FDA Not Keeping Pace with Non-Oncology Basket Trials: Column

Share

An online Clinical Trial Vanguard post says FDA has not kept pace with the advancing science of oncology-based basket trials migrating into non-oncology drug trials. “FDA’s guidance on master protocols, covering basket, umbrella, and platform trials, was finalized in 2022 and is explicitly anchored to oncology use cases,” the post says…. “The problem is that FDA’s current guidance on master protocols offers sponsors limited specific direction on how to handle cross-population safety signal adjudication when adverse event profiles differ meaningfully across baskets.”

The 2022 guidance says that sponsors should consult with the relevant review division early in development to discuss the basket trial design, the post says. “That sentence is doing an enormous amount of work,” it continues. “It is, functionally, an acknowledgement that the guidance itself is incomplete, and that the real regulatory framework for any given basket trial will be negotiated in Type B meetings, not derived from published doctrine.”

The article cautions that sponsors who view the consultation sentence as reassurance are misreading it. “Sponsors who treat it as a starting gun for early engagement, submitting detailed basket design rationales in pre-IND meetings before a single patient is enrolled, will build the precedent that eventually becomes the guidance update the field actually needs,” it concludes. “Within 18 months, the first NDA or BLA submission on a non-oncology basket trial Phase 1 foundation will force FDA’s hand. Either the agency will accept the cross-basket safety synthesis as sufficient for Phase 2 dose selection, establishing a workable precedent, or it will issue a Complete Response Letter that resets the field’s expectations about what basket architecture can carry into registration. The sponsors who have already had those Type B communications will be protected. The ones relying on the 2022 guidance to do the regulatory heavy lifting will not be ready for what comes back.”

Read more