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EARNINGS CALL TRANSCRIPT
EARNINGS CALL TRANSCRIPT 2018 - Q4
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Operator

Good day, ladies and gentlemen, and welcome to the Akebia Therapeutics Preliminary Full-Year 2018 Financial Results and Business Highlights conference call. As a reminder, this conference call is being recorded. [Operator Instructions]. I would now like to introduce your host for today's conference, Megan [ph]. The floor is yours..

Unidentified Company Representative

Thank you, Operator. Good afternoon, and thank you for joining us to discuss our recent business progress and Akebia's preliminary full year 2018 financial results and business highlights conference call.

The press release containing the company's preliminary financial results for the fourth quarter and full year 2018 was issued earlier this afternoon and is also available on our Investor Relations website. For your convenience, an audio replay of today's call will also be available on our website shortly after we conclude today's webcast.

Joining our call are John Butler, President and Chief Executive Officer; and Jason Amello, Chief Financial Officer. Rita Jain, Chief Medical Officer; Michel Dahan, Chief Business Officer; and Doug Jermasek, VP of Marketing and Strategy, will also be joining for the Q&A session.

Before we begin, I'd like to remind everyone that this conference call includes forward-looking statements. Each forward-looking statement contained in this call is subject to risks and uncertainties that could cause actual results to differ materially from those described in these statements.

Additional information regarding these factors are described in the Risk Factors and Management's Discussion and Analysis sections of our most recently quarterly and annual financial reports.

The forward-looking statements on this call speaks only as of the original date of this call, and we do not undertake any obligation to update or revise any of these statements. With that, I'd like to turn the call over to our CEO, John Butler.

John?.

John Butler Chief Executive Officer, President & Director

a correction and a conversion study. PRO2TECT enrollment is tracking in line with our expectations. We've informed sites that we plan to close screening shortly, so we do expect to complete enrollment this year and we continue to anticipate a PRO2TECT readout in mid-2020, subject to the accrual of MACE.

I'd now like to turn the call over to Jason for a review of our preliminary financials..

Jason Amello

our Otsuka U.S. Agreement, our Otsuka International Agreement and our MTPC agreement. These collaborations are considered multiple element arrangements under the revenue recognition guidance.

This generally means that the noncontingent payments will be recognized over the life of the arrangement based on how activities under the arrangement are performed or delivered by Akebia versus when payments are actually received.

With that said, collaboration revenue was $53 million for the fourth quarter of 2018 compared to $90.6 million for the fourth quarter of 2017.

A significant decrease is due to the recognition of $42.9 million of previously deferred MTPC collaboration revenue in the fourth quarter of 2017, for which, there is no comparable amounts recorded in the fourth quarter of 2018.

As the company's performance obligations under the MTPC agreement were substantially complete as of Q3, future MTPC collaboration revenue will now come in the form of regulatory and commercial milestones and royalties. Collaboration revenue for the full year of 2018 was $200.9 million compared to $181.2 million for 2017.

This full year increase relates primarily to our collaboration agreements with Otsuka. Through 2018, Otsuka had funded 52.5% of the company's Phase III development costs for vadadustat. And in Q2 2019, Otsuka will begin to fund 80% of those costs. Moving to our research and development expenses.

R&D expenses were $87.1 million for the fourth quarter of 2018 compared to $68.4 million for the fourth quarter of 2017 and $291.1 million for the full year of 2018 compared to $230.9 million for the -- for 2017.

The increase was primarily attributable to an increase in external costs related to the continued advancement of the PRO2TECT and INNO2VATE Phase III program, including ongoing enrollment, manufacture of drug substance and drug product and regulatory activities, partially offset primarily by costs associated with the Phase II studies in Japan, which were primarily incurred in 2017.

R&D expenses were further increased by headcount and consulting costs required to support our expanding R&D programs. We expect R&D expenses to increase modestly for 2019 as we expect to fully enroll both PRO2TECT and INNO2VATE Phase III studies in 2019.

It's important to keep in mind that a significant portion of these R&D costs are reimbursed by our collaboration partners which gets recorded as collaboration revenue, as I mentioned earlier.

