INTRODUCTION
Mr. Chairman, Ranking Member Brown and Members of the Subcommittee, I am
Theresa Mullin, Assistant Commissioner for Planning at the U.S. Food and Drug
Administration (FDA or the Agency). I advise and assist the Commissioner
concerning the performance of FDA planning, evaluation and economic analysis
activities. Since the beginning of January 2003, I have been directing FDA's
development of a new strategic plan and have played a lead role in coordinating
the Agency's new initiative to "Improve Innovation in Medical Technology
Beyond 2002." I am also Co-Chair of the National Cancer Institute (NCI)/FDA
Interagency Oncology Task Force, which involves senior staff from both agencies.
We appreciate the opportunity to testify with NCI about our collaborative
efforts to facilitate cancer drug development. As you may know, we are at the
very beginning of this new initiative, but this is a goal that both agencies
have shared. Today I will provide FDA's perspective as to why we are entering
into this collaboration and what we hope to achieve.
FDA'S DRUG DEVELOPMENT PROCESS FDA's primary mission is to protect and
promote the public health. One way we do this is by promptly and efficiently
reviewing investigational new drug applications (INDs) for clinical studies
within 30 days of submission by the product sponsor. In addition, FDA reviews
new drug applications (NDAs) and biologics license applications (BLAs) and does
so on an expedited basis for applications with priority status, such as those
for new cancer drugs. We also monitor on-going clinical studies to ensure that
subjects who volunteer for studies are protected and that the quality and
integrity of scientific data are maintained. There are several phases to drug
development, and FDA makes itself available to interact with product sponsors
during this process (see Attachment A, Drug Development Pipeline). Meetings
requested by the sponsor provide an important venue for communication. Formal
meetings were established by Congress under the FDA Modernization Act of 1997,
and FDA has committed to performance goals for such meetings under the
Prescription Drug User Fee program. These meetings can occur from the pre-IND
phase all the way to pre-NDA/BLA submission. FDA receives requests for and
convenes over 1,000 such meetings with sponsors each year. Meetings with FDA can
help sponsors to clarify research questions that need to be addressed, identify
earlier the unsuccessful compounds, and focus research on studies of compounds
that are likely to lead to approval. The Tufts Center for the Study of Drug
Development has cited earlier consultation between FDA and sponsors as a key
factor in reducing drug development time. Tufts estimates that shifting 5
percent of all clinical failures from Phase III/regulatory review to Phase I
would reduce out-of-pocket clinical costs by up to $20 million. Upon completing
and analyzing their research, sponsors, including NCI-funded researchers, send
us applications providing evidence from clinical trials to demonstrate that a
product is safe and effective for its intended use. We assemble a team of
physicians, statisticians, chemists, biologists, microbiologists,
pharmacologists, and other scientists to review the sponsor's data and proposed
labeling for the drug. By setting clear standards for the evidence we need to
approve a product, we try to take the guesswork out of the process and help
medical researchers bring new products to American consumers more rapidly. Once
a drug is approved for sale in the United States, our consumer protection
mission continues. We monitor the use of marketed drugs for unexpected health
risks. If new, unanticipated risks are detected after approval, we take steps to
inform the public and change how a drug is used or even remove a drug from the
market. We also monitor manufacturing changes to make sure they will not
adversely affect safety or efficacy. We evaluate reports about suspected
problems from manufacturers, health care professionals and consumers. As the
pharmaceutical industry has become increasingly global, we are involved in
international negotiations with other nations to harmonize standards for drug
quality and the data needed to approve a new drug. This harmonization can assist
in reducing the number of redundant tests manufacturers do and help ensure drug
quality for consumers at home and abroad.
CURRENT STATUS OF FDA NEW DRUG APPROVALS By the end of 2002, FDA was able to
meet all of the review goals for NDAs and BLAs established under the
Prescription Drug User Fee Act. We evaluated many new drugs that offered
important treatment options for Americans. Thanks to the enormous growth in
research investments, more complex and innovative products are in development.
We see this situation as one of great opportunity, and FDA is doing its part to
help sponsors capitalize on the opportunities presented. However, we are
concerned that the number of approvals for truly new drugs is at the lowest
level in a decade, and this is directly related to the decline in the number of
new applications for drugs and biologics being submitted to the Agency for
approval. This trend is illustrated in the bar chart depicted in Attachment B.
This pattern is occurring at the same time that the government is allocating
significantly more resources to promote research, and the pharmaceutical
industry has increased spending on research and development to more than $30
billion per year.
