FDA Prodded to Improve Surrogate Endpoint Transparency

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A Federation of American Scientists (FAS) online paper calls for an interagency approach to increase transparency in validating surrogate endpoints used in FDA drug approvals. While FDA regularly updates its Table of Surrogate Endpoints That Were the Basis of Drug Approval or Licensure, FAS says, the table does not include information about the strength of evidence for each surrogate marker and its association with a clinical outcome.

“As surrogate markers are increasingly being accepted by FDA to support approval of new drugs and biologics,” the paper says, “it is imperative that patients and clinicians understand whether such novel endpoints are reflective of meaningful clinical benefits. Thus, FDA, in collaboration with other agencies, should take steps to increase transparency regarding the strength of evidence for surrogate endpoints used to support product approvals, routinely reassess the evidence behind such endpoints to continue justifying their use in regulatory decision-making, and sunset those that fail to show association with meaningful clinical outcomes.”

FAS recommends a three-step plan of action:

  • FDA should make more transparent the strength of evidence of surrogate markers included within the “Adult Surrogate Endpoint Table” and the “Pediatric Surrogate Endpoint Table”;
  • In collaboration with FDA, other federal research agencies should contribute evidence generation to determine whether surrogate markers are appropriate for use in regulatory decision-making, including approval of new therapeutic products and indications for use; and
  • Congress should build upon the provisions related to surrogate markers that passed as part of the 21st Century Cures Act of 2016 in their “Cures 2.0” efforts.

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