Broader Use for Pediatric Cancer Trial Eligibility: PhRMA
Pharmaceutical Research and Manufacturers of America (PhRMA) says that a draft guidance on “Cancer Clinical Trial Eligibility Criteria: Minimum Age for Pediatric Patients” should be applicable across other therapeutic areas, as appropriate. In comments on the guidance, PhRMA says it believes that the considerations for inclusion of pediatric patients in adult clinical trials outlined in the draft guidance are relevant beyond oncology products. “Further, the recommendations in this draft guidance could help provide a pragmatic solution for numerous medical conditions across the therapeutic spectrum, particularly where the relevant disease or condition is serious or life-threatening,” the group says.
PhRMA’s comments addressed FDA’s recommendation on modeling and simulation used to understand potential differences in pharmacokinetic (PK) and pharmacodynamic (PD) as well as dose selection. “As this wording can be potentially interpreted as limiting in its intent, PhRMA recommends that the discussion of modeling and simulation be addressed in greater detail in a separate section of this draft guidance as these methods are relevant in both preclinical and clinical contexts,” according to the comments. “Data from clinical and nonclinical contexts can be used to understand PK/PD and can support extrapolation. PhRMA also believes that real-world data (RWD) and real-world evidence (RWE) can provide supportive evidence for the inclusion of children in adult oncology clinical trials.” PhRMA also recommends that any final guidance include a discussion of RWD/RWE as a form of evidence that may support including pediatric patients in adult oncology trials.
Additionally, PhRMA seeks clearer recommendations on pediatric starting doses. The group recommends that the guidance indicate that “clinical and nonclinical data can be used to determine the safe starting dose in children. Modeling and simulation approaches, including extrapolation, can also be used to determine the starting dose. Although the starting dose in children is typically lower than in adults, PhRMA believes that consideration should be taken to determine the safe and efficacious dose (e.g., if pediatric patients experience similar exposure response as adults).”