us-fda-guidance-385be3b8c33274060f9ae9509041e070•Chronic Fatigue Syndrome/Myalgic Encephalomyelitis: Developing Drug Products for Treatment
Chronic Fatigue Syndrome/Myalgic Encephalomyelitis: Developing Drug Products for Treatment
us-fda-guidance-385be3b8c33274060f9ae9509041e070Chronic Fatigue Syndrome/Myalgic Encephalomyelitis: Developing Drug Products for TreatmentDraft 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Administrative draft guidance, not enacted legislation.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-2014-D-0264
- Issued by:
- Guidance Issuing OfficeCenter for Drug Evaluation and Research
This guidance is intended to assist sponsors in the development of drug products for the treatment of chronic fatigue syndrome/myalgic encephalomyelitis (CFS/ME). This guidance focuses on specific drug development and trial design issues that are unique to the study of CFS/ME and on the FDA’s current thinking on how effective treatments can be developed for CFS/ME. The points discussed in this guidance may not be applicable to all drug products. The FDA encourages sponsors to design clinical programs that fit their particular needs and to discuss their planned approach with the Division of Pulmonary, Allergy, and Rheumatology Products.
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Guidance for Industry Chronic Fatigue Syndrome/ Myalgic Encephalomyelitis: Developing Drug Products for Treatment DRAFT GUIDANCE This guidance document is being distributed for comment purposes only.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be submitted within 60 days of publication in the Federal Register of the notice announcing the availability of the draft guidance.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 http://www.regulations.gov. Submit written comments to the Division of Dockets Management (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 Dr. Janet W. Maynard at 301-796-2300. U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) March 2014 Clinical/Medical 16617dft.doc 03/06/14
Guidance for Industry Chronic Fatigue Syndrome/ Myalgic Encephalomyelitis: Developing Drug Products for Treatment Additional copies are available from: Office of Communications, Division of Drug Information Center for Drug Evaluation and Research Food and Drug Administration 10903 New Hampshire Ave., Bldg. 51, rm. 2201 Silver Spring, MD 20993-0002 Tel: 301-796-3400; Fax: 301-847-8714; E-mail: druginfo@fda.hhs.gov http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) March 2014 Clinical/Medical
TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. 1 II. BACKGROUND ............................................................................................................... 2 III. DEVELOPMENT PROGRAM ....................................................................................... 3 A. General Considerations .................................................................................................................3 1. Drug Development Population .........................................................................................................3 2. Unmet Medical Need ........................................................................................................................3 3. Efficacy Considerations ...................................................................................................................4 B. Specific Efficacy Trial Considerations .........................................................................................4 1. Trial Design......................................................................................................................................4 2. Efficacy Endpoints............................................................................................................................5 3. Trial Duration ..................................................................................................................................6 4. Number of Trials ..............................................................................................................................6 5. Concomitant Treatments ..................................................................................................................6 C. Safety Considerations.....................................................................................................................7 D. Other Considerations .....................................................................................................................7 1. Combination Drug Products ............................................................................................................7 2. Drug-Device Combination Product Considerations ........................................................................7 REFERENCES.............................................................................................................................. 9
