Neuropace, Inc. Common Stock 0 Earnings Call
Key Takeaways
- NeuroPace received communication from the FDA that their PMA supplement submission for expanding the indication of the RNS system to drug resistant idiopathic generalized epilepsy (IGE) was not approvable in its current form due to requests for additional clinical evidence.
- The Nautilus trial met its primary safety endpoint with no new safety concerns identified by the FDA.
- At 18 months, patients treated with the RNS system experienced a 77% median reduction in generalized tonic clonic (GTC) seizures, with 40% achieving GTC seizure freedom.
- 24-month data showed continued improvement with a median 100% reduction in GTC seizures among evaluable patients.
- The FDA requested additional data including full 24-month data, subpopulation analyses, patient-reported outcomes, and literature supporting clinical meaningfulness of seizure reduction.
- No new clinical trials were requested by the FDA; the focus is on additional analyses and real-world evidence.
- NeuroPace plans to submit a submission issue request (SIR) to align with the FDA on the supplemental package content and structure before filing an amendment.
- The FDA has not requested additional safety endpoints and is satisfied with the safety profile observed in the Nautilus study.
- Full-year 2026 financial guidance does not include any contribution from the expanded IGE indication.
Outlook
- The FDA is engaging interactively and collaboratively with NeuroPace to clarify the path forward for approval of the expanded indication.
- The agency is considering the totality of evidence including seizure frequency reduction, patient subpopulations, and patient quality of life improvements.
- FDA review classification of the amendment and timing remain to be determined, with the possibility of an extended review period up to 180 days.
- Post-market studies may be considered to address additional questions or gather further data after approval.
Guidance
- NeuroPace intends to submit an amendment shortly after the SIR meeting with the FDA.
- The company expects the FDA may review the amendment without restarting the full 180-day review clock due to breakthrough device designation and ongoing interactive dialogue.
- Full financial results and any updates to the full-year outlook will be provided on the earnings call scheduled for August 11, 2026.
- The timeline for resubmission and approval will be clarified following the SIR meeting in the coming weeks.
Executive Comments
- Joel Becker emphasized the company's belief in the strength of the Nautilus data and the potential of the RNS system to address an unmet need for patients with drug resistant IGE.
- Dr. Martha Morrell highlighted the clinical burden and safety risks of uncontrolled GTC seizures and the meaningful improvements observed in the Nautilus trial.
- FDA's requests focus on understanding clinical meaningfulness across patient subgroups and detailed patient-reported outcomes.
- Joel Becker noted the FDA did not issue a denial or disapproval letter and is interested in ongoing discussions and collaboration.
- Management confirmed no new clinical trials are required and that the FDA strongly recommended pursuing the SIR process.
- Patrick Williams stated that the current FDA feedback does not impact the company's cash runway or financing plans, and the 2026 guidance excludes any revenue from the expanded indication.
- Joel Becker reaffirmed NeuroPace's commitment to leadership in neuromodulation and advancing treatment options for drug resistant IGE patients.
Q&A
- The FDA requested the full 24-month data set and additional analyses on patient subpopulations to assess clinical meaningfulness, including differences in baseline seizure frequencies.
- 41 patients had data with 23 to 24 months of stimulation; 84 patients had data with some period of stimulation.
- FDA showed strong interest in patient-reported outcomes, programming details, and literature on the clinical impact of GTC seizures.
- FDA has not requested any additional safety endpoints and is satisfied with the safety profile.
- There was no discussion of requiring a new clinical trial; the FDA is focused on additional analyses of existing data and real-world evidence.
- The FDA is interested in both median seizure reduction and time to second GTC seizure as endpoints.
- FDA's questions include whether benefits apply across all subpopulations or are driven by specific groups; NeuroPace's analyses show consistent benefit across subgroups.
- The FDA did not issue a denial letter and expressed willingness to continue interactive discussions and collaboration.
