us-fda-guidance-3ff0d95cb3ea2e4fb022f6e8f14ac1f4•Interstitial Cystitis/Bladder Pain Syndrome: Establishing Drug Development Programs for Treatment: Draft Guidance for Industry
Interstitial Cystitis/Bladder Pain Syndrome: Establishing Drug Development Programs for Treatment: Draft Guidance for Industry
us-fda-guidance-3ff0d95cb3ea2e4fb022f6e8f14ac1f4Interstitial Cystitis/Bladder Pain Syndrome: Establishing Drug Development Programs for Treatment: Draft Guidance for IndustryDraft Guidance
Administrative draft guidance, not enacted legislation.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-4656
- Issued by:
- Guidance Issuing OfficeCenter for Drug Evaluation and Research
The Food and Drug Administration (FDA or Agency) is announcing the availability of a draft guidance for industry entitled “Interstitial Cystitis/Bladder Pain Syndrome: Establishing Drug Development Programs for Treatment.” This draft guidance is intended to revise and replace the current draft guidance for industry entitled “Interstitial Cystitis/Bladder Pain Syndrome (IC/BPS): Establishing Effectiveness of Drugs for Treatment” issued on December 5, 2019. This draft guidance provides recommendations for drug development programs for drugs intended to treat patients with interstitial cystitis/bladder pain syndrome (IC/BPS).
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43360869dft.docx 05/09/23 Interstitial Cystitis/Bladder Pain Syndrome: Establishing Drug Development Programs for Treatment Guidance for Industry DRAFT GUIDANCE This guidance document is being distributed for comment purposes only.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be submitted within 60 days of publication in the Federal Register of the notice announcing the availability of the draft guidance.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 Margaret Kober at 301-796-0934. U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) June 2023 Clinical/Medical Revision 1
Interstitial Cystitis/Bladder Pain Syndrome: Establishing Drug Development Programs 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 U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) June 2023 Clinical/Medical Revision 1
TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. 1 II. BACKGROUND ............................................................................................................... 2 III. EARLY DRUG DEVELOPMENT PROGRAM FEATURES–KEY CONSIDERATIONS ........................................................................................................ 3 IV. CLINICAL TRIAL DESIGN FEATURES–KEY CONSIDERATIONS .................... 5 A. Enrollment Criteria ....................................................................................................................... 5 B. Clinical Trials Efficacy Endpoints ............................................................................................... 6 C. Other Considerations..................................................................................................................... 6 D. Hunner’s Lesions Subpopulation ................................................................................................. 7 E. Selecting Potential PRO and Other Secondary Endpoints for IC/BPS Clinical Trials ........... 8
Contains Nonbinding Recommendations Draft — Not for Implementation 1 Interstitial Cystitis/Bladder Pain Syndrome: Establishing Drug 1 Development Programs for Treatment 2 Guidance for Industry1 3 4 5 6 This draft guidance, when finalized, will represent the current thinking of the Food and Drug 7 Administration (FDA or Agency) on this topic. It does not establish any rights for any person and is not 8 binding on FDA or the public. You can use an alternative approach if it satisfies the requirements of the 9 applicable statutes and regulations. To discuss an alternative approach, contact the FDA staff responsible 10 for this guidance as listed on the title page. 11 12 13 14 I. INTRODUCTION 15 16 This guidance provides recommendations for clinical drug development for drugs intended to treat 17 patients with interstitial cystitis/bladder pain syndrome (IC/BPS). This guidance incorporates 18 advice FDA received at a December 2017 advisory committee meeting2 on appropriate patient 19 selection criteria and trial design features, including enrollment criteria and acceptable efficacy 20 endpoints for drugs intended to treat IC/BPS. 21 22 In general, FDA’s guidance documents do not establish legally enforceable responsibilities. 23 Instead, guidance documents describe the Agency’s current thinking on a topic and should be 24 viewed only as recommendations, unless specific regulatory or statutory requirements are cited. 25 The use of the word should in Agency guidance documents means that something is suggested or 26 recommended, but not required. 27 28 Although this guidance discusses the selection of endpoints for clinical trials, it does not address 29 detailed design considerations for patient-reported outcome (PRO) instruments. Those issues are 30 addressed in the FDA guidance for industry Patient-Reported Outcome Measures: Use in 31 1 This guidance has been prepared by the Division of Urology, Obstetrics, and Gynecology in the Center for Drug Evaluation and Research at the Food and Drug Administration. 2 Information on the meeting of the Bone, Reproductive and Urologic Drugs Advisory Committee is available at https://public4.pagefreezer.com/browse/FDA/01-03-2022T00:42/https:/www.fda.gov/advisory-committees/bone- reproductive-and-urologic-drugs-advisory-committee-formerly-reproductive-health-drugs-advisory/2017-meeting- materials-bone-reproductive-and-urologic-drugs-advisory-committee-formerly-advisory.