Contains Nonbinding Recommendations Draft — Not for Implementation 1 Guidance for Industry1 2 Chronic Fatigue Syndrome/Myalgic Encephalomyelitis: Developing 3 Drug Products for Treatment 4 5 6 7 8 This draft guidance, when finalized, will represent the Food and Drug Administration’s (FDA’s) current 9 thinking on this topic. It does not create or confer any rights for or on any person and does not operate to 10 bind FDA or the public. You can use an alternative approach if the approach satisfies the requirements of 11 the applicable statutes and regulations. If you want to discuss an alternative approach, contact the FDA 12 staff responsible for implementing this guidance. If you cannot identify the appropriate FDA staff, call 13 the appropriate number listed on the title page of this guidance. 14 15 16 17 18 I. INTRODUCTION 19 20 This guidance is intended to assist sponsors in the development of drug products for the 21 treatment of chronic fatigue syndrome/myalgic encephalomyelitis (CFS/ME). 2 This guidance 22 focuses on specific drug development and trial design issues that are unique to the study of 23 CFS/ME and on the FDA’s current thinking on how effective treatments can be developed for 24 CFS/ME. The points discussed in this guidance may not be applicable to all drug products. The 25 FDA encourages sponsors to design clinical programs that fit their particular needs and to 26 discuss their planned approach with the Division of Pulmonary, Allergy, and Rheumatology 27 Products. 28 29 This guidance does not contain discussion of the general issues of statistical analysis, clinical 30 trial design, or patient-reported outcome (PRO) instruments. Those topics are addressed in the 31 ICH guidances for industry E9 Statistical Principles for Clinical Trials and E10 Choice of 32 Control Group and Related Issues in Clinical Trials and the guidance for industry Patient- 33 Reported Outcome Measures: Use in Medical Product Development to Support Labeling 34 Claims, respectively.3 This guidance does not address nomenclature considerations or 35 nonclinical development. 36 1 This guidance has been prepared by the Division of Pulmonary, Allergy, and Rheumatology Products in the Center for Drug Evaluation and Research (CDER) at the Food and Drug Administration. 2 In this guidance, the term drug product includes all types of therapeutic agents, such as small and large molecule drugs, and therapeutic biological products, regulated within CDER. 3 We update guidances periodically. To make sure you have the most recent version of a guidance, check the FDA Drugs guidance Web page at http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm. 1
Contains Nonbinding Recommendations Draft — Not for Implementation 37 For this guidance, the terms CFS, ME, and CFS/ME are used interchangeably. The term 38 CFS/ME is used in the singular to refer to a disease or set of diseases. The term CFS/ME is 39 intended to be inclusive and does not infer the cause of different symptom complexes. 40 Currently, the FDA does not recognize a particular definition or name as appropriate for use in 41 clinical trials of drug products for CFS/ME. 42 43 FDA’s guidance documents, including this guidance, do not establish legally enforceable 44 responsibilities. Instead, guidances describe the Agency’s current thinking on a topic and should 45 be viewed only as recommendations, unless specific regulatory or statutory requirements are 46 cited. The use of the word should in Agency guidances means that something is suggested or 47 recommended, but not required. 48 49 50 II. BACKGROUND 51 52 CFS/ME is a complex disease that can be debilitating. The exact cause or causes of CFS/ME are 53 unknown. Symptoms affect several body systems and may include severe fatigue or exhaustion, 54 unrefreshing sleep, weakness, muscle and joint pain, impaired memory or mental concentration, 55 tender lymph nodes, sore throat, headaches, and sleep dysfunction. Many patients experience 56 post-exertional malaise, which may occur without warning and upon even minimal physical or 57 cognitive exertion, and is associated with acute exacerbation of these symptoms. The nature and 58 severity of symptoms vary from person to person, and diagnosis is challenging because there are 59 no specific tests for the disease. Post-exertional malaise and cognitive impairment are symptoms 60 that can be particularly severe and disabling.4 61 62 According to the Centers for Disease Control and Prevention (CDC), between one and four 63 million people in the United States are afflicted with CFS.5 Although CFS/ME is most common 64 in 40- to 60-year-old women, CFS/ME affects both sexes and all racial, age, and socioeconomic 65 groups. The disease may occur with a sudden onset, such as following an infection, or may 66 occur with a gradual onset. Some patients improve spontaneously; however, many patients 67 experience a prolonged course of illness with either periods of remission and exacerbation or 68 steady decline. 