- NeuroPace expects to have the SIR meeting with FDA in the next few weeks, followed by an amendment submission.
- The FDA may treat the amendment as a major amendment extending the review clock up to 180 days but is expected not to restart the full review period due to breakthrough device designation and ongoing dialogue.
- Management does not anticipate the recent FDA feedback will change their approach to additional indications or geographies.
- Financial guidance for 2026 excludes any contribution from the expanded IGE indication and the company remains on track with its financial plans.
Greetings. Welcome to the NeuroPace IGE PMA Supplement Update Call. At this time, all participants are in a listen-only mode. A question and answer session will follow prepared remarks. Please note this conference is being recorded. I will now turn the call over to Scott Schaper, Head of Investor Relations. Please go ahead. Good afternoon.
Thank you for joining today's conference call. On the call, we will hear from Joel Becker, NeuroPace's President and Chief Executive Officer, and Dr. Martha Morrell, NeuroPace's Chief Medical Officer. Patrick Williams, NeuroPace's Chief Financial Officer, is also on the line. Earlier today, NeuroPace issued a press release providing an update on the status of the company's PMA supplement, seeking to expand the indication for the RNS System to include patients with anti-seizure medication-resistant idiopathic generalized epilepsy, or IGE. A copy of the press release is available on the investor relations section of our website. Before we begin, I would like to remind you that certain statements made on today's call may constitute forward-looking statements within the meaning of Federal Securities laws.
These statements include, among others, comments regarding our expectations and beliefs with respect to regulatory matters, including FDA review of our PMA supplement through IGE, our Submission Issue Request process, our intent to amend the submission with supplemental information, our ability to place the PMA supplement in approvable form, potential labeling and post-approval study approaches, timing of future interactions with FDA, timelines for FDA review of PMA supplement amendments, the potential approval of an expanded indication, the potential clinical and commercial opportunity in IGE, and our expectations regarding operating performance and growth. Forward-looking statements are based on management's current expectations and assumptions informed by the information that is known at the time the statements are made. They are subject to risks and uncertainties that could cause actual results to differ materially.
A discussion of these risks and uncertainties can be found in today's press release and in our filings with the Securities and Exchange Commission, including our most recent Form 10-K and Form 10-Q. We undertake no obligation to update or revise any forward-looking statements except as required by law. With that, I'll now turn the call over to Joel Becker. Joel? Thank you, Scott, and good afternoon, everyone.
As Scott mentioned, this afternoon we issued a press release providing an update on the FDA review of our PMA supplement seeking indication expansion for the RNS System into drug-resistant idiopathic generalized epilepsy, or IGE. Let me begin with the headline. We received communication from FDA on the status of our PMA supplement, indicating that our submission was not approvable in its current form due to additional information requested regarding the clinical evidence supporting the submission. Having reviewed FDA's written communications and had subsequent discussions with the agency, we believe there is a path for approval of the submission. Our interactions are now focused on providing the information needed to answer FDA's remaining questions.
While we are disappointed with not receiving an initial approval, we were encouraged by our subsequent discussion with the agency, and importantly, their interest in engaging interactively, their request for additional information to address certain questions, and their willingness to work collaboratively to bring the RNS indication expansion for drug-resistant IGE patients to market. We view our subsequent interactions with FDA as a constructive step in clarifying the path forward in the regulatory process. As I mentioned, following receipt of the communication and at the agency's invitation, we met with FDA to discuss their feedback. The review team and Office of Health Technology, consistent with the letter, indicated that providing additional data from the NAUTILUS trial and additional clinical context could help address the agency's remaining questions. Importantly, the submission not being approvable in its current form was not based on any new safety concern.
The primary safety endpoint in NAUTILUS was met, and the FDA communication did not identify any new safety signals with the RNS System. From a forward process standpoint, based on the strong recommendation from the agency, we are in the process of submitting a Submission Issue Request, or SIR, to further discuss our planned approach. A Submission Issue Request is a process that allows a sponsor to engage with FDA on specific issues in an active application. We expect to meet with the agency over the next few weeks, and this meeting gives us an opportunity to discuss our planned approach with FDA before submitting an amendment. We believe that is the right next step because it can help us align with FDA on the content and structure.