Contains Nonbinding Recommendations Draft — Not for Implementation 2 Medical Product Development to Support Labeling Claims (December 2009)3 and the FDA 32 Patient-Focused Drug Development (PFDD) guidance series.4 33 34 35 II. BACKGROUND 36 37 IC/BPS is a complex, poorly understood heterogeneous syndrome of unknown etiology. 38 39 Interstitial cystitis (IC) was first characterized over 100 years ago in patients as a symptom 40 complex with these two factors: 41 42 • Bladder pain related to bladder filling 43 • Historical pathognomonic cystoscopic finding of Hunner’s lesion5 in the bladder 44 45 In the intervening years, beginning in the 1970s and 1980s, there began a gradual 46 acknowledgment that IC might encompass more diverse forms of the disorder than solely 47 identifying patients with Hunner’s lesions (mucosal lesions or ulcerations seen with or without 48 hydrodistention of the bladder). The disorder definition was expanded to include patients with 49 very similar symptoms but not necessarily requiring the presence of Hunner’s lesions on 50 cystoscopic examination. 51 52 Clinical IC management has evolved and expanded to include patients with symptoms of pain or 53 discomfort and accompanying urinary symptoms, and with or without obvious bladder 54 inflammation, which encompasses a very heterogeneous patient population, hereafter referred to 55 as IC/BPS. 56 57 Currently, there are no FDA-authorized diagnostic laboratory tests or biomarkers to establish IC/BPS 58 presence or response to therapy. There is wide variability in IC/BPS diagnostic criteria, which results 59 in patient population heterogeneity, complicating development of drugs for widespread use among 60 all patient subpopulations. 61 62 In general, current IC/BPS clinical diagnosis requires the following: 63 64 • Chronic pain or discomfort localized to the bladder with the following variabilities: 65 66 – Can be related to bladder filling and/or voiding 67 – Can be constant, of variable intensity, or intermittent in nature 68 3 We update guidances periodically. 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. 4 These guidances are part of FDA’s PFDD efforts in accordance with the 21st Century Cures Act and the Food and Drug Administration Reauthorization Act of 2017 Title I. When final, the PFDD guidance series will replace the 2009 final PRO guidance. 5 Hunner G., 1918, A Rare Type of Bladder Ulcer: Further Notes, with a Report of Eighteen Cases, JAMA, 70(4):203–212.
Contains Nonbinding Recommendations Draft — Not for Implementation 3 69 • Accompanying lower urinary tract symptoms such as urinary frequency, urgency, or 70 nocturia 71 72 • Exclusion of other disorders or conditions that can have similar presentations, such as 73 malignancy, any surgically diagnosed endometriosis, chronic prostatitis, and bladder 74 outlet obstruction 75 76 • Cystoscopy may show bladder inflammation, including Hunner’s lesions or other 77 nonspecific pathology, but also can be normal. 78 79 80 III. EARLY DRUG DEVELOPMENT PROGRAM FEATURES–KEY 81 CONSIDERATIONS 82 83 Current IC/BPS clinical diagnosis criteria encompasses a very heterogeneous patient population 84 who present with a common symptom: pain or discomfort localized to the bladder. Historically, 85 this has resulted in difficulty developing drug products intended for use in a heterogenous patient 86 population. Early clinical trials during drug development should focus on well-defined IC/BPS 87 populations with similar clinical features in addition to pain or discomfort localized to the 88 bladder. This approach may better inform the selection of clinically meaningful efficacy 89 endpoints and outcomes for future studies. 90 91 Sponsors are encouraged to assess dosing strategies, including dose-finding. In addition, drug 92 programs should explore multiple efficacy endpoints, and collect safety information during early 93 drug development to inform design strategy and selection of clinically meaningful endpoints for 94 later studies. 