COMPASS Pathways Plc - American Depository Shares

COMPASS Pathways Plc - American Depository Shares

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Q1 FY2026 · Earnings Call TranscriptMay 13, 2026

Operator

Good day, ladies and gentlemen, and welcome to the Compass Pathways first quarter results conference call. At this time, all participants are in a listen-only mode.

As a reminder, this call is being recorded. I would now like to introduce to you your host for today's call, Stephen Schultz.

You may begin.

Stephen Schultz

Welcome, all of you, and thank you for joining us today for this conference call. I'm Steve Schultz, Senior Vice President, Investor Relations at Compass Pathways.

Today I'm joined by Kabir Nath, our Chief Executive Officer, and Lori Englebert, our Chief Commercial Officer. Teri Loxam, our Chief Financial Officer, and Dr.

Steve Levine, our Chief Patient Officer, will be available for the Q&A. The call is being recorded and will be available on the Compass Pathways Investor Relations website shortly after the conclusion of the call, and will be available for a period of 30 days.

Before we begin, let me remind everyone that during the call today, we will be making statements about our future plans and prospects that constitute forward-looking statements. Each forward-looking statement is subject to risks and uncertainties that could cause actual results and events to differ materially from those projected in that statement, including those risks and uncertainties described under the heading Risk Factors in our most recent filings with the US Securities and Exchange Commission.

These forward-looking statements represent our views only as of today, and we specifically disclaim any obligation to update or revise any forward-looking statement, even if our estimates or assumptions change. I'll now hand the call to Kabir Nath.

Kabir Nath

Thank you, Steve. Thank you all for joining us today.

It has been a very exciting and productive quarter for Compass. The company continues to lead the way in psychedelic science, validated by the confirmation of a rolling NDA submission and review, and the award of a Commissioner's National Priority Voucher, or CNPV.

With our 005 and 006 data announcement in February, we have delivered positive data from both our Phase 3 studies. COMP360 has therefore demonstrated what no approved drug for TRD offers: clinically meaningful efficacy with both rapid onset and extended durability.

In fact, these extraordinary results redefine rapidity and durability for TRD patients. With only one drug approved and actually used for TRD today, we are confident that COMP360, with its differentiated and compelling profile, will be an important option for the millions of patients that have been failed by the many approved treatments for MDD.

After we announced results of our first positive Phase 3 trial last year, and based on discussions with the FDA, we began preparing for a potential accelerated launch. As we've said before, we will be launch-ready by the end of this year.

We've aligned with the FDA on our rolling submission and review plan, and have begun submitting modules for the COMP360 NDA. We will continue to submit additional modules on a rolling basis over the coming months.

Part B data from 006, which we continue to expect in early Q3, will be the final data set to complete the submission. Given the award of the CNPV, we are already working closely with the FDA to enable as much efficiency and acceleration as possible.

In addition, based on the executive order, we are accelerating our engagement with the DEA, since there is the potential for federal rescheduling to be completed sooner than the current statutory 90 days post-FDA approval. Our two large Phase 3 trials, blinded to an unprecedented 26 weeks for psychiatry trials, supported by our large Phase 2b trial, has resulted in over 1,000 patients in the program.

With comprehensive and strong preclinical, toxicology, safety, and CMC data, we are confident that we will have a robust NDA submission that supports a COMP360 approval. We've also continued to make great progress in our commercial preparedness, which Lori will cover in detail.

Our strategic collaborations across diverse settings of care, including the interventional psychiatry infrastructure, have provided significant learnings. Together with our foresight in establishing CPT III codes, specifically for providers to get fully reimbursed for psychedelic monitoring, this has set us up well for a potential near-term launch.

We are ramping up rapidly, building out the commercial team with outstanding, highly motivated talent, and initiating all activities in anticipation of approval. In addition to TRD, we are also progressing our program in PTSD, which affects 13 million Americans.

PTSD is another significant area of unmet need, and an opportunity to expand COMP360 to individuals that have few medical options. We believe COMP360 can be an important new treatment for PTSD, and it is a very logical next target indication for Compass.

Our work with the CRO and sites for our late-stage PTSD trial is underway, and we look forward to updating you as it progresses. With both the successful financing and warrant exercises in the first quarter, we have a strong balance sheet, with cash that carries us well beyond launch and into 2028.

Let me now hand the call to Lori for more on our commercial preparations.

Lori Englebert

Thank you, Kabir. Hi, everyone, and thank you for joining.

Today, there are 4 million patients with MDD who are considered treatment-resistant. Spravato, the only drug indicated and used for TRD, is expected to reach $3 billion in revenue by 2027, and as of 2025, was treating less than 2% of the TRD patient population.

We believe that, if approved, COMP360 will reach blockbuster potential by offering a transformative new treatment for the millions of patients who deserve more options. As Kabir noted, we are pleased to have been selected for the Commissioner's Priority Review Voucher.

One benefit of being selected for the voucher includes the potential for an ultra-accelerated review timeline of one to two months after final NDA submission. This provides helpful clarity on timing expectations and allows for more thoughtful and focused planning efforts.

Based on the current timelines for data and submission, we remain focused on being launch-ready by the end of the year. Last month, the White House also issued an executive order recognizing the profound urgency of the mental health crisis facing millions of Americans and the potential impact FDA-approved psychedelics could have.