Following alignment with the agency as part of these interactions, we intend to amend the submission with supplemental information, including additional data and analysis regarding the patient populations evaluated in NAUTILUS, real-world evidence, and context with regard to the clinical meaningfulness of seizure reduction. I want to emphasize that we continue to believe in the strength of the NAUTILUS dataset and in the potential of the RNS System to address a significant unmet need for patients with drug-resistant IGE. These patients have no approved neuromodulation or surgical treatment options.
For patients who continue to experience uncontrolled generalized tonic-clonic seizures, the status quo is not without significant clinical risk. Dr. Morrell will walk through the clinical data in more detail. To close, we are working with urgency and discipline to develop the supplemental package aligned with FDA on appropriate data requests through the Submission Issue Request process and move the application forward to approval. I will now turn the call over to Dr. Morrell to discuss the clinical context and data. Marty? Thank you, Joel, and thank you to everyone joining this afternoon.
Let's begin with the patient population. That is central to our conviction in this indication and our commitment to advancing a therapy for these patients who have a meaningful unmet clinical need. Patients with drug resistant idiopathic generalized epilepsy who continue to experience generalized tonic-clonic or GTC seizures face a substantial life burden and risk to safety. GTC seizures are among the most severe and dangerous seizure types. Each GTC seizure is a serious medical event that can involve sudden loss of consciousness, a fall, and convulsive movements of arms and legs, often leading to injury. Recovery may be prolonged and rescue medication is often required. Additionally, patients with uncontrolled GTCs have the highest risk of sudden unexpected death in epilepsy or SUDEP. Reducing GTC seizures can meaningfully improve patient safety, independence, and quality of life.
For these patients, as Joel said, there are no approved neuromodulation or surgical treatment options available today. That is the unmet need that the NAUTILUS study was designed to address. I will not review the study design in detail, but I want to remind you of a few points. NAUTILUS is the first prospective, multi-center, randomized, single blind, sham stimulation controlled study evaluating responsive thalamic stimulation using the RNS System in patients with drug resistant IGE. Importantly, the study met its primary safety endpoint. While the primary effectiveness endpoint did not achieve statistical significance, the pre-specified additional analyses comparing seizure frequency during treatment with baseline seizure frequency demonstrated statistically significant improvements. FDA has requested information to help them understand whether these improvements are clinically meaningful with a focus on certain patient subgroups. FDA wishes to consider this using the totality of evidence.
This includes the entirety of the data from the NAUTILUS trial, including additional effectiveness data at 24 months, analyses of response according to patient baseline seizure frequency, and detailed information on patient reported outcomes. Additionally, published literature will be provided that supports the clinical meaningfulness of the response to RNS System treatment. The clinical data generated in the NAUTILUS trial that was provided in the initial submission and what will be provided in the amendment consistently shows what we believe are meaningful and lasting improvements in outcomes that matter to patients and their physicians. The initial submission provided data to 18 months. At 18 months, patients treated with RNS System experienced a 77% median reduction in generalized tonic-clonic seizures compared with baseline. 40% of patients experienced GTC seizure freedom at that time point. We also saw rapid and sustained reductions in other generalized seizure types, including absence and myoclonic seizures.
The 18-month data also showed benefits beyond seizure counts. More than 90% of patients reported improvement on the Patient Global Impression of Change, and 80% of their physicians reported improvement on the Clinical Global Impression of Improvement. Responsive stimulation treatment was also associated with an approximate 30% reduction in seizure-related injury events and 44% lower odds of use of a benzodiazepine as a rescue medication for a generalized tonic-clonic seizure. Those data are now peer reviewed and recently published in "Epilepsia," which is important both scientifically and clinically. The publication provides level 1 evidence supporting responsive thalamic stimulation as a potential treatment approach for patients with drug resistant IGE. Since that 18-month analysis, the data set has continued to strengthen. At the request of the FDA during the review process, the company provided 24-month data, which showed patients continued to improve with stimulation.