95 96 Patients’ experience with IC/BPS symptoms may vary (e.g., symptom type, severity, and 97 duration). It is important to incorporate the patient’s voice during early drug development. 98 Obtaining information from patients can better define the appropriate target population (e.g., 99 IC/BPS patient subpopulations) and identify what matters most to patients regarding their 100 condition to inform endpoint selection. Sponsors should specify and define concepts (e.g., 101 symptoms, functional impacts) early in development that are both relevant and important to 102 patients with IC/BPS. These concepts are more likely to lead to demonstration of clinically 103 meaningful and interpretable changes in later planned clinical trials. Identification of concepts 104 should come from patient input (e.g., conducting patient interviews, identifying literature related 105 to previously conducted patient qualitative studies). The Agency refers sponsors to the following 106 guidances for industry, FDA staff, and other stakeholders for more details about the collection of 107 evidence to inform the patient experience and obtain information from patients, caregivers, and 108 other relevant stakeholders: 109 110
Contains Nonbinding Recommendations Draft — Not for Implementation 4 • Patient-Focused Drug Development: Collecting Comprehensive and Representative 111 Input (June 2020)6 112 113 • Patient-Focused Drug Development: Methods to Identify What Is Important to Patients 114 (February 2022) 115 116 Once concepts from patient input are identified, sponsors should select and prioritize fit-for- 117 purpose patient-reported outcome (PRO) assessments and related endpoints to assess the targeted 118 concepts in their phase 2 clinical trials.7 The Agency encourages collaboration among patient 119 groups, medical product developers, PRO developers, and other stakeholders with the goal of 120 generating publicly available fit-for-purpose8 PRO instruments for use in IC/BPS across multiple 121 medical product development programs.9 122 123 In general, FDA recommends that early targeted IC/BPS studies assess the following concepts 124 related to the patient experience, at a minimum: 125 126 • Most bothersome pain or discomfort symptom(s) 127 128 • Accompanying urinary symptom(s) not captured by the pain or discomfort outcome (e.g. 129 urinary frequency, urgency, or nocturia) 130 131 • Symptom intensity/severity scoring or measurement, where applicable 132 133 • Symptom changes, including worsening of symptoms 134 135 • Functional impacts (e.g., interference with daily activities) 136 137 Sponsors may refine their IC/BPS indication during the drug development program based on 138 earlier study results to include the following: 139 140 • Findings in the targeted patient subpopulations 141 • Focused inclusion/exclusion criteria 142 6 We update guidances periodically. 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. 7 See the draft guidance for industry, FDA staff, and other stakeholders Patient-Focused Drug Development: Selecting, Developing, or Modifying Fit-for Purpose Clinical Outcome Assessments (June 2022) and the draft guidance for industry Patient-Focused Drug Development: Incorporating Clinical Outcome Assessments Into Endpoints For Regulatory Decision-Making (April 2023). When final, these guidances will represent the FDA’s current thinking on these topics. 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. 8 For purposes of this guidance, fit-for-purpose is defined as a conclusion that the level of validation associated with a tool is sufficient to support its context of use. See the BEST (Biomarkers, Endpoints, and other Tools) Resource, available at https://www.ncbi.nlm.nih.gov/books/NBK326791/?report=reader. 9 See the guidance for industry and FDA staff Qualification Process for Drug Development Tools (November 2020).
