us-fda-guidance-24067d6883593212867aff411e6111ce•Fabry Disease: Developing Drugs for Treatment Guidance for Industry
Fabry Disease: Developing Drugs for Treatment Guidance for Industry
us-fda-guidance-24067d6883593212867aff411e6111ceFabry Disease: Developing Drugs for Treatment Guidance for IndustryDraft Guidance
Administrative draft guidance, not enacted legislation. This captured publisher edition preserves the listed document and attachments; later developments are not independently consolidated.
- Docket Number:
- FDA-2019-D-2973
- Issued by:
- Guidance Issuing OfficeCenter for Drug Evaluation and Research
The purpose of this guidance is to provide recommendations to sponsors regarding clinical trial design features that can support approval of drugs and biological products intended for the treatment of Fabry disease (FD).
In general, FDA’s guidance documents do not establish legally enforceable responsibilities. Instead, guidances describe the Agency’s current thinking on a topic and should be viewed only as recommendations, unless specific regulatory or statutory requirements are cited. The use of the word should in Agency guidances means that something is suggested or recommended, but not required.
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30042664dft.docx 08/06/19 Fabry Disease: Developing Drugs for Treatment Guidance for Industry DRAFT GUIDANCE This guidance document is being distributed for comment purposes only. Comments and suggestions regarding this draft document should be submitted within 90 days of publication in the Federal Register of the notice announcing the availability of the draft guidance. Submit electronic comments to https://www.regulations.gov. Submit written comments to the Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. All comments should be identified with the docket number listed in the notice of availability that publishes in the Federal Register. For questions regarding this draft document, contact (CDER) Patroula Smpokou at 240-402- 9651 or (CBER) Office of Communication, Outreach, and Development at (240) 402-8010. U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) Center for Biologics Evaluation and Research (CBER) August 2019 Clinical/Medical
Fabry Disease: Developing Drugs for Treatment Guidance for Industry Additional copies are available from: Office of Communications, Division of Drug Information Center for Drug Evaluation and Research Food and Drug Administration 10001 New Hampshire Ave., Hillandale Bldg., 4th Floor Silver Spring, MD 20993-0002 Phone: 855-543-3784 or 301-796-3400; Fax: 301-431-6353; Email: druginfo@fda.hhs.gov https://www.fda.gov/drugs/guidance-compliance-regulatory-information/guidances-drugs and/or Office of Communication, Outreach, and Development Center for Biologics Evaluation and Research Food and Drug Administration 10903 New Hampshire Ave., Bldg. 71, Room 3128 Silver Spring, MD 20993-0002 Phone: 800-835-4709 or 240-402-8010; Email: ocod@fda.hhs.gov https://www.fda.gov/vaccines-blood-biologics/guidance-compliance-regulatory-information-biologics/biologics- guidances U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) Center for Biologics Evaluation and Research (CBER) August 2019 Clinical/Medical
Contains Nonbinding Recommendations Draft — Not for Implementation TABLE OF CONTENTS I. INTRODUCTION..................................................................................................1 II. BACKGROUND ....................................................................................................1 III. KEY CONSIDERATIONS FOR CLINICAL TRIALS .....................................3 A. Eligibility Criteria ............................................................................................................. 3 B. Trial Design and Efficacy Endpoints ............................................................................... 4 1. Trial Design......................................................................................................................... 4 2. General Considerations for Efficacy Endpoints.................................................................. 5 3. Specific Considerations for Efficacy Endpoints .................................................................. 5 a. Neuropathic and gastrointestinal symptoms ................................................................. 5 b. Renal disease ................................................................................................................ 6 c. Cardiac disease ............................................................................................................. 6
