PhRMA’s 4 Open FDARA Implementation Issues

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Pharmaceutical Research and Manufacturers of America (PhRMA) says there are four key, open FDA Reauthorization Act (FDARA) implementation issues that FDA should address. In its comment letter submitted to the docket for the Pediatric Oncology Subcommittee 5/22 meeting to discuss perspectives relating to implementation of FDARA, PhRMA identifies the issues as:

  • clarifying the evidentiary standard that it applies to determine if a molecular target is “substantially relevant” to the growth or progression of a pediatric cancer;
  • confirming that an applicant may submit, but is not obligated to generate, nonclinical data to inform a substantial relevance determination;
  • establishing a time-bound process for deciding whether the molecularly targeted pediatric cancer investigation requirement applies to an application; and
  • confirming the inapplicability of the traditional Pediatric Research Equity Act assessment requirement to an orphan-designated indication for which the molecularly targeted pediatric investigation requirement does not apply.

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