Can You Predict Whether You Will Face an FDA Advisory Committee?

blog header linkedin - Prediction Ad Com v5 resizeThe US Food and Drug Administration (FDA) review of drugs, although guided by broad standards, remains individualized. Each drug or drug class faces unique challenges during the FDA review phase – thus no two reviews are exactly the same. Each review division within the FDA has its own approach, and evaluations often differ among the centers. To help understand the review process, the team at ProEd Regulatory sought to learn from the past to inform our future. We reviewed applications submitted to the Center for Drug Evaluation and Research (CDER) data over the last 70 years to see what patterns might emerge. Although the largest proportion of products (drugs and biologics) fails between discovery and Phase 3, an evaluation of applications submitted to the FDA over the last 70 years shows that the vast majority of products that reach the submission stage are ultimately approved (Figure 1).1
predict_fig_1It wasn’t until the Kefauver-Harris Drug Amendments of 1962 that the FDA required sponsors to demonstrate both efficacy and safety of their drugs prior to market access. In the wake of this significant legislation’s impact on drug development, we still see a consistent flow of approved applications and a corresponding subset of new molecular entities (NMEs) (Figure 2).1

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GPP3: Is It a Better Guidance?

blog header linkedin - GPP3 v3 FINAL WP

The International Society for Medical Publication Professionals (ISMPP) recently released its latest guidance—GPP3, or Good Publication Practice 3. This is the first update of the ISMPP guidance since GPP2 was released in 2009. A steering committee first met to draft the guidance, and then ProEd colleagues, Laura McCormick, PhD; Heather Hlousek, and Jim Cozzarin, ELS, had the privilege, with 91 reviewers (from agencies and sponsors), to provide critical feedback before the new guidance was published in Annals of Internal Medicine.1

So, what are the important changes from GPP2? In addition to being more user-friendly than its predecessor—with an overall simplification of language and format, a new Guiding Principles section, and quick reference tables that address guidance on authorship criteria and common authorship issues—GPP3 also reflects some important updates and new elements1:

  • Updated International Committee of Medical Journal Editors (ICMJE) 2013 authorship criteria
  • Common issues regarding authorship
  • Improved clarity on author payment and reimbursement
  • Additional clarity on what constitutes ghost or guest authorship
  • Expanded information on the role and benefit of professional medical writers
  • Guidance for appropriate data sharing

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