In that executive order, timely rescheduling of approved treatments was stated as a priority. As a Schedule I product, COMP360 will need to be rescheduled at both the federal and state level after approval in order to be prescribed.

We are accelerating work with the DEA to ensure rescheduling at the federal level goes as rapidly and smoothly as possible. We have also been working at the state level for the past two years to ensure that the states follow the federal rescheduling decision in a timely manner.

Over the past two years, we have made significant progress, and today, almost 90% of the US population live in a state that intends to reschedule COMP360 within 30 days after FDA approval and DEA rescheduling. Through this work, we have markedly reduced the timeline to launch and for patients to access COMP360 after approval.

Enabling broad and equitable access includes ensuring that both COMP360 and provider monitoring time are adequately reimbursed. Kabir mentioned earlier the work we did a few years ago on securing psychedelic-specific CPT III codes, which will ensure that sites are reimbursed fully for the time required for psychedelic treatment monitoring.

These codes are billable by the hour and were designed to cover clinical work and practice expenses incurred with multi-hour psychedelic treatments. We are also accelerating reimbursement and formulary discussions for COMP360 with payers.

TRD has a significantly greater impact on individuals' lives and accounts for a disproportionate share of healthcare costs versus MDD. TRD patients accrue 62% more mental healthcare costs and experience 41% higher work-related costs than MDD patients.

COMP360 has consistently demonstrated, through three late-stage trials, clinical effects and a well-tolerated safety profile in a TRD patient population, and we expect payers to respond favorably to the emerging clinical profile and potential value that COMP360 can bring to the healthcare system. Along with enabling access to COMP360, we want to ensure that the clinical experience for the patient and the site of care is positive.

This requires thoughtful consideration of how we deploy the field force and how we educate, train, and prepare patients and the sites that will be administering COMP360. Through the insights generated through our growing medical science liaison team, through market research, and through continued close work with our strategic collaborations, we have a deep understanding of what is required to enable a well-prepared and well-supported COMP360 experience.

Lastly, but notably, we have been rapidly building the commercial organization in preparation for launch. This includes bringing in an extremely experienced commercial leadership team that has collectively launched over 50 products.

This level of experience is remarkable, and we are privileged to have such an impressive team leading launch preparation for COMP360. COMP360 has the potential to fundamentally change the way that patients living with depression are cared for, and Compass is committed to helping as many patients as possible.

With COMP360 expected to be first to market in a highly anticipated new class for mental health, Compass is at the forefront of shaping the future of psychiatric patient care. We are strongly positioned to successfully launch COMP360, and I look forward to updating you more on our progress.

Thank you, and let me hand the call back to Kabir for closing remarks.

Kabir Nath

Thank you, Lori. This is an incredibly exciting and defining time for patients and Compass.

We are confident in the rigor and robustness of our development program to demonstrate the benefit of COMP360. We have conducted our program to the highest standards, which we believe must be paramount in this new field of psychedelic science.

We now have data from three robust, well-controlled clinical trials that enrolled over 1,000 participants, including over 800 from two successful pivotal Phase 3 trials. I do want to underscore the difficulty of establishing efficacy in TRD, with only two medicines ever having been approved despite multiple efforts.

That COMP360 has consistently demonstrated a clinically meaningful, rapid, and durable effect, and a generally safe and well-tolerated profile, is a remarkable achievement, and one that promises to be a transformative new offering for those living with TRD. I want to sincerely thank our investigators, trial site teams, and most importantly, the participants whose commitment and trust has made this progress possible.

Thank you, and let me now pass the call to the operator for Q&A.

Operator

Thank you. The floor is now open for questions.

If you have dialed in and would like to ask a question, please press star one on your telephone keypad to raise your hand and join the queue. If you would like to withdraw your question, simply press star one again.

If you are called upon to ask your question and are listening via loudspeaker on your device, please pick up your handset and ensure that your phone is not on mute when asking your question. Your first question comes from the line of Andrew Tsai of Jefferies.

Your line is open.

Andrew Tsai

Hi. Good morning.

Congrats on the great progress and the great news. I had two questions.

The first one is, based on your guys's ongoing FDA discussions, has the FDA given you any inclination whether there will be an AdCom or not for COMP360? Because on one hand, the review timelines could be really accelerated.

Then, FDA does seem to be doing away AdComs. Then I can't help but think that Lykos got one and maybe it could be prudent for the FDA to hold one.

I'd be curious to know where you guys lean here. Thank you.

Kabir Nath

Thank you, Andrew. It's Kabir.

Just checking that you can hear us clearly.

Andrew Tsai

I can hear you, yeah.

Kabir Nath

Great, thanks. Thank you, yes.

It is the FDA's decision and the FDA's only decision around whether or not to hold an advisory committee. They will only make that determination once they see the totality of the data that we've submitted.

We will be prepared for one, and that is in our planning if necessary, but at the moment, we do not have an indication of whether or not that's likely to happen. Got it.

Then

Andrew Tsai

secondly, when you share the 26-week Part B data from COMP 006 study, the second one, in early Q3, would you consider sharing a cut of the additional 26-week-long Part C portion of the 005 study, your first study, in conjunction with that top-line release? If not in early Q3, then can we expect maybe a cut before you're possibly approved?

I figure it's open-label, and then sharing additional long-term data could be helpful or important for pricing or labeling discussions. Thanks.

Kabir Nath

Thanks, Andrew, yes. From a timing perspective, you're right that the 52 weeks of 005 clearly run in parallel with that.

