Pediatric Drug Development:

Similar documents
Guidance for Industry Pediatric Study Plans: Content of and Process for Submitting Initial Pediatric Study Plans and Amended Pediatric Study Plans

Chin Koerner Executive Director US Regulatory and Development Policy

September 12, Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, Room 1061 Rockville, MD 20852

Pediatric Clinical Trials: The Need for Regulation (Part 1)

Pediatric drug development - do we need a PIP so early in development? American versus European approach

Sec Short title; finding. Sec Authority to assess and use drug fees. Sec Reauthorization; reporting requirements.

Pediatric Exclusivity and Drug Development Requirements in the Overall Pediatric Population. Prepared by Beckloff Associates, Inc.

Key concepts of the paediatric regulation and latest developments

Medicines for Children

Report from the Paediatric Committee on its first anniversary

(Information) INFORMATION FROM EUROPEAN UNION INSTITUTIONS, BODIES, OFFICES AND AGENCIES EUROPEAN COMMISSION

Clarification of Orphan Designation of Drugs and Biologics for Pediatric Subpopulations of Common Diseases

Jonathan Davis, MD Vice-Chair of Pediatrics, Floating Hospital for Children at Tufts Medical Center, Boston, MA Chair, Neonatal Advisory Committee,

Pediatric Exclusivity and other Emerging Issues in Clinical Trials Management

Version January 2007

Multiregional Regulatory Considerations in Pediatric Drug Development

This template is to be used by companies willing to submit an overview of relevant

Pediatric Cancer Drug Development: Impact of US Regulations

Attachment B: A Guideline for Writing a Clinical Protocol for CPRN

Docket #: FDA-2018-D-3268

International Collaborations in Pediatrics: FDA and EMA growing together March 2018

Extrapolation in Pediatric Product Development: Practical Application of the Principle of Scientific Necessity

1. Can you tell us about your organization and your role within the organization?

PIP s Pup s and Problems

Yodit Belew, MD Senior Medical Officer Division of Antiviral Products OAP/OND/CDER/FDA 1

FDARA 2017 and the RACE for Children Act: Implications for Pediatric Cancer Drug Development

Juvenile Animal Studies: Industry Perspective

What s New in GCP? FDA Draft Guidance Details FIH Multiple Cohort Trials

Reflection paper on the use of extrapolation in the development of medicines for paediatrics

Questions and Answers on Biosimilar Development and the BPCI Act

EU Regulation Review: challenges and opportunities for industry

Clinical Development and enabling Regulatory Steps: How to obtain ODD and Scientific Advice at EMA

Creation of a pan-european Paediatric Clinical Trials Network. Heidrun Hildebrand (Bayer) & William Treem (Janssen),

ARNOLD & PORTER UPDATE

Investigational New Drug Application

FDA Public Hearing: Approval Pathway for Biosimilar. Products. November 2-3, 2010

Gemzar (gemcitabine) is currently approved in adult patients for use in the treatment of:

Toxicology for Pediatric Drug Development

CTTI History and Methodology ABDD Program History

QUESTIONS AND ANSWERS ON THE PAEDIATRIC REGULATION (REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (EC) No 1901/2006, AS AMENDED)

International Consortium For Innovation & Quality in Pharmaceutical Development

A. TRIAL IDENTIFICATION

Exploratory clinical trials workshop

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

Summary Pediatric Device Stakeholders Meetings June 28, October 4 & 25, and November 1, 2004

Selecting A Right Patient Recruitment Company: The Key To Success

Submission of comments on COMMISSION NOTICE ON THE APPLICATION OF ARTICLES 3, 5 AND 7 OF REGULATION (EC) NO 141/2000 ON ORPHAN MEDICINAL PRODUCTS

EMEA/CHMP WORKSHOP Draft guideline on requirements for first-in. in- man clinical trials for potential high-risk medicinal products

Re: Comments on January 2017 Draft Guidance: Considerations in Demonstrating Interchangeability with a Reference Product (Docket No.

