the costs for each WBS Level 2
and two Level 3 elements is shown in Table 7.
1.1
1.2
1.3
1.4
Total Budget
$10.390
$29.212
$41.787
Initial
Acquisition
$4.390
$6.940
Fixed
$4.390
$29.212
1.5
1.6
1.7
1.8
$41.890
$3.336
$13.603
$38.717
$0.000
$0.000
$0.000
$0.000
$0.000
$20.062
$41.890
$2.571
$9.397
$4.990
1.5.1
1.5.2
$25.066
$20.062
$0.000
$0.000
$0.000
$0.000
Page 7 of 20
Variable
$0.600
$0.000
$7.490
$4.152
$0.000
$0.000
$0.765
$0.526
$3.351
Direct
$4.390
$26.247
$36.962
$19.793
$20.062
$41.890
$3.336
$5.592
$0.000
Indirect
$6.000
$2.965
$4.826
$5.273
$0.000
$0.000
$0.000
$8.011
$38.717
(per
year assuming 4
lots)
$0.600
$0.000
$7.490
$4.152
$0.000
$0.000
$0.765
$0.526
$3.351
Non-recurring
$4.390
$29.212
$0.000
$0.000
$20.062
$41.890
$2.571
$9.397
$4.990
Labor
$0.000
$8.471
$13.787
$15.066
$0.000
$0.000
$0.000
$8.603
$16.662
Direct Labor
$0.000
$5.506
$8.962
$9.793
$0.000
$0.000
$0.000
$5.592
$0.000
Labor Burden
$0.000
$2.965
$4.826
$5.273
$0.000
$0.000
$0.000
$3.011
$8.498
G&A
$0.000
$0.000
$0.000
$0.000
$0.000
$0.000
$0.000
$0.000
$8.164
Material
$10.390
$20.740
$28.000
$10.000
$20.062
$41.890
$3.336
$5.000
$22.055
Direct Material
$0.000
$13.800
$28.000
$10.000
$20.062
$41.890
$3.336
$0.000
$0.000
Material
Burden
$6.000
$0.000
$0.000
$0.000
$0.000
$0.000
$0.000
$5.000
$22.055
Equipment
$4.390
$6.940
$0.000
$0.000
$0.000
$0.000
$0.000
$0.000
$0.000
Subcontract
$0.000
$0.000
$0.000
$0.000
$20.062
$41.890
$0.000
$5.000
$1.000
Recurring
7.0
ELECTRONIC ESTIMATE
In this section I will outline the makeup of the Excel file that was used to electronically put
together the cost estimate for this project. The descriptions of each sheet of the Excel file
are shown in Table 8.
Table 8: Excel File Description
Sheet
#
Name
Description
WBS
Ground Rules
(Assumptions)
The project scope and Work Breakdown Structure for the project.
The ground rules/assumptions made for this estimate model (may not have listed every
assumption so it can be expanded upon).
Point Estimate
The budget schedule for this project and the data is linked to various sheets throughout
the Excel file.
Sensitivity Analysis
Contains data and parameters used to perform the Sensitivity Analysis of the cost model.
Uncertainty - Risk
Analysis
The estimating methodology is noted for each bottom-level WBS element and the costs
associated with that element. The total cost for each estimating methodology is compiled
and the data is linked to various sheets throughout the Excel file.
Model Limitations
The known limitations of this cost model will be listed here (still need to clearly identify
most of the limitations).
Labor Rates
A compilation of the labor rates data and the calculation of the wage inflation rate for
various skills.
Labor Costs
The staffing method used to quantify the labor costs for the R&D phase and the labor
costs per year associated with the Manufacturing/QA departments.
10
Cost data, estimating methodology, and types of costs for WBS 1.1.
11
1.2 R&D
Cost data, estimating methodology, and types of costs for WBS 1.2.
12
1.3 Manufacturing
Cost data, estimating methodology, and types of costs for WBS 1.3.
13
1.4 QA
Cost data, estimating methodology, and types of costs for WBS 1.4.
14
Cost data, estimating methodology, and types of costs for WBS 1.5.1.
15
Cost data, estimating methodology, and types of costs for WBS 1.5.2.