We haven't made a final determination of what we'll share at what point, but I hear you loud and clear in terms of the value potentially for payers and for commercial purposes, so that's a decision we will come to in due course.

Andrew Tsai

Great, thank you.

Kabir Nath

Thanks.

Operator

Your next question comes from the line of François Brisebois of LifeSci Capital LLC. Your line is open.

François Brisebois

Yep, thank you. Very well said on the François, yep, that was great.

Just quickly here, in terms of the third quarter data for implications, can you just help us understand maybe what the expectations are and is it still a gating factor to complete the filing based on the developments that have happened recently? I just want to kind of better understand what that data is and how important it is for a launch here.

Kabir Nath

Thanks. François, may I call you Frank, please?

François Brisebois

Frank is totally fine.

Kabir Nath

He's the star. Thanks for the question, Frank.

Clearly, and just for complete clarity, we had already aligned on our rolling submission plan with the FDA before the executive order and the award of the CNPV. We had already fully aligned with the psychiatry division on what we were going to do and the time frames in which we were going to do it.

That hasn't changed. I think it's really important to note that the CNPV potentially accelerates the end part of this process, the final review, but it's been very clear in our discussions with the agency that in no way does it change the evidentiary basis that's needed for an approval.

From our perspective, we remain on track with the filing strategy we've laid out with a rolling submission, and that does indeed include the 26 weeks of 006, which we see as significant in terms of really finalizing the profile and again, for commercial purposes.

François Brisebois

Great. Thank you.

Then can you give us a little more color on the reimbursement and maybe the CP3—CPT codes? Is there anything else that we need from the CPT angle, between now and approval and after?

There's a lot of discussions about the psychological support and kind of the prep, and then maybe the amount of people that you would expect to be in a room and their qualifications, just on the commercial side, thoughts around those ideas. Thank you.

Kabir Nath

I'll hand that question to Steve.

Steve Levine

Thanks, Kabir. Hi, Frank.

On the CPT portion of the question, in terms of the work remaining for the CPT III codes, they are in a Category III format at the moment, which is their tracking form. As those codes are reported more, and they have started to be reported in a limited number of cases, it really will require our approval and launch for them to be reported in greater quantity.

As they're reported, that will enable the American Medical Association with their RUC committee, which is an acronym for the RVU Update Committee, with representation from APA to do their work to understand the work involved in delivering this treatment and the practice expenses in order for them to make a recommendation to CMS on the valuation for the code. This is not entirely a black box.

It's formulaic. There are analogous treatments to look at in terms of having some expectations coming in for where this valuation may land.

Again, ultimately, the codes will need to be reported so the codes can be progressed to the Category I valued form. Ahead of that, there will be the opportunities for negotiations directly with payers by providers for reimbursement of treatment.

On the staffing-related question with how patients will be prepared and what delivery will look like as far as treatment models, ultimately, those treatment models will be up to sites of care as part of the practice of medicine. Staffing ratios, descriptions of the roles of people involved, the language that will ultimately end up in our REMS will be a result of discussion with FDA in due course during the review period.

We have been guided to expect to this point that the REMS will be consistent with the one that exists for Spravato today, as well as what FDA had prepared in the briefing materials for Lykos's AdCom, which used language to the effect of a prescriber available, a licensed healthcare provider on-site, and these, of course, are the important elements in terms of having the sufficient experience and training of providers necessary to ensure safeguarding of patients.

François Brisebois

Great, thank you very much.

Operator

Your next question comes from the line of Paul Matteis of Stifel. Your line is open.

Hey, thanks so much. This is Julian on for Paul.

Appreciate taking our questions, and congrats on all the great progress. Just two from us.

What are your expectations for rates of retreatment after sequential doses versus one initial dose, thinking about the 006 26-week data coming out? How do you think that will be assessed by FDA with respect to implications for labeling?

Then our second question is, from your commercial work, have you been able to identify what proportion of patients being prescribed Spravato are at large academic medical centers versus private practice clinics? Curious how that may or may not influence your commercial strategy.

Thank you.

Kabir Nath

Thanks, Julian. On the first question, as you know from what we've already shown, we saw that there was a 25% of patients had a clinically meaningful response in 005 from that single administration of COMP360, and we saw that that was 40% in 006 with the addition of the second fixed dose.

Clearly, we are expecting that higher level of response to be sustained through 26 weeks, but we really do need to see the data to understand what the potential impact of a third dose for those who had it may be, and indeed, what the second dose after week 3 does for sustained response without necessarily a third dose. Turning to what that means, and I'll start, but Lori and Steve may want to jump on here.

We are seeking a label that essentially says from one or two doses and then with further episodic dosing at provider discretion. That gives discretion, because clearly, if somebody responds very well to a first dose, there may not be a need for something within three weeks or a short time period, but equally, we clearly saw so far that there are patients who do benefit from having that second dose three weeks apart.

That's how we're thinking about labeling. Then I'll hand to Lori and Steve to talk about first that, and then the percentage of patients.

Lori Englebert

Hi, Julian, by the way, this is Lori. I agree with Kabir's assessment on what we're seeking for the label.

The 26-week data that we're getting from 006, combined with the 005 data, is really going to be used to help guide clinical decision-making from the field force as we're out educating providers. Steve, do you want to add on that?

Steve Levine

No, that covers it.

