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Drug Name: Provigil / Modafinil
Tablet Strength: 200 mg
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Provigil is a wakefulness-promoting agent that is currently approved in 21 European countries, though its indications vary across Member States. The only universally approved use is for sleepiness associated with narcolepsy. Additionally, Provigil is authorized for excessive sleepiness related to:

  • Idiopathic hypersomnia (IH) in 4 Member States
  • Obstructive Sleep Apnea (OSA) in 11 Member States
  • Moderate to severe chronic Shift Work Sleep Disorder (SWSD) in 10 Member States

Provigil was first approved in the EU in France in June 1992. While its exact mechanism of action remains unclear, studies suggest it primarily inhibits dopamine and norepinephrine transporters.

In 2007, safety concerns arose regarding serious psychiatric side effects (such as suicidal thoughts, psychosis, and mania) and severe skin reactions (including erythema multiforme and Stevens-Johnson syndrome). A review by the Pharmacovigilance Working Party (PhVWP) analyzed clinical trial data and adverse event reports. Findings indicated a risk of severe skin reactions requiring hospitalization in children, leading to stricter warnings in product information across Europe.

A later assessment by the MHRA raised additional concerns about the benefit-risk balance for certain indications, particularly where efficacy data was limited. Given the newly identified psychiatric, dermatological, and cardiovascular risks—along with evidence of off-label use and potential abuse—a full benefit-risk evaluation of Provigil was initiated by the CHMP under an article 31 referral procedure.

The CHMP reviewed data from preclinical and clinical studies, spontaneous reports, published research, and submissions from marketing authorization holders (MAHs). The CHMP Scientific Advisory Group (SAG) was also consulted.

Efficacy

Narcolepsy

Two phase 3, randomized, double-blind, placebo-controlled multicenter trials demonstrated statistically significant benefits of Provigil over placebo using objective efficacy measures. Subjective assessments also indicated improvements, supporting its short-term effectiveness in reducing excessive daytime sleepiness in narcoleptic patients.

However, the dose-response relationship does not appear linear, as no significant differences were observed between the 200 mg and 400 mg doses across multiple measures. Additionally, long-term efficacy has not been confirmed, as existing data lacks controlled studies.

Obstructive Sleep Apnea (OSA)

Two phase 3 randomized, double-blind, placebo-controlled multicenter studies evaluating Provigil showed only modest improvements in objective sleep parameters. In Study 303, patients taking 200 mg and 400 mg of Provigil experienced increases in MWT of 1.6 and 1.4 minutes, respectively, compared to baseline. However, the difference between Provigil and placebo was minimal (6-10%) for robust MWT improvements. In Study 402, MSLT increased from 7.6 minutes at baseline to 8.6 minutes. While statistically significant, these changes were small, raising concerns about their clinical relevance. After four weeks, Study 402 participants still had MSLT scores below the normal threshold (10 minutes). Furthermore, there was no significant difference in the percentage of patients achieving normalized MSLT scores, suggesting that a meaningful clinical benefit was not established. Statistically significant differences were observed in subjective measures like ESS and CGI-C.

None of the studies required an objective measurement of sleepiness for patient inclusion, casting doubt on the appropriateness of the study population. While minor short-term improvements were noted in objective sleep parameters, more pronounced effects were observed in subjective sleepiness assessments. However, the influence of Provigil on subjective measures should be interpreted cautiously due to the potential for unblinding caused by its neuropsychiatric effects.

The SAG determined that only a small subgroup of OSA patients—those fully optimized on disease-modifying treatments (e.g., CPAP) and with all other sleepiness causes addressed—might benefit from Provigil. However, a CHMP analysis of possible prognostic factors failed to identify a subgroup with a significantly higher likelihood of benefiting from treatment. Additionally, differences in objective sleep measurements between Provigil and placebo were clinically significant for only a small percentage of patients.

As with narcolepsy studies, no dose-response effect was observed; the 400 mg dose in Study 303 did not produce greater improvements in MWT or ESS scores compared to the 200 mg dose. Long-term efficacy remains unproven, as existing long-term data is uncontrolled and relies solely on subjective measures.

Shift Work Sleep Disorder (SWSD)

In Study 305, a phase 3 randomized, double-blind, placebo-controlled trial, Provigil demonstrated a modest but statistically significant improvement in MSLT scores. However, the clinical relevance of this change is questionable since, by the end of the study, patients still met the criteria for severe illness under ICSD-1 (MSLT <5 minutes). This was further emphasized by the fact that participants remained sufficiently sleepy at the trial’s conclusion to still qualify for study entry (MSLT <6 minutes).

Although significant improvements were observed in CGI-C and PVT scores among patients treated with Provigil, these subjective measures have uncertain validity for this particular disorder. Reports indicated a reduction in accidents or near-accidents during commutes; however, the study did not account for commute duration or type, nor were baseline values collected, making this data less meaningful.

Long-term efficacy has not been established. Existing long-term data is uncontrolled, based on subjective measures, and has failed to demonstrate a significant effect of Provigil. Following consultation with the SAG, the CHMP concluded that the observed effects on both subjective and objective measures did not provide strong evidence of an overall beneficial effect.

