Stakeholders Seek Changes in Effectiveness Guidance

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Stakeholders are asking FDA to consider making changes to a draft guidance on demonstrating substantial evidence of effectiveness for human drug and biological products. The Biotechnology Innovation Organization says that the agency should combine the draft with existing guidance on effectiveness. It also says the guidance (1) should more clearly indicate FDA flexibility around data and/or evidence from a range of sources for demonstrating substantial evidence of effectiveness; (2) should include a reference to the use of patient experience data in the context of demonstrating substantial evidence of effectiveness; (3) could benefit from examples that are relevant to CBER-regulated products; and (4) should reflect flexibility for the full range of therapies and patients.

Regeneron says drafting of the guidance “is a step in the right direction in enhancing industry understanding of agency expectations with regard to demonstrating substantial evidence of effectiveness and also modernizing the 1998 guidance.” The company says the draft also presents an opportunity to provide more concrete recommendations that may assist sponsors in designing trials and development programs that are more scientifically sound when demonstrating substantial evidence.

Finally, Flatiron Health says the document “provides much-needed agency guidance on the flexibility in the amount and type of evidence needed to meet the substantial evidence standard to ensure patients have timely access to safe and effective drugs, and better reflects the current drug development paradigm to address unmet medical needs, rare diseases, and therapies targeting disease subsets, especially for oncology. This flexibility is important due to ethical concerns and feasibility challenges unique to certain disease areas presenting unmet medical need, as FDA recognizes in the draft guidance.”

All comments also include specific line-by-line recommendations.

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