Pediatric Assessment in Drug Development and Regulatory Approval in Japan

Office for Human Subject Protection. University of Rochester

While individually rare, orphan diseases are actually collectively common, with an OF ORPHAN DRUG DEVELOPMENT MEETING THE UNIQUE CHALLENGES

Recommendations for Strengthening the Investigator Site Community

Orphan designation in the EU

Drug Safety and FDA Revitalization Legislation

EUROPEAN COMMISSION HEALTH AND CONSUMERS DIRECTORATE-GENERAL

Conducting Successful pre-ind Meetings to Reach FDA Concurrence for Sound 505(b)(2) Development

Special Considerations and Utility of Modeling and Simulation for Pediatric Medical Countermeasures: Introduction

Orphan Drug Designation within the Development Strategy

ORPHAN DESIGNATION BY THE EMA. Paillard Juliette M2 AREIPS 15/11/2016

MAINTENANCE OF THE ICH GUIDELINE ON NON-CLINICAL SAFETY STUDIES FOR THE CONDUCT OF HUMAN CLINICAL TRIALS FOR PHARMACEUTICALS M3(R1)

Orphan designation in the EU

Compassionate Use Navigator Information for Physicians

Roles and responsibilities of members and alternates, rapporteur and peer reviewers, experts and observers of the Paediatric Committee (PDCO)

The Evolving Regulatory Landscape for Orphan Drugs: FDA Perspectives

EU regulatory tools for expedited antibacterial development programmes

Model-Informed Drug Development: Past, Present, Future

BLA /122 SUPPLEMENT BLA APPROVAL July 29, 2011

Public release of clinical information in drug submissions and medical device applications

Regulatory Perspective

Priority Medicines (PRIME) scheme

Re: Docket No. FDA-2014-D-1461: Rare Pediatric Disease Priority Review Vouchers

Re: Docket No. FDA-2017-D-6380: Clarification of Orphan Designation of Drugs and Biologics for Pediatric Subpopulations of Common Diseases

CATEGORY Advertising. CATEGORY Biopharmaceutics. CATEGORY Biosimilarity

EU scientific regulatory support mechanisms and initiatives for innovation in drug development: the EMA perspective

Clinical Trials Environment EU Legislation: Ausblick auf die neue Gesetzgebung für klinische Prüfungen

EARLY DRUG DEVELOPMENT CONSULTANCY & SERVICES CLINICAL RESEARCH SOLUTIONS

Contribution regarding Public consultation on the revision of "COMMISSION REPORT ON THE PAEDIATRIC REGULATION PCPM/16 Paediatric Report.

Guidelines: c. Providing the investigational drug for the requested use will not interfere with the initiation, conduct, or completion of clinical

Key Aspects of Non-Clinical Pharmacology and Pharmacokinetics in the Evaluation of Safety

Critical Path to TB Drug Regimens (CPTR)

Ophthalmology Workshop EMA October The orphan perspective. Presented by: Dr Stelios Tsigkos

Summary of Provisions in 21 st Century Cures Act (H.R. 6) as passed by full House of Representatives, July 10, 2015

Deal Making and Product Development in Europe: Changes and Trends You Need to Know About: Regulatory Strategy

'Health, demographic change and well-being' Clinical Studies

Interchangeability: What is Next? Analysis of the concept & of the FDA Draft Guidance

EMA/CAT support to ATMP developers

Expanded Access and the Individual Patient IND

Commission notice on the application of Articles 3, 5 and 7 of Regulation (EC) No 141/2000 on orphan medicinal products (2016/C 424/03)

CHECKLIST: Pre-review

ACG Public Forum. Join ACG, the FDA, and EMA for a discussion on biosimilars and IBD. Monday, 12:45 pm 2:15 pm

New and Revised Draft Q&As on Biosimilar Development and the BPCI Act (Revision 2)

Guide for National Scientific and Regulatory Advice

CPTR Mission, Structure & Goals for Innovation

Role of Academic Investigators in Drug Development

Scientific advice and its impact on marketing authorisation application reviews

Track III: International Clinical Trials: Global Compliance Norms and EU Focus

PRIME. 7 th STAMP meeting Brussels, 27 th June Presented by Sonia Ribeiro Head of Regulatory Affairs Office, Human Medicines Evaluation Division

EU perspective: European procedure for Qualification of novel methodologies for medicine development. Elmer Schabel MD

APPLICATION FOR PAEDIATRIC INVESTIGATION PLAN / WAIVER

Transcription:

Pediatric Drug Development: Where Have We Been and Where Are We Going? Barry Mangum, PharmD, FCP Director Clinical Pharmacology Duke Clinical Research Center Duke University Medical Center

Specialty Pediatric Populations

Pediatric and Adolescent Care

Where Have We Been? Building a regulatory story (FDA and EMA) Defining the patient population Age, weight, sex, ethnicity, etc. Deciding if we need formulation development Palatability Increased cost of study Drug Information Association www.diahome.org 4

