Combination Products at US FDA

Similar documents
Combination Products Determination and Review Processes: Impact of 21 st Century Cures Act and Recent FDA Initiatives

Plamena Entcheva-Dimitrov, PhD, RAC On-line Course.

Is FMT A Drug? Lance Shea, M.S., J.D. Washington Square, Suite Connecticut Ave., NW Washington, DC, D

Guidance for Industry and FDA:

Drug /Device Combinations: The Convergence of Pharmaceutical and Biomaterial Science

Science & Research. Frequently Asked Questions. 1 of 6 7/8/ :52 PM

Navigating the FDA, and understanding Medical Device Preemption. Special Counsel Foulston Siefkin

Copyright. Jeremiah J. Kelly (2015). All rights reserved. Further dissemination without express written consent strictly prohibited.

Regulation of Microbiota- Based Products

Introduction to the FDA. Historical Context. Changes over Time FDA - BE-200 9/23/2004. Copyright C. S. Tritt, Ph.D. 1

Drug-Device Combination Product Development: INDs for Device Companies

Draft Guidance for Industry, Clinical Laboratories, and FDA Staff. In Vitro Diagnostic Multivariate Index Assays

Paths to Market & FDA Product Lifecycle Regulation. Patricia Kaeding Design of Medical Devices University of Minnesota April 14, 2005

Laura Andrews, PhD, DABT, Fellow ATS

COMBINATION PRODUCTS A RECENT FDA PERSPECTIVE. Sugato De

CBER Regulation of Devices for Cell Therapy

Guidance for Industry

DRAFT GUIDANCE. This guidance document is being distributed for comment purposes only. Document issued on: July 14, 2011

Medical Device Accessories: Defining Accessories and Classification Pathway for New Accessory Types. Draft Guidance for Industry and

The Deemed to be a License Provision of the BPCI Act Questions and Answers Guidance for Industry

COMBINATION PRODUCTS. Karyn M. Campbell, Director Investigations Branch Philadelphia District Office Food and Drug Administration

The Children s Hospital of Philadelphia Committees for the Protection of Human Subjects Policies and Procedures Determination of IND/IDE Requirement

Nonproprietary Naming of Biological Products

FDA N-5319 VIA ELECTRONIC SUBMISSION. January 10, 2018

The FDA/CDRH Perspective in the Regulation of Surgical Mesh

Development of Regenerative Medicine Products: FDA Perspectives

Toxicology - Problem Drill 24: Toxicology Studies in Pharmaceutical Development

MOBILE MEDICAL APPLICATIONS REVIEWING FDA GUIDANCE FOR INDUSTRY USE

Role of Human Factors Engineering in Medical Products Regulatory Reviews and Research

INVESTIGATIONAL DEVICES & DRUGS. What is an IRB to do?

CDRH Device Approval

Guidance for Industry

Combination products Updates Final FDA Guidance

Molecular Diagnostics: The Shift to Complexity. Molecular Diagnostics Regulation: Where do we go from here? David W Feigal, Jr.

Comparative Study of Regulatory Requirements for Biologics Filing in United States and European Union

Summary of the Actions of the March Virtual House of Delegates. March 16-23, 2018

Combination Products: A 40 Year Regulatory Evolution

PHARM 532 Regulation of Pharmaceuticals II

FDA Update. Scott A. Brubaker, CTBS Director, Division of Human Tissues Office of Tissues and Advanced Therapies CBER/FDA

Nanosystems in regenerative medicine. Jöns Hilborn Materials Chemistry The Ångström Laboratory Uppsala University Sweden

Structure and Mandate of FDA

POLICY FOR RESEARCH INVOLVING DRUGS, BIOLOGICS OR DEVICES 6/1/2011

Draft Guidance for Industry and FDA Staff Premarket Notification [510(k)] Submissions for Medical Devices that Include Antimicrobial Agents

Risk Based Review and the Management of Residual Uncertainty in the Regulation of Biological Products

Interpretation of the Deemed to be a License Provision of the Biologics Price Competition and Innovation Act of 2009

