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【小白说】FDA四条“特别审批通道”

 tina360tina 2018-01-26


近期朋友和小编,在《药物一致性评价》公共号平台,推出特别栏目,名字为【小白说】,既是小白的学习笔记,也是跟大家共同交流的话题。同时欢迎各位大牛,小白提供话题讨论。



FDA四条“特别审批通道”

小白整理自网络

FDA有三条特别审批通道,即快速通道(Fast Track)、优先审评(Priority Review)、加速批准(Accelerated Approval)。
    201279日,《FDA安全与创新法案》(Food and Drug Administration Safety and Innovation Act)正式实施,FDA第四条特别审批通道诞生,即突破性药物(Breakthrough Therapies)。
    进入特别通道的条件有两个,即目前无有效药物(no current therapy),新药能填补空白(first available treatment),或者新药在有效性或安全性上有明显优势(have advantages over existing treatments)。

 

审批通道

FDA定义

Fast track

Fast track is a process designed to  facilitate the development, and expedite the review of drugs to treat serious  conditions and fill an unmet medical need.

Accelerated  Approval

These regulations allowed  drugs for serious conditions that filled an unmet medical need to be approved  based on a surrogate endpoint.

Priority  Review

A Priority Review  designation means FDA’s goal is to take action on an application within 6  months.

Breakthrough  Therapy

A process designed to  expedite the development and review of drugs which may demonstrate substantial  improvement over available therapy.


快速通道(Fast Track
   
由制药企业主动申请(可以在药物研发的任何阶段),FDA在收到申请后6个月内给出答复。对于进入快速通道的药物,FDA将进行早期介入,就哪些试验该、做哪些试验可以不做等内容提出指导意见,以达到让该产品在研发过程中少走弯路,加快整个研发过程的效果。另外,药企还可分阶段递交申报资料,而不需要一次性递交全部材料才进行审评。
加速批准(AcceleratedApproval
   
药物临床试验拿到clinical outcome需要很长时间,在1992FDA引入加速批准通道,用surrogate endpoint代替clinical endpoint,先批准后验证,如果上市后验证了临床疗效,则FDA维持原先的批准。例如抗癌药的clinical endpoint是增加患者的生存率或延长存活时间,但直接拿到这样的临床结论需要很长的时间,这时可以采用surrogate endpoint替代,即研究肿瘤的萎缩程度。如果药物能缩小肿瘤,那么基本可以认定它能延长患者存活时间。
优先审评(Priority Review
   
优先审评不仅针对严重疾病(serious diseases),也适用于普通疾病(less serious illnesses),能否进入优先审评的关键在于是否有优于现有治疗手段的潜力(have the potentialto  provide significant advances in treatment)。优先审评需药企主动申请,FDA将在45天内给出答复。与快速通道、加速批准不同的是,优先审评只针对审评阶段,而不加速临床试验。根据Prescription Drug User Act,快速审评的周期为6个月,而标准审评(Standard Review)周期为10个月。

突破性药物(BreakthroughTherapies
    “
突破性药物资格申请一般与IND一同提交,或者作为补充文件提交,FDA在收到申请60天内给予答复。FDA不会公开申请者名单,也不会公布授予突破性药物资格的名单,因为FDA不能公开IND信息。
    “
突破性药物的认定需满足两个条件,即(1)适应症是严重或致死性疾病(serious or life-threateningdisease or condition),(2)有证据显示在某一重要临床终点上明显优于现有药物(substantial improvement over existing therapies)。突破性药物快速通道几乎一模一样,都是为了加速严重或致死性疾病药物的研发与审批,而不同点在于取得认定所需要提供的证据。FDA的原话为:
    A breakthrough therapy program is fora drug that treats a serious or life-threatening condition and preliminaryclinical evidence indicates that the drug may demonstrate substantialimprovement on a clinically significant endpoint(s) over available therapies.
    A fast track program is for a drugthat treats a serious or life-threatening condition, and nonclinical orclinical data demonstrate the potential to address unmet medical need. Fillingan unmet medical need is defined as providing a therapy where none exists orproviding a therapy which may be potentially superior to existing therapy.
     “
突破性药物的认定比快速通道更加严格,享有快速通道的所有权利,能得到FDA更加密切的指导,当然如果一个药物获得了突破性药物就不需要再申请快速通道。如果一个药物申请突破性药物失败,FDA不会自动启动快速通认定程序,研发单位需要重新申请。



FDA原文:

Fast Track

Fast track is a processdesigned to facilitate the development, and expedite the review of drugs totreat serious conditions and fill an unmet medical need. The purpose is to getimportant new drugs to the patient earlier. Fast Track addresses a broad rangeof serious conditions.