Lori Englebert

In terms of the Spravato patients being treated in academic centers versus what everyone calls the interventional psychiatry treatment centers, the academic centers are treating very, very small portion. It is I think less than 5% of patients are actually being treated at academic centers.

The primary focus of ours will be at launch on the interventional psychiatry treatment centers that are currently prescribing Spravato, which is at about 7,500 already.

Steve Levine

I'll just add to that that we do engage with many academic centers. We hear a lot of excitement from them about the potential of implementing COMP360, we do expect academic sites to deliver COMP360.

The nuance is that they are typically not built to have high-volume operations. They tend not to treat high volumes of patients.

They don't have the kind of throughput that the interventional clinics have. They will deliver the treatment, but reflective of the breakdowns that we see with Spravato prescriptions, we expect that to be similar with those centers having a higher capacity to treat more patients.

Super helpful. Thanks for the color.

Operator

Your next question comes from the line of Josh Schimmer of Cantor. Your line is open.

Josh Schimmer

Hey, thanks for taking the questions. How are you thinking about the incremental capacity for COMP360 administration at those 7,300 or so interventional pathways?

Is there anyway to quantify that? Then what percent of the centers do you expect will be adopting the buy-and-bill model for COMP360 early on, and how do you expect that to evolve over time?

Thank you.

Kabir Nath

Thanks, Joshua. Pass the first to Steve.

Steve Levine

Hi, Josh. Good to hear from you.

Thanks for the question. On the capacity side, we know that these centers have existing capacity today, and it's an important consideration when we often get questions about how these sites will make decisions about which treatment to deliver and whether they're making trade-offs based upon reimbursement that they may receive for delivering various treatments.

These sites know that there are huge unmet needs for the treatment-resistant depression population. They are excited to have more tools available and to have the opportunity to make decisions of which treatment to deliver.

In the meantime, given especially that a Spravato room and a Spravato staffing model are the same as what we anticipate to be required to deliver COMP360, they don't need to make any adjustments in their centers today in order to have capacity to deliver the new treatment. They'll be able to use the rooms interchangeably.

It is likely that within the same day, they may treat a patient with COMP360 and one with Spravato later in the day, or that over the course of the week, these rooms may be used for either treatment. There's plenty of existing capacity that they will first fill prior to adding additional space.

Should they have the good problem from their perspective of treating lots of patients and running out of capacity, the economics are very favorable for them to add space or add new locations. On the buy-and-bill part of the question, what we've seen with Spravato is that the penetration of buy-and-bill relative to specialty pharmacy reimbursement has increased over time.

We don't know the exact numbers. We believe it's somewhere between 35% to 45% of Spravato prescriptions at this point are buy-and-bill.

This is something that the psychiatry model has not been used to prior to the advent of Spravato, but they are beginning to recognize the economic value of processing claims in this way. I'll hand to Lori to augment this, but I think we would expect that in the earliest days of launch, more sites may, as they get used to delivering our treatment, initially work with the specialty pharmacy channels, but we would quickly expect them to adopt buy-and-bill and for that to increase over time.

Lori Englebert

The only thing I'll add, Josh, is that we will enable both at launch, and so that is just an important nuance to add, is that it will be enabled, but we do, from a realistic expectation standpoint, expect there to be a little bit of a ramp to heavier buy-and-bill.

Josh Schimmer

Great, thanks very much.

Operator

Your next question comes from the line of Judah Frommer of MS. Your line is open.

Judah Frommer

Hi, guys. Thanks for taking the question, and congrats on all the progress.

Maybe just a follow-up on how providers are thinking about potential administration. I think there's a little bit of discussion about whether psychedelic treatments should fit into that Spravato dosing window versus maybe something longer that COMP360 would take.

Can you just remind us, from the provider's perspective, the economics of turning over a room maybe two or three times for multiple Spravato applications versus maybe a single administration of COMP360 and what the economics look like relative to each other? Thank you.

Steve Levine

Thanks, Judah. This is Steve's favorite question.

Yes, thank you for the opportunity to talk about this, Judah. Exactly as you said, there are inefficiencies with shorter treatments and needing to turn a room over multiple times in a day because—this is, I guess, self-evident, but when you have time in between patients where you need to turn the room over, to clean it, the administrative work of an additional patient, etc., that is a gap that is unreimbursed time.

Therefore, if you are able to fill that room with one patient and you are reimbursed for the entire time that the patient is in that room, then that is much more efficient for these sites. To put some numbers to it, if you consider that a site operating at full capacity, which as I've just said earlier doesn't exist—these sites have plenty of capacity—but to be conservative, let's say they're at full capacity, and then let's say they're maximally efficient, which most sites also are not, that would mean they could get three Spravato patients in a room in a day.

With average reimbursement for a Spravato session somewhere south of $300, but using $300 as round numbers, then that means they're potentially being reimbursed for the room at $900 per day. That works for these sites.

That is not ideal necessarily in their minds. That's really kind of the target that would be the minimum that they would need if they were just purely making these trade-offs.

That makes us very confident that this will make sense for them. In addition, if we consider that the observation time for COMP360 will probably be about 6 hours within a typical operating day for these sites, it means they could also most likely get a Spravato patient in that room, too.

Since most of these sites aren't having more than one Spravato patient in that room in a day anyway, this is all upside. This is all additive for them.

Operator

Your next question comes from the line of Ritu Baral of TD Cowen. Your line is open.