Contains Nonbinding Recommendations Draft — Not for Implementation 1 Fabry Disease: Developing Drugs for Treatment 1 Guidance for Industry1 2 3 4 5 This draft guidance, when finalized, will represent the current thinking of the Food and Drug 6 Administration (FDA or Agency) on this topic. It does not establish any rights for any person and is not 7 binding on FDA or the public. You can use an alternative approach if it satisfies the requirements of the 8 applicable statutes and regulations. To discuss an alternative approach, contact the FDA staff responsible 9 for this guidance as listed on the title page. 10 11 12 13 I. INTRODUCTION 14 15 The purpose of this guidance is to provide recommendations to sponsors regarding clinical trial 16 design features that can support approval of drugs and biological products intended for the 17 treatment of Fabry disease (FD).2 18 19 In general, FDA’s guidance documents do not establish legally enforceable responsibilities. 20 Instead, guidances describe the Agency’s current thinking on a topic and should be viewed only 21 as recommendations, unless specific regulatory or statutory requirements are cited. The use of 22 the word should in Agency guidances means that something is suggested or recommended, but 23 not required. 24 25 26 II. BACKGROUND 27 28 FD is a rare, X-linked, slowly progressive, lysosomal storage disorder caused by pathogenic 29 variants (disease-causing mutations) in the galactosidase alpha (GLA) gene resulting in absent or 30 deficient activity of the lysosomal enzyme α-galactosidase A (α-Gal A). The α-Gal A enzyme 31 breaks down glycosphingolipids within lysosomes. α-Gal A deficient activity leads to 32 progressive intralysosomal accumulation of the undegraded substrate globotriaosylceramide 33 (GL-3, also known as Gb3), a glycosphingolipid. FD is characterized by chronic 34 symptomatology (e.g., gastrointestinal symptoms, neuropathic symptoms including pain, 35 hypohidrosis or anhidrosis), slowly progressive organ damage eventually leading to chronic renal 36 disease and renal failure, cardiovascular disease (e.g., hypertrophic cardiomyopathy, heart 37 1 This guidance has been prepared by the Division of Gastroenterology and Inborn Errors Products in the Center for Drug Evaluation and Research in cooperation with the Center for Biologics Evaluation and Research at the Food and Drug Administration. 2 For purposes of this guidance, unless otherwise specified, references to drugs include drugs submitted for approval or approved under section 505(b) or (j) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) and biological products submitted for licensure or licensed under section 351 of the Public Health Service Act, other than biological products that also meet the definition of a device in section 201(h) of the FD&C Act (21 U.S.C. 321(h)).
Contains Nonbinding Recommendations Draft — Not for Implementation 2 failure, myocardial infarction, arrhythmias), cerebrovascular disease (strokes), and early 38 mortality.3 39 40 FD is divided into two subtypes based on age of symptom onset and extent of organ 41 involvement:4 42 43 • Classic FD presents in patients with absent or minimal residual α-Gal A enzyme activity 44 (less than 1 percent of mean normal). Childhood-onset clinical manifestations in classic 45 FD include chronic gastrointestinal symptoms (e.g., diarrhea, abdominal pain, 46 constipation), neuropathic pain crises involving the extremities (acroparesthesias), 47 proteinuria, and hypohidrosis or anhidrosis leading to heat and exercise intolerance. 48 Angiokeratomas on the skin and cornea verticillata (corneal whorls) on ophthalmologic 49 slit lamp exam, both asymptomatic, are also sometimes observed. Adult-onset 50 manifestations in classic FD include progressive renal failure, cardiac disease (e.g., 51 hypertrophic cardiomyopathy, heart failure, myocardial infarction, arrhythmias), and 52 stroke, which cause chronic morbidity and early mortality. The highest concentrations in 53 tissues and plasma of the substrate GL-3 and of its degradation product, 54 globotriaosylsphingosine (lyso-GL-3), are typically seen in patients with classic FD. 55 56 • Nonclassic (late-onset) FD is more prevalent than classic FD.5 Patients with late-onset 57 FD have some residual α-Gal A enzyme activity, which is highly variable (greater than 1 58 percent of mean normal). Late-onset FD presents clinically in adulthood with renal, 59 cardiac, and/or cerebrovascular disease; has a highly variable age-of-symptom onset; and 60 follows a highly variable rate of progression.6 Within the late-onset subtype, patients may 61 have only single organ involvement.7 Patients with late-onset FD (and female patients) 62 show variable levels in tissues and plasma of the substrate GL-3 and its degradation 63 product, lyso-GL-3. 