16
Cost data, estimating methodology, and types of costs for WBS 1.6.
17
1.7 PM Support
Cost data, estimating methodology, and types of costs for WBS 1.7.
18
1.8 Overhead
Cost data, estimating methodology, and types of costs for WBS 1.8.
The breakdown of the cost types including the definition of each cost type. The data is
linked to various sheets throughout the Excel file.
Page 8 of 20
Sheet
#
Name
19
8.0
Description
The Gantt chart and my attempt at an AON network diagram for this project (requires
some revisions).
The major cost drivers of this model are the Comparative Testing activities (WBS 1.5), which
makes up approximately 30% of the total budget, and the chromatography resin material
cost (WBS 1.3.2), which makes up approximately 75% of the material cost for the
Manufacturing department (WBS 1.3). A Sensitivity Analysis was performed on both of these
cost drivers and is described as follows.
The Clinical Trial costs data was obtained from a cost estimation report that had a model and
obtained data from around 7,000 studies for NDA/BLA trials. The costs were associated with
the testing of new drugs, therefore an Analogy estimating methodology was used to assign
costs to these comparative clinical tests. Since the safety and efficacy of the innovator drug
is known it was assumed that the cost of the clinical trials would be less than the reported
cost in that cost estimation report.
The range of costs and parameters that are related to this cost are shown in Tables 9 and 10.
The percentage multiplier in WBS 1.5.1.1 indicates that its cost is a percentage of WBS
1.5.2.1 and the factor for WBS 1.5.1.2 is a percentage of WBS 1.5.2.2. The percentage
multiplier for WBS 1.7.4 indicates its cost is a percentage of the costs of WBS 1.5.1.1 and
1.5.1.2.
Table 9: Range of Clinical Trial Costs
Clinical Trial Costs
1.5.2.1
1.5.2.2
1.5.2.3
Low (Expected
Cost):
$13.800
$15.000
$16.000
Middle:
$16.400
$17.445
$17.975
High:
$19.000
$19.890
$19.950
1.5.1.2
1.7.4
Low %:
50%
30%
5%
Expected
%:
75%
50%
15%
High %:
90%
80%
20%
The Sensitivity Analysis for the Comparative Testing (WBS 1.5) is shown in Table 11. As can
be seen from the data in the table the total project cost is very sensitive to the clinical trial
costs and the preclinical parameters, which indicates that more research/data is necessary
to further refine these costs.
Table 11: Sensitivity Analysis for the Comparative Testing
Total Project Cost
Low
Difference
Middle
Difference
High
Difference
Low %:
$214.079
$9.984
-4.46%
$223.336
$0.727
-0.32%
$232.594
$8.531
3.81%
Expected %:
$224.063
$0.000
0.00%
$235.084
$11.02
1
4.92%
$246.105
$22.042
9.84%
Page 9 of 20
$234.371
Difference
$10.30
8
Middle
4.60%
$247.161
Point
Estimate:
Difference
$23.09
8
10.31
%
High
$259.950
Difference
$35.887
16.02%
$224.063
As is shown in Figure 6, the material for WBS 1.3.2, which is the chromatography resin, is a
major cost driver of the Manufacturing departments costs, and note that this is without
considering material which may drive up the associated costs.
$500,000
Middle (Expected
Cost):
$1,000,000
High:
$1,500,000
FY
2017
Low
(Expected):
Middle:
High:
Page 10 of 20
Overhead
Parameters
1.8.1
1.8.2
Low %:
15%
15%
Expected
%:
30%
30%
High %:
50%
50%
The Sensitivity Analysis for the various Resin costs are shown in Tables 15-17. As can be
seen from the data in the tables the total project cost is very sensitive to the Resin Costs,
fairly sensitive to the Overhead parameters, and less sensitive to the number of R&D Lots,
which indicates that more research/data, such as quotes/actuals, is necessary to further
refine the Resin Costs.
