Dose Optimization Info for Combo Drugs Needed: PhRMA

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Pharmaceutical Research and Manufacturers of America (PhRMA) says a recent FDA draft guidance on oncologic drug development provides limited information on how to optimize the dosage for oncology products that are developed for use in combination with other oncology therapies. In comments to FDA on its draft “Optimizing the Dosage of Human Prescription Drugs and Biological Products for Treatment of Oncologic Diseases,” PhRMA encourages the agency to “explicitly note in the final guidance that FDA will take a case‐by‐case approach when evaluating dosage optimization for combinations.

The drug lobbying group also took issue with the guidance’s discussion on the historic use of dose-finding trials to determine the maximum tolerated dose (MTD). It says the document highlights the “risk of unnecessary toxicities using the MTD approach but does not emphasize the potential risk of exposing patients with life-threatening disease to a sub‐therapeutic dosage and lower efficacy in instances where the MTD or maximum administered dose (MAD) may be the only biologically active dose or in instances where observed non‐clinical pharmacodynamic data is the main basis for requests to evaluate lower dosage(s),” it says. PhRMA requests that the FDA further elaborate on how sponsors can “minimize the risk of underdosing patients, particularly in expansion cohorts, while continuing to assess optimal dosage.”

Additionally, PhRMA pointed out that antibody‐drug conjugates (ADCs) require a hybrid approach to dose optimization. “The dose‐response relationships for these oncologic products could be different from other modalities described in the current draft guidance and in some cases, efficacy may be correlated with toxicity,” the group’s comments say. It suggests that FDA include considerations for dosage optimization of ADCs in the final guidance.

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