Contains Nonbinding Recommendations Draft — Not for Implementation 5 • Diagnostic procedures follow-up or serial diagnostic procedures for confirmation of 143 effect(s) 144 145 146 IV. CLINICAL TRIAL DESIGN FEATURES–KEY CONSIDERATIONS 147 148 A. Enrollment Criteria 149 150 Sponsors of investigational drugs intended to treat IC/BPS should consider including the 151 following for subject enrollment criteria in clinical trials: 152 153 • Subjects should report bladder pain and/or bladder discomfort and lower urinary tract 154 symptoms: 155 156 – Subjects should have at least 6 months’ duration of bladder pain and/or discomfort 157 symptom(s) before enrollment to exclude other disorders with similar presentations 158 that have a shorter time course. 159 160 – Subjects should have at least 6 months’ duration of one or more accompanying lower 161 urinary tract symptom(s), such as urinary frequency, urgency, or nocturia. This may be 162 intermittent or persistent. 163 164 • The reported symptoms (bladder pain and/or bladder discomfort and lower urinary tract 165 symptoms) should be of sufficient severity (intensity or frequency) at baseline to allow 166 for measurement of a clinically meaningful improvement with the drug (i.e., a score 167 greater than the prespecified threshold or range of thresholds for clinically meaningful 168 within-patient change). Refer to section E, Selecting Potential PRO and Secondary 169 Endpoints for IC/BPS Clinical Trials, later in this guidance. 170 171 • Subjects should have a cystoscopy at screening (if not obtained within the preceding 6 172 months) to exclude other conditions (e.g., transitional cell carcinoma and endometriosis, 173 etc.). 174 175 • Subjects may have received prior treatment(s) for IC/BPS, including surgical procedures 176 such as fulguration. In general, FDA recommends including these subjects in the trials to 177 improve the generalizability of the results unless a compelling effectiveness or safety 178 reason exists for excluding them. During the protocol trial design phase, sponsors should 179 discuss with the Agency the extent to which such subjects should be included in the trials. 180 181 • Subjects should undergo standard medical evaluation to exclude other conditions or 182 diseases that can cause similar symptoms, using information from medical history, 183 physical and pelvic examination findings, laboratory studies (e.g., negative urine bacterial 184 culture), and other previously performed procedures (e.g., gynecologic or prostate 185 examination, urodynamics, cystoscopy, laparoscopy, radiological studies). 186 187
Contains Nonbinding Recommendations Draft — Not for Implementation 6 B. Clinical Trials Efficacy Endpoints 188 189 When developing efficacy endpoints for clinical trials, sponsors of investigational drugs intended 190 to treat IC/BPS should include both of the following as co-primary endpoints: 191 192 • Improvement in bladder pain and/or bladder discomfort 193 • Improvement in accompanying lower urinary tract symptom(s) 194 195 Sponsors are reminded that statistical improvement in these symptoms is not sufficient. Sponsors 196 should demonstrate that the changes reported are clinically meaningful to establish effectiveness 197 (refer to section E for more details about interpretation of PRO results). 198 199 If a drug is not expected to improve lower urinary tract symptoms10 based on the mechanism of 200 action specific for IC/BPS, a single primary effectiveness endpoint related to symptoms of 201 bladder pain and/or bladder discomfort may be considered, but clinical meaningfulness should 202 still be demonstrated. However, lower urinary tract symptoms should still be captured as a 203 secondary endpoint as these symptoms should not be worsened by the drug. 204 205 Sponsors should discuss with the Agency early in the development program the endpoints, 206 analyses, and anchors11 to ensure that study results are both clinically meaningful and 207 interpretable. 208 209 C. Other Considerations 210 211 Sponsors of investigational drugs intended to treat IC/BPS should also consider the following for 212 trial design: 213 214 • Treatment duration should be at least 6 months to adequately assess persistence of benefit 215 and capture intermittent symptomatic disease flares. For example, studies can be 216 designed with two treatment phases: 217 218 − Randomized, double-blind, placebo-controlled treatment phase of a minimum of 3 219 months or longer 220 221 − Extension treatment phase of a minimum of 3 months or longer following the initial 222 randomized, double-blind, placebo-controlled phase. This extension phase could be 223 open-label, crossover, or active control. 224 225 10 See section II, Background, “lower urinary tract symptoms such as urinary frequency, urgency, or nocturia.” 11 For general recommendations regarding PRO instruments and documents to be provided to FDA for review, see the guidance for industry Patient-Reported Outcome Measures: Use in Medical Product Development to Support Labeling Claims and the FDA Patient-Focused Drug Development Guidance Series for Enhancing the Incorporation of the Patient’s Voice in Medical Product Development and Regulatory Decision Making, available at https://www.fda.gov/drugs/development-approval-process-drugs/fda-patient-focused-drug-development-guidance- series-enhancing-incorporation-patients-voice-medical.