Idiopathic Hypersomnia (IH) cognitivebehaviortherapycenter.com

The data supporting Provigil for idiopathic hypersomnia consisted of only six patients, at least two of whom had excessive sleepiness due to sleep apnea rather than IH. Given the rarity of IH (estimated at 1/10,000 to 1/25,000 for IH with long sleep time and 1/11,000 to 1/100,000 for IH without long sleep time), the difficulty in conducting large-scale trials is acknowledged. However, with such a small dataset, no conclusions can be drawn to support Provigil’s efficacy for this indication.

Safety Considerations

Skin and Hypersensitivity Reactions

A total of 16 cases of Stevens-Johnson Syndrome (SJS), Toxic Epidermal Necrolysis (TEN), and Erythema Multiforme (EM) have been reported in post-marketing data, with three cases resulting in fatalities. In most cases, a causal link to Provigil could not be excluded. Additionally, three cases of Serious Cutaneous Adverse Reactions (SCARs) were observed in clinical trials, raising particular concern given the rarity of such events in the general population. Notably, all three serious SCAR cases in clinical trials occurred in children, suggesting a higher risk in the pediatric population.

Post-marketing reports and clinical trial data support a causal link between Modafinil and hypersensitivity reactions. In trials, hypersensitivity-related adverse events were reported more frequently with Provigil than placebo. Temporal associations further support this connection.

Multi-Organ Hypersensitivity

Although there is no clear definition for multi-organ hypersensitivity, reports of allergic reactions affecting multiple organs—including a well-documented fatal case—are particularly concerning. Given the rarity of such events, their occurrence in a clinical trial setting was unexpected and suggests a higher incidence than previously estimated.

Nervous System Disorders

Serious neurological adverse events have been spontaneously reported in connection with Provigil, including cerebrovascular disorders, seizures, and extrapyramidal symptoms. These events were also observed in clinical trials, with their onset often showing a temporal relationship with Provigil use. Several cases also reported positive re-challenge or de-challenge. In clinical trials, apart from headache, dizziness, and cataplexy, nearly all other nervous system-related adverse events were exclusive to Provigil-treated patients.

Psychiatric Disorders

A substantial number of psychiatric-related adverse events have been reported, including 517 cases of hostility/aggression (four fatal), 331 cases of psychosis or psychotic disorders (one fatal), 330 cases of depression, and 118 cases of suicide or self-injury (15 fatal). Most spontaneous reports reviewed indicated that these events typically occurred within the first few months of starting Provigil, with some cases documenting positive de-challenge or re-challenge.

The percentage of patients experiencing psychiatric adverse effects in clinical trials was notably higher than in the placebo group. The most common reasons for study discontinuation were insomnia, anxiety, depression, and agitation. There were also reports of suicidal ideation, aggression, and psychotic episodes among participants receiving Provigil.

Cardiovascular Disorders

An analysis of the MAH’s pharmacovigilance database identified 873 spontaneous reports of cardiovascular issues, 171 of which were classified as serious and 17 of which resulted in fatal outcomes. These included 69 cases of torsades de pointes/QT prolongation, 405 cases of cardiac arrhythmia, 74 cases of cardiac failure, 205 cases of hypertension, 462 cases of cardiomyopathy, and 57 cases of ischemic heart disease. Some cases documented positive de-challenge or re-challenge.

In placebo-controlled studies, cardiovascular events were predominantly observed in patients treated with Provigil. Reported serious cases included moderate chest pain linked to symptomatic mitral valve prolapse, increased heart rate, congestive heart failure, cardiomegaly, palpitations, syncope, and bradycardia. Three fatal cases were reported due to cardiomyopathy, cardiac failure, and syncope.

In many cases where Provigil was discontinued due to cardiovascular events, there was a strong temporal association between the drug and the reaction. Several affected patients were young and had no known cardiovascular risk factors. Although some spontaneous reports lacked thorough documentation, many included details of de-challenge or re-challenge, further supporting Provigil’s potential role in increasing cardiovascular risk.

The elevated rate of cardiovascular adverse events in the Provigil-treated group during OSA trials is particularly concerning, given the already heightened cardiovascular risk in this population. In placebo-controlled studies, six patients in the Provigil group discontinued treatment due to cardiovascular adverse events, compared to only one patient in the placebo group. Although interpreting these results is challenging due to existing cardiovascular comorbidities in OSA patients, the increased incidence of cardiovascular issues with Provigil use appears consistent across various indications, not just in OSA patients.

Pediatric Use

Although Provigil is not currently approved for pediatric use, serious adverse reactions have been reported in children. In particular, data suggests a higher incidence of severe skin disorders in the pediatric population.

Pregnancy and Lactation

While some preclinical studies have indicated reproductive toxicity, the available human data remains insufficient to determine whether Modafinil poses risks during pregnancy or lactation.

Potential for Abuse, Misuse, and Diversion

A search of the MAH’s pharmacovigilance database revealed 485 reports related to abuse, misuse, dependency, and tolerance associated with Provigil use. A monitoring program conducted between 1999 and 2007 tracked online references and discussions regarding Provigil, with misuse and illicit use accounting for less than 3% of online messages. However, there have been reports of Provigil being used as a cognitive or performance enhancer.