Comments on FDA Rare Diseases Draft Guidance
The Biotechnology Innovation Organization (BIO) says an FDA draft guidance on early drug development for rare diseases and the role of pre-IND meetings “provides important information to drug developers regarding pre-IND meetings to support better the consistency, transparency, [and] efficiency of drug development, and the review of rare disease therapies. BIO included line-by-line edits in its comment letter.
Pharmaceutical Research and Manufacturers of America (PhRMA) commends FDA for its “continued acknowledgment of the need for regulatory flexibility for rare diseases, for example, when determining which clinical pharmacology studies are essential to inform the safe and effective use of a drug.” The association says it supports inclusion of modeling and simulation approaches to inform dosing and elements of the clinical trial design. “Model-informed approaches may help improve clinical trial efficiency, increase the probability of regulatory success, and optimize dosing in the absence of dedicated trials,” it says. The association also offers recommendations and requests for additional clarity on issues that would ensure the maximum benefit of the draft guidance to FDA, patients, sponsors, and other stakeholders.