Ritu Baral

Thanks for squeezing me in, guys. Steve, you mentioned the RUC committee of the AMA.

Our understanding is that this committee meets once a year and unfortunately has only one psychiatry rep, and is very sort of surgeon-dominated. Do you know when this RUC committee is scheduled for the year?

Second, is there anything you can do as far as prep for this committee to sort of optimally communicate the value proposition of COMP360? Then I've got a follow-up on the DEA discussions.

Have you been in communication with the DEA proper, and do you have an idea at this point if communications and review of the FDA will start even before the NDA is complete, or would you expect that this would still be sort of expedited review on the tail end of approval? Then if I can just ask a quick follow-up after that.

What are your expectations for the REMS in so far as the requirements for administration as well as either preparation and consolidation afterwards, like what will actually be required by the REMS, because we've heard from doctors that that will be absolutely the most important thing?

Kabir Nath

Thanks, Ritu. I'll ask Steve to comment on the RUC.

I'll take the DEA question with Lori, and then Steve will take the REMS question.

Steve Levine

A sandwich, okay. Starting with the RUC portion, you asked about the date of the next RUC meeting.

I don't have the schedule on the top of my head. We can follow up on that.

To the rest of it, you're correct that historically there has been the overrepresentation, let's say, on the RUC of surgeons and other procedurally focused committee members. That has been shifting, fortunately.

I don't know exactly how many psychiatrists are currently sitting on the committee, but there has been an effort to correct the historical imbalance in the representation on the committee. When we did the initial work on the Category III code a few years ago, we took advice from a number of people, including those who had served on the RUC in the past.

We were very well informed heading into the initial application for the Category III code. We will continue to work with experienced consultants as the code progresses to Category I and make sure that this goes in a direction that is very favorable to ensuring that there is adequate reimbursement to ensure patient access.

I will hand over for the second part of the question, and be back with you on REMS.

Kabir Nath

Yeah. Ritu, on the DEA, as the executive order mentions the fact that the analysis could potentially start as soon as Phase 3 is completed.

After further conversation with those responsible for that, it's clear that the intent is that the DEA and the FDA can arrive at their conclusions simultaneously. However, it would still be a sequential process.

Essentially, we will provide an eight-factor analysis. The controlled substance staff within the FDA will then review that.

Historically, they have submitted their findings at the end of the review period because that's just been the way the FDA has worked. That could potentially be accelerated with the DEA then doing their sequential review, but all of this coming together in time on the same day or a day apart at the end of it.

That's the intent. Where we will actually get to in practice, we will have to see.

Lori Englebert

Hi, Ritu, the only thing I'll add is that we are working with DEA consultants, as well as accelerating our timelines to when we would traditionally communicate with the DEA so that we can reach a further understanding. For planning purposes, as of right now, we will be ready if there's anything that happens before, but we see no indication that these timelines have shifted forward.

Then

Steve Levine

back to me for REMS. Steve again.

You're referencing in our clinical trials that we had spent time preparing patients ahead of administration, supported them on the day of administration, and then followed them up for safety after. Within a clinical trial context, it was important that everyone had the same conditions, the same experience, that everything was highly standardized.

In that context, we specified a number of preparatory sessions as an example, as well as a standardized length of those visits. As this translates into real-world care delivery and how this will be guided by the REMS, what becomes most important is not a certain number of sessions or a length of those sessions, just that patients are adequately prepared and they are properly followed up for safety.

Anything that would be in a REMS would be very typical of REMS language and not get down to the granular level of detail of dictating the practice of medicine. The reality is that with any treatment, there is some preparation and safety follow-up anyway, so much as any necessary language that just gives a little bit of guidance on what activities are important in terms of preparing patients, and that would include being enrolled in the REMS, having informed consent, and so on, and then ensuring that patients are followed up afterwards as a safety check.

Operator

Your next question comes from the line of Madison El-Saadi of B. Riley Securities.

Your line is open.

Madison El-Saadi

Hi, thanks for taking our question. A couple from us.

Maybe what have you learned about the CNPV mechanics since receiving the award a couple weeks ago? Should we think of this one to two-month CNPV review clock as not really starting until that final module is submitted, or has it, I guess, to some degree already started, which would imply the FDA response closer to one month versus two months?

Then afterwards, an unrelated follow-up.

Kabir Nath

Yeah. No, thank you for the question.

Our understanding is certainly that that formal one to two-month goal is following the completion of the NDA submission. However, what it also does imply, clearly, is an even more flexible and responsive way of working with the agency.

As we've said before, we already have an excellent relationship with the psychiatry division. It's collaborative, it's constructive, it's focused on solving problems.

What we've already seen in the last couple of weeks is that that is even more so. In particular, some of the standard timelines of 30 days to request a meeting and X days for a response and so on, those have gone away entirely.

This really is about, first, a much more flexible day-to-day interaction with the agency. No, the actual formal clock of that one to two months, as we understand it, will only start with the submission.

Again, to be clear, that's a goal, yes. It's a goal that they can complete it within a couple of months.

Madison El-Saadi

Understood. That's great to hear.

Then secondly, so many of these sites offer TMS. Based on what we know or what we believe we know about how psilocybin works, how TMS works, do you think there may be an additive or even a synergistic effect from combining these treatments?

Thanks.

Kabir Nath

That's definitely a Steve question. Any psychiatrist on the call?

