Making NDA/BLA Development Meetings Better: Parexel

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Two Parexel executives write in a Life Science Leader online post that drug developers could make NDA/BLA development meetings with FDA staff more productive by adopting a framework for the discussion that helps them consider the advantages and disadvantages of every option, both with and without FDA advice. The executives say that problems in presubmission meetings can arise because the two sides have different aims.

“Sponsors would like guidance, and preferably certainty, on which development features will make their results acceptable to FDA reviewers,” they write. “Much is discussed in these meetings, but sponsors are primarily looking for what they must do to achieve regulatory approval…. On the other side of the table, FDA regulators generally view presubmission meetings and other interactions with sponsors as opportunities to brainstorm, head off bad ideas, or warn sponsors about potential pitfalls. They shy away from providing absolute clarity … in the hope that sponsors will attend to the broadest possible range of issues that could impact their development plan.”

The authors praise the FDA “Structured Approach to Benefit-Risk Assessment in Drug Regulatory Decision-Making” for its effort to provide transparency about risk-benefit calculations during the formal review of new drug applications by summarizing the relevant facts, uncertainties, and key areas of judgment and how those factors influence a regulatory decision.

They suggest that sponsors could get more out of presubmission meetings if they used a similarly structured advantages/disadvantages framework to map the decision space around important development questions and FDA responses, and show a hypothetical example of how such a framework might look.

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