Suggestions for Oncology Accelerated Approval Guidance
The National Organization for Rare Disorders says it appreciates FDA efforts in a draft guidance on clinical trial considerations to support accelerated approval of oncology drugs “since the guidance, when finalized, will likely have far-reaching impacts on rare disease drug development well beyond oncology products.” The comment letter recommends:
- providing concrete guidance and best practices for effective confirmatory trial enrollment;
- providing more nuanced guidance on the effective and efficient use of single-arm trials and other external controls using real-world evidence;
- providing more guidance for the validation of surrogate or intermediate clinical endpoints in rare diseases and the intersections with the Rare Disease Endpoint Advancement pilot program; and
- creating an education campaign to demonstrate the history and efficiency of accelerated approval drugs.
Pharmaceutical Research and Manufacturers of America (PhRMA) says the guidance provides “concise recommendations on the design of clinical trials to support accelerated approvals in oncology.” The association urges the agency to consider how single-arm trials, including those using real-world data/real-world evidence and historical clinical trials for comparison, may be used in the context of oncology accelerated approval and address that issue in the final guidance. It further suggests that FDA address considerations for when using real-world data may be appropriate to verify clinical benefit. PhRMA also provides specific comments.