Among the evaluable patients with completed 24-month post-implant follow-up, those who had received stimulation for 23 of 24 months post-implant achieved a median percent reduction in GTC seizures of 100% compared with baseline. This continued improvement over time is entirely consistent with what we have observed with RNS therapy in focal epilepsy. FDA is asking us to further support benefit in subpopulations of patients evaluated in NAUTILUS and to help characterize the clinical meaningfulness of benefit, including in patients with different baseline generalized tonic-clonic seizure frequencies. NeuroPace will provide evidence from the NAUTILUS trial to illustrate the magnitude of the clinical benefit of RNS therapy in these various subpopulations and the meaningfulness of that benefit as reported by the patients and their physicians. This will be supplemented by the literature describing the potential consequences of each single GTC and the patient-recognized benefits of reducing that seizure burden.
Another example of feedback from the agency was that there was limited representation to support an indication for individuals 12 to 18 years of age. NeuroPace will work to identify pathways to support an indication for use in this age group. We understand FDA's request for additional information and for the context they have requested to help to understand the clinical meaningfulness of RNS treatment. We appreciate the opportunity to interact proactively and are working to provide that information to FDA in a structured, comprehensive, and expeditious manner. I will now turn the call back to Joel.
Thank you, Marti. Let me close by describing where we go from here. Based on our interactions with FDA, we view this as a delay and a waypoint in the regulatory process and are working to address feedback on patient populations, real-world evidence, and labeling as we continue pursuing approval of the RNS System for a drug-resistant IGE indication. We have already met with the FDA review team to discuss the agency's feedback. There have already been further interactions this week. We are in the process of submitting a Submission Issue Request to further discuss our planned approach with the agency over the next few weeks. We believe that this is the right next step because it gives us the opportunity to align with FDA on the content and structure of a supplemental package.
If we are able to align with FDA on the clinical evidence package through the SIR process, we plan to submit an amendment shortly after the SIR meeting. FDA will determine the appropriate review classification for the amendment, and the agency has the ability to treat an amendment as a major amendment and extend the review clock up to 180 days. Based on our Breakthrough Device Designation, the interactive nature of our ongoing dialogue, and the agency's handling of prior amendments during this review, our current expectation is that the amendment could be reviewed without requiring a restarting of the full 180-day review clock. We will provide more specific timing as we gain additional clarity following the SIR meeting.
As previously communicated, our full year 2026 guidance did not include any contribution from the expanded IGE indication, and we plan to provide full financial results and any updates to our full-year outlook on our upcoming earnings conference call scheduled for August 11, 2026. Stepping back, while disappointed by FDA's recent communication regarding our initial application, we're encouraged by the agency's continued engagement, their interactive collaboration, and interest in working on a path for approval. We are focused on doing the work required to address FDA's feedback. We will do that with urgency, discipline, and a clear focus on the patients and physicians who need new options for drug-resistant IGE.
NeuroPace has consistently led the field by generating high-quality clinical evidence and advancing neuromodulation into patient populations that have historically had no device-based treatment options, and we remain committed to that leadership as we continue working toward an IGE indication approval. This concludes our prepared remarks. I will now turn the call back to the operator to open the line for questions.
At this time, I would like to remind everyone in order to ask a question, please press star, then the number one on your telephone keypad. Please limit yourself to one question and one follow-up. We will pause for a moment to compile the Q&A roster. Your first question comes from the line of Anthony Petrone with Mizuho Group. You may go ahead. Thanks, and good afternoon, everyone.