Determining whether acondition is serious is a matter of judgment, but generally is based on whetherthe drug will have an impact on such factors as survival, day-to-dayfunctioning, or the likelihood that the condition, if left untreated, willprogress from a less severe condition to a more serious one. AIDS, Alzheimer’s,heart failure and cancer are obvious examples of serious conditions. However,diseases such as epilepsy, depression and diabetes are also considered to beserious conditions.

Filling an unmetmedical need is defined as providing a therapy where none exists or providing atherapy which may be potentially better than available therapy.

Any drug beingdeveloped to treat or prevent a condition with no current therapy obviously isdirected at an unmet need. If there are available therapies, a fast track drugmust show some advantage over available therapy, such as:

  • Showing superior effectiveness, effect on serious outcomes or     improved effect on serious outcomes

  • Avoiding serious side effects of an available therapy

  • Improving the diagnosis of a serious condition where early     diagnosis results in an improved outcome

  • Decreasing a clinical significant toxicity of an available     therapy that is common and causes discontinuation of treatment

  • Ability to address emerging or anticipated public health need

A drug that receives FastTrack designation is eligible for some or all of the following:

  • More frequent meetings with FDA to discuss the drug's     development plan and ensure collection of appropriate data needed to     support drug approval

  • More frequent written communication from FDA about such things     as the design of the proposed clinical trials and use of biomarkers

  • Eligibility for Accelerated Approval and Priority Review,     if relevant criteria are met

  • Rolling Review, which means that a     drug company can submit completed sections of its Biologic License     Application (BLA) or New Drug Application (NDA) for review by FDA, rather     than waiting until every section of the NDA is completed before the entire     application can be reviewed. BLA or NDA review usually does not begin     until the drug company has submitted the entire application to the FDA

Fast Track designation must be requested by the drug company. The request canbe initiated at any time during the drug development process. FDA will reviewthe request and make a decision within sixty days based on whether the drugfills an unmet medical need in a serious condition.

Once a drug receives FastTrack designation, early and frequent communication between the FDA and adrug company is encouraged throughout the entire drug development and reviewprocess. The frequency of communication assures that questions and issues areresolved quickly, often leading to earlier drug approval and access bypatients.

Breakthrough Therapy

Breakthrough Therapydesignation is a process designed to expedite the development and review ofdrugs that are intended to treat a serious condition and preliminary clinicalevidence indicates that the drug may demonstrate substantial improvement overavailable therapy on a clinically significant endpoint(s).

To determine whetherthe improvement over available therapy is substantial is a matter of judgmentand depends on both the magnitude of the treatment effect, which could includeduration of the effect, and the importance of the observed clinical outcome. Ingeneral, the preliminary clinical evidence should show a clear advantage overavailable therapy.

For purposes ofBreakthrough Therapy designation, clinically significant endpoint generallyrefers to an endpoint that measures an effect on irreversible morbidity ormortality (IMM) or on symptoms that represent serious consequences of thedisease. A clinically significant endpoint can also refer to findings thatsuggest an effect on IMM or serious symptoms, including:

  • An effect on an established surrogate endpoint

  • An effect on a surrogate endpoint or intermediate clinical     endpoint considered reasonably likely to predict a clinical benefit (i.e.,     the accelerated approval standard)

  • An effect on a pharmacodynamic biomarker(s) that does not meet     criteria for an acceptable surrogate endpoint, but strongly suggests the     potential for a clinically meaningful effect on the underlying disease

  • A significantly improved safety profile compared to available     therapy (e.g., less dose-limiting toxicity for an oncology agent), with     evidence of similar efficacy

A drug that receivesBreakthrough Therapy designation is eligible for the following:

  • All Fast Track designation features

  • Intensive guidance on an efficient drug development program,     beginning as early as Phase 1

  • Organizational commitment involving senior managers

Breakthrough Therapydesignation is requested by the drug company. If a sponsor has not requestedbreakthrough therapy designation, FDA may suggest that the sponsor considersubmitting a request if: (1) after reviewing submitted data and information(including preliminary clinical evidence), the Agency thinks the drugdevelopment program may meet the criteria for Breakthrough Therapy designationand (2) the remaining drug development program can benefit from thedesignation.

