Technical Suggestions on FDA Myeloid Leukemia Guidance

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AbbVie says that an FDA draft guidance, Acute Myeloid Leukemia: Developing Drugs and Biological Products for Treatment, would be most useful if the agency modified it to include instructions on analysis of best/overall response in the presence of post-study treatment. The company comment letter says, for example, the guidance could indicate that data collected after post-study treatment will not be included in the analysis of the best/overall response.

Novartis says FDA should consider adding the Estimand framework and its application to acute myeloid leukemia. The company acknowledges the coordinated approach on defining the elderly and unfit acute myeloid leukemia populations and asks the agency to consider opening the definition to allow alignment of the population with current practice as it is likely to evolve as more knowledge is available and additional treatments become available.

Both AbbVie and Novartis provided specific comments in addition to their general recommendations. Specific technical comments also were submitted by Regeneron, Pfizer, Otsuka, and Janssen.

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