Maybe we can start with, I guess, a little bit more detail on the clinical side from feedback in the initial conversations with FDA. Again, you had the 18-month and then the supplemental 24-month follow-up data, which certainly showed good median control seizure rate for generalized tonic-clonic seizures. One option here was to get the GTC-only clearance. A little bit more detail on what the feedback was on why the company and the data that is submitted did not get this over the goal line here for GTC only. Thanks. Thank you, Anthony, and it is obviously a very good question.
Glad to have you here on the call. Wish we were under a little bit different circumstances in welcoming you to call for the first time, but thanks for being on and thanks for your interest in NeuroPace. You are exactly right. We had provided the 18-month data and some of the 24-month data. Dr. Morrell, Marti is very close to both the data that has been submitted as well as the data that we plan to submit, the new data, the incremental information that we are looking at. I am going to ask her to say a little bit more about that, answer your question.
Yeah, thanks. With our initial submission, we provided the 18-month data. FDA came back and requested some of the newly completed 24-month data, but they asked for a subset of that data only. They were not provided the entire data set. What they have requested is to have that entire 24-month data set, and their intent is to look at the overall benefit as well as the response in certain subpopulations. They also have a great deal of interest in seeing more detail on the patient-reported outcomes. They have asked us for the literature that comprises the real-world evidence for treatment of the RNS System, as well as the literature establishing the clinical meaningfulness of a reduction in generalized tonic-clonic seizures. They are obviously wanting to engage interactively and quite intensely with us to truly understand this patient population and what the RNS System brings.
I guess the only thing I would add to that, Anthony, is that as their analysis has gone on, and remembering this is the first time the device group has ever reviewed a study for drug-resistant idiopathic generalized epilepsy patients. They have also come up with additional questions. As their analysis has also continued, specific questions come up too. In addition to the things that Marti mentioned here, exactly the 24 months, the subpopulations, the patient outcomes, et cetera, and the clinical meaningfulness of the generalized tonic-clonic seizures. There is also a temporal element here where their knowledge of the study and the analysis also has continued to progress over time.
I'll say that we internally have performed these analyses, and we see that in the subpopulations, there is consistency and a directional improvement and in the magnitude of improvement. We believe that we'll be able to satisfy their questions and assist their understanding.
If I could sneak one quick one in. I know it's early here, you have this Submission Issue Request, and there'll be another follow-up meeting with FDA. Is there any way to just give a little bit more substance on timing? When do you think the initial meeting with FDA will be, and if you had to handicap, what timing on a resubmission could look like, that would be helpful, and I'll get back in queue. Thanks. You bet. We're in the process of preparing that SIR submission.
Once that goes in, the agency has a period of time in which to respond. In general, you could think about it as we expect to be having the SIR meeting with the agency over the next few weeks. Coming out of that, there's obviously some different scenarios. Ideally, what we would see and what we're working to, and most expeditiously, is we would file an amendment following that if we have good alignment with the agency on what they're looking for and the answers to their questions. We would file an amendment. From there, the agency has some further discretion. They could evaluate that information, and this is what we're working to. They could evaluate that information and move forward with a decision based on what has gone into that submission.
Based on our current understanding, our expectation is that would not require a full restarting of the 180-day clock. They have discretion within that. They do have the right, as a case here too, to treat the submission as a major amendment, which could extend up to 180 days after submission. Again, based on the Breakthrough Device Designation, the interactive nature of our ongoing dialogue, the way the agency has handled prior amendments during this review, our current expectation is that our amendment could be evaluated without requiring a restarting of the full 180-day clock. Hopefully that gives you a little bit of extra color.
Your next question comes from the line of Mike Kratky with Leerink Partners. You may go ahead. Hi, everyone.
Thanks for taking my questions. Maybe just to follow up on that last one, did you have a sense of what specifically within the current evidence package the FDA found insufficient? Any specific questions they asked in terms of the efficacy and what remains unresolved? Maybe just to ask the follow-up up front, can you confirm how many patients completed that 24-month data that you mentioned in the press release?