Selling, general and administrative expenses were $55.1 million for the fourth quarter of 2018 compared to $7.6 million for the fourth quarter of 2017 and $87.1 million for the full year of 2018 compared to $27 million for 2017.

The increase in SG&A expense is primarily attributable to merger-related costs of $49.5 million, of which $41.7 million was incurred in the fourth quarter of 2018, including a noncash expense of $13.4 million related to the conversion of the Keryx convertible notes.

The increase of both periods was also attributable to an increase in costs to support our R&D programs, including headcount, information technology and compensation-related costs. Keep in mind that SG&A only includes about 2 weeks of commercialization costs for Auryxia since the merger was closed on December 12.

SG&A expenses will therefore increase substantially in 2019 as we include full year of commercialization expenses. As a result of the foregoing operating results, the company reported a pretax net loss for the fourth quarter of 2018 of $88.4 million as compared to a pretax net income of $15.5 million for the fourth quarter of '17.

The pretax net loss for the fourth quarter of '18 includes total merger-related costs of $46.5 million, and the pretax net income reported for the fourth quarter of 2017 was attributable to the $42.9 million of collaboration revenue recognized in connection with the MTPC collaboration agreement as the criteria for revenue recognition was satisfied in that fourth quarter.

For the full year, the company reported pretax net loss of $171.9 million as compared to a pretax net loss for the prior year of $73.7 million. And pretax net loss for the full year of 2018 includes total merger-related costs of $54.3 million. Turning to our capital position.

We ended 2018 with cash, cash equivalents and available-for-sale securities of $321.6 million. We expect our cash resources, including the prepaid quarterly committed cost-share funding from our collaborators, to fund our current operating plan into the third quarter of 2020.

And lastly, we ended the year with approximately 116.9 million shares outstanding or 126.7 million shares on a fully diluted basis, inclusive of outstanding options and RSUs. With that, I'll turn it back to John for additional remarks..

John Butler Chief Executive Officer, President & Director

execute on Auryxia sales plan, drive our vadadustat development program forward and support Mitsubishi Tanabe with its regulatory filing for vadadustat in Japan. In the meantime, we remain committed to our core mission, which is delivering innovative therapies to advance care for patients with kidney disease.

And with that, we'll open the line for questions.

George?.

Operator

[Operator Instructions]. Our first question comes from the line of Chris Raymond with Piper Jaffray..

Christopher Raymond

I just wanted to maybe understand Auryxia a little bit better. So just backing into the Q4 number, it looks like revenue was about $24.7 million, and I think that's down about 7% quarter-on-quarter. But I think I heard you state that at year-end, it exited with 6.6% market share.

But I think Keryx said at the end of the third quarter of '18, it was 6.4%.

So can you maybe sort of square those two trends? Am I not getting a full picture with some of those numbers? Or what's happening?.

John Butler Chief Executive Officer, President & Director

No. You're right on target, Chris. So if you recall, in the fourth quarter, actually, starting in September of last year, DaVita Rx, the specialty pharmacy arm of DaVita, stopped shipping. And when you looked at fourth quarter of last year, the entire phosphate binder market decreased by roughly 10%.

I can't remember the exact numbers, but roughly 10%, and Auryxia scripts actually grew a little bit. So from a share perspective, it actually ticked up a small percentage of share in the market. So again, I mean, it was DaVita Rx decreasing the market as patients were moved to other pharmacy providers. They use the product that was on the shelf.

It was very much a time-limited issue but one that impacted the entire market, Auryxia continues to grow modestly through that difficult time..

Christopher Raymond

Okay.

So understanding that there was some disruption from that DaVita Rx situation, I guess just going forward, I guess, at what point -- and so it looks like the script numbers still have not yet really picked up, and I guess that's sort of -- a key question is when do you think we should start to see some normalization and maybe some reflection of what's really going on with Auryxia from the script numbers? And then maybe a second part to that is you mentioned some specific steps to deal with the prior auth requirement.

What are those steps? And maybe talk about what you can do to sort of get past this and get to the point where I think you were saying you'd want to give guidance once you get past the CMS issue..