Contains Nonbinding Recommendations Draft — Not for Implementation 7 • Other randomized, double-blind, placebo-controlled study design approaches for a 226 dedicated 6-month-or-longer trial may be appropriate depending on the drug under 227 development. Sponsors should discuss their approach with the Agency before initiating 228 the trials. 229 230 • Sponsors should clearly prespecify in the protocol and statistical analysis plan how: 231 232 – Bladder pain or discomfort will be defined, documented, and treated during clinical 233 trials, including localization to bladder (i.e., physical findings, patient-derived 234 diagrams, etc.) 235 236 – Pain flares will be defined, documented, and treated during clinical trials 237 238 – Types and doses of rescue medications and accompanying sensitivity analysis will be 239 used and documented during clinical trials 240 241 The following should be discussed with the Agency in advance of clinical trial initiation: 242 243 • How sponsors will include targeted subgroups in their drug development program (e.g., 244 patients with Hunner’s lesion(s)). 245 246 • How sponsors will ensure that there is a sufficient representative proportion of males and 247 females in the clinical trials for a general IC/BPS indication. Sponsors should take into 248 consideration the underlying proportion of males and females in the IC/BPS population 249 or subpopulation targeted by the drug. We encourage sponsors to collect information on 250 race, age, and other demographics to assist enrichment of their patient population. If the 251 product is studied only in a specific subpopulation, the labelled indication would be 252 limited to that subpopulation. 253 254 D. Hunner’s Lesions Subpopulation 255 256 Patients with Hunner’s lesions have been described in the literature as a “classic” IC patient 257 population, distinguishable from other IC/BPS populations. Hunner’s lesions have been 258 described as distinctive inflammatory bladder wall areas, found only at cystoscopy.12 Patients 259 with Hunner’s lesions may be a subgroup of IC/BPS patients, and alternative endpoints, such as 260 healed lesion and regression of bladder inflammation, may be considered in designing clinical 261 trials in this subgroup.13 262 263 FDA recommends that sponsors specify criteria for diagnosis and treatment benefits if patients 264 with documented Hunner’s lesions are included in studies. Sponsors may study patients with 265 12 Fall, M, Y Logadottir, and R Peeker, 2014, Interstitial Cystitis Is Bladder Pain Syndrome With Hunner’s Lesion, Int J Urology, 21(Suppl 1): 79–82. 13 Peeker, R, F. Aldenborg, and M Fall, 2000, Complete Transurethral Resection of Ulcers in Classic Interstitial Cystitis, Int Urogynecol J, 11:290–295.
Contains Nonbinding Recommendations Draft — Not for Implementation 8 Hunner’s lesions alone or include this group as a subpopulation in individual trials. Detailed 266 design features should be discussed with the Division in advance. 267 268 If studies are restricted to patients with documented Hunner’s lesions, sponsors should ensure 269 that the diagnostic tools used to diagnose Hunner’s lesions are available for use by the intended 270 provider community in the United States. If sponsors determine that they would like to develop a 271 companion diagnostic, refer to section IV.E. 272 273 • Sponsors should consider the following if they will recruit participants with Hunner’s 274 lesions for their trial(s): 275 276 – Baseline appearance of bladder pathology should be documented in a standardized 277 fashion during screening and at follow-up after treatment. For this purpose, sponsors 278 can opt to use a standard representative bladder diagram, photographic imagery, or 279 videography. 280 281 – Resolution of Hunner’s lesions should correlate with improvement in a clinical 282 outcome in the IC/BPS population. 283 284 • Sponsors that choose to adopt Hunner’s lesions as an inclusion criterion for trial entry 285 should discuss their approach in advance with the Agency. Sponsors that select patients 286 with Hunner’s lesions for their trials should provide specific guidance to clinicians about 287 how these lesions were identified to ensure that providers who are not familiar with 288 identification of these lesions will be able to select appropriate patients for treatment. 289 290 E. Selecting Potential PRO and Other Secondary Endpoints for IC/BPS Clinical 291 Trials 292 293 IC/BPS is a symptomatic condition, so use of a PRO assessment is the most appropriate clinical 294 outcome assessment for evaluating changes in symptoms. A separate PRO assessment can also 295 be used to evaluate the impacts of IC/BPS symptoms on activities of daily living (e.g., 296 functioning). Then these PRO assessments can be used to better assess impacts of the 297 investigational drugs on IC/BPS symptoms. It is critical that sponsors use fit-for-purpose PRO 298 instruments to assess IC/BPS symptoms (including lower urinary tract symptoms).14 FDA 299 encourages sponsors to seek Agency input as early as possible and at important milestones 300 throughout the drug development process to ensure the inclusion of fit-for-purpose PRO 301 instruments in phase 3 trials. 302 303 14 For general recommendations regarding PRO instruments and documents to be provided to FDA for review, see the guidance for industry Patient-Reported Outcome Measures: Use in Medical Product Development to Support Labeling Claims and the FDA Patient-Focused Drug Development Guidance Series for Enhancing the Incorporation of the Patient’s Voice in Medical Product Development and Regulatory Decision Making, available at https://www.fda.gov/drugs/development-approval-process-drugs/fda-patient-focused-drug-development-guidance- series-enhancing-incorporation-patients-voice-medical.
