Has FDA's Drug Development Tools Qualification Program Improved Drug Development?

Abstract

Background: The Drug Development Tools (DDTs) Qualification program creates a pathway to evaluate Clinical Outcome Assessments (COAs) that capture a specific concept of interest (COI) in a specified Context of Use (COU). If successfully qualified, a COA can be relied upon to measure a COI that has an application in drug development and regulatory decision-making. Thus, qualified COAs are important DDTs. This analysis aims to assess the Food and Drug Administration's (FDA's) performance reviewing applications in the COA Qualification Program, as well as the uptake of qualified COAs in drug development to date.

Methods: In order to assess the use of qualified COAs in drug development, we analyzed the Summary Basis of Approvals (SBA) retrieved from Drugs@FDA and the COA compendium. The submission and review dates for the Letter of Intent (LOI), Qualification Plan (QP), and Full Qualification Package (FQP) steps were retrieved from Center for Drug Evaluation and Research (CDER) & Center for Biologics Evaluation and Research's (CBER) database, as well as the FDA COA Qualification Program website.

Results: Our analysis showed that 86 COAs were listed on the FDA COA website, with a majority of them being Patient Reported Outcomes (PRO). Completeness Assessment (CA) for each portion of submission, as well as review times for the LOI, QP, and FQP steps vary widely, with 46.7% of submissions having a review time exceeding the published targets. To date, 7 COAs (8.1%) have achieved qualification, and one (1.1%) has been denied after undergoing all steps for qualification. On average, it takes 6 years for a COA to be qualified. Our analysis of FDA's approval documents shows that the Agency has relied on qualified COAs to support benefit-risk assessment of 11 medicines. Only three of the seven qualified COAs have been used to support benefit-risk assessment of medicines. The three qualified COAs that have been used are KCCQ, E-RS, and EXACT. Each of these has been used to support multiple indication claims. KCCQ - cardiomyopathy for 2 medicines, heart failure for 6 medicines; E-RS - chronic obstructive pulmonary disease (COPD) for 1 medicine; and EXACT - COPD for 3 medicines. Note: E-RS and EXACT were both used in aclidinium bromide/formoterol/fumarate. In each case they were used as secondary or exploratory endpoints, none as primary endpoints. Only 1 qualified COA was included in drug labels.

Conclusion: The lengthy and unpredictable nature of the COA Qualification Program review timelines poses a risk for tool developers and sponsors intending to qualify a new COA, to use an existing COA or sponsors intending to qualify and use a new COA in the drug development process. Our findings show that, to date, the DDT Qualification Program has not significantly improved the inclusion of qualified COAs in clinical development plans to support regulatory decision-making and label claims, and therefore the impact of the pathway to facilitate the use of innovative tools has been limited. To improve the utility of this program, FDA should publicly share the timelines so participants can be better prepared to integrate into their development programs. Furthermore, FDA should clearly articulate how and when COAs can be used in drug development.

Keywords: COA; Context of use; FDA; Primary/secondary endpoints; Qualification.

Fig. 1

Process Map for DDT submission and qualification This process map is based on the FDA DDT Guidance [15] and provides the COA developer/requestor the steps they need to follow if they want to submit a DDT for review. Acronyms Used: LOI = Letter on Intent; CA = completeness assessment; QP = Qualification Plan; FQP = Full Qualification Package

Fig. 2

Average review time for each type of submission (LOI, QP, and FQP). For each submission, the average times are greater than the time FDA outlined in its DDT guidance. Error bar indicates SD

Fig. 3

Average time for CA for each type of submission (LOI, QP, and FQP). CA timeline is not specified in FDA DDT Guidance. Error bar indicates SD

Fig. 4

Number of submissions that were reviewed on time versus number of submissions that were delayed when compared against the timeline outlined in the DDT guidance. Error bar indicates SD

Fig. 5

Application of KCCQ in different benefit-risk assessments of drugs over time as found in SBAs including COU and if it was included in the drug label