Where Have We Been? Developing the internal pediatric expertise to handle the mandate for pediatric study Pharma, academia developing new skill sets and personnel BMS, Pfizer, J&J, and Shire Creating the internal regulatory expertise for pediatrics within the agencies (EMA and FDA) FDA considering neonatologist under FDASIA FDA and EMA having monthly teleconferences to discuss pediatric programs Drug Information Association www.diahome.org 5

Where are We Going? Increase in pediatric requirements from FDA and EMA Age categories for study will move to the neonatal patient population Orphan drug designation will drive the birth of new pharmaceutical companies within companies Drug Information Association www.diahome.org 6

Where are We Going? New pharmaceutical company expertise will emerge Orphan disease groups Pediatric pharmacometrics Dedicated pediatric research organizations will emerge to handle the volume of pediatric trials Site networks will be formed executing a new paradigm in recruitment globally Drug Information Association www.diahome.org 7

Regulatory Path Forward Written request issued (BPCA) PSP end of ph2 Agreed PREA requirements PIP process begins (adult PK) Approved PIP required for MAA submission

Pediatric Research Sites Academic Experts Specialty Clinics Phase I/ Phase II Trained Research Medical Practice Centers Phase II/ Phase III Condition-ofuse General Clinics Phase IIIB, IV

Sustainable Network Vision Consortia of pharma companies collaborate Centrally managed network of 30 international sites 10 US, 10 EU, and 10 LA Reduction of site administrative burden Auxiliary site staff dedicated to identifying and recruiting patients into consortia trials Cost effective model for pharma decreases start up and enrollment timelines XXX company will work with sites to understand their unique challenges to enrollment and to develop mitigation plans. These plans will include resources to be financially supported by the consortia, paid and managed through XXX Company, and dedicated to consortia trial enrollment at the site.

Knowledge JF Marier, B Mangum, E Reid, and JS Barrett. A Modeling and Simulation Framework to Support Global Regulatory Strategies for Pediatric Drug Development Programs. Therapeutic Innovations and Regulatory Sciences, Sept, 2013. Nonclinical Phase I PIP Phase II PSP Phase III Final Pediatric Protocol Pediatric Protocols Design by Simulations Drug Model Disease Model Trial Model Continuum of learn and apply cycles for traditional drug development program in adults, with specific triggers points (shaded arrows) for developing dosing rationale in pediatric patients.

Pharmacometrics FDA set a target to design 50% of all pediatric trials using simulations by 2015 and 100% by 2020

European Regulatory Position

European Regulatory Framework EMA (European Medicines Agency) is not an FDA for Europe! Member States (MS) have pooled their sovereignty for authorization of medicines for children EMA coordinates the existing scientific resources of Member States An interface with all partners

Objectives of the EU Regulation Improve the health of children globally: Increase high quality, ethical research into medicines for children Increase availability of authorized medicines for children Increase information (data) on medicines Achieve the above: Without unnecessary studies in children Without delaying authorization for adults

The Latest USA Regulation Drug Information Association www.diahome.org 16

Food and Drug Administration Safety and Innovation Act (FDASIA) Makes permanent the Best Pharmaceuticals for Children Act (BPCA) and the Pediatric Research Equity Act (PREA). Clarifies the Secretary s authority to award exclusivity for studies conducted pursuant to a written request, including a conforming change for biological products. Requires the Secretary to issue guidance providing for Pediatric Review Committee (PeRC) review of any significant modifications made to written requests or pediatric study plans. Requires the Secretary, within three years of enactment, to make public the medical, statistical, and clinical pharmacology reviews of written requests made between 2002 and 2007 that resulted in a labeling change. Allows for extensions of pediatric study deadlines in appropriate circumstances. Current tracking requirements would be expanded to collect data about deferral extensions and the timeline to completion of assessments. If a required pediatric study was not completed or deferred, the Secretary would issue a letter and require a response within 45 days, both of which would be made publicly available. Drug Information Association www.diahome.org 17

Food and Drug Administration Safety and Innovation Act (FDASIA) Ties the submission of an initial pediatric study plan (PSP) to the sponsor s end of the Phase II meeting with FDA, unless the Secretary and the applicant agree to an alternative date. The requirements and process for pediatric study plan submissions would be further clarified through regulations. Reauthorizes the Pediatric Advisory Committee, reauthorize the Pediatric Subcommittee of the Oncologic Drug Advisory Committee (ODAC) in a manner consistent with the authorization of ODAC, reauthorize the Humanitarian Device Exemption Extension through 2017, and reauthorize the Program for Pediatric Study of Drugs. Requires a report every five years evaluating the effectiveness of BPCA and PREA. Requires the FDA s Office of Pediatric Therapeutics to have a neonatologist on staff. Drug Information Association www.diahome.org 18

