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Accelerated Approvals in Oncology A 10 - Year Experience. Purpose. Review past accelerated approvals Discuss current progress of associated phase 4 commitments Solicit input for improving the process. Outline. Oncology product AA from CDER and CBER Regulatory background
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Purpose • Review past accelerated approvals • Discuss current progress of associated phase 4 commitments • Solicit input for improving the process
Outline • Oncology product AA from CDER and CBER • Regulatory background • Approvals based on controlled trials lacking a concurrent comparator • Approvals based on randomized studies • Converted indications • Issues for the committee
Overview • 19 NDAs or BLAs for new treatment indications (involving 16 drugs) • Seven within l8 months of meeting invitation • Subsequent full approval in 4 • Remaining 8 to be presented over next two days
Regulatory Basis - Subpart H (21CFR 314) • For serious or life-threatening diseases • Where the drug appears to provide benefit over available therapy • Approval based on a surrogate that is reasonably likely to predict clinical benefit
21CFR314 (continued) • Subject to the requirement that the applicant verify and describe benefit • Post-marketing studies would usually be underway • The applicant shall carry out such studies with due diligence
Endpoints in Oncology • Survival and improvement in patient reported symptoms considered clinical benefit • Objective Response Rate and Time to Progression usually viewed as surrogates • RR representing benefit: relatively non-toxic products such as hormonal therapies or some biologics
Endpoints Utilized • No concurrent comparator : ORR • Randomized setting : Cytologic response, number of polyps, ORR, TTP, DFS, LVEF ; CHF
Uncertainty of Benefit to Ultimate Outcome • Amifostine (Ethyol) • Dexrazoxane (Zinecard) • Anastrozole (Arimidex) • Imatinib mesylate (Gleevec) • first-line CML
Protocol Issues • Has accrual been satisfactory ? • If not, what strategies can address this ? • Have changing circumstances impeded the conduct of a planned trial ? • If so, what alternative designs should be contemplated ?