Challenges of ‘N-of-one’ Medicine: Woodcock, Marks

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CDER director Janet Woodcock and CBER director Peter Marks review in a New England Journal of Medicine editorial some of the regulatory, ethical, and other considerations that arise with true individualized therapies. After describing cases in which single patients were treated with an individualized gene therapy, Woodcock and Marks ask what type of evidence should be needed before exposing a human to such a drug.

“Even in rapidly progressing, fatal illnesses, precipitating severe complications or death is not acceptable,” they write, “so what is the minimum assurance of safety that is needed? How persuasive should the mechanistic or functional data be? How should the dose and regimen be selected? How much characterization of the product should be undertaken? How should the urgency of the patient’s situation or the number of people who could ultimately be treated affect the decision-making process?”

The two also discuss the ethical and societal issues raised by the new drug discovery paradigm.

“If such individualized interventions become common, and some are successful,” they conclude, “the questions of regulatory approval and sustainability of production also become pertinent…. In the upcoming months, these issues will need to be addressed at FDA with input from academic, patient advocate, pharmaceutical industry, and other stakeholders.”

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