Steve Levine

Thanks, Madison. That's an intriguing one.

It's something that has been raised to date. It's really a matter of speculation.

You can concoct theoretical reasons why there may be synergies. Be good to see some data.

I know that there's at least one small academic study already looking at the concurrent use of these two modalities. I'm sure that the sites that deliver both treatments, both TMS and COMP360, may be interested in that question.

If they do, I hope they track outcomes and we gather data and have some guidance on whether that may be an effective approach. Ultimately, these sites are ecosystems of care.

They offer multiple treatments. They're trying to offer as many tools as possible for these patients to maximize their outcomes.

Treatment-resistant depression is, for many patients, a chronic condition and they will receive many treatments over a lifetime. Whether these treatments are combined in some way or whether, over time, they wind up having multiple of them, we would expect that somebody receiving their care in one of these sites may have more than one of these treatments over the course of their care.

Lori Englebert

Madison, if you don't mind, I'll chime in as well. Part of the benefit of us producing the data in treatment-resistant depression is that we believe that there's a huge unmet need.

Spravato is the only indicated drug product being used right now in this patient population. Given the frequency of treatment that Spravato requires, it is often patient-prohibitive.

In order for patients to want to receive these type of treatments, it has to fit into their schedule. We believe COMP360 brings a very complementary patient profile, a patient-friendly profile, to these patients.

We expect COMP360 to be earlier-line than where TMS is currently being used right now, which is traditionally one of the later to last lines of treatment.

Madison El-Saadi

Understood, that's very helpful. Thanks.

Operator

Your next question comes from the line of Patrick Trucchio of H.C. Wainwright.

Your line is open.

Patrick Trucchio

Thanks. Good morning.

A few questions. The first is regarding the Phase 3 trial, the COMP 006, for the Part B 26-week data that's expected in the third quarter.

Can you tell us, first, just which measures will be released at that time? Is it sort of maintenance of greater than 25% MADRS reduction, remission durability, time to relapse, treatment frequency, patient-reported outcomes, as well as safety?

Which parts of those data matter most for the NDA as well as the label and payer discussions?

Kabir Nath

Yeah. Patrick, we haven't yet determined what we would release publicly.

From a simple perspective, all of that data will be necessary for an NDA perspective, clearly, everything, all those endpoints, primary, secondary, all the safety data, will clearly go to the FDA. I'll hand to Lori to talk about the commercial piece.

Lori Englebert

All of that data will also be important for payer and clinical decision-making, which we will have in due course to help inform all of those decisions. In immediate discussions with payers, it will be the redosing and durability piece that we're really looking for so that we can inform payers on how many doses to expect per patient.

Steve?

Steve Levine

Sorry, Patrick, just one thing to add to that, which is, similar to what we guided prior to the release of Part B of 005, just to be clear, there isn't a particular bar, there isn't some number that's a measure of success there. It is important data, but it's data to really round out the profile of the drug.

As Lori said, to have discussions with payers, to guide expectations clinically with providers. There's nothing that we're rooting for necessarily.

We just need to understand the longer-term trajectories of these patients.

Patrick Trucchio

Great. Then just on the commercial side, more specifically, I'm just wondering if you can talk more about just your launch readiness and being ready by the end of the year, and to what extent you've begun that process of hiring a field force and building out a REMS infrastructure and sort of discussed the structure with payers and distribution contracts, and as well, related to that, of the 7,300 centers that could offer the treatment, or greater than 7,300 centers, how many have you actively engaged with and what proportion do you think are ready or will be ready to administer COMP360 within the first 3 to 6 months after approval?

Lori Englebert

Given the work with the strategic collaborations that we've been doing for several years now, which really sets us up for success and also enabled us, largely, to be able to say that we will be launch-ready under such short timelines, I'm going to let Steve answer that last question, and then I'll answer your original question at the end.

Steve Levine

We're flipping it around on you, in reverse order, okay. Yes, in terms of the sites that we've engaged with and will be ready, as Lori said, we've been working with sites like this for quite some time now, whether it's formally within our strategic collaborations, whether it's engagement by our field medical team as they've been out for the past couple of years meeting with healthcare providers around the country, or other relationships we already have with the leadership of these organizations, I think it's fair to say that we've engaged with the vast majority and we know really quite many of them quite well.

It is that level of engagement and knowing them that well that gives me a lot of confidence to say, we don't need to encourage these sites to get ready. They're almost more excited than we are.

This is really why they've built the infrastructure in the first place. It wasn't to deliver one treatment, it wasn't to deliver Spravato.

It was in anticipation of having more treatments, particularly ones with a profile like COMP360. The feedback we've been getting since the last data release is that they are just so excited for their patients to have a treatment that has this rapidity of effect, this durability of effect, which is on a scale far different from anything they've had available to them to this point.

The ability to recruit patients from a much larger radius, to the point that Lori made earlier about the burden on patients of the frequency of treatment with Spravato, but particularly with TMS needing to come every day, it's really hyper-local patient recruitment. With COMP360, with just one or two treatments, they're able to have patients travel from much further area.

They are excited. They are really bombarding us every day with questions of, when are you going to be approved, what do we need to know.

They will be ready.

Lori Englebert

Patrick, will we. Hopefully you can hear through mine and Steve's excitement, collective excitement here about this particular topic, just how confident we are in the fact that we are not only building out a pretty remarkable team—this team, this leadership team, getting them on board first was very important so that they could start to build out their teams, and all of that is underway right now.

