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Medical	Product	Development	For	Rare	Diseases			
Part	2:	Regenerative	Medicine	Therapies	
FDA	Regulatory	Perspective	
Rare	International	Dialogue:	Drivers	of	Drug	Development	
Canadian	Organization	for	Rare	Disorders		
May	10-12,	2019	
		
	
Larissa	Lapteva,	MD,	MHS,	MBA	
Associate	Director		
Division	of	Clinical	Evaluation	and	Pharmacology/Toxicology		
Office	of	Tissues	and	Advanced	Therapies	
Center	for	Biologics	Evaluation	and	Research		
US	Food	and	Drug	Administration
2
Efficient	Development	
				Regulatory	Programs	
•  Fast	Track	
•  Breakthrough	Therapy		
•  Regenerative	Medicine	Advanced	Therapy	
•  Qualified	Infectious	Disease	Product			
•  Orphan*	Product			
•  Priority	review	
•  priority	review	voucher	program		
•  Accelerated	approval	
•  Grant	programs,	user	fee	waivers,	and	other	
incentives	
								Product	Development		
•  INTERACT**	
•  Innovative	study	designs	
•  Effective	use	of	“reduce,	refine,	replace”	
principle	and	modeling	in	preclinical	
programs	
•  Enrichment	strategies	
•  Adaptive	and	complex	innovative	
designs****	
•  Product	development	tools	including	
biomarkers	and	clinical	outcomes	assessments	
•  Patient	Engagement***	
			to	support	
*Designating	an	Orphan	Product:	Drugs	and	Biological	Products	
https://www.fda.gov/ForIndustry/DevelopingProductsforRareDiseasesConditions/HowtoapplyforOrphanProductDesignation/default.htm	
**INTERACT	https://www.fda.gov/BiologicsBloodVaccines/ResourcesforYou/Industry/ucm611501.htm		
***Patient-Focused	Drug	Development		https://www.fda.gov/drugs/developmentapprovalprocess/ucm610279.htm			
****Complex	Innovative	Design	Pilot	Program	https://www.fda.gov/Drugs/DevelopmentApprovalProcess/DevelopmentResources/ucm617212.htm
3
Fast	Track	(FT)	 Breakthrough		
Therapy	(BT)	
Regenerative	Medicine	Advanced	
Therapy	(RMAT)	
Criteria	 -Serious	condition	
AND	
-Nonclinical	or	clinical	
data	demonstrate	the	
potential	to	address	
unmet	medical	need	
Note:	Information	to	
demonstrate	potential	
depends	upon	stage	of	
development	at	which	FT	
is	requested	
-Serious	condition	
AND	
-Preliminary	clinical	
evidence	indicates	that	the	
product	may	demonstrate	
substantial	improvement	
over	available	therapy	on	
one	or	more	clinically	
significant	endpoints	
	
-Serious	condition	
AND	
-Preliminary	clinical	evidence	indicates	that	
the	product	has	the	potential	to	address	
unmet	medical	need	
Note:	RMT	include	cell	therapies,	therapeutic	tissue	
engineering	products,	human	cell	and	tissue	
products,	and	combination	products	using	such	
therapies	or	products	(human	gene	therapies,	
including	genetically	modified	cells,	that	lead	to	a	
sustained	effect	on	cells	or	tissues,		xenogeneic	cell	
products)	
Expedited	Programs	for	Product	Development		
Guidance	for	Industry:	Expedited	Programs	for	Serious	Conditions	–	Drugs	and	Biologics		
https://www.fda.gov/downloads/Drugs/Guidances/UCM358301.pdf		
Guidance	for	Industry:	Expedited	Programs	for	RMAT	for	Serious	Conditions		
https://www.fda.gov/downloads/BiologicsBloodVaccines/GuidanceComplianceRegulatoryInformation/Guidances/CellularandGeneTherapy/UCM585414.pdf
4
Expedited	Programs	for	Product	Development	
Fast	Track	(FT)	 Breakthrough		
Therapy	(BT)	
Regenerative	Medicine	
Advanced	Therapy	(RMAT)	
Features	 	
Frequent	meetings		
	
Frequent	written	
communication		
	
Eligibility	for	*:	
	
ü  Accelerated	approval		
ü  Priority	review	
	
Rolling	Review	
	
*if	relevant	criteria	are	met	
All	of	FT	Features	+	
ü  Intensive	guidance	on	an	
efficient	drug	development	
program,	beginning	as	early	
as	Phase	1	
ü  Organizational	commitment	
All	of	BT	Features	+	
ü  Early	interactions	to	discuss	
any	potential	surrogate	or	
intermediate	endpoints	
ü  Statute	addresses	potential	
ways	to	support	accelerated	
approval	and	satisfy	post-
approval	requirements	
	