John Butler Chief Executive Officer, President & Director

Yes, yes. So we talked about DaVita Rx. And then in the remarks, I talked about the CMS issue, which really was, once again, an administrative prior auth that was put on all patients who -- Medicare Part D patients who were prescribed Auryxia.

90-something percent of those prescriptions are being approved because they're mostly being written for hyperphosphatemia today, but that creates an administrative burn for the provider.

So if you look at weekly scripts, you saw that right out of the beginning of the year, remember, you take all of the patients who are on Part D, January 1 comes and you need to get a prior auth. So you have this large number of patients who have to work through the PA process, and we've seen this.

And you saw this drop in scripts in the first couple of weeks, but you've seen a very robust rebound in scripts to the point where, again, looking at weekly scripts, you're back right around the highest point you've had since before DaVita Rx stopped shipping. So -- really like the momentum that we're seeing. People are working through it.

There are a number of tools that are available for centers to -- prescribers to use to help work through the prior auth. Prior auth is not something that providers aren't used to dealing with, right? I mean, it's something they deal with every day. But no matter how good you are at it, it doesn't take you two days to get it through.

It takes some time to get it through. When you have a bowless of patients that come through, it takes a bit more time. So when I look at the prescriptions now coming out of the last week we saw in March, there's the robust -- the growth is really robust again. But to the point of giving guidance, you do want to see that sustained over time.

When you look at the growth in scripts we had across '18, are we back on that? Can the sales force focus on growing the product versus kind of helping manage the experience that physicians are having today across the prior auths? That's the point that I want to see more.

Very pleased with the prescription momentum but not quite ready to feel like we understand it well enough to be accurate in guidance. And just to remind you, Chris, also, this is kind of a onetime thing, right -- at least once a year. Once you get a prior auth, it's good for the year.

And this hit towards the end of the year as we were closing the merger, et cetera. If we are unsuccessful in reversing or reestablishing coverage, and we certainly have an expectation that will be, will be. But we're preparing sort of this to be a very smooth process 12 months from now. And we don't go through the same upsetment in the market..

Operator

And our next question comes from the line of Kennen MacKay with RBC Capital Markets..

Kennen MacKay

Congrats on the quarter as well as the Japanese Phase III data. First, just another housekeeping question on Auryxia.

If we look at that annual number of $96 million, is that inclusive of the post-December $126.8 million that was reported in the financials? Or could that -- is that additive on top of that?.

John Butler Chief Executive Officer, President & Director

That includes -- that's the full year pro forma 2018. That just includes U.S. Auryxia sales. And when you layer on the Japan Tobacco royalties, it was $101.7 million for the year..

Kennen MacKay

Got you. And maybe just on that, that's a little bit different than I think what we were looking at in terms of script analysis.

Is there anything in terms of gross to net that's sort of unfolded over the course of Q4 that could lead to sort of a different script growth rate versus revenue growth rate reported there?.

Jason Amello

No. I mean, if you look at just the stuff here that I referred to on the revenue, that's coming at 40%. I just think that's just an anomaly because of the two week period, but our normalized kind of gross-to-net ratio was about 50%..

Kennen MacKay

Got you. Okay.

And then on the vadadustat data, I was wondering if there was anything relating to the MACE rate from either the non-dialysis-dependent or dialysis-dependent Japanese trials that you could comment on, so that maybe we could get sort of a better sense of how we can be expecting the MACE rate to accumulate in the ongoing PRO2TECT and INNO2VATE trials.

And then also just wondering if you can remind us, what the powering was in those trials or what the expectations for the MACE event rates were based on there?.

John Butler Chief Executive Officer, President & Director

Thanks, Kennen. I think it's important to point out that when you have studies like the Japanese studies, we're thrilled with the data and very excited for what this can do for our filing in Japan. But to project that, what you see from a MACE event rate to our global studies, I think, is something we certainly wouldn't want to do.

Remember, these are -- this is 24-week data in these patients and not something that should be easily projected out beyond that. And it's like the [indiscernible] and we've never talked about powering of MACE events across the global study. But I don't know, Rita, if you have any other color to add there..

Rita Jain

No. I think -- thank you, John. I would just say that we were pleased with the results of the Mitsubishi Phase III studies in Japan. It does give us further support and understanding of the vadadustat profile and further indicates the potential for vadadustat to provide a new therapeutic option for subjects with anemia due to chronic kidney disease.