64 65 Despite its X-linked inheritance, FD affects both males and females, although to different 66 degrees. In general, male patients with the classic subtype experience the most severe clinical 67 manifestations, multi-organ disease, faster disease progression, and an earlier age of symptom 68 onset compared to male patients with the late-onset subtype and to female patients. In female 69 3 Germain, DP, 2010, Fabry Disease, Orphanet J Rare Dis, 5:30, doi: 10.1186/1750-1172-5-30. 4 Germain, DP, 2010, Fabry Disease, Orphanet J Rare Dis, 5:30, doi: 10.1186/1750-1172-5-30; Spada M, Pagliardini S, Yasuda M, Tukel T, Thiagarajan G, Sakuraba H, Ponzone A, and Desnick RJ, 2006, High Incidence of Later- Onset Fabry Disease Revealed by Newborn Screening, Am J Hum Genet, 79(1):31–40; and Ortiz A, Germain DP, Desnick RJ, et al., 2018, Fabry Disease Revisited: Management and Treatment Recommendations for Adult Patients, Mol Genet Metab,123(4):416–427. 5 Ortiz A, Germain DP, Desnick RJ, et al., 2018, Fabry Disease Revisited: Management and Treatment Recommendations for Adult Patients, Mol Genet Metab, 123(4):416–427. 6 Ortiz A, Germain DP, Desnick RJ, et al., 2018, Fabry Disease Revisited: Management and Treatment Recommendations for Adult Patients, Mol Genet Metab, 123(4):416–427. 7 Spada M, Pagliardini S, Yasuda M, Tukel T, Thiagarajan G, Sakuraba H, Ponzone A, Desnick RJ, 2006, High Incidence of Later-Onset Fabry Disease Revealed by Newborn Screening, Am J Hum Genet, 79(1):31–40.
Contains Nonbinding Recommendations Draft — Not for Implementation 3 patients, disease severity and age of symptom onset depend, at least partly, on tissue-specific X 70 chromosome inactivation. The spectrum of organ involvement and disease severity in female 71 patients with FD can range from completely asymptomatic to the severe phenotype seen in male 72 patients with classic FD. Overall, the rate of disease progression is highly variable in male 73 patients with late-onset FD and in female patients. 74 75 76 III. KEY CONSIDERATIONS FOR CLINICAL TRIALS 77 78 A. Eligibility Criteria 79 80 All eligible patients should have a confirmed diagnosis of FD based on both biochemical testing 81 and molecular genetic testing (as outlined below). Of note, both plasma and leukocyte α-Gal A 82 activity should be assayed given that some pathogenic GLA variants affect intracellular 83 trafficking and secretion of α-Gal A such that the reduction in α-Gal A enzyme activity in plasma 84 may be more pronounced than within leukocytes. Clinical trials should allow enrollment of both 85 male and female patients. As early as feasible, sponsors should consider enrolling pediatric 86 patients with FD in clinical trials. 87 88 Criteria for confirming the diagnosis of FD should include, at a minimum, the following:8 89 90 • In symptomatic male patients: 91 92 − Absent or minimal α-Gal A enzyme activity (i.e., less than 1 percent of the mean 93 normal) in both plasma and isolated peripheral leukocytes. 94 95 − When α-Gal A enzyme activity is low but not absent (i.e., greater than 1 percent of 96 the mean normal), identification of a clinically significant9 GLA variant (mutation). 97 98 8 Mehta A and Hughes DA, 2017, Fabry Disease. In: Adam MP, Ardinger HH, Pagon RA, et al., editors, GeneReviews, Seattle (WA): University of Washington, Seattle, accessed July 30, 2018, https://www.ncbi.nlm.nih.gov/books/NBK1292/; and Arends M, Wanner C, Hughes D, et al., 2017, Characterization of Classical and Nonclassical Fabry Disease: A Multicenter Study, J Am Soc Nephrol, 28(5):1631–1641. 9 Richards S, Aziz N, Bale S, et al., 2015, Standards and Guidelines for the Interpretation of Sequence Variants: A Joint Consensus Recommendation of the American College of Medical Genetics and Genomics and the Association for Molecular Pathology, Genet Med, 17(5):405–424. Laboratory reports of genetic testing results may include the terms likely pathogenic or pathogenic to characterize whether a given GLA variant (mutation) causes FD. For the purposes of this guidance, the term clinically significant includes variants considered either pathogenic or likely pathogenic.
