Avoid Tissue Agnostic Therapy Unintended Consequence: PhRMA

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Pharmaceutical Research and Manufacturers of America (PhRMA) says that while it supports continued development of targeted therapies for molecularly defined conditions, it is important to avoid unintended consequences that might adversely affect orphan drug development. “If the incentives for development of products shift away from tumor histology to tissue agnostic treatments,” PhRMA says in a docket comment, “there could be a lack of investment in histological diseases with significant unmet medical needs. While addressing the molecular targets in different tumor types is important, it also will be important to continue to study drugs’ impact on histological targets. FDA policies should ensure incentives in both areas rather than favoring one over the other.”

The association also recommends that the agency consider a biomarker-positive, tissue-agnostic disease and a tissue-specific disease as the different diseases or conditions to maintain incentives to seek orphan drug exclusivity and orphan drug designation for both tissue-specific and biomarker-defined, tissue-agnostic diseases. And it says that FDA should exercise greater flexibility with respect to the evidence necessary to support orphan drug designation for a biomarker-defined tissue-agnostic disease.

The National Organization for Rare Disorders (NORD) says the current designation paradigm is flexible enough to appropriately address tissue agnostic therapies, orphan designation requests for oncology therapies should be comprehensive, and multiple exclusivity periods should not be awarded for the same drug in the same population.

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