But I think in terms of MACE, we're really not able to draw any conclusions from a smaller, shorter data set..

John Butler Chief Executive Officer, President & Director

Yes. And just to remind you, Kennen, I mean, it is -- it's not -- it wasn't a MACE trial, right? So there were -- of course, you're looking at events, at safety. But Japan, the PMDA, the Japanese regulatory authorities don't need a MACE study for approval. So -- and this didn't have a MACE endpoint.

And again, I mean, we're really pleased with the fact that the safety was well balanced. And these were our first active-controlled darbepoetin-controlled studies that we look forward and beyond..

Operator

And our next question comes from the line of Difei Yang with Mizuho Securities..

Difei Yang

So just a couple here.

With regards to the commercial infrastructure, how high of a priority you think it is to bring a second product into the sales force?.

John Butler Chief Executive Officer, President & Director

Well, we're looking forward to bringing vadadustat into the sales force in a couple of years, but we're looking to build the company. I mean, it's very important that it's understood that our strategy is clearly to continue to build a kidney disease-focused organization.

Now whether that's a commercial product today or adding to our development pipeline, well, you have to be opportunistic about these things. As I've mentioned, our focus is on driving the Auryxia sales plan.

We think there are some modest investments that we are planning to make in the commercial organization to that end, to help us do that, to help us maximize the value, but we're not -- we don't think it's critical in the short term to add a commercial product to the bag of the sales reps..

Difei Yang

Okay.

So now with regards to the competitor's MACE readouts, upcoming MACE readout, could you share your thoughts with regards to how likely can we read across from that trial into Akebia's drug with the understanding the 2 drugs are in the same cost but not identical compounds?.

John Butler Chief Executive Officer, President & Director

Yes. Well, I think we're all looking forward to seeing data from the studies of vadadustat. Again, any time we have the opportunity to provide innovative therapies and advancements in care for these patients, we're supportive of that. And I think that we always need to be careful about reading through too far. The programs are designed very differently.

The compounds are different compounds, albeit in the same class. I think we should wait and see the data..

Operator

And our next question comes from the line of Reni Benjamin with Raymond James..

Reni Benjamin

Can you talk a little bit about how we should be thinking about the revenue numbers for Auryxia in the context of the CMS decision and what you had kind of reported prior to the acquisition of Keryx and what that impact could be for 2019?.

John Butler Chief Executive Officer, President & Director

Yes, well, as we mentioned, we're not guiding on revenue at this point, kind of given these -- the issues we dealt with. We're pleased with the progress we're making, but when we announced the acquisition, you look at the S-4, DaVita Rx kind of not shipping and the CMS noncoverage decision, neither of those were incorporated into that thinking.

When I look at the momentum of scripts in the last couple of weeks, last few weeks, as the team does a great job of working through, I'm really pleased with the momentum that we see.

And once we feel like we have a better handle on what that will translate into from a revenue perspective this year, I think that's the point we want to guide when we feel more confident.

What I will say, Ren, from a long-term perspective, there's nothing that we've seen in the product and market research and interacting with our team here that changes my long-term feeling about what the opportunity for the product is..

Reni Benjamin

Okay. That's good to know.

And can you remind us or update us on what the split between hyperphosphatemia and IDA scripts are and maybe the split between Medicare and commercial?.

John Butler Chief Executive Officer, President & Director

Well, we've never really broken out the hyperphosphatemia versus IDA. I don't believe Keryx did that either. It is -- what you really look at is the size of the prescriptions that are written. And you saw in 2018, I think it was about 200, was the exit number.

Doug, was there -- I mean, it was down slightly, which suggests that you're getting growth in IDA, but dominated still by hyperphosphatemia scripts..

Douglas Jermasek

Most of the year, we're in about 215 tablets per prescription and by the end of the year, that was down about 200..

John Butler Chief Executive Officer, President & Director

Right. And that -- there is a reflection of IDA. So as you continue to grow on IDA, you'll see that the average prescription, because the prescribed dose is basically half of what it is for hyperphosphatemia, you'll see the average prescription size a little bit smaller.

