The FDA has an accelerated approval mechanism for new drugs. Is
accelerated FDA approval a good thing? Probably Yes. This mechanism of approval
was put into place to help patients who suffer from certain serious diseases.
As the phrase suggests accelerated FDA approval involves a faster
approval than for non-accelerated approvals. To get an accelerated approval
sponsors must submit their application to the FDA. Before an application is
accepted for approval, two major regulatory tests described below are
applied.
THE DRUG HAD TO TARGET SERIOUS CONDITIONS
What is a serious condition? If you are a patient almost every
disease would be a serious condition. The FDA has clarified this in a guidance
document.
This is a disease or condition which has significant impacts on a
person's day-to-day ability to function or even die.
Clinical judgment has to be made in determining whether a disease
is serious or not.
The judgment is based on the impact of the disease on factors such
as the patients' survival and day-to-day functioning. In addition, an
assessment is made on the likelihood that the disease will progress to a more
severe condition if no treatment is provided.
There are other three pathways for expedited approval of NDA which
require establishment of serious condition. They include fast track,
breakthrough therapy and priority review.
All diseases that are life threatening qualify as serious illnesses
but not necessarily for accelerated FDA approval as we will see later. Some
will qualify for fast track, breakthrough therapy and priority review but not
for accelerated approval.
THE DRUG HAD TO BE FOR AN UNMET MEDICAL NEED
The term "unmet t Medical Need" is used to refer to a
medical condition that does not have adequate treatment or diagnosis. It may be
for treatment of cancer or a method for better and faster diagnosis of a
serious illness. The application of the term "unmet medical need"
could be quite broad.
The term "unmet medical need" could be used where there
is no available appropriate treatment to the patients. Sometimes a new therapy
may be available but unmet medical need may still exist such as when the new
reduces the symptoms but not the serious outcome such as progressive disability
or progression of the illness.
WHAT THE SPONSOR SHOULD DO
Because many sponsors may want to use accelerated FDA approval,
certain pre-qualification criteria have been put into place.
As the accelerated FDA approval application is based on surrogate
endpoints. Sponsors should ordinarily discuss with the FDA of the intention to
request for accelerated approval.
The request would help the sponsor to choose the best surrogate
endpoints during the clinical trials. Surrogate endpoints are endpoints other
than clinical endpoints which take longer to determine for diseases that take
long to show a clinical endpoint.
For example, it might take long to show that a drug prolongs life.
Prolongation of life is a clinical endpoint. Decrease in the blood in viral
load such as in HIV would be a surrogate endpoint.
Surrogate endpoints include laboratory measurements and images
among others. The use of clinical endpoints is however required in the confirmatory
clinical trial reports.
By the time this application is being submitted the sponsor should
be in a position to discuss the confirmatory clinical trials which should be in
progress.
Without evidence of these confirmatory trials the FDA may be
reluctant to approve the requested accelerated FDA approval. The risk to
patients is exposure to expensive drugs which may offer no clinical benefits.
The sponsor must provide evidence for commitment to complete the pending
confirmatory trials.
Does Canada have a similar program to accelerated FDA approval? The
Canadian equivalence is called priority review. In this program the sponsor is encouraged to request for priority
review status early. The sponsor will get a notice of compliance status with
conditions after the application when the only data available is from surrogate
end-points.
The target review period is 200 days. Just as in USA, the sponsor
has to submit confirmatory clinical trial data for full compliance without
conditions.