FDA Seeks New Accelerated Approval Requirement
FDA may be raising the bar for sponsors seeking accelerated approval by requesting that they be “well underway with their Phase 3 confirmatory trial and ideally fully enrolled.” At least, that is the requirement the agency laid out for ADC Therapeutics during a meeting to discuss a potential accelerated approval BLA filing for Cami (camidanlumab tesirine) and its use in relapsed or refractory Hodgkin lymphoma (HL).
Requiring sponsors to have their confirmatory trials well underway at the time of initial submission was a goal FDA supported as an accelerated approval reform provision during the recent user fee reauthorization. It and other reform provisions were abandoned by lawmakers when they ran out of time as the user fee programs were set to expire 9/30 (see earlier story).
Last month, FDA commissioner Robert Califf revived his previous support for revamping the drug accelerated approval program. Delivering remarks at the 2022 National Organization for Rare Disorders (NORD) Breakthrough Summit in Washington, DC, Califf said improvements in the accelerated approval program are needed as soon as possible. Califf acknowledged then that the program’s biggest fault is probably companies being “too focused on just the acceleration and not enough on the evidence that’s needed to fill in that gap between when approval occurs and when you need the definitive evidence that the treatment fulfills its promise.” He said he supported user fee provisions, such as requiring sponsors to have a confirmatory trial underway at the time of approval, and additional authorities to more efficiently deal with companies who don’t fulfill their confirmatory evidence requirements.
In ADC’s case, the company met with agency officials in September to discuss a BLA based on recent Phase 2 data, which demonstrated an overall response rate of 70% and a complete response rate of 33%. After being presented with the confirmatory trial stipulations, the company says now it will not submit the BLA for Cami next year, as it is estimated that it would take at least two years to fully enroll a randomized confirmatory Phase 3 study. “The company is engaged with the FDA in an ongoing and constructive dialog regarding their guidance and the potential regulatory path forward,” it says. “At this time, the company is pausing any material investments in the HL program and will evaluate options for Cami in HL with a disciplined and strategic approach to resource allocation.”