But we still think that hyperphosphatemia is going to be the dominant driver certainly this year and again, as we know more, we'll tell you more. And -- but again, as I mentioned, there's still a tremendous amount of room.

Even with the CMS noncoverage decision, about 45% of the IDA opportunity, which is hundreds of thousands of patients, is in commercial Medicaid private patients. So we still expect to see growth, I mean, we are seeing growth in IDA. But long term, we need to change that coverage decision..

Reni Benjamin

Got it.

And then just talking about the IP, can you just remind us kind of where we are with Teva and kind of the other players and what the current sort of stay of discrimination is and what -- when we should start -- be thinking about this?.

John Butler Chief Executive Officer, President & Director

Right. So as expected when you hit 4-year anniversary of approval, we had ANDA filers, and we have filed litigation against those ANDA filers. With that, you have a 30-month stay, which takes us to May of 2021.

But again, I want to remind everyone that we have 14 Orange Book-listed patents for Auryxia with varying expiry dates on those patents and we are protecting or defending our IP vigorously..

Reni Benjamin

Got it. And then just switching gears real quick to vadadustat. Can you just remind us of where we are with FO2RWARD? And are we still expecting that data? I think you had mentioned before, in the second half of this year..

John Butler Chief Executive Officer, President & Director

That's right. We're enrolling patients in FO2RWARD. That's a Phase II study and we'll have multiple data cuts there. But we will have top line data before the end of this year..

Operator

And our next question comes from the line of Bert Hazlett with BTIG..

Robert Hazlett

Congratulations on a successful quarter and successful merger. The Auryxia, maybe you've touched on this, but my apologies, but I'd love a little more granularity on your expectations for cost of goods sold with regard to that product moving forward..

John Butler Chief Executive Officer, President & Director

So -- do you have the cost [indiscernible] the stuff here. So cost of goods, we don't -- we certainly don't expect any significant changes in cost of goods. We have multiple contracts in place with providers. As a matter of fact, we have a third tablet provider from Patheon, who is now shipping product in the U.S.

So we're in a very good place from that perspective. But we don't think there'll be any significant changes. I can't remember the number off top of my head, so I don't want to say one, Bert, but we can follow up in that..

Robert Hazlett

Okay. That would be great. And then just with....

John Butler Chief Executive Officer, President & Director

Go ahead, Jason..

Jason Amello

Yes, and just to add to that, as I mentioned in the call here, there's a charge for merger accounting in this particular stub period, was $4.8 million. We will continue to have charges like that in subsequent periods because this is the inventory that we acquired, which has all been marked up to market value.

So we'll continue to have these ongoing charges until we bleed through that purchase inventory. But we'll disclose that piece of the cost of sales so that you could see the normalized run rate of the margin versus this anomaly from the markup..

Robert Hazlett

Okay. And as you -- just a follow-up on that.

As you think about the rate at which you're churning through the inventory or burning through the inventory, the -- how long during 2019 would you expect those types of charges to occur?.

Jason Amello

That will probably continue throughout '19..

Robert Hazlett

Okay. And then just with regard to Otsuka and the comment that's -- they funded 52.5% of the company's Phase III development costs for vadadustat and in the second quarter, expected to increase its contribution to 80%.

Can you just remind us of the pushes and pulls that go into that 80%? And what are the expectations going forward for that line item as well?.

John Butler Chief Executive Officer, President & Director

So that -- the 80% is of the -- we have a global development plan that we agreed to as two companies, and that is -- that basically encompasses all of the vadadustat development costs. So that's been 52%, and that's what's now going to be going in Q2 to 80%, which of course is a vast majority of our R&D expenses..

Robert Hazlett

And the decision as to the level of that contribution going forward?.

John Butler Chief Executive Officer, President & Director

Oh, sorry, Bert, I didn't understand the question. So again, contractually, remember there was two -- there's two kind of contracts. There's the U.S. contract and the international contract. And under the U.S.

contract, we have a right, once we pass a certain kind of negotiated budget level, which we'll pass in the second quarter of this year, to ask them to cover -- remember, the U.S. is a 50-50 deal. So we're basically asking them to cover our half of the development expenses for the U.S. portion of the contract.

