FDA Often Wants More Studies for 2-Drug Combos: Blog

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While it may seem that fewer Phase 2 and 3 studies would be needed for a fixed-dose drug-drug combination product using two drugs that have already been approved, in fact they often require more studies than single component products, according to a Camargo Pharmaceutical Services 505(b)(2) Blog post. Camargo product ideation consultant Angela Drew writes that of the 93 drug-drug combination products in Camargo’s proprietary 505(b)(2) database for which approval data are available, 63 required at least one Phase 2 or 3 study and 28 required more than four Phase 2/3 studies.

“In many cases,” Drew says, “additional studies beyond those required for the original approvals of the two component drugs are required because FDA must apply what is commonly referred to as the combination rule. This regulations states that ‘two or more drugs may be combined in a single dosage form when each component makes a contribution to the claimed effects and the dosage of each component (amount, frequency, duration) is such that the combination is safe and effective for a significant patient population requiring such concurrent therapy as defined in the labeling for the drug.’”

Proving that each component contributes to the safety or efficacy of the product typically requires a multi-factorial study in which each component is compared separately and in combination to a placebo control.

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