Praise for FDA Final PFDD Guidance

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Genentech says an FDA draft guidance on incorporating clinical outcome assessments into endpoints for regulatory decision-making “marks a critical milestone as the final installment in FDA’s patient-focused drug development (PFDD) methodological guidance series that aims to describe a sustainable path to incorporate patient input as data in medical product development and decision-making.” The company comment letter says, however, that the guidance discussion on how the meaningfulness of treatment benefit can be evaluated using meaningful score differences or meaningful score regions is overly complex and it is unclear how the two techniques relate to meaningful within-patient change or between-group change. “We are concerned that this will introduce unnecessary confusion and differences of interpretation amongst sponsors and reviewers, and will ultimately limit the uptake of PFDD methods and deter investment, development, validation, and acceptance of clinical outcome assessment data,” the company says.

In its comment, AbbVie says it appreciates the emphasis in the guidance series on providing an evidence-based rationale for incorporating patient experience data into medical product development, as well as the approach in this guidance to allow for greater flexibility in endpoint construction and score interpretation.

EMD Serono says the final guidance could benefit from a methodological elaboration on how best to weigh and consolidate the respective contributions of patients and their caregivers on study design elements and avoid considering the patient voice out of context. It also says the guidance could benefit from clarification on whether the meaningfulness of clinical outcome assessment endpoints is only from the patient’s perspective or from additional stakeholders, such as their caregivers, as well.

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