Contains Nonbinding Recommendations Draft — Not for Implementation 4 • In symptomatic female patients: 99 100 − Identification of a clinically significant10 GLA variant. This is needed as α-Gal A 101 enzyme activity may range from normal to absent because of the presence of both 102 normal and abnormal copies of the GLA gene in tissues. 103 104 In cases where the GLA variant is considered a “variant of uncertain significance,”11 additional 105 biochemical and/or histopathological evidence should be used to establish the diagnosis of FD 106 (e.g., elevated plasma lyso-GL-3, demonstration of tissue GL-3 inclusions or other). 107 108 109 B. Trial Design and Efficacy Endpoints 110 111 1. Trial Design 112 113 Given the rarity of FD, sponsors can use a single adequate and well-controlled trial (as described 114 in 21 CFR 314.126), showing a clinically meaningful treatment effect on core clinical aspects of 115 FD, as the basis for drug approval when accompanied by confirmatory evidence. A parallel- 116 group design should be used with an appropriate concurrent control group (placebo or active 117 treatment). Sponsors should consider stratifying at randomization by known prognostic factors, 118 such as sex and age. If the drug is intended to slow or arrest disease progression but not reverse 119 it, the trial should be of sufficient duration to observe disease progression in the control group. 120 There are special considerations regarding the length of long-term follow up for gene therapy 121 products.12 122 123 Importantly, all laboratory tests conducted in a clinical development program should be 124 performed using appropriately validated methods to ensure reliability of the results and should be 125 conducted at a central laboratory. 126 127 10 Richards S, Aziz N, Bale S, et al., 2015, Standards and Guidelines for the Interpretation of Sequence Variants: a Joint Consensus Recommendation of the American College of Medical Genetics and Genomics and the Association for Molecular Pathology, Genet Med, 17(5):405–424. See footnote 9. 11 Richards S, Aziz N, Bale S, et al., 2015, Standards and Guidelines for the Interpretation of Sequence Variants: a Joint Consensus Recommendation of the American College of Medical Genetics and Genomics and the Association for Molecular Pathology, Genet Med, 17(5):405–424. 12 See the draft guidance for industry Long Term Follow-Up After Administration of Human Gene Therapy Products (July 2018). When final, this guidance will represent the FDA’s current thinking on this topic. For the most recent version of a guidance, check the FDA guidance web page at https://www.fda.gov/regulatory-information/search-fda- guidance-documents.
Contains Nonbinding Recommendations Draft — Not for Implementation 5 2. General Considerations for Efficacy Endpoints 128 129 Demonstration of clinical benefit on any core disease manifestation (e.g., renal disease, 130 cardiovascular disease, cerebrovascular disease, gastrointestinal symptoms, neuropathic 131 symptoms, pain) can be the basis for traditional approval.13 When selecting efficacy endpoints, 132 the sponsor should consider the natural history and time course of the selected disease 133 manifestation(s) assessed, the drug’s mechanism of action and the target organ(s), and the target 134 FD patient population or subpopulation. For instance, certain clinical outcome assessments may 135 not be appropriate for use in pediatric FD patients based on their age or symptom presence or 136 absence or severity. Similarly, classic FD and late-onset FD patients often have differences both 137 in the presence of disease manifestations (some late-onset FD patients may only have renal 138 disease or only cardiac disease) and in the rate of disease progression. Given the multisystemic 139 nature of FD, the highly variable rate of disease progression (especially in late-onset FD patients 140 and in female patients), and the heterogeneity of clinical manifestations, sponsors could consider 141 combining multiple clinical outcomes for assessment in clinical trials. Specifically, sponsors 142 could consider the use of a composite endpoint such that changes in symptoms and/or functional 143 outcomes could be captured across a variety of FD manifestations. The choice of such endpoints 144 could be based on baseline symptom presence and severity in enrolled patients. FDA strongly 145 encourages sponsors to engage in early discussions (as early as the pre-investigational new drug 146 application phase) with the appropriate review division regarding the selection of efficacy 147 endpoints and when considering combining efficacy outcomes for demonstration of efficacy. 148 149 3. Specific Considerations for Efficacy Endpoints 150 151 a. Neuropathic and gastrointestinal symptoms 152 153 Sponsors can establish drug effectiveness with the demonstration of clinically meaningful 154 improvement in neuropathic symptoms, including pain, or gastrointestinal symptoms (abdominal 155 pain, diarrhea, constipation). Sponsors should select well-defined and reliable instruments for 156 assessments of changes in such symptoms in accordance with the recommendations of the 157 guidance for industry Patient-Reported Outcome Measures: Use in Medical Product 158 Development to Support Labeling Claims (December 2009). FDA strongly encourages sponsors 159 to engage early with the appropriate review division for selection of the most appropriate clinical 160 outcome assessment instruments. FDA encourages the development of publicly available, fit-for- 161 purpose, patient-reported outcome instruments that can be used across multiple drug 162 development programs in FD to facilitate and accelerate drug development in this disease.14 163 164 13 The term traditional approval denotes the longstanding route of drug approval based on the demonstration of clinical benefit or an effect on a surrogate endpoint known to predict clinical benefit. That term is distinguished from accelerated approval, which is associated with use of a surrogate endpoint or intermediate clinical endpoint that is reasonably likely to predict clinical benefit to support drug approval. 14 See the draft guidance for industry and FDA staff Qualification Process for Drug Development Tools (January 2014). When final, this guidance will represent the FDA’s current thinking on this topic. For the most recent version of a guidance, check the FDA guidance web page at https://www.fda.gov/regulatory-information/search-fda- guidance-documents.