You bet, Mike. Thanks for those questions. I'll ask maybe, Marti, if you could just say a little bit more about the different categories of incremental information that we're planning on providing there, as well as then to the specific question on patient completion of the 24-month timeframe.
I don't think that FDA had any issue with the data that was provided. They knew that we had 24-month data wanted to see that and wanted some additional analyses performed that were not pre-specified. The patients were all followed for 24 months post-implant. Because of the way they were randomized early on, not every patient received that full 23 to 24 months of stimulation. Some received stimulation later and therefore did not have the complete 24 month of treatment. We're looking at everybody at every point that they were receiving stimulation, every month of stimulation, including those who completed with that 23 months. That represents 41 of the patients in the trial for whom we have data of stimulation to 23 months, 84 patients for whom there is data with some period of stimulation.
The first part of Mike's question was maybe just say a little bit more about the incremental data, the new information that we're going to be providing. You touched on that previously.
Right. The new information is really more of what we had already provided, and so that would be the 18-24 month data. We also had provided patient-reported outcomes. They would like to see that in more detail. They're interested in the programming, how detection and stimulation were programmed during the study. Understandably, we obviously can provide that to them. We had not really spent much time providing literature to them about what it means to have a generalized tonic-clonic seizure and what it means to be medically intractable, and how much of a change is necessary to be clinically meaningful to a patient. We're very happy to provide the extensive literature that describes the clinical need.
And Mike, just to emphasize a couple of those points there. Marti mentioned it earlier, but just want to make sure that it came through here as you listen to all the data coming at you here. An incremental piece of the analysis that we had not provided and will be new is the subpopulation analysis.
Right. It'll be supportive, I think, of looking at the indication and potential claims around seeing what we see as a consistent and directional effect across populations.
It's not a subpopulation benefit. Marti, would you- These, as I mentioned, these analyses were not pre-specified.
FDA's question, is this substantial benefit being driven by a particular subpopulation? Asked us to look at these subpopulations to see if they derive equivalent benefit, and we are very comfortable with the outcomes of those analyses.
The last thing I would add here, Mike, is just that, and you did not ask it, but just as we talk about the incremental data that we will be providing, et cetera, our discussions with the agency have really focused on data from the NAUTILUS trial as well as published literature. We have not been discussing with them any data that would require a new trial. Again, you were not asking that specifically, but just to the point of as we think about buckets of data and in the discussion, everything has really been either around the trial, around additional real-world evidence and meta-analysis of publications for patients having been treated, or publications around the clinical meaningfulness of GTCs, et cetera. Nothing that has been outside of the trial or current publications.
No, that is really helpful. Appreciate the color there. Joel, maybe just to follow up on that last point quickly, but did it seem like the FDA expressively green-lit this path that you guys are taking, or did it seem like they maybe do want to see another study at some point? How explicit were they in terms of approving this path that you guys are pursuing now?
There was no discussion or mention of an additional study.
Yeah. It was really pulling additional information and performing post hoc analyses on the data that exists.
The literature is there. We will provide that to them. There was no discussion about a new study.
Specifically, Mike, with regard to process, starting with their written communications, they strongly recommended that we follow this SIR path to really provide an opportunity to discuss. I think we didn't really even have the letter almost open in our email boxes when we got a follow-on email that said, "Hey, as you would've noted, we think you should pursue this, and we'd like to get together to talk about it." We met with them the next day to talk about it. They've been very interested in both the SIR process as well as interactively, quickly, expeditiously getting together to talk about it. I would also just, being careful about interpretation of all language and that kind of thing, they were very clear about. They specifically pointed to the fact that they did not issue a denial letter.
This is not a disapproval. This is not a denial. We issued the letter that we did because we're interested in having ongoing discussions and being collaborative and interactive on the questions that we've got. I think we got pretty clear signals here and now we're just working on executing that path.
Very helpful. Thanks very much.
