Traditional FDA Approval Paves the Way for Donanemab
In a landmark decision on July 2, 2024, the U.S. Food and Drug Administration (FDA) granted traditional (full) approval to donanemab (Kisunla™) for treating early symptomatic Alzheimer's disease. This decision was based on compelling evidence from clinical trials like TRAILBLAZER-ALZ 2, which showed the drug's effectiveness in slowing cognitive decline. For patients and their families, this full approval represented a significant step forward, moving donanemab from an accelerated approval pathway to a status that would trigger broader coverage from Medicare.
CMS Coverage with Evidence Development (CED) Requirements
Following the FDA's full approval, the Centers for Medicare & Medicaid Services (CMS) confirmed it would provide coverage for donanemab under its existing National Coverage Determination (NCD) for monoclonal antibodies directed against amyloid for Alzheimer's disease. This coverage is provided under a specific framework known as Coverage with Evidence Development (CED).
This means that for Medicare to cover donanemab infusions and associated care, two key conditions must be met:
- The prescribing physician and their clinical team must participate in a qualifying patient registry. This registry is designed to collect real-world data on how the drug works in the broader Medicare population, tracking patient outcomes and safety.
- The beneficiary receiving the drug must also be enrolled in a CMS-approved patient registry.
The registry data helps answer important treatment questions and ensures ongoing safety monitoring outside of the controlled clinical trial environment. This approach is intended to strike a balance between providing access to new, innovative treatments and ensuring they are safe and effective for the Medicare population over the long term.
Who is Eligible for Donanemab Under Medicare?
For Medicare to cover donanemab, beneficiaries must meet specific eligibility criteria, which are consistent with the FDA label and clinical trial parameters. These include:
- Diagnosis: The patient must have a diagnosis of mild cognitive impairment (MCI) or mild dementia due to Alzheimer's disease. The treatment is not indicated for more advanced stages of the disease.
- Confirmed Amyloid Pathology: The presence of beta-amyloid plaques in the brain must be confirmed. This is typically done via a positron emission tomography (PET) scan or a lumbar puncture (spinal tap).
- Safety Monitoring: Patients must undergo regular magnetic resonance imaging (MRI) scans throughout treatment to monitor for Amyloid-Related Imaging Abnormalities (ARIA), a common side effect.
- Registry Enrollment: As a condition of Medicare coverage, the patient must be enrolled in a CMS-approved registry.
Required Baseline Assessments
Before starting treatment, a comprehensive evaluation is needed:
- Cognitive Assessment: Tests like the MMSE or MoCA are used to confirm early symptomatic Alzheimer's.
- MRI Scan: A baseline MRI is required to rule out other potential causes of dementia and assess for exclusionary findings, such as significant cerebrovascular disease.
- APOE Genotyping: Testing for the APOE $\epsilon$4 gene is encouraged, as homozygotes have a significantly higher risk of ARIA. This helps inform the risk-benefit discussion.
Understanding the Costs and Potential Side Effects
Costs to Beneficiaries For those enrolled in Original Medicare, donanemab is covered under Part B, which handles outpatient drugs and infusions. Beneficiaries are responsible for the Part B deductible, followed by a standard 20% coinsurance of the Medicare-approved amount. Costs can vary significantly based on whether a patient has supplemental coverage (like a Medigap plan) or a Medicare Advantage plan. In 2024, the manufacturer listed the price at $32,000 per year, though this does not account for insurance coverage or associated costs like MRIs and infusions.
Potential Side Effects (ARIA) As with other amyloid-targeting therapies, the most common side effect is Amyloid-Related Imaging Abnormalities (ARIA), which can present as brain swelling (ARIA-E) or bleeding (ARIA-H). While often asymptomatic, ARIA can sometimes cause serious symptoms, including headache, confusion, dizziness, and seizures. Regular MRI scans are crucial for monitoring this risk, especially for APOE $\epsilon$4 carriers.
Donanemab vs. Lecanemab: Key Coverage Differences
While both donanemab (Kisunla) and lecanemab (Leqembi) are amyloid-targeting monoclonal antibodies, there are several key differences to consider:
| Feature | Donanemab (Kisunla) | Lecanemab (Leqembi) |
|---|---|---|
| Infusion Frequency | Once per month | Twice per month (every 2 weeks) |
| Treatment Duration | Limited duration; can be stopped once amyloid plaques are cleared | Ongoing treatment |
| Infusion Time | 30 minutes, plus observation | Approximately 1 hour, plus observation |
| ARIA Risk | Risk of ARIA, potentially higher than lecanemab, especially for APOE $\epsilon$4 carriers | Risk of ARIA, lower than donanemab |
| Medicare Coverage | Covered under CED via patient registry | Covered under CED via patient registry |
The Future of Alzheimer's Treatment and Medicare
Medicare's coverage for donanemab is a testament to the evolving landscape of Alzheimer's treatment. The CED framework ensures that as new therapies become available, they can be accessed by beneficiaries while still gathering necessary real-world data to inform future coverage decisions. For individuals with early-stage Alzheimer's and their families, these advancements, coupled with clear coverage pathways, provide a new sense of hope and purpose.
It is vital for patients to engage in a shared decision-making process with their healthcare team. This includes understanding the potential benefits and risks of treatment, navigating the logistical requirements, and preparing for any associated costs. Resources from CMS and the Alzheimer's Association can provide further clarity on Medicare coverage. You can find more information on the official CMS website at cms.gov.
Conclusion
The question, "Has Medicare approved donanemab?" has a positive but conditional answer. Following its full FDA approval in July 2024, Medicare provides broad coverage for donanemab under a Coverage with Evidence Development (CED) framework. This requires beneficiaries with mild cognitive impairment or mild dementia due to Alzheimer's, and confirmed amyloid plaques, to enroll in a CMS-approved registry. While this approach helps ensure the drug is used appropriately and safely, it requires careful consideration of the costs, potential side effects, and registry participation. Navigating these requirements with a healthcare team is crucial for accessing this promising new therapy.