Contains Nonbinding Recommendations Draft — Not for Implementation 6 b. Renal disease 165 166 Sponsors could use the demonstration of a sustained treatment effect on a specified magnitude of 167 loss of renal function (e.g., a 30 percent decline in glomerular filtration rate (GFR), assessed via 168 a widely accepted estimating equation for GFR or measured GFR) or on the rate of loss of renal 169 function as the basis for traditional drug approval. In general, sponsors of trials using rate of loss 170 of renal function as an endpoint (e.g., a comparison of the annualized change in estimated GFR 171 (eGFR) between the treatment arms) should assess whether the treatment effect continues to 172 accrue across the various stages of renal disease by enrolling patients with different levels of 173 renal function at baseline. In addition, the trial duration should be sufficient (generally at least 24 174 months) to evaluate for long-term effectiveness and to obtain a more reliable estimate of the 175 treatment effect on the rate of change in eGFR. 176 177 In general, programs should collect information on progression to end-stage renal disease 178 requiring chronic dialysis or renal transplantation while acknowledging that such events are 179 likely to be uncommon in clinical trials of early-stage renal disease in FD given the slowly 180 progressive nature of FD. 181 182 Sponsors can use histological reduction of GL-3 inclusion burden in biopsied kidney interstitial 183 capillaries (KIC) as a surrogate endpoint reasonably likely to predict clinical benefit to support 184 accelerated approval. If a sponsor plans to use a surrogate endpoint based on histological 185 assessment of GL-3 inclusions, FDA encourages the sponsor to engage in early discussion with 186 the appropriate review division to more precisely define such an endpoint (including the 187 magnitude of change in that endpoint) that would be reasonably likely to predict clinical benefit. 188 When assessing (counting) KIC GL-3 inclusions in histology specimens, the sponsor should use 189 validated and standardized assay methodologies, and scoring of KIC GL-3 inclusions should be 190 conducted by experienced pathologists in a blinded and systematic fashion. In general, 191 postmarketing studies to verify and describe the clinical benefit should already be underway at 192 the time of submission of a marketing application. FDA encourages sponsors to engage in early 193 discussion with the appropriate review division regarding trial design features of such 194 postmarketing studies. 195 196 Patients’ concomitant therapies that could affect renal function or the measurement of renal 197 function (e.g., angiotensin converting enzyme inhibitors, angiotensin receptor blockers) should 198 be optimized before trial enrollment, and doses of such therapies should remain stable for the 199 duration of the trial. 200 201 Although proteinuria is an important prognostic marker in patients with renal diseases in general, 202 including FD, it is not clear whether treatment effects on proteinuria predict treatment effects on 203 important renal outcomes in FD. At this time, additional evidence is needed to support the use of 204 proteinuria as a validated or reasonably likely surrogate endpoint for clinical benefit in FD. 205 206 c. Cardiac disease 207 208 Endpoints that assess treatment effects on cardiovascular hospitalization, functional capacity 209 (e.g., exercise capacity), and/or cardiovascular symptoms can be used to provide evidence of 210
Contains Nonbinding Recommendations Draft — Not for Implementation 7 effectiveness in treating the cardiac manifestations of FD. At this time, additional evidence is 211 needed to support the use of left ventricular mass index and global longitudinal strain as 212 validated or reasonably likely surrogate endpoints for clinical benefit in FD. 213
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