ICER Questions Diversity Action Plan Goal
The Institute for Clinical and Economic Review (ICER), a private, independent, nonprofit research institute, says that while it applauds FDA’s continued effort to create policies and guidance to enhance greater diversity in clinical trials, it is concerned about the stated intended goal of a draft guidance on diversity action plans to improve enrollment of participants from under-represented populations in clinical studies. The ICER comment letter says the guidance’s goal is to “increase the enrollment of participants from historically under-represented populations in clinical studies to help improve the strength and generalizability of the evidence for the intended population.”
ICER says the goal runs the risk of equating a lack of diversity in clinical trials to a lack of generalizability, when in many cases there is no heterogeneity in treatment effects based on factors such as race, ethnicity, and sex, that are evaluated in clinical trial diversity. “This intended goal may have a negative impact on how the evidence from clinical trials is perceived in practice,” the letter says. “Furthermore, while the target enrollment commonly set to achieve adequate clinical trial diversity may have some implications for assessing potential treatment differences between subgroups, these are often hypothesis-generating due to the small sample sizes and should not be the key goal of improving clinical trial diversity.”
The letter also has specific comments on sections of the guidance.