Every single aspect of function within a commercial organization has a remarkable leader at the helm, and they are currently in the process of building out, and have already expanded the team. The team has already doubled in the past two months.

We are well on our way of making sure that we are adequately prepared. Everything you mentioned is underway.

Compliant payer discussions are beginning right now. The negotiating piece, I just want to set expectations on the negotiating piece with payers: we won't start negotiations until we understand the clinical profile better of COMP360, as we mentioned before, but we certainly are engaging with payers to start those initial discussions right now.

Trade and distribution is well on its way. We are working there to understand what our distribution strategy is, and again, with some really remarkable leaders and very, very experienced at the helm.

Patrick Trucchio

Terrific. Thanks so much.

Steve Levine

Thanks, Patrick.

Operator

Your next question comes from the line of Leonid Timashev of RBC Capital Markets. Your line is open.

Leonid Timashev

Hey, guys. Thanks for taking my question.

I wanted to ask on PTSD. Obviously, another part of the executive order was significant underlying excitement for treating PTSD.

I guess I'm curious how you're thinking about your program specifically, whether there's any changes you're envisioning to the trial, whether you think the evidentiary standards may be lower and you can move ahead with just one Phase 3 registrationally, and given the focus on veterans from the administration, whether there's plans to explore that subpopulation more deeply. Thanks.

Kabir Nath

Thanks, Leonid, and I'll start on that. First, yeah, we agree.

PTSD is a very significant unmet need. As we have said, we are planning that as a single late-stage trial.

Obviously, we will have to see what the data says and so on, because ultimately, that will be a FDA decision around that. Within that trial, we will have VA sites.

More broadly, though, we are already heavily engaged with the VA, and I'm going to hand to Steve to talk a little bit about what that is. Just before I do, we should also note that it is now publicly available: we are supporting a study within the VA, which is a very robust clinical study, which is a TRD population with heavy PTSD comorbidity.

That study, we are also supporting. I'll hand to Steve to talk more broadly about the work we're doing with the VA.

Steve Levine

Thanks, Kabir. PTSD is an area where we are really excited.

This is 13 million US adults who currently have very few options, terribly underserved. Really excited to be moving this program forward.

As a reminder, the design of this study was from the beginning intended to support registration with a single trial, and so that still remains the aim. As Kabir said, we already are engaged with the VA in various ways.

He mentioned the study that we are supporting. We are supplying the drug, as well as the training of the initial cohort of trainers for a large multisite VA study looking at people living with both treatment-resistant depression and PTSD, in addition to a second study as well within the VA.

Beyond that, we have had active engagement for quite some time now with VA's integrated project team, which has been working for multiple years now on their preparations to be able to implement psychedelic treatments as they're approved, so that engagement is robust and ongoing, and it certainly is a priority for us to ensure that as we bring new treatments to market, that these are available for our veterans.

Operator

Your next question comes from the line of Sumant Kulkarni of Canaccord Genuity. Your line is open.

Sumant Kulkarni

Hi, team. Thanks for taking our questions.

I have a few here. First, how do you expect competitive and legal dynamics on psilocybin to play out given Usona Institute also has a National Priority Voucher for its product and could already have its Phase 3 data in-house for major depressive disorder?

Kabir Nath

I can only comment on the fact that we, Sumant, at Compass, have two very large Phase 3 trials where we've already declared the primary endpoint, and we've agreed on a rolling submission and review plan, and that's what we're focused on right now.

Sumant Kulkarni

Thank you. Do you expect a label limit on the number of treatments per year for COMP360, and how soon after a patient needs retreatment would they be able to get it in the real world?

Kabir Nath

No, but I'll hand from a kind of commercial payer perspective to either Lori or Steve. Lori?

Lori Englebert

I'll speak to it from the payer standpoint. Steve can speak to it from the clinician standpoint.

Agree with Kabir completely: we expect no limit in the label. We will, through negotiations, be discussing with payers what that looks like and if there will be limits from a prior authorization re-approval process.

That is not only standard practice, especially with these type of treatments, but also should be expected. It is, again, not going to be overly onerous for the sites, nor again, is it outside of the norm of what happens in clinical practice right now.

Steve Levine

To answer the last part of your question, Sumant, about the treatment frequency or the intervals, what we've seen so far is that some patients have some benefit from a second administration, whether it's on the fixed interval three weeks after the first, or on a more variable basis as we saw in Part B of 005. Because the minimum interval we studied is three weeks, I would expect that there likely would not be dosing closer than three weeks apart.

There really clinically would likely not be a reason to. Otherwise, I think the upcoming data from Part B of the longer-term progress in 006, but together with Part B of 005, will help give some guidance to clinicians on how they would think about retreatment, and then otherwise, as Lori said, that would be further guided by payer policy.

Sumant Kulkarni

Got it. Then the last one on PTSD.

Other than less frequent dosing, what are the key reasons that would make patients want to take COMP360 versus Otsuka Transcend's TSND-201 or methylone? They are likely to be

Kabir Nath

first. We need to see data in terms of efficacy and safety on both of them, clearly.

They are likely to be very different experiences from a patient perspective. These are very different medicines with different MOAs.

To your point, certainly the Transcend protocol hitherto has been more burdensome from a patient perspective as well. I think we will need to see how that's fully characterized through the clinical trials.