Your next question comes from the line of Larry Biegelsen with Wells Fargo. You may go ahead. Hi, this is Ross.
I was working for Larry. Thanks for taking our questions. Following up on the last question, your comments, you noted that FDA's questions were around clinical meaningfulness within specific patient populations. Can you walk through those populations that the agency has questions on outside of the adolescents group?
Yes. The populations they're particularly interested in are those with higher and lower baseline seizure frequencies. They want to know, first of all, whether the median percent reduction is similar. They also want to know what that reduction means. Is it as meaningful for somebody with many seizures to experience a 60% reduction as it is with somebody who comes in and has a 60% reduction with a lower baseline seizure frequency? That, you point to the literature about what it means to have each single generalized tonic-clonic seizure, the risk of each one of those. We also can point to the extensive patient-reported outcome data that we collected, which indicate that there are substantial improvements in quality of life overall and in many of the 14 domains that were tested.
Also, that 90% of patients indicated that they had experienced improvement at 18 months and 24 months, and their physicians endorsed their perception of improvement, 80%. We do believe we have the support. The other is that we did not see any adverse events such as problems with sleep, any changes in mood, any changes in cognition. The absence of those effects are also part of the patient experience.
Got it. Then lastly, do you feel the agency is now comfortable with median seizure reduction as the appropriate endpoint, or is time to second GTC still a focus?
I believe that they're interested in both. Obviously, the time to second GTC was the pre-specified endpoint. The other endpoints were pre-specified also. Those pre-specified endpoints are very impressive. It's not possible to ignore a median percent reduction of 100% at 24 months and 75% at 18 months. I think what we need to do is to answer their questions about whether these benefits apply only to a subpopulation or whether they are available to the patients across the board. They really emphasized and said a number of times that they want to consider the totality of the evidence. They want to understand the entire picture. As Joel mentioned, this is the first time that they have considered a study in this patient population, and they are sincerely trying to understand what life is like for them.
Thank you. Thanks, Ross. Your next question comes from the line of Frank Takkinen with Lake Street Capital Markets.
You may go ahead. Great.
Thank you for taking the questions. I heard the comments on no need for additional clinical trials, is there a scenario where the FDA might request for the data to mature for a longer period of time, for example, say 36 months? Were they really satisfied with the 24-month mark?
The study is complete. The final report will be provided to FDA in the next couple of months. There is an opportunity in the post-market environment to address any additional questions or perhaps to gather additional data in areas of particular interest. We have not discussed what a post-market study would look like in detail. We have provided some high-level suggestions, of course, the specifics of a post-market study will evolve in the discussions that we're having now with FDA.
Okay. That's helpful. Just one last one, another confirmatory one. It sounded like across the different interactions with the FDA, they were largely satisfied with the safety and adverse event-related profile. Is that a fair assumption, is there additional safety endpoints that they were also requesting?
No. They have not requested any additional safety endpoints and are very satisfied with the experience in the study.
Okay. Thank you for taking the questions.
Thanks, Frank. Your next question comes from the line of Lily Lozada with JP Morgan.
You may go ahead. Great.
Thank you for taking the question. To follow up on the question around the subgroup analyses, based on what you know about the data across different subgroups, how are you feeling about the chance that you potentially get approved for a smaller indicated population than you initially intended, and what are the implications of that for the TAM?
Well, I believe the first step is to show them what those analyses looked like. We'll be able to show them that the benefit is evident in both the patients with lower baseline seizure frequencies as well as the higher seizure frequencies. As I mentioned, we did not provide those sub-analyses to them before because they weren't pre-specified in the statistical analysis plan. These are post hoc at their request. We've performed them, and we don't have any concern about what they show. The benefit is not specific to one group.