What is Required to Meet the New Legislation? Drug Information Association www.diahome.org 19

Pediatric Study Plans Who must submit an initial PSP When an initial PSP must be submitted What should be included in an initial PSP What should be included in a requested amendment to an agreed-upon initial PSP A template that should be used for an initial PSP submission Drug Information Association www.diahome.org 21

TIMING OF A PSP SUBMISSION A sponsor must submit the initial PSP no later than 60 calendar days after the date of the end-of-phase 2 meeting. In the absence of an end-of-phase 2 meeting, the initial PSP may be submitted as early as practicable but before the initiation of any phase 3 studies. If a phase 3 study will not be conducted, the sponsor should submit the initial PSP no later than 210 calendar days before a marketing application or supplement is submitted. In cases when there is no active IND for the drug, but the sponsor expects upon submission of the IND that the initial studies would include a phase 3 study, the initial PSP should be submitted as a pre- IND submission. In this situation, the FDA encourages sponsors to schedule a pre-ind meeting before submission of the initial PSP.

Regulatory Path Forward Written request issued (BPCA) PSP end of ph2 Agreed PREA requirements PIP process begins (adult PK) Approved PIP required for MAA submission

CONTENTS OF THE INITIAL PSP 1 of 12 1. Overview of the Disease Condition in the Pediatric Population Brief summary of the pathophysiology of the disease, methods of diagnosis, and currently available treatments and/or prevention strategies in the pediatric population, including neonates. Incidence and prevalence of the disease in the overall population and the incidence and prevalence in the pediatric population should be discussed.

CONTENTS OF THE INITIAL PSP 3 of 12 3. Overview of Planned Extrapolation to Specific Pediatric Populations Plans for extrapolation of efficacy data from adults to pediatrics (or from adolescents). Appropriate if the course of the disease and the effects of the drug are sufficiently similar in adult and pediatric patients. Extrapolation of efficacy from one pediatric age group to another pediatric age group. Application of exposure-response relationships in adults to pediatrics and ability to extrapolate Include information on similarities (and differences) between adults and children in disease pathogenesis, criteria for disease definition, clinical classification, and measures of disease progression, as well as pathophysiologic, histopathologic, and pathobiological characteristics. All age ranges of pediatric patients should be considered, including neonates. A justification for the extrapolation, including any available supporting data for all age groups for which efficacy will be extrapolated should be provided. Supportive data from all available sources (e.g., sponsor data, published literature, expert panels, and workshops) should be provided. Extrapolation of efficacy for other drugs in the same class, if previously accepted by the FDA, also can be considered supportive information.

CONTENTS OF THE INITIAL PSP 4 of 12 4. Request for Drug-Specific Waiver(s) Plans and justification to request a waiver (either full or partial) of the requirement to provide data from pediatric studies. Supportive data should include data from all relevant sources, including sponsor data, published literature, expert panels and workshops, and consensus documents. Full or partial waivers previously granted for other drugs in the same class can be considered supportive information. It should be noted that requested waivers in the PSP will not be formally granted or denied until the application is approved. If studies will be waived because there is evidence that the drug would be ineffective or unsafe in any pediatric age group, this information must be included in the product labeling. Generally, this information would be included in the Pediatric Use subsection of labeling.

CONTENTS OF THE INITIAL PSP 5 of 12 5. Summary of Planned Nonclinical and Clinical Studies

CONTENTS OF THE INITIAL PSP 6 of 12 6. Pediatric Formulation Development Provide details of any pediatric-specific formulation development plans, if appropriate, including whether the formulation that is being developed can be used for all pediatric populations. Age-appropriate formulation for all pediatric age groups that will be studied. Sponsors also should provide details about the size of all planned capsules or tablets, to the extent practicable, to be used in pediatric studies.