Table 15: Sensitivity Analysis for Low Resin Cost
Total Project Cost at Low Resin Cost
Low Lots
Middle
Lots
Difference
Difference
High
Lots
Difference
Low %:
$202.343
$21.72
0
-9.69%
$204.413
$19.65
0
8.77
%
$202.343
$21.720
-9.69%
Expected %:
$206.513
$17.55
0
-7.83%
$208.853
$15.21
0
6.79
%
$206.513
$17.550
-7.83%
High %:
$212.073
$11.99
0
-5.35%
$214.773
$9.290
4.15
%
$212.073
$11.990
-5.35%
Point
Estimate:
$224.063
Middle
Lots
Difference
Difference
High
Lots
Difference
Low %:
$217.868
$6.195
-2.76%
$221.088
$2.975
1.33
%
$224.308
$0.245
0.11%
Expected %:
$224.063
$0.000
0.00%
$227.703
$3.640
1.62
%
$231.343
$7.280
3.25%
High %:
$232.323
$8.260
3.69%
$236.523
$12.46
0
5.56
%
$240.723
$16.660
7.44%
Point
Estimate:
$224.063
Difference
Middle
Lots
Difference
High
Lots
Difference
Low %:
$233.393
$9.330
4.16%
$237.763
$13.70
0
6.11
%
$242.133
$18.070
8.06%
Expected %:
$241.613
$17.55
0
7.83%
$246.553
$22.49
0
10.04
%
$251.493
$27.430
12.24%
Page 11 of 20
High %:
$252.573
$28.51
0
12.72
%
Point
Estimate:
9.0
$34.21
0
$258.273
15.27
%
$263.973
$39.910
17.81%
$224.063
ESTIMATE UNCERTAINTY
I did not have enough time to set up a Monte Carlo simulation for my cost model, so instead
I decided to quantify the total cost attributed to each estimating methodology I employed,
which is shown in Table 18. An appropriate plus-minus error percentage (see the highlighted
column) was assigned to each methodology based on the potential uncertainty introduced
by that method.
Table 18: Cost by Estimating Methodology
Range
Estimating Methodology
Total Cost
% Error
Low
High
Direct
$6.000
2.68%
100.00%
$0.000
$12.000
Direct w/ Parametric
$18.500
8.26%
75.00%
$4.625
$32.375
SME
$4.500
2.01%
50.00%
$2.250
$6.750
SME w/ Parametric
$59.762
26.67%
35.00%
$38.845
$80.679
Analogy
$6.000
2.68%
25.00%
$4.500
$7.500
Analogy w/ Parametric
$64.962
28.99%
15.00%
$55.218
$74.706
SME w/ quote
$15.514
6.92%
7.50%
$14.351
$16.678
Parametric
$45.489
20.30%
5.00%
$43.214
$47.763
Actuals
$3.336
1.49%
0.50%
$3.319
$3.353
$224.063
100.00%
$166.322
$281.804
Based off this simple analysis, Im 90% confident that the actual project costs will fall within
the estimate range of $224.063 $281.804 million. The high side was chosen based off
the projection that the cost to receive FDA approval for a biosimilar will be $75-$250 million,
and I have found some reports that indicate that this projection does not include the
operation of a GMP Facility, which is expected to be very costly.
10.0
RISK ANALYSIS
A more thorough risk analysis of the overall project and organization needs to be performed
in order to better understand the process and determine in more detail potential schedule
delays and cost escalations.
The most obvious and biggest risk is with the FDA review process for the biosimilar
application, as the FDA can outright reject it or may require more testing and data for
approval, which can add a lot more to the overall cost and was not really addressed as part
of this budget.
11.0
ANALYSIS/CONCLUSIONS
Based off the analysis that was performed and the current data that has been collected, I
believe this cost estimate is a good starting point in identifying the major cost drivers and
outlines a plan to achieve FDA marketing approval for a biosimilar.
There is large uncertainty in the estimate due to the fact that a lot of the data was obtained
from a SME, so further refinements can be made by obtaining more quotes/actuals. Although
Page 12 of 20
I noted that I excluded Travel and Marketing/Sales Support, I do believe that my indirect
costs may be a little low. These excluded items should be added to the estimate when
considering the generation of a fee/profit after the biosimilar has been approved.
Page 13 of 20
12.0
REFERENCES
[8] Direct Estimating was performed by me based off my experiences in the pharmaceutical
industry
Page 14 of 20