FDA Draft Trial Diversity Guidance Outlined
Three Troutman Pepper attorneys say a 4/14 FDA draft guidance, Diversity Plans to Improve Enrollment of Participants from Underrepresented Racial and Ethnic Populations in Clinical Trials, is the agency’s first attempt to articulate detailed expectations for submission of a plan by trial sponsors to ensure that clinical trial diversity goals are realized. The document recommends submitting diversity plans for products associated with an IND, IDE, NDA, BLA, PMA, 510(k), de novo classification, or HDE as soon as practicable and no later than when the sponsor is seeking feedback for applicable pivotal trials.
The attorneys list the five elements the agency is looking for in a diversity plan: (1) an overview of the disease or condition; (2) scope of the medical product development program; (3) goals for enrollment of underrepresented racial and ethnic participants; (4) a specific plan of action to enroll and retain diverse participants; and (5) status of meeting enrollment goals (as applicable).
“Although previous FDA guidance mentioned the need for a diversity plan,” the attorneys write, “sponsors now have a roadmap to ensure that their diversity plans contain the necessary elements to satisfy FDA and are submitted timely.”
They say it is likely the most difficult part of the diversity plan will be developing a strategy to ensure sufficient enrollment of under-represented populations. “An effective strategy should consider community outreach and burden reduction,” they say.