HCT/P Regulation vs 361 Products

Overview of the FDA Approval Process for TB Diagnostics

CGMP Requirements for Investigational Products

Title: Department: Approved by: Director, Human Research Review and Compliance

Hot Topics in Drug Product Process Validation: A Reviewer s Perspective

The Device Side of Combination Products

FDA PLANS TO REGULATE TESTS AS DEVICES. August 2010 SPECIAL REPRINT. By Ellen Flannery and Scott Danzis

IRB APPLICATION OF FDA REGULATIONS Click for Animation

Guidance for Industry

An Introduction to Health Care: Agencies, Laws and Regulations

LUNCH AND LEARN. October 14, CE Activity Information & Accreditation

Office for Human Subject Protection. University of Rochester

Medical Product Communications That Are Consistent With the FDA-Required Labeling Questions and Answers Guidance for Industry

Bioresearch Monitoring Inspections in Vitro Diagnostics Devices

Point-of-Care Cell Processing Devices A Manufacturer s Perspective Clinical trials, regulatory compliance, and commercialization.

An Overview of FDA Regulation: What the Canadian Biomedical Industry Needs to Know

Postmarketing Safety Reporting and cgmp Requirements for Combination Products. Katlin McKelvie Backfield November 2, 2017

CDRH s Inspection Strategy for 2018: How it Will Impact Your Company

Regulatory Challenges of Combination Products in EU and US. Afternoon seminar, 24 January 2018 by COBIS and IWA Consulting

Presentation Outline

An Introduction to the Worldwide Regulatory Framework for Medical Devices. Elizabeth Malo M.S., Director, Regulatory Affairs

Overview of Biologics Testing and Evaluation: Regulatory Requirements and Expectations. Audrey Chang, PhD, Senior Director Development Services

Guidance for Industry Compounding Animal Drugs from Bulk Drug Substances

NEW YORK STATE BAR ASSOCIATION FOOD, DRUG AND COSMETIC LAW SECTION AND HEALTH LAW SECTION COMMITTEE ON MEDICAL RESEARCH AND BIOTECHNOLOGY

Scientific Considerations in Demonstrating Biosimilarity to a Reference Product. Guidance for Industry

How to put together an IND application

FDA-Regulated Research

A REVIEW ON COMPARISON OF REGULATORY REQUIREMENTS TO APPROVED DRUG DEVICE COMBINATION PRODUCTS IN EUROPE AND USA

US FDA: CMC Issues for INDs

Medical Devices; Immunology and Microbiology Devices; Classification of the Nucleic Acid-

Evolving Regulatory Pathways for Medical Devices FDLI Annual Conference Access materials at fdli.org/annual2018

Copyright. Jeremiah J. Kelly (2015). All rights reserved. Further dissemination without express written consent strictly prohibited.

CANADA (HEALTH CANADA)

CANADA (HEALTH CANADA)

The Rise of the Medical Device/Pharmaceutical Product combination and how it affects traditional Pharmacovigilance

Regulatory Considerations and Trends Europe and the U.S.

First Global Forum on Medical Devices Bangkok-Thailand, September Regulatory Control of Medical Devices in Tanzania

March 4, Dockets Management Branch (HFA-305) Food and Drug Administration 5630 Fishers Lane, Rm Rockville, MD 20852

Developing a Companion Diagnostics in parallel to a medicinal product Legal and Regulatory requirements in Europe and in the US

Biosimilars: Questions and Answers Regarding Implementation of the Biologics Price Competition and Innovation Act of 2009

FDA identifies this generic type of device as: Absorbable perirectal spacer.

Device research sponsors, whether companies or investigators, are held responsible for meeting the same regulations.