CONTENTS OF THE INITIAL PSP 7 of 12 7. Nonclinical Studies A brief summary of the data from relevant nonclinical studies that support the use of the drug in all pediatric age groups. The sponsor should include information that supports the maximum dose and duration of treatment to be used in pediatric studies. If additional nonclinical studies are not planned, the rationale for this decision should be included. If the existing nonclinical data are not sufficient to support the proposed clinical trials, sponsors should provide a brief description for each of the studies they will conduct, including, at a minimum: The species to be studied The age of animals at start of dosing Duration of dosing Target organ systems of concern with key developmental endpoints to be evaluated

CONTENTS OF THE INITIAL PSP 8 of 12 8. Clinical Data to Support Design and/or Initiation of Studies in Pediatric Patients This section should provide a brief summary of any clinical data that support the design and/or initiation of pediatric studies. This section also can include available data in adult or pediatric patients who have received treatment with the drug (or related drugs) for the proposed indication, for other conditions, or in earlier studies.

CONTENTS OF THE INITIAL PSP 9 of 12 9. Planned Pediatric Clinical Studies 9.1 Pediatric PK/PD Studies This section should provide an outline of each of the pediatric pharmacokinetic/ pharmacodynamic (PK/PD) study (or studies) planned, if applicable. The studies should be discussed in the order they are presented in the table in section 5. For each study, to the extent practicable, the sponsor should address the following: Type of study/study design Objectives of study Age group and population in which the study will be conducted Pediatric formulation(s) used in this study Dose ranges to be used in the PK studies Endpoints and justification (PK parameters; PD biomarkers) Existing or planned modeling and simulation to support dose selection and/or study design for the pediatric studies Any planned pharmacogenomic analyses Sample size justification

CONTENTS OF THE INITIAL PSP 9 of 12 9.2 Clinical Effectiveness and Safety Studies This section should provide an outline of each pediatric study planned, discussed in the order they are presented in the table in section 5. For each study, to the extent practicable, the sponsor should address the following: Type of study/study design Objectives of the study Age group and population in which the study will be conducted Inclusion and exclusion criteria for the study Endpoints (primary and key secondary) to be used Timing of endpoint assessments Safety assessments (including timing and length of follow-up) Statistical approach (e.g., statement of null and alternative hypotheses, sample size/power justification)

CONTENTS OF THE INITIAL PSP 10 of 12 10. Timeline of the Pediatric Development Plan Each study listed in the table in section 5 should include a general timeline for completion of the study in this section. The sponsor should estimate these dates based on current projections for the drug development program. If the dates provided in the initial PSP change as drug development proceeds, a request to amend the initial PSP should be provided. Furthermore, the request should include justification for the change in the dates provided below for amendment of the initial PSP. 1.Formulation development, if applicable 2. Nonclinical studies, if applicable 3. Clinical Studies 4. Target date of application submission

CONTENTS OF THE INITIAL PSP 11 of 12 11. Plan to Request Deferral of Pediatric Studies The initial PSP should include any plans to request deferral of pediatric assessments in some or all pediatric groups until after approval of a future application (or supplement) in other age groups. If new information, such as data from ongoing or planned studies, indicates that a criterion for a waiver (or partial waiver) is met, planned requests for deferral of pediatric assessments in the initial PSP can be changed to planned requests for waiver (or partial waiver). These changes should be submitted as an amendment to an agreed-upon initial or amended PSP. The FDA may grant a deferral of required pediatric studies if it finds that: (1) the drug or biological product is ready for approval for use in adults before pediatric studies are complete; (2) pediatric studies should be delayed until additional safety or effectiveness data have been collected; or (3) there is another appropriate reason for deferral. The planned request for a deferral should be listed in the order of the proposed studies in the table in section 5, and should include adequate justification and any currently available evidence justifying the request for a deferral (1 to 2 pages). It should be noted that requested deferrals in the initial PSP will not be formally granted or denied until the drug is approved.

CONTENTS OF THE INITIAL PSP 12 of 12 12. Agreements for Other Pediatric Studies A summary of the agreed-upon pediatric investigation plan with other regulatory authorities (e.g., European Medicines Agency) should be provided. If negotiations with a regulatory authority are in progress, a summary of the draft plan should be included. A summary of any agreements with other regulatory authorities also should be included. A summary of any clinical investigation conducted under an IND for an indication other than the indication that is the subject of the initial PSP also should be included.

The Future: The Way Forward Globalization of pediatric research is a reality Volume of pediatric trials will escalate globally PREA (mandate and exclusivity) will sunset in October 1, 2012, possibly reauthorized EU passed legislation mandating pediatric clinical trials ( 2006 ), no reauthorization necessary EU passed exclusivity tied to study performance (6 months patent extension) EU mandate required for MAA

If we don t stand up for children, then we don t stand for much. Marian Wright Edelman Drug Information Association www.diahome.org 37