Nearly 300 stakeholders from government, industry, academia and patient groups filled the FDA’s Great Room on November 19, 2018, for the Reagan-Udall Foundation’s public meeting on Leveraging Real-World Treatment Experience from Expanded Access (EA) Protocols.

  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols
  • Highlights from Leveraging Real-World Treatment Experience from EA Protocols

 

Foundation Board Chair Ellen Sigal welcomed the group, underscoring that the event represents the Foundation’s charge to advance science, innovation and collaboration, and stressing the importance of EA to patients who can’t get into clinical trials and are running out of options.

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Leveraging Real-World Treatment Experience from EA Protocols

FDA is advancing efforts to expand real-world data collection through digital technology and enhanced patient-reported outcomes, especially at the point of patient care. FDA Commissioner Scott Gottlieb announced a docket on the Federal Register for feedback on FDA’s newly proposed framework for regulating apps intended for use with prescription drugs. He also emphasized the agency’s partnership with the Foundation as a “critical component” of efforts to modernize the framework for drug development and review, highlighting how IMEDS leverages the Sentinel data “to support public health research and identify new approaches for reviewing safety signals.”

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EA Post Event Quote

Rachel Sherman, Principal Deputy Commissioner at FDA, reviewed with attendees what the FDA and the healthcare field learned about EA in the 1970s and 1980s, when faced with the HIV crisis and the need for very sick individuals to get quick access to investigational therapies, clearly stating that EA informs rather than hurts the development of drug therapies. She asserted that EA can save lives – both by providing earlier access and by providing very important data.

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Leveraging Real-World Treatment Experience from EA Protocols

Alison Bateman-House of NYU School of Medicine, Paul Melmeyer of NORD and Emil Kakkis of Ultragenyx and the EveryLife Foundation joined moderator Richard L. Schilsky of the Reagan-Udall Foundation Board to discuss Patient, Physician and Bioethics Perspectives.

Panelists agreed that:

  • Patients have a lot of useful information to share with drug companies and patient advocacy groups can be valuable to companies in the planning of EA and Clinical Trials programs
  • EA can increase health equity that’s not always inherent in clinical trials due to inclusion/exclusion criteria
  • Companies have an obligation to ensure unbiased, rigorous data collection from EA physicians and patients to extend safety for the next patient
  • Companies recognize the benefits of EA programs, but face hurdles such as product availability and cost of patient/physician support
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Leveraging Real-World Treatment Experience from EA Protocols

Representatives from industry emphasized that EA is not “one size fits all,” as programs differ for each drug candidate and need to be planned alongside clinical trials. Moderator Kay Holcombe of the Reagan-Udall Foundation Board explored how even small amounts of clinical data can be incredibly useful—especially in rare disease populations—with Novartis’ Paul Aliu, Amicus Therapeutics’ Jayne C. Gershkowitz, KSQ Therapeutics' David Meeker and Johnson & Johnson’s Joanne Waldstreicher.

Industry lessons included:

  • Important to collect data on a wide variety of patients, which can help inform payors as well as companies and regulators
  • Small companies have real limits, from breadth of experience to staff focus, that larger companies often do not experience
  • Companies should not wait to receive their first EA request before planning – it takes time to engage patient organizations as partners and to build relationships
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Leveraging Real-World Treatment Experience from EA Protocols

When moderator Andrew C. von Eschenbach, 20th FDA Commissioner, engaged with current FDA officials Jacqueline Corrigan-CurayRobert Temple and Peter Stein of the Center for Drug Evaluation and Research, Peter Marks from the Center for Biologics Evaluation and Research, and Amy McKee of the Oncology Center of Excellence, the message was clear: EA is an opportunity to enhance a drug’s regulatory package rather than threaten it. And, they are not looking to add more regulation, although the panel warned about the potential for irregularity in EA data collection not governed by stringent protocols. FDA approves 99% of the EA requests they receive. 

Their advice to companies was to: 

  • See the value of EA requests that can sometimes lead reviewers to suggest new avenues to explore
  • Recognize that adverse events in EA programs do not typically have a negative impact on regulatory review
  • Speak with FDA staff about EA data collection early in the planning process
  • Rethink some exclusions to possibly allow more diverse populations into clinical trials

Citing a good balance of both large and small company considerations, participants appreciated the "varied perspectives and constructive ideas"  as well as the "wide-ranging and well-informed discussion" around the important topic of EA. Read more in the Pink Sheet article

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