69 70 CFS/ME affects patients’ ability to function in daily activities of work, school, household 71 management, and personal care. Many patients with CFS/ME are bedbound some or all of the 72 time and experience loss of careers, decreased quality of family life, social isolation, and feelings 73 of hopelessness. 74 2 4 The Voice of the Patient, A Series of Reports From the U.S. Food and Drug Administration’s (FDA’s) Patient- Focused Drug Development Initiative, Chronic Fatigue Syndrome and Myalgic Encephalomyelitis (http://www.fda.gov/downloads/ForIndustry/UserFees/PrescriptionDrugUserFee/UCM368806.pdf). 5 Recognition and Management of Chronic Fatigue Syndrome: A Resource Guide for Health Care Professionals (http://www.cdc.gov/cfs/hcp.html)
Contains Nonbinding Recommendations Draft — Not for Implementation 75 CFS/ME is a serious disease and there are no approved therapies indicated to treat CFS/ME. The 76 lack of approved therapies indicated for the treatment of CFS/ME represents a public health 77 concern. 78 79 80 III. DEVELOPMENT PROGRAM 81 82 A. General Considerations 83 84 1. Drug Development Population 85 86 A number of different clinical diagnostic criteria are in use for CFS/ME, including the 1988 87 CDC criteria (Holmes, Kaplan, et al. 1988), the Fukuda Criteria (1994 Case Definition; Fukuda, 88 Straus, et al. 1994), the International Criteria (Carruthers, van der Sande, et al. 2011), and the 89 Canadian consensus criteria (Carruthers, Jain, et al. 2003). Currently, there is no single case 90 definition or set of criteria that is uniformly recognized as the standard for diagnosing patients 91 with the disease. At this time, the FDA does not recognize any particular disease definition, 92 nomenclature, or diagnostic criteria for CFS/ME as the most appropriate for use in clinical trials 93 of new drug products. Consequently, any case definition or criteria for CFS/ME can be used to 94 define the patient population. Sponsors should provide justification for the chosen case 95 definition or criteria and should provide sufficient details of the enrollment criteria (21 CFR 96 314.126). Regardless of the case definition or criteria used, the clinical trial should exclude 97 patients with potentially confounding diagnoses, including, but not limited to, congestive heart 98 failure, malignancy, and chronic hepatitis, that cause fatigue and similar symptom complexes. 99 100 Drug development in CFS/ME should focus on measures of clinically relevant effects in a defined patient population.6 101 102 Sponsors should define whether the targeted patient population reflects the general CFS/ME 103 population or a subset, such as patients with CFS/ME and postural orthostatic tachycardia 104 syndrome (POTS). Generally, it is helpful to define the specific indicated population early in the 105 clinical development program. Ultimately, the targeted patient population used in the definitive 106 clinical trials should be reflected in labeling. 107 108 2. Unmet Medical Need 109 110 CFS/ME is a serious disease and there is unmet medical need in the treatment of CFS/ME. 111 There are FDA programs intended to help ensure that therapies for serious conditions are 112 approved and available to patients as soon as it can be concluded that the benefits of a therapy 113 outweigh its risks. For information regarding expedited programs, including fast track 114 115 designation, breakthrough therapy designation, accelerated approval, and priority review, see the draft guidance for industry Expedited Programs for Serious Conditions—Drugs and Biologics.7 116 This guidance includes information regarding FDA programs intended to facilitate and expedite 6 See the ICH guidance for industry E8 General Considerations for Clinical Trials. 7 When final, this guidance will represent the FDA’s current thinking on this topic. 3