FDA's Perspectives on Cross- Contamination in CMO Facilities, Considering High Risk Products

3.1. Overall Principal Investigator (PI), who holds the IDE and/or is the Sponsor

Niccolo Machiavelli (1523)

Title: Review of Medical Devices Page: 1 of 5 Written by:

Pre-Clinical Testing for Devices and Diagnostics

Medical Devices; Immunology and Microbiology Devices; Classification of the Automated

Beth Hutchins, PhD PhRMA ICH Gene Therapy Discussion Group

SUPPLEMENTAL NOTE ON HOUSE BILL NO. 2055

FDA Regulatory Updates: Related to Cancer Immunotherapy

FDA Regulatory Environment for Wearables, Implantables, and Other Digital Health Devices

Regulation of Biologics in The United States: From a Rich Tradition To A Challenging Future

REGULATORY REQUIREMENTS FOR THE REGISTRATION OF BIOLOGICS IN U.S

I N S I D E T H E M I N D S

Transcription:

Multimodal Therapies for Brain Disorders: Session II Regulatory and Reimbursement Considerations Combination Products at US FDA Patricia Y. Love, MD, MBA Deputy Director Office of Combination Products, OSMP, OMPT, OC, FDA June 14, 2016

Discussion Topics Within the spectrum of multimodal therapies for brain disorders When are multimodal products combination products? What are combination product implications for the FDA regulatory review process?

What is the basis of Product Classification? Biological product; PHS Act 351(a)* Device; FD&C Act, 201(h)* Drug; FD&C Act, 201(g)* Combination Product; FD&C Act 503(g) *See reference slides

What is a combination product? A combination product is: A product comprised of two or more different types of medical products (e.g., drug and device, drug and biological product, device and biological product, or all three together). Constituent part: A drug, device, or biological product that is part of a combination product. (See 21 CFR 3.2(k) and 21 CFR 4.1.) A combination product is not: A product comprised of only two or more of the same type of human medical product (e.g., drug - drug, device - device, or biologic - biologic). A human medical product combined only with a non-medical product (e.g., drug with a food or cosmetic). FDA INTERNAL USE ONLY 4

Combination Product: Definition 21 CFR Part 3 Physically or chemically into a single entity; 3.2(e)(1) Co-packaged (Kit); 3.2(e)(2) Sold separately and labeled for use together; 3.2(e)(3) or (e)(4) 5

21 CFR Part 3.2(e) - Details (e)(3) A drug, device, or biological product packaged separately that according to its investigational plan or proposed labeling is intended for use only with an approved individually specified drug, device, or biological product where both are required to achieve the intended use, indication, or effect and where upon approval of the proposed product the labeling of the approved product would need to be changed, e.g., to reflect a change in intended use, dosage form, strength, route of administration, or significant change in dose; or (e)(4) Any investigational drug, device, or biological product packaged separately that according to its proposed labeling is for use only with another individually specified investigational drug, device, or biological product where both are required to achieve the intended use, indication, or effect

Separately Provided Products: Labeling Jargon General labeling: Broad use - does not restrict to a particular drug or device One-way labeling: Brand Drug A for use with Brand Device A Brand Device A for use with drugs with certain characteristics, or labeled for use with Device A Two-way labeling (cross-labeling; combination Product) Brand Drug A for use with Brand Device A Brand Device A for use with Brand Drug A

Combination Product Examples (e)(1) Chemically / physically combined single entity CP Drug-eluting stent Antibody-drug conjugates Pre-filled disposable drug / biological delivery device (e)(2) Co-package Drug with empty syringe, diluent, and transfer pack Drug-device implant with implantation tools (e)(3) or (e)(4) Separately provided and cross-labeled Dedicated light source and dedicated photo-activated drug Dedicated drug and dedicated infusion pump 8

For a Combination Product 9

Assignment / Jurisdiction of CP Combination Product (CP) CDER, CBER, or CDRH Assigned based on the primary mode of action (PMOA)* or algorithm** *FD&C Act, Section 503(g); **21 CFR 3.2(m) 10

Assignment / Jurisdiction of CP, Cont d Mode of Action (MOA) the means by which a product achieves its intended therapeutic effect or action, 3.2(k) Action is based on the drug, device, biologic definitions PMOA the single mode of action of a combination product that provides the most important therapeutic action Most important therapeutic action is the mode of action expected to make the greatest contribution to the overall intended therapeutic effects ; 3.2(m) 11

