Prior Decisions Should Guide New Drug Reviews: Researchers
Researchers from FDA and Stanford University say the agency has no mechanism to find or tradition to cite similar cases when weighing evidence for drug approvals, resulting in “standalone, bespoke decisions.” Writing in the Annals of Internal Medicines, the researchers say that as a result, FDA’s decisions show highly variable criteria for “substantial evidence” when flexible evidential criteria are used.
“A precedential tradition and suitable information system are required for FDA to improve institutional memory and build upon past decisions,” the authors conclude. “These would increase FDA’s decisional transparency, consistency, and predictability, which are critical to preserving FDA’s most valuable asset, the public’s trust.”
The researchers looked at 912 drug applications submitted between 2013 and 2018, with 117 requiring multiple reviews. Of the 117, 22 were initially rejected because clinical efficacy was deemed inadequate for various reasons, including disagreement between FDA and the applicant about clinical meaningfulness of the findings, inconsistent results, and deficiencies of data integrity or statistical analysis.
Some were approved after submission of new pivotal studies, the report says, and others after clarification of inconsistent results. Eight were approved by an FDA division director despite unresolved issues. Occasionally, it says, approval followed shifting the application to a different FDA division without any change in the evidence.
In a companion report, Joel Perlmutter from the Washington University in St. Louis School of Medicine says the research is an important first step “in trying to demystify the actions of FDA.” He says prospective rules for transparency must be developed and followed. He also says that breaking the “financial tether” between FDA and industry would help ensure independence.