And when you do the math between the two contracts, that's what brings us to 80%. Now for those dollars that are the difference between 52% and 80%, they have the right to credit those dollars against future milestones and future royalties; no more than 50% in any calendar year, but that is the way that the contract is structured..

Operator

And our next question comes from the line of David Lebowitz with Morgan Stanley..

Ishmael Asante

This is Ishmael on for David. In the long term, you mentioned hoping to get the CMS IDA decision overturned.

What will you have to do and what steps are you taking now on that front?.

John Butler Chief Executive Officer, President & Director

So you basically have to get CMS to restore coverage for the product and that is -- we're kind of working with CMS, we have a whole number of steps in a plan that we have put together to communicate the reasons why. I have been through this before. At Genzyme, we had a similar determination that was made for Hectorol, our vitamin D product.

And we had to have multiple meetings with CMS to explain the particular use of the product, et cetera, and we're able to change that coverage decision. It's hard to know whether that comes in one quick meeting or if it takes multiple meetings to have that.

But again, having seen this, we've not only been through it myself but seen multiple other products that have had been able to overcome the same issues, we feel quite confident that we'll be able to make that happen. In the meantime, as we think about 2019, there's still lots of room with the commercial payers to grow the IDA market..

Ishmael Asante

And a quick follow-up. Would you be able to walk us through the dynamics of the Japanese market for vadadustat and how that may vary for the U.S.

market?.

John Butler Chief Executive Officer, President & Director

Michel, do you want to maybe take that question?.

Michel Dahan

With pleasure. So generally speaking, in Japan, you have two large populations, and the nondialysis population, unlike the U.S. market, is generally well treated in terms of treatment rate. So you do have a larger market relative to the U.S. so that's one key difference.

And I'll note another important difference in that -- the target range is different as well. So in Japan, for example, you're going from 11 to 13 in the nondialysis patient population and 10 to 12 in the dialysis patient population. So those are the two main differences. Other than that, it is similar..

John Butler Chief Executive Officer, President & Director

And generally, when you look at the patient population in Japan, you don't do transplant. So you'll have these kind of healthier patients on dialysis generally because a lot of those patients have transplant in the U.S.

And the reason to be on dialysis or the reason for kidney disease is less frequently, it was like diabetes that you see in the U.S., which just make it a little different from a profile perspective..

Operator

And our next question comes from the line of Chad Messer with Needham & Company..

Chad Messer

I was just wondering, John and team, if you could maybe give us a little bit more perspective on the performance of vadadustat in the 2 Japanese studies. Congratulations on two positive studies there. But on that primary endpoint of hemoglobin versus a placebo in those studies, how good does that look? I know -- were not inferior.

Was that kind of within your expectations? And then also versus some of the roxadustat, a Phase III data in nondialysis, just kind of at the top line level, over half a gram per deciliter better for vadadustat.

Is that something I should get excited about? Or should I kind of temper my excitement until we get all the outcomes data?.

John Butler Chief Executive Officer, President & Director

Thanks, Chad. So I mean, we're excited, right? We're very pleased with the data that we've seen. I just want to remind you that both the 01 and the 03 studies were [indiscernible] and controlled. So they were active controlled studies. And reference to the point Michel was making before, you're looking to treat patients into a target range.

And so we were able to do that and show that non-inferiority to darbepoetin from an efficacy standpoint. That was the goal of the study. That's what we were looking to achieve. And of course, the fact that the safety was balanced between them, I think, was something we were pretty excited about as well.

But Rita, do you have any other -- anything to add?.

Rita Jain

No. I think the key here, as you know, was that the hemoglobin targets of 11 to 13 in the nondialysis population and 10 to 12 in the dialysis population was the goal. We did achieve non-inferiority and the 95% confidence in both the nondialysis and dialysis trials or within the target hemoglobin range.

So I think this does support vadadustat development, but I think nothing further..

John Butler Chief Executive Officer, President & Director

Yes, I think one thing to point out, because there may be some confusion around it, remember, vadadustat and darbepoetin, these are titratable drugs. So if you want to increase hemoglobin further, you can titrate to a higher dose.