Assignment / Jurisdiction Cont d When the PMOA is uncertain, use the assignment algorithm:* Assign to center with combination products raising similar S/E questions for CP as a whole (Tier-1) If there aren t similar combination products, then Assign to center with most expertise in the most significant safety and effectiveness questions for the CP (Tier-2) *21 CFR 3.4 12

What Happens After Assigned? Product is still a combination product; it does not change classification to that of the type of products customarily in that center. The constituent parts retain their identity and their applicable requirements apply to the combination Lead center is the point of contact Use the communication procedures and timelines of the lead center submission type Selection of submission type considers what is needed for the entire combination product; e.g., comply with applicable regulations / requirements of both constituent parts without being contrary or confounding. Data: use cross-center due diligence to address the scientific questions to ensure safety and effectiveness for the combination product as a whole and its constituent parts

Combination Product: General Regulatory Approach Premarket Apply consistent standards to assess safety and effectiveness regardless of Center assignment Use consistent and appropriate regulatory pathways One investigational application (i.e., the one used by the lead center) One marketing application for most combination products but might vary based on the marketing configuration 14

Combination Product: Consistency Considerations for Safety & Effectiveness - Examples Indication for Use: same or different from approved / cleared labeling(s) Drug changes; e.g., dose, rate, route or method of administration; dosing regimen or frequency Device changes; e.g., modality or exposure differences; Drug-Device interactions; preclinical, non-clinical, biocompatibility Human factors Safety or other labeling revisions for new use

Premarket Review Observations What is the appropriate regulatory pathway to market; e.g., Type of marketing application(s) Does the label of a marketed product need to change? Resolving potential differences in data requirements 16

Premarket Review Observations, Cont d Managing changes to the product configuration during the premarket review (e.g., how to leverage existing data) Managing different review processes, different application types, and different review times Assessing combination product CGMPs* and scheduling of inspections *21 CFR Part 17 4

What Else Happens After Assigned? OCP provides assistance in: Responding to questions from industry or FDA staff Attending internal meetings and meetings with sponsors when requested Hosting OCP-cross center meetings at industry requests Identifying and resolving CP regulatory/policy review issues (small or large). Facilitate resolution of scientific / process issues

Postmarket Regulation / Review Postmarket Combination Product Changes Compliance with regulatory requirements for each constituent part while avoiding redundancy Ensure consistent compliance and inspectional standards Ensure consistent standards and regulatory review pathways for postmarket changes

What is similar regardless of combination product or non-combination status? Centers and OCP continue to work together to Determine if the product is appropriately classified and in the appropriate center Identify and assess the scientific and technical data Consider the labeling that is appropriate to ensure safe and effective use of the product(s) for the proposed indication Achieve consistency and transparency Speak with one agency voice

Contact Us We re Here to Help! combination@fda.gov www.fda.gov/combinationproducts/default.htm patricia.love@fda.hhs.gov 21

Reference slides

Classification Definitions: Drug or Device Drug: articles intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease in man or other animals; and articles intended to affect the structure or any function of the body of man or other animals. (FD&C Act, 201(g)) Device: an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article,... intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease, in man, or intended to affect the structure or any function of the body of man, and does not achieve its primary intended purposes through chemical action within or on the body of man and is not dependent upon beingmetabolized for the achievement of itsprimary intended purposes. (FD&C Act, 201(h)) 23

Classification Definition: Biological Product Biological product:* A virus, therapeutic serum, toxin, antitoxin, vaccine, blood, blood component or derivative, allergenic product, protein (except any chemically synthesized polypeptide), or analogous product, Or arsphenamine or derivative of arsphenamine (or any other trivalent organic arsenic compound), Applicable to the prevention, treatment, or cure of a disease or condition of human beings. *PHS Act, 351(a) 24

Useful Assignment Information Guidance documents and regulation* PMOA Rule, 21 CFR Part 3 revision 2005 Chemical Action (draft) 2011 Classification (draft) 2011 How to Write an RFD -update 2011 * http://www.fda.gov/combinationproducts/default.htm 25