Ideally, a BreakthroughTherapy designation request should be received by FDA no later than theend-of-phase-2 meetings if any of the features of the designation are to beobtained. Because the primary intent of Breakthrough Therapy designation is todevelop evidence needed to support approval as efficiently as possible, FDAdoes not anticipate that Breakthrough Therapy designation requests will be madeafter the submission of an original BLA or NDA or a supplement. FDA willrespond to Breakthrough Therapy designation requests within sixty days ofreceipt of the request.

Accelerated Approval

When studying a newdrug, it can sometimes take many years to learn whether a drug actuallyprovides a real effect on how a patient survives, feels, or functions. Apositive therapeutic effect that is clinically meaningful in the context of agiven disease is known as “clinical benefit”. Mindful of the fact that it maytake an extended period of time to measure a drug’s intended clinical benefit,in 1992 FDA instituted the Accelerated Approval regulations. Theseregulations allowed drugs for serious conditions that filled an unmet medicalneed to be approved based on a surrogate endpoint. Using a surrogate endpointenabled the FDA to approve these drugs faster.

In 2012, Congresspassed the Food and Drug Administration Safety Innovations Act (FDASIA).Section 901 of FDASIA amends the Federal Food, Drug, and Cosmetic Act (FD&CAct) to allow the FDA to base accelerated approval for drugs for seriousconditions that fill an unmet medical need on whether the drug has an effect ona surrogate or an intermediate clinical endpoint.

A surrogate endpointused for accelerated approval is a marker - a laboratory measurement,radiographic image, physical sign or other measure that is thought to predictclinical benefit, but is not itself a measure of clinical benefit. Likewise, anintermediate clinical endpoint is a measure of a therapeutic effect that isconsidered reasonably likely to predict the clinical benefit of a drug, such asan effect on irreversible morbidity and mortality (IMM).

The FDA bases itsdecision on whether to accept the proposed surrogate or intermediate clinicalendpoint on the scientific support for that endpoint. Studies that demonstratea drug’s effect on a surrogate or intermediate clinical endpoint must be“adequate and well controlled” as required by the FD&C Act.

Using surrogate orintermediate clinical endpoints can save valuable time in the drug approvalprocess. For example, instead of having to wait to learn if a drug actuallyextends survival for cancer patients, the FDA may approve a drug based onevidence that the drug shrinks tumors, because tumor shrinkage is considered reasonablylikely to predict a real clinical benefit. In this example, an approvalbased upon tumor shrinkage can occur far sooner than waiting to learn whetherpatients actually lived longer. The drug company will still need to conductstudies to confirm that tumor shrinkage actually predicts that patients willlive longer. These studies are known as phase 4 confirmatory trials.

Where confirmatorytrials verify clinical benefit, FDA will generally terminate the requirement.Approval of a drug may be withdrawn or the labeled indication of the drugchangedif trials fail to verify clinical benefit or do not demonstratesufficient clinical benefit to justify the risks associated with the drug(e.g., show a significantly smaller magnitude or duration of benefit than wasanticipated based on the observed effect on the surrogate).

Priority Review

Prior to approval, eachdrug marketed in the United States must go through a detailed FDA reviewprocess. In 1992, under the Prescription Drug User Act (PDUFA), FDA agreed tospecific goals for improving the drug review time and created a two-tieredsystem of review times – Standard Review and Priority Review.A Priority Review designation means FDA’s goal is to take action on anapplication within 6 months (compared to 10 months under standard review).

A Priority Review designationwill direct overall attention and resources to the evaluation of applicationsfor drugs that, if approved, would be significant improvements in the safety oreffectiveness of the treatment, diagnosis, or prevention of serious conditionswhen compared to standard applications.

Significant improvementmay be demonstrated by the following examples:

  • evidence of increased effectiveness in treatment, prevention,     or diagnosis of condition;

  • elimination or substantial reduction of a treatment-limiting drug     reaction;

  • documented enhancement of patient compliance that is expected     to lead to an improvement in serious outcomes; or

  • evidence of safety and effectiveness in a new subpopulation.

FDA decides on thereview designation for every application. However, an applicant may expresslyrequest priority review as described in the Guidance for Industry ExpeditedPrograms for Serious Conditions – Drugs and Biologics. It does not affect thelength of the clinical trial period. FDA informs the applicant of a PriorityReview designation within 60 days of the receipt of the original BLA, NDA, orefficacy supplement. Designation of a drug as “Priority” does not alter thescientific/medical standard for approval or the quality of evidence necessary.

 

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