Contains Nonbinding Recommendations Draft — Not for Implementation 9 • Considerations for selecting assessments of bladder pain and/or bladder discomfort in 304 patients with IC/BPS include: 305 306 – Patient input to understand how to describe and qualify pain and/or discomfort (with 307 bladder empty or full, relief or not relief with voiding) that is consistent with reported 308 symptom changes 309 310 – Inclusion of pain and/or discomfort type in the question stem (e.g., localization of 311 pain, localization of discomfort) 312 313 – Inclusion of pictorial diagram identifying the area where bladder pain and/or bladder 314 discomfort may present 315 316 – Assessments with a recall period15 (including patient diaries, if appropriate) that is 317 suitable for how bladder pain and/or bladder discomfort presents in the target 318 population (e.g., variability, duration (chronic versus episodic), frequency, and/or 319 intensity) 320 321 • Considerations for selecting assessments of functioning in study participants with IC/BPS 322 include: 323 324 – Assess bladder pain and/or bladder discomfort in relation to how it interferes with a 325 patient’s ability to perform activities of daily living to provide direct evidence of 326 whether there is an impact on a patient’s function. 327 328 – Provide detailed evidence (i.e., qualitative and quantitative data) that the instrument is 329 fit-for-purpose for the context of their drug development program. The Agency is 330 open to evaluating existing or modified PRO instruments for use in the IC/BPS 331 population. 332 333 Piloting the proposed PRO instruments in phase 2 trials provides opportunities to evaluate the 334 instruments’ measurement properties (reliability, validity, and ability to detect change), to 335 develop and propose an appropriate scoring algorithm, to document evidence to support a 336 definition of clinically meaningful within-patient change in scores, and to confirm the endpoint 337 definition before use in phase 3 trials. 338 339 • To interpret PRO endpoint results, FDA has the following recommendations: 340 341 15 For general recommendations regarding PRO instruments and documents to be provided to FDA for review, see the guidance for industry Patient-Reported Outcome Measures: Use in Medical Product Development to Support Labeling Claims and the FDA Patient-Focused Drug Development Guidance Series for Enhancing the Incorporation of the Patient’s Voice in Medical Product Development and Regulatory Decision Making, available at https://www.fda.gov/drugs/development-approval-process-drugs/fda-patient-focused-drug-development-guidance- series-enhancing-incorporation-patients-voice-medical.
Contains Nonbinding Recommendations Draft — Not for Implementation 10 – Propose an appropriate range of within-patient score change that patients consider to 342 be clinically meaningful using anchor-based methods supplemented with anchor- 343 based empirical cumulative distribution function curves. 344 345 – Anchor each pain or discomfort assessment and functioning assessment. The sponsor 346 should generate an anchor scale specific to bladder pain and/or bladder discomfort 347 and an anchor scale specific to functioning to provide the most direct evidence for 348 evaluating clinically meaningful patient-level improvement. 349 350 – Develop anchor scales to assess at baseline (where applicable) and at the same time 351 points as the target PRO–derived endpoint(s). These anchors should be clearly stated 352 in the protocol and statistical analysis plan. At a minimum, the following anchor 353 scales should be used to generate a threshold for clinically meaningful within-patient 354 change: 355 356 Static current state patient global impression rating of severity/status scale 357 Patient global impression of change scale 358 359 Secondary Endpoints: 360 361 Sponsors may choose to capture other exploratory or diagnostic endpoint(s) in their drug 362 development program. The following points can be considered: 363 364 • No specific biomarkers or other laboratory tests have been associated with change in the 365 diagnosis or changes in symptomatology in patients with IC/BPS to date. The Agency 366 will consider new biomarkers and laboratory assessments relevant to the development of 367 therapeutic products seeking to treat IC/BPS. 368 369 • For sponsors considering developing a therapeutic product for an IC/BPS indication with 370 a companion diagnostic device, FDA recommends that they request a meeting with the 371 relevant device and therapeutic product review divisions to ensure that the development 372 plan will provide sufficient data to establish the safety and effectiveness of both the 373 companion diagnostic device and the therapeutic product.16 374 375 16 See the draft guidance for industry and FDA staff Principles for Codevelopment of an In Vitro Companion Diagnostic Device with a Therapeutic Product (July 2016). When final, this guidance will represent the FDA’s current thinking on this topic.
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