Guidance	for	Industry:	Evaluation	of	Devices	Used	with	RMATs	
https://www.fda.gov/downloads/biologicsbloodvaccines/guidancecomplianceregulatoryinformation/guidances/cellularandgenetherapy/ucm585417.pdf
5www.fda.gov
Requested	and	Granted	BT	and	RMAT	Designations		
(through	April	1,	2019)		
BT Requested
BT Granted
RMAT Requested
RMAT Granted
6
Draft	Guidance	Documents	To	Facilitate			
Gene	Therapies	for	Rare	Diseases:	July	2018	
•  Human	Gene	Therapy	for	Rare	Diseases	
•  Human	Gene	Therapy	for	Hemophilia	
•  Human	Gene	Therapy	for	Retinal	Disorders	
•  Chemistry,	Manufacturing,	and	Control	(CMC)	Information	for	Human	Gene	
Therapy	Investigational	New	Drug	Applications	(INDs)		
•  Long-Term	Follow-up	After	Administration	of	Human	Gene	Therapy	Products			
•  Testing	of	Retroviral	Vector-Based	Human	Gene	Therapy	Products	for	
Replication	Competent	Retrovirus	During	Product	Manufacture	and	Patient	
Follow-up	
		https://www.fda.gov/BiologicsBloodVaccines/
GuidanceComplianceRegulatoryInformation/Guidances/CellularandGeneTherapy/
default.htm
7
Medical	Product	Development	Tools		
•  Methods,	materials,	and	measures	that	can	potentially	facilitate	medical	
product	development	
	
•  May	be	developed,	qualified,	and/or	used	within	individual	product	programs	
OR	outside	any	specific	product	development	in	the	pre-competitive	space	
through	the	existing	regulatory	qualification	programs	
•  Animal	Model	Qualification	Program		
•  Biomarker	Qualification	Program	
•  Clinical	Outcome	Assessment	Qualification	Program	
	
FDA	Qualification	Programs	Contacts	
https://www.fda.gov/Drugs/DevelopmentApprovalProcess/DrugDevelopmentToolsQualificationProgram/ucm284396.htm		
FDA’s	COA	Qualification	Program	
https://www.fda.gov/Drugs/DevelopmentApprovalProcess/DrugDevelopmentToolsQualificationProgram/ucm284077.htm
8
Complex	Innovative	Design	(CID)	Pilot	Program	
•  Highly	innovative	trial	designs	which	may	require	simulations	to	determine	
clinical	trial	operating	characteristics	(type	I	error	rate	and	power)		
•  Sponsors:	
•  submit	meeting	requests	to	discuss	proposed	CIDs	(CBER	and	CDER	will	
select	up	to	2	requests	per	quarter)	
•  have	the	opportunity	to	engage	with	FDA	regulatory	staff	on	designs	via	
2	extra	meetings	with	statistical	reviewers	
•  Need	an	active	IND	or	Pre-IND	number	
•  FDA:	uses	the	design	as	a	case	study	for	continuing	education	and	
information	sharing	
For	more	information,	visit:	
https://www.fda.gov/Drugs/DevelopmentApprovalProcess/DevelopmentResources/ucm617212.htm
9
Patient	Engagement	and	
Patient-Focused	Drug	Development	
•  FDA	Patient	Representative	Program	
•  Patient-Focused	Drug	Development	meetings	(FDA	and	stakeholders)	
•  Formation	of	FDA	Patient	Affairs	Staff	group	in	2017	
•  FDA	Listening	Sessions	(patient	experiences	with	specific	conditions)	
•  Science	of	Patient	Input:	series	of	guidance	documents	on	methodological	
approaches	to	incorporating	patient	voice	in	medical	product	development	and	
regulatory	decision-making	
https://www.fda.gov/Drugs/DevelopmentApprovalProcess/ucm610279.htm			
•  Inclusion	of	Patient	Experience	Data	in	marketing	applications	and	reviews	
The	21st	Century	Cures	Act	(2016)	and	the	FDA	Reauthorization	Act	(2017):	Plan	for	Issuance	of	Patient-Focused	Drug	Development	Guidance	
https://www.fda.gov/downloads/ForIndustry/UserFees/PrescriptionDrugUserFee/UCM563618.pdf
10
Contact	Information	
§  Larissa.Lapteva@fda.hhs.gov	
§  Regulatory	Questions:	
	OTAT	Main	Line	–	240	402	8190	
	Email:	OTATRPMS@fda.hhs.gov	and	
	Lori.Tull@fda.hhs.gov		
§  OTAT	Learn	Webinar	Series:		
	http://www.fda.gov/BiologicsBloodVaccines/NewsEvents/ucm232821.htm	
	
§  CBER	website:	www.fda.gov/BiologicsBloodVaccines/default.htm	
§  Phone:	1-800-835-4709	or	240-402-8010	
§  Consumer	Affairs	Branch:	ocod@fda.hhs.gov	
§  Manufacturers	Assistance	and	Technical	Training	Branch:	industry.biologics@fda.hhs.gov	
§  Follow	us	on	Twitter:	https://www.twitter.com/fdacber

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