So the concept of superiority when it comes to hemoglobin, it -- it's really trying to manage hemoglobins into a target range. If you want it to be a higher hemoglobin, you can always get a higher dose.

So what we saw in the Japanese studies is we manage patients into the target range -- higher target range in the nondialysis population in Japan than we see in the U.S. and with a very balanced safety profile, and that to us is exciting..

Operator

And our next question comes from the line of Ed Arce with H.C. Wainwright & Co..

Antonio Arce

I'll add my congratulations on the closure of the merger and the success so far as an integrated company. A couple questions and then maybe a follow-up. First, if you could remind us how we should think about a reasonable MACE rate for darbepoetin overall in a treatment period that's analogous to INNO2VATE and PRO2TECT.

And then separately, you had mentioned revenues going forward from MTPC, expected really to be just milestones from this point forward. Have there been any -- has there been any disclosure around the timing or amounts of those? And then I have a follow-up..

John Butler Chief Executive Officer, President & Director

Jason, do you want to take the second one?.

Jason Amello

Yes. So the milestones are basically regulatory and commercial. So obviously, the regulatory ones are basically approval-related. So obviously, when they get to that point, that's when the milestones will become payable. Those particular milestones on the regulatory is up to $40 million and then the commercial is up to $175 million.

But the timing is specific to the events that occur..

John Butler Chief Executive Officer, President & Director

And we had $10 million....

Jason Amello

We had $10 million in '18..

John Butler Chief Executive Officer, President & Director

In '18, when we started the study. And so on the MACE rate, there's -- what you really look at is previous studies that have been done to inform you as to what MACE rate would be.

And you always have to take into consideration with that, things like when it was done, the target hemoglobin ranges that people were looking for, the patient population, et cetera. And so we do see a range, which is why we always have a range of expectation of MACE rate that we're going to see.

Again, looking at when they were targeting higher hemoglobin ranges, you saw MACE rates up to 14% or so and in placebo, 9% or 10%. I'm looking at Rita and she's nodding her head, so I think I'm getting that right. Is there any other....

Rita Jain

I think generally, historically, the MACE rates have been higher in the dialysis population than in the nondialysis population and maybe higher in the incident dialysis population as compared to -- which is new onset dialysis as opposed to established dialysis.

It also factors in, in terms of the proportion of subjects that you've enrolled in your trials who have diabetes, hypertension, preexisting cardiovascular disease, et cetera. We have looked at all of these factors and considered changes from historical trends as we've assessed what we thought our likely MACE rates would be.

And of course, at this point, we are seeing blinded data to help us guide actual time lines..

Antonio Arce

Okay. That's great. And one more question around a previous question that was asked in raising hemoglobin levels.

Could you just talk about how the issue of excursions and the number and the rate and the degree of excursions factors into the considerations of treating physicians versus an ability, as you said, with darbepoetin and others to titrate and really looking at versus the drug where you can just think of it as a blunt force reducing hemoglobin?.

John Butler Chief Executive Officer, President & Director

Right. So clearly, the idea of excursions as you think about the market and the way physicians are treating patients, and they're -- they are looking to avoid excursions. And when you have a long-acting drug like darbepoetin, you'll see hemoglobins rise when you get the drug and then it'll drop again over time.

So you'll have -- you potentially have excursions, which are generally most physicians would define as hemoglobins above 13 in the market. And -- but you also have hemoglobin cycling, which is that kind of up and down of hemoglobin, which is something they want to avoid as well.

So showing more stability of response of hemoglobin is certainly a goal, also the physicians have with treatment, because we talk about the differences in EPO levels. Certainly, those EPO doses have been associated with increased cardiovascular risk, but so have excursions and hemoglobin cycling.

And that really kind of is the basis of the theory that we could have a difference in cardiovascular safety ultimately..

Operator

And I show no further questions at this time. I would like to turn the call back over to John Butler for closing comments..

John Butler Chief Executive Officer, President & Director

Thanks, George, and thanks, everyone, for attending today. We do look forward to updating you again in the future. Have a great afternoon..

Operator

Ladies and gentlemen, thank you for participating in today's conference. This does conclude the program, and you may all disconnect. Everyone, have a great day..

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