Contains Nonbinding Recommendations Draft — Not for Implementation 117 development and review of drugs to address unmet medical need in the treatment of serious or 118 life-threatening conditions. 119 120 3. Efficacy Considerations 121 122 To meet the regulatory standards for approval under section 505(d) of the Federal Food, Drug, 123 124 and Cosmetic Act, sponsors must provide substantial evidence of efficacy in the enrolled patient population and demonstrate an acceptable risk-benefit profile for their drug product.8 This 125 section outlines the principles of assessing efficacy of drug products for the treatment of 126 CFS/ME. 127 128 The efficacy endpoints selected for evaluation of drug products for the treatment of CFS/ME 129 should include patient-reported symptoms using well-defined and reliable PRO instruments. 130 These patient-reported symptoms can include any scientifically supported and logical 131 combination of symptoms that are common in CFS/ME. Additionally, sponsors should consider 132 using objective measures. Several potential efficacy endpoints that may be suitable for use in 133 clinical trials of drug products for CFS/ME are mentioned in the following sections; however, 134 sponsors are encouraged to also propose other clinically meaningful endpoints that may better 135 assess the efficacy of their drug products. As with all adequate and well-controlled clinical 136 investigations, the protocol for the study and the report of results should explain the variables 137 measured, the methods of observation, and criteria used to assess response (21 CFR 138 314.126(b)(6)). 139 140 For most drug products, phase 3 trials that use a single primary efficacy endpoint with supportive 141 secondary efficacy endpoints should be adequate to establish efficacy, provided the efficacy 142 findings are robust and clinically meaningful. The wording of the indication statement should 143 reflect the effect assessed by the primary efficacy endpoint used. 144 145 The FDA understands that there is an emerging body of research focused on understanding a 146 range of laboratory abnormalities and biomarkers in CFS/ME. Although biomarkers can be 147 considered as exploratory endpoints, the primary endpoints used to demonstrate efficacy should 148 reflect the claimed clinical benefit related to how a patient feels or functions. 149 150 B. Specific Efficacy Trial Considerations 151 152 1. Trial Design 153 154 The nature and design of the definitive trials depends on the type of drug product that is being 155 studied and the clinical benefit to be demonstrated. In general, trials should be placebo- 156 controlled, double-blinded, randomized, and parallel-group in design. The use of a placebo 157 control should not preclude usual care treatments in patients randomized to placebo (see section 158 III.B.5., Concomitant Treatments). The appropriateness of a placebo control may change in the 159 future when approved drug products become available such that use of placebo control raises 160 ethical issues (i.e., if a drug product is approved for treatment of patients with CFS/ME). 161 8 21 U.S.C. 355(d) 4
Contains Nonbinding Recommendations Draft — Not for Implementation 162 2. Efficacy Endpoints 163 164 This section outlines the principles sponsors should follow to assess efficacy of drug products for 165 the treatment of CFS/ME. 166 167 168 Establishing efficacy in key CFS/ME domains. To support efficacy of drug products for the treatment of CFS/ME, sponsors should demonstrate substantial evidence9 of 169 efficacy in the key CFS/ME domain: symptoms. 170 171 ‒ Symptoms. The primary efficacy endpoint should reflect the claimed clinical benefit 172 (e.g., a drug product intended to reduce fatigue associated with CFS/ME should show 173 174 the effect through assessments of fatigue, subjectively measured). The selected primary efficacy endpoint should be clinically meaningful.10 175 176 Methods for symptom assessments. The FDA is not aware of existing PRO 177 instruments or set of instruments optimal for measurement of fatigue or other 178 symptoms of CFS/ME. The division will consider the use of symptom 179 assessments that have been developed and evaluated in other conditions or novel 180 instruments. These alternatives should be discussed with the division early in 181 drug development. 182 183 Other domains. Other domains that are important to patients can provide further 184 characterization of the efficacy of the drug product and its utility in clinical practice. 185 Other domains can include the following: 186 187 ‒ Exercise capacity and post-exertional malaise. CFS/ME can be associated with both 188 reduced exercise capacity and post-exertional malaise. It is important to consider that 189 post-exertional malaise and exercise capacity represent two different potential 190 treatment benefits, and a drug product may act on both, or it may act on one, but not 191 the other. The efficacy endpoints should reflect the claimed clinical benefit (e.g., a 192 drug product intended to decrease post-exertional malaise should show the effect 193 through objective assessments of exercise capacity and PROs). 