Transcript FDASIA - Rare Disease Legislative Advocates

Rare Diseases and FDASIA
Gayatri R. Rao MD, JD
Director
Office of Orphan Products Development (OOPD), FDA
Rare Disease Congressional Caucus Briefing
November 14, 2012
Where in the FDA?
Office of the
Commissioner
(OC)
OO
OF
OMPT
OGROP
Office of
Operations
Office of Foods
Office of Medical
Products and
Tobacco
Office of Global
Regulatory
Operations &
Policy
OSMP
Office of Special
Medical Programs
OOPD
CDER
Center for
Drug
Evaluation
and Research
Office of Orphan
Products
Development
RDP
Rare Diseases
Program
CBER
Center for
Biologics
Evaluation and
Research
CDRH
CTP
Center for
Devices and
Radiological
Health
Center for
Tobacco
Products
For Complete FDA Organizational Chart see:
http://www.fda.gov/downloads/AboutFDA/CentersOffices/Orga
nizationCharts/UCM288864.pdf
Office of the
Commissioner
Step 1:
Orphan Drug
Designation
(OC)
OSMP
OOPD
Office of Special
Medical Programs
OMPT
Office of Medical
Products and
Tobacco
Office of Orphan
Products
Development
Humanitarian Use
Device (HUD)
Designation
CDER
Center for Drug Evaluation
and Research
CBER
Center for Biologics
Evaluation and Research
For Complete FDA Organizational Chart see:
http://www.fda.gov/downloads/AboutFDA/CentersOffices
/OrganizationCharts/UCM288864.pdf
CDRH
Center for Devices and
Radiological Health
Step 2:
Marketing Application NDA / BLA / HDE
What is the Advantage to Designation?
• When a drug or biological product is designated an orphan,
certain financial incentives can flow:
– Tax Credits – 50% of clinical trials costs
– Waiver of User Fees - $1.9 M
– 7-year Marketing Exclusivity
• When a device is designated as a HUD, device is eligible for
an alternate pathway to market – Humanitarian Device
Exemption (HDE)
– Exempt from an effectiveness showing; in lieu need only show
probable benefit
Orphan Drug Highlights
Designations
~ 3700 Designation requests received
~ 2550 Products granted designation (~70%)
Approvals
>400 Drugs brought to market
FY 2011 – 26; FY 2012 (to date) – 17
Number of Orphan Designations and Approvals
250
Designations
Approvals
200
150
100
50
0
83 84 85 86 87 88 89 90 91 92 93 94 95 9 6 97 98 99 00 01 02 03 04 05 06 07 08 0 9 10 11
Year
Size of Populations (1983-2011)
500
Number of Designations and Approvals
450
400
Designations
Approvals
350
300
250
200
150
100
50
0
0-9 10-19 20-29 30-39 40-49 50-59 60-69 70-79 80-89 90-99 100- 110- 120- 130- 140- 150- 160- 170- 180- 190- 200 &
109 119 129 139 149 159 169 179 189 199
up
US prevalence (in thousands) of diseases for which products received an orphan designation
HUD Designation Program
Total
2011
# of HUDs
Received
283
21
# of HUDs
Designated
183
(65%)
17
# of HDEs
Approved
Devices labeled for peds
Berlin Heart EXCOR®
Pediatric Ventricular Assist
Device (VAD)
(majority rec’d in 2011)
56
6
NeuRx DPS™, Diaphragm
Pacing System
3 labeled for peds
1 funded by OPG pgm
Elana Surgical Kit
Source: OOPD Database
2012 – To date
20 HUDs received
12 HUDs designated
Berlin Heart EXCOR® Pediatric
VAD received 3-year funding
for ~$1.19M which funded a
pivotal study in support of
HDE approval
FDASIA and PDUFA Performance Goals:
Provisions Related to Rare Diseases
• Expedited Approval for Serious or LifeThreatening Diseases/ Conditions
– Accelerated Approval
– Breakthrough Therapies
•
•
•
•
•
External Experts
Patient-Focused Drug Development
Rare Pediatric Disease Voucher Program
Meetings and Guidance Development
Humanitarian Device Exemptions
Reauthorization of
Grants:
1. Orphan Products
Grant Program $30M/year
2. Pediatric Devices
Consortia Grant
Program $5.25M/year
Expedited Approval for Serious or LifeThreatening Diseases/ Conditions:
Accelerated Approval
• Based on a determination that the product has an effect
on a:
– Surrogate endpoint that is reasonably likely to predict clinical
benefit OR
– Clinical endpoint that can be measured earlier than irreversible
morbidity or mortality, that is reasonably likely to predict effect
on irreversible morbidity or mortality or other clinical benefit
• Takes into account severity, rarity, or prevalence, as well
as lack of alternative treatments
Expedited Approval for Serious or LifeThreatening Diseases/ Conditions:
Breakthrough Therapy
• Designate drug as a breakthrough therapy if:
– Intended to treat a serious or life-threatening disease/condition
AND
– Preliminary clinical evidence indicates that drug may
demonstrate substantial improvement over existing therapies on
1 or more clinically significant endpoints
• Submit request for designation with original IND or
later
• If designated:
– Eligible for everything Fast Track receives
– Also get more interactive involvement with review division to
help guide efficient yet scientifically appropriate trial design
10
External Experts
• Ensure that opportunities exist for consultations with
stakeholders for topics, including for example:
– Severity of rare diseases
– Unmet medical need associated with rare diseases
– Willingness and ability of individuals with a rare disease to
participate in clinical trials
– Assessment of benefits and risks of therapies to treat rare
diseases
• Develop and maintain a list of external experts for
consultation
11
Patient-Focused Drug Development
• FDA to conduct 20 meetings on different disease areas to
obtain patient perspective on disease severity or unmet
medical need
– Sept. 24, 2012 – Published a preliminary list of nominated
disease areas and the criteria used for nomination
• Included rare diseases (e.g., sickle cell disease, amyloidosis,
hereditary angioedema)
– Oct. 10, 2012 - Kicked off bi-monthly process consultation
meetings
– Oct. 25, 2012 – Open public meeting to discuss the proposed set
of disease areas
Rare Pediatric Disease Priority Review Vouchers
• Similar to the Tropical Disease Priority Review Voucher
Program
• Uses priority review vouchers as an incentive to develop
drugs and biologics for “rare pediatric diseases”
• Authorized until “the last day of the 1-year period that
begins on the date that FDA awards the third rare
pediatric disease priority voucher”
13
Meetings and Guidance
• Public Meetings
– Issues in clinical trials for drugs for rare diseases (e.g., endpoint
selection, use of surrogate endpoints, patient reported outcomes)
– Ways to encourage/accelerate development of new therapies for
pediatric rare diseases
• Guidance Development
– PDUFA Performance Goal (IX.E.): FDA, on an ongoing basis, will
develop guidance to address issues to facilitate development of
drugs for rare diseases (e.g., study design, endpoints, statistical
analysis, etc.)
– FDASIA provisions related to accelerated approval, breakthrough
therapies, etc. likewise call for guidance development
Humanitarian Device Exemption
• Expands profit-making to HDE devices that
– Don’t occur in pediatrics OR
– Occurs in pediatrics in such number that development of device
is “impossible, highly impracticable, or unsafe“
• Changes the definition of annual distribution number
(ADN)
– Equals the # of devices needed to treat/diagnose/cure 4,000
individuals
15
Questions?
For more information on OOPD’s programs, check out
www.fda.gov/orphan