The other thing there, I might connect a dot here, Lily, around that line of analysis and discussion is also then in parallel with their interest in and our providing information around the clinical meaningfulness of each generalized tonic-clonic seizure and the impact that has, as well as the risk of things like Martha had mentioned in her prepared comments of injury and rescue medications. We haven't really talked about SUDEP so much. Maybe Martha, I'd ask you to comment a little bit here on the SUDEP risk associated with poorly controlled GTC. The subgroup analysis and the impact in different patient populations then is really paired with their interest and request to discuss further on clinical meaningfulness for what it means to control a GTC patient well.
Yeah. I'll just frame it with an example of a single patient. A patient who came into our study with a baseline seizure frequency of three per month, and who goes to no seizures a month, just had a 15-fold reduction in their risk for SUDEP. We also know, and the literature is very solid about this, that every GTC carries a 20% chance of a serious injury. Subtract the numbers of seizures, and that's your injury rates going down. Of course, what the patients express changes in their life quality, which is quite compelling.
Thanks, Marty. Your next question comes from the line of Mike Polark with Wolfe Research.
You may go ahead. Hey, good afternoon.
Thank you for taking the questions. Just two from me. I'll ask them both upfront. Any medical device analogies you'd have us consider as we calibrate your path here? Recent examples where FDA issued not approvable letter, subsequent engagement was constructive, an amendment was submitted and ultimately approved. If there's anything that comes to mind that we could go study, I'd love the suggestion. The second one is, this is a follow-up to your response to Joel from Mike Kratky. I think I know the answer, but I want to ask it anyways. If at this point in your regulatory journey, the FDA thought there wasn't a path, would they tell you no? Thank you. Thanks, Mike. The short answer is yes, they would.
Our view is if they were intending on sending a denial and a disapproval, they would have, and they told us the same. They said, "We didn't send you a denial or a disapproval for a reason," that's because they want to continue the discussion. They've laid out a path for how we can address their questions, both in terms of content as well as process. The answer is yes, they didn't do that. With regard to predicates or other analogies, you'll have to forgive me, Mike. We have been very focused on us the past few days.
Fair enough. As our knowledge perhaps broadens, I'd be happy to communicate it, but we're really focused on helping drug-resistant idiopathic generalized epilepsy patients, and our plan to execute on it right now.
Fair enough. Thank you. Your final question comes from the line of Yi Chen with H.C.
Wainwright. You may go ahead.
Hi. Thank you. This is Katie on for Yi. I guess I'm just going to finish us off with what kind of incremental spin does this add to your path forward? Does it change your cash runway or any financing plans? Does this change your appetite for or approach to additional indications of geographies for this platform?
I'll comment on the indications and geographies and then ask Patrick to speak to runway and cash, et cetera. It does not impact our interest in or focus on additional indications or other opportunities for growth within the business. We see a path. We're focused on that path, and we think it's of significant potential benefit for us. Patrick, what would you say about current events and how that looks from a financial perspective?
Sure. At this time, we're not prepared to make any comments around that. I would say that, as a reminder, and as we said in the press release and in some of Joel's prepared comments, that we have previously and consistently communicated that our 2026 financial guidance did not have any contribution from IGE. Perhaps a little bit of a slight delay here, but we remain on track, and we'll come back as we get more clarity on the timeline, as we move through 2027 and 2028.
That concludes our question and answer session. I will now turn the call back over to Joel Becker for closing remarks.
Thank you, and thanks everybody for getting on the line, and for those of you listening. While we're disappointed in FDA's initial communication here, we believe that there is a path for approval of the submission. We appreciate FDA's expeditious and interactive engagement, and their willingness to discuss their questions, and the work that they've been willing to put into this review. We also really appreciate their specific interest in patient experience and clinical meaningfulness that has been expressed at this point in the review as well. We remain confident, as I mentioned, in the NAUTILUS clinical data, and we believe that this will be a waypoint on our approval journey and our leadership in developing and obtaining the first and only device indication in the drug-resistant epilepsy, idiopathic generalized epilepsy population. I look forward to updating you as activities progress. Thank you. Ladies and gentlemen, this concludes today's conference call.