194 195 Methods for exercise capacity and post-exertional malaise assessment. 196 Assessment of exercise capacity by treadmill or cycle ergometry or PROs 197 intended to measure post-exertional symptoms can be used to assess efficacy of a 198 drug product. Although the FDA is not aware of existing PRO instruments for 199 post-exertional malaise, the division will consider the use of existing or newly 200 developed measures for this use. These assessment tools should be considered in 201 the context of the desired trial population, because some assessment tools would 202 not be appropriate for patients with large degrees of functional impairment. 203 9 21 U.S.C. 355(d) 10 See ICH E8. 5
Contains Nonbinding Recommendations Draft — Not for Implementation 204 ‒ Improving health-related quality of life. Health-related quality of life (HRQL) is a 205 multidomain concept that represents the patient’s general perception of the effect of 206 illness and treatment on physical, psychological, and social aspects of life. 207 Improvement in HRQL is an important aspect of CFS/ME treatment. 208 209 Methods for assessing HRQL. The FDA is not aware of existing HRQL 210 instruments that are designed to systematically assess different aspects of the 211 effect of CFS/ME on a patient’s life. However, the division will consider the use 212 of HRQL instruments that have been developed in other populations or novel 213 instruments for the purposes of assessment of efficacy in CFS/ME. The FDA 214 often suggests that specific domains of health status and HRQL that are most 215 relevant to the disease of interest (e.g., disease-related symptoms or disease- 216 related effect on physical functioning or cognitive functioning) be specified as 217 primary or secondary endpoints to assess treatment benefit in clinical trials, while 218 broader measures of overall HRQL be used as exploratory outcome measures in 219 clinical trials. 220 221 For example, CFS/ME impairs the degree to which patients can perform 222 successfully tasks and roles required for everyday living (e.g., patients’ ability to 223 function in daily activities of work, school, household management, and personal 224 care). Direct evidence of treatment benefit can be supported by demonstration of 225 the effect of treatment on the patient’s performance of activities of value in his or 226 her daily life. The choice of the specific assessment tool depends on the context 227 of the targeted trial population. 228 229 3. Trial Duration 230 231 The duration of controlled clinical trials may be influenced by data from earlier trials, so this 232 should be discussed with the FDA during protocol development. In general, sponsors should use 233 data from 24-week placebo-controlled clinical trial(s) to provide evidence of efficacy in 234 symptom relief domains. Assessment of efficacy in some other domains may need long-term 235 controlled clinical trial data. Longer durations of treatment may be needed to adequately assess 236 safety. 237 238 4. Number of Trials 239 240 Generally, support from two definitive trials should establish efficacy for a drug product being 241 developed to provide symptom relief for CFS/ME. The trials should provide independent 242 substantiation of the evidence of efficacy, but need not be identical in design. 243 244 5. Concomitant Treatments 245 246 In general, patients enrolled in the trial should be permitted to use concomitant treatments as 247 needed to manage disease symptoms. An appropriate analysis plan should be defined in the 248 protocol to account for possible imbalance of concomitant treatment use between treatment 249 groups. For some treatments, consideration should be given in the design, conduct, and 6
Contains Nonbinding Recommendations Draft — Not for Implementation 250 interpretation of the trial to the need for any medications for acute symptoms (e.g., analgesics for 251 pain exacerbations). 252 253 C. Safety Considerations 254 255 Treatment of CFS/ME is usually prolonged; therefore, sponsors should collect long-term safety 256 data. The size of the safety database should be consistent with the recommendations outlined in 257 the ICH guidance for industry E1A The Extent of Population Exposure to Assess Clinical Safety: 258 For Drugs Intended for Long-Term Treatment of Non-Life-Threatening Conditions. 