We believe both in terms of patient experience, provider experience, and infrequency of administration, there's clear differentiation between them.

Steve Levine

To be clear, there hasn't been an approved drug in PTSD this century. There are only two approved options right now.

Both are old generic SSRIs that are only modestly efficacious. More options, more options, right?

There's 13 million people with PTSD. It is not one or the other.

There's not going to be one winner here. We are excited for any new option that is safe and efficacious in this population.

The patients living with PTSD deserve to have more treatment options.

Sumant Kulkarni

Thanks.

Operator

Your next question comes from the line of Tom Shrader of BTIG. Your line is open.

Jinnie Kim

Good morning. This is Jinnie Kim on for Tom Shrader.

Thank you for taking our questions, and congrats on all the progress. A couple of PTSD questions.

What's the primary endpoint for the PTSD Phase 2b/3 trial, and has the FDA aligned on that endpoint in a special protocol assessment? In the TRD program, the two doses of COMP 006 were administered three weeks apart, but in COMP 202 for PTSD, you landed on a four-week interval.

Could you walk us through the clinical rationale for that difference? Thank you.

Kabir Nath

Sure. The primary endpoint is the CAPS-5, which is very well validated as the normal primary endpoint in PTSD.

We are using the standard primary endpoint. Because the CAPS-5 requires a four-week lookback, practically speaking, the second dose has to be at four weeks.

It can't be at three weeks, so that's the reason for that. It's tied to that endpoint.

As I say, this is the standard endpoint that has been used in PTSD trials. No, there is no SPA on this, there doesn't need to be.

Thank you.

Operator

Your next question comes from the line of Jay Olson of Oppenheimer. Your line is open.

Jay Olson

Oh, hey, congrats on the progress, and thanks for taking our questions. Maybe we'll just follow up on PTSD.

Could you talk about any synergies that you expect to capture from the infrastructure that you're building for TRD? Also, what are some of the differentiating benefits to psilocybin versus other compounds being used or studied for PTSD?

Then maybe just any other indications you're planning to pursue for psilocybin beyond TRD and PTSD? Thank you.

Kabir Nath

Yeah. We'll go backwards through these.

I'll leave Steve and Lori to talk both about synergies and some of the reasons to believe. We're clearly very focused on some of these broader neuropsychiatric conditions that do indeed share synergies in terms of patterns of prescribing, locations of treatment, and so on.

While we haven't made any determination on other areas, you can imagine there are some such as bipolar II, OCD, in all of which we have seen signals based on IISs and studies we've supported, but we've not yet in a position to lay out formally where else we might go. Let me hand to Lori to talk about kind of the commercial synergies, and then maybe Steve to touch on reasons to believe.

Lori Englebert

Given the high overlap and comorbidities between TRD and PTSD, the infrastructure that currently treats will be the same infrastructure that treats for TRD patients. The synergies are exceptionally high.

Steve mentioned earlier the work we're doing at the VA. Obviously, there's a large focus on PTSD patients at the VA, we fully anticipate that the VA will be well-equipped and ready to treat patients once it becomes available.

From a sales force standpoint, there would be very minimal change to the sales force to add on PTSD. Then

Steve Levine

the last part, nice to talk to you, Jay. One of the things that we saw in our Phase 2 study in PTSD, one of the reasons along with the opportunity to meet the unmet needs for these patients, was the experience that our patients had in that study.

We were able to do qualitative interviews with the participants, and we heard some really important feedback that seems highly differentiated from other options that are available for patients living with PTSD or are currently being investigated. That is that one of the reasons why people often avoid PTSD care is that they're forced to confront exactly the source of their trauma, which is a very frightening prospect.

It can make treatment itself very distressing. It's something that we're aware comes up with some of the empathogenic treatments like MDMA, where these are very intensive sessions.

It's the reason why, in many cases, these are studied with psychotherapy, with trained psychotherapists actively engaging with them as traumatic material comes up. What we saw in our Phase 2 study, which was largely focused on safety, feasibility, acceptability, was that this was a very acceptable treatment, one that was very pleasant for patients, where the trauma itself didn't even necessarily come up during the experience.

That was something that surprised and was gratifying to them afterwards, that despite the fact that they weren't forced to go through such a traumatic experience in getting treatment, that they had profound shifts in the emotional relationship to that trauma. We think that bodes really well for the further development of this as a potential treatment because of that really positive patient experience.

Jay Olson

Super helpful. Thank you.

Operator

With no further questions, that concludes our Q&A session. I would now like to turn the conference back over to management for closing remarks.

Kabir Nath

Thanks, everyone, for your participation today. As you've heard, we are excited by the fact that we have aligned on a rolling submission review with the FDA.

We were already aligned on that before the award of the CNPV, but that clearly validates and is a recognition of the really great work we've done, the robust data that we have generated. As you've heard, we are working with the FDA and DEA to see if there are other further opportunities for acceleration.

Most importantly, though, you've heard how excited we are about the opportunity to launch a first-in-class psychedelic. As we talk to providers, patients, current employees, prospective employees, everyone truly sees this as the opportunity of a lifetime.

We are delighted to be in the forefront of that and leading the way in establishing psychedelics as a transformative new option for patients in need of new treatments. Thanks for your attention, and we look forward to updating you on our continued progress during the remainder of the year.

Thank you.

Operator

This concludes today's conference call. You may now disconnect.