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Qualification of Innovative Development Methods/Tools Themes from Breakout Discussion 13 February 2013
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Participating Group Members Richard Meibach Martha BrumfieldCarolyn Compton ShaAvhree BuckmanAlan Morrison Nathalie SeigneuretBernard Munos Carol MimuraSharon Olmstead Lynn HudsonHubert Leufkens Nancy Cutter Foster Ruth Mcnerney Mike ward
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Premise of Qualification Need to define Context of Use – Defines specific purpose, method of use Biomarkers need careful scrutiny – are population specific – Predictive, prognostic, etc – How to garner interest with those using “accepted biomarkers” to fully “validate” them for qualification processes
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Harmonize or not? Meaning of FDA qualification and EMA Scientific Advice Opinion are not equivalent – FDA prefers some degree of predictability – EMA prefers a more principles based approach Level of evidence varies because of the above Legal structure with fees, timelines are not the same
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CTD or not? Willingness of FDA and EMA to consider commonalities where there are similarities with parts of dossier being customized for what that Agency requires Discussed possibility of conducting a pilot with C-Path and FDA/EMA
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Prioritization Priority to whom? Perhaps best to start with gap analysis – Where is the greatest need – for diseases with lack of treatments; with industry being successful?? With regulatory review? – Vet information with all stakeholders
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Performance Indicators Why do this? – To learn from successes and failures Who should own the collection and reporting? – Publication of information should be a goal Agreement that it is needed but not sure how to go about it
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Performance Indicators MAAs in EU will include information about how Scientific Advice was addressed – including any use of biomarkers……so the information could likely be extracted NDAs/BLAs in US do not necessarily require this specificity Industry will need to step up to assist with collecting this information
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Transparency Theme Better understanding of what “qualification” means with FDA, with EMA, with PMDA Better communications of decisions Ideal to be able to share lessons learned – Rejected Letters of Intent ?? – Idea to consider a publication of Regulator’s and Industry’s perspective
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Incentive to Qualify Encourage researchers and industry to bring more tools forth for Incentive of a “priority review voucher” concept – Faster review or waiver of fees???
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