Firms Seek Broad Extrapolation for Pediatric IBD Dosing
Joint comments from AbbVie, Genentech, and Johnson & Johnson on a draft guidance about pediatric inflammatory bowel disease (IBD) drug development question why FDA does not allow broader use of extrapolating adult data to determine an appropriate dose for pediatric patients. “We recommend that the agency re-evaluate the need for routinely enrolling 100-120 pediatric study participants (ages 2 to 17 years) over two doses… ‘to inform the risk-benefit assessment’ for approval,” the comments say.
“Modeling and simulation and other appropriate methods can be used to identify the appropriate dose for pediatric patients,” the companies continue. “We recommend FDA encourage use of these tools rather than fully powered clinical studies. Efficacy (benefit) may be extrapolated from adults with little uncertainty, and safety in adults (and often other pediatric populations) will inform the risk in adolescents and children…”
The recently released draft guidance, entitled Pediatric Inflammatory Bowel Disease: Developing Drugs for Treatment, provides agency recommendations about the necessary attributes of clinical studies for drugs being developed for the treatment of pediatric ulcerative colitis or pediatric Crohn’s disease, including study population, study design, efficacy considerations, and safety assessments.
“The recommendations for clinical study design in this guidance are based upon the assumption that a robust development program is being conducted in adults and that efficacy data from adults will be available to help inform the pediatric program and to support extrapolation of efficacy,” FDA says. “Sponsors seeking to develop a drug only for pediatric ulcerative colitis or Crohn’s disease patients in the absence of an adult program should meet with the appropriate review division to discuss their proposals.”
Additionally, the comments from the three companies also raise issues with FDA encouraging the inclusion of adolescent subjects in adult ulcerative colitis or Crohn’s disease clinical trials. “It is possible for sponsors to attempt this, but the agency should not expect to see large numbers of adolescents in Phase 3 studies that include placebo, due to unwillingness of sites to potentially expose such subjects to placebo, and the fact that many ex-U.S. countries do not allow enrollment of adolescents until efficacy and safety has been adequately demonstrated in adults,” they write.