However, in rare diseases, we're working with very limited patient populations. It does often bring into question whether it's ethical to give a patient with such a rare disease a placebo. Allowing the sponsors that flexibility to use natural history data as the control arm in the trials is something that we have seen used to get accelerated approval (and then they are required to run a larger phase three trial to confirm those results as well).
That's one area of flexibility that we have seen previously, but we’re also seeing novel endpoints across clinical trials. We are also seeing biomarkers accepted as relevant endpoints that can then determine the efficacy of the asset at a later stage. FDA has also come up with the plausible mechanism pathway.
PE: How do recent actions from FDA provide insight to the agency's enforcement posture?
Johari: Things are changing almost every day within that space. In theory, there are good guidelines and guardrails that FDA has put into place to allow innovative development in the CTD and rare diseases.
One thing that is not missed across regulators and sponsors alike is that safety is paramount. We're often dealing with either very young patients or patients that have no other options. So, making sure that we're delivering a safe treatment is going to be the number one priority, as well as making sure it is efficacious and delivers on the benefit that the sponsors are promising.
On one hand, the guidelines are pushing towards that and promising additional hope for the sponsors. With the CRS that we're seeing come through, I think it's raising doubts as to how FDA is actually taking these guidelines and applying them into practice.
There have been comments made about the clinical trial design or the control arm used which might not always resonate with the guidelines that have been shared previously. That's where a lot of uncertainty is coming into play for the sponsors.
There is likely the need for more alignment across the regulators to ensure that the regular touch point meetings are conveying the message and the sponsors are able to act on it accordingly.
PE: How have recent regulatory actions impacted the rare disease space?
Johari: When we look at the rare disease space in general, we are seeing that rare disease is often explored by smaller companies that are working on maybe one or two assets in a very niche indication. They are really focused on those assets that they are developing for this large unmet need population.
However, we have seen recent changes in the past hinting that Big Pharma is also showing signs of interest with rare diseases. This might come through acquisitions of the smaller biotechs, but they're really looking for that proof-of-concept and making sure that in theory, the cell or gene therapy is delivering on the promise that they're showing.