259 Consideration should be given to whether the drug is designed for intermittent or continuous use. 260 Consideration also should be given to other concomitant drugs that CFS/ME patients are likely to 261 take. In cases where efficacy trials are substantially less than 1 year, or if the drug product is to 262 be chronically administered, separate long-term safety trials should be conducted with 263 consideration of including a control arm to facilitate interpretation of these data. Additional 264 265 safety data may be needed depending on the safety profile observed for the drug product and the specific situation.11 Sponsors are encouraged to discuss their plans for specific safety monitoring 266 with the FDA during the early stages of drug product development. 267 268 D. Other Considerations 269 270 1. Combination Drug Products 271 272 Given the complexity of CFS/ME, it is possible that a single drug may not possess all necessary 273 pharmacological activity to result in a desired therapeutic effect. Therefore, a new drug product 274 can be a combination of two or more individual drugs. Two or more drugs may be combined in 275 a single dosage form when each component makes a contribution to the claimed effect and the 276 dosing of each component is such that the combination is safe and effective for a significant 277 patient population requiring such concurrent therapy (21 CFR 300.50, Fixed-combination 278 prescription drugs for humans). A reasonable way to support the efficacy of a combination drug 279 product would be to compare the combination drug product to each of its constituents in the 280 same placebo-controlled clinical trial to demonstrate that the combination drug product provides 281 clinical benefit that is superior to each of its constituents (see section III.B.1., Trial Design). 282 283 2. Drug-Device Combination Product Considerations 284 285 Therapies developed for the treatment of CFS/ME can include drug products that require 286 parenteral administration and the use of an accessory delivery unit (e.g., an injector device). In 287 these cases, the manufacturer of the drug product should ensure that the accessory delivery unit 288 is approved or cleared for marketing through the device regulatory process (e.g., 510(k) process 289 or premarket approval) by the Center for Devices and Radiological Health. If the accessory 290 delivery unit is not already approved or cleared for marketing, then it should be approved or 291 cleared at least concurrently with the drug product approval. Generally, each drug-device 292 combination product should have a complete chemistry, manufacturing, and controls database; 293 device design and development; and a substantially complete clinical development program to 294 support efficacy and safety of the entire combination product. Sponsors are encouraged to 11 See ICH E1A. 7
Contains Nonbinding Recommendations Draft — Not for Implementation 295 contact the Office of Combination Products and the division early in the development stage to 296 seek guidance for their drug-device combination product. 8
Contains Nonbinding Recommendations Draft — Not for Implementation 297 REFERENCES 298 299 Guidances 300 301 Draft guidance for industry Expedited Programs for Serious Conditions—Drugs and Biologics 302 303 Guidance for industry Patient-Reported Outcome Measures: Use in Medical Product 304 Development to Support Labeling Claims 305 306 ICH guidance for industry E1A The Extent of Population Exposure to Assess Clinical Safety: 307 For Drugs Intended for Long-Term Treatment of Non-Life-Threatening Conditions 308 309 ICH guidance for industry E8 General Considerations for Clinical Trials 310 311 Other 312 313 The Voice of the Patient, A Series of Reports From the U.S. Food and Drug Administration’s 314 (FDA’s) Patient-Focused Drug Development Initiative, Chronic Fatigue Syndrome and Myalgic 315 Encephalomyelitis 316 (http://www.fda.gov/downloads/ForIndustry/UserFees/PrescriptionDrugUserFee/UCM368806.p 317 df) 318 319 Recognition and Management of Chronic Fatigue Syndrome: A Resource Guide for Health Care 320 Professionals (http://www.cdc.gov/cfs/hcp.html) 321 322 Literary 323 324 Carruthers BM, Jain AK, De Meirleir KL, et al., 2003, Myalgic Encephalomyelitis/Chronic 325 Fatigue Syndrome: Clinical Working Case Definition, Diagnostic and Treatment Protocols, J 326 CFS, 11:7-116. 327 328 Carruthers BM, van der Sande MI, DeMairleir KL, et al., 2011, Myalgic Encephalomyelitis: 329 International Consensus Criteria, J Intern Med, 270:327-38. 330 331 Fukuda K, Straus S, Hickie I, et al., 1994, The Chronic Fatigue Syndrome: A Comprehensive 332 Approach to its Definition and Study, Ann Inter Med, 121:953-9. 333 334 Holmes GP, Kaplan JE, Gantz NM, et al., 1988, Chronic Fatigue Syndrome: A Working Case 335 Definition, Ann Intern Med, 108:387-89. 336 9
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