FDA MEDICAL TECHNOLOGY INITIATIVE
In January of this year, FDA launched an initiative to improve the
development and availability of innovative medical products. We recognize that
early communication with sponsors is essential to achieve the Agency's goal to
further reduce delays and avoidable product development costs, and also to
improve the quality of new product applications. With the complex new
technologies in development, FDA sees an opportunity to reduce the uncertainty
for product innovators, including small companies with limited experience
bringing a medical technology to commercial development. We are working to
clarify regulatory pathways for emerging technologies, by, for example, working
to further characterize, and define the dosing for new products like cellular
and gene therapies. Also, we think it would help sponsors for FDA to update
current guidance and provide new ones that specify clinical endpoints, including
surrogate endpoints, such as tumor shrinkage, that will provide good evidence of
safety and effectiveness for new treatments for particular diseases. FDA hopes
to facilitate the development of new technology by addressing and clarifying
regulatory uncertainty and by increasing the predictability of product
development. Some of the steps FDA is taking under its new initiative to more
quickly facilitate the drug development process are listed in Attachment A.
In addition to doing what we can to help sponsors improve the quality of
their data and submitted applications, the Agency is also taking steps to
further improve its application review process by identifying and addressing the
causes of avoidable delays in new drug review. This month we expect to publish a
request for proposals to conduct both a retrospective analysis and a prospective
evaluation of our review process and to provide us with ideas for possible
process improvements based on comments from both FDA staff and drug sponsors.
NCI-FDA COLLABORATION
FDA is committed to finding better ways to get safe and effective treatments
to patients with life-threatening diseases as quickly as possible. FDA's
participation in the NCI-FDA Oncology Task Force is consistent with the Agency's
initiative to improve the development and availability of innovative medical
products. FDA's role is to help ensure the safety and effectiveness of drug
products through the pre-market drug review process and through post-marketing
programs. Through basic and clinical biomedical research and training, NCI
conducts and supports programs to understand the causes of cancer; prevent,
detect, diagnose, treat, and control cancer; and disseminate information to the
practitioner, patient, and public. NCI's clinical research for new drug
development is also subject to FDA regulation and oversight. The NCI-FDA
collaboration will provide FDA with exposure to state-of-the-art technology that
will enable the Agency to have a better understanding of new products in
development. Similarly, NCI will benefit from hands on experience with FDA's
review process that will help it to conduct and oversee research to provide
evidence of safety and effectiveness, resulting in faster development of
approvable products. We are hopeful that our collaborative efforts will result
in better communication between reviewers and researchers, which we believe is
essential to improving the development and availability of innovative medical
products. Though the Task Force is in its early stages, we are considering
several areas of collaboration including: joint training and fellowships;
developing markers of clinical benefit, including surrogate endpoints;
information technology infrastructure to better collect and share data; and ways
to improve the drug development process.
Joint Training and Fellowships Staff capabilities can be enhanced through
collaborative training, joint rotations, and joint appointments. We hope that
bridging gaps between research and regulatory processes will make the drug
development process more efficient. As noted above, early effective
communication between researchers and reviewers is critical in product
development. Cancer drugs are typically designated by FDA as priority review
products and are eligible to be designated as "Fast Track" products.
Beginning in fiscal year 2004, FDA will be piloting two programs to provide
earlier FDA review and feedback for "Fast Track" products while they
are still in development.
While a primary goal of the NCI/FDA collaboration is to provide
cross-fertilization between the two agencies, the Task Force will also explore
the possibility of a nationwide program to rotate fellows through FDA and NCI
who have completed their training in medical oncology.
Developing Markers of Clinical Benefits The Medical Technology Initiative
that FDA announced last January included a series of collaborative discussions
with the American Society of Clinical Oncology to identify appropriate endpoints
for clinical trial design for cancer therapies, by type of cancer and stage of
disease. NCI is also involved in this process. These identified endpoints will
be published in guidance documents. Such guidance documents, developed in
collaboration with other government and academic organizations, the
pharmaceutical industry, health practitioners and patients, can help sponsors
structure claims, offer proven standardized approaches to evaluating efficacy,
and give insights into safety testing. In NCI-FDA's Interagency Task Force
discussions to date, there has been interest in further extending this work and
in further identification of clinically valid surrogate endpoints.
NCI and FDA will also continue their current collaboration involving
proteomics, the discovery of protein markers in the blood that can be used to
detect and monitor disease course and drug response. In addition, FDA's Center
for Biologic Evaluation and Research is currently collaborating with NCI on a
Microarray Program for the Quality Assurance of Cancer Therapies including
therapeutic cancer vaccines and other cellular and gene therapy biological
products. The Microarray Program has provided a foundation for the
identification of new molecular targets, understanding of the mechanism of
action of targeted cancer therapeutics, and characterization of complex
therapeutic cancer vaccines. As potency and identity of these cancer vaccines is
difficult to assign, the genomics (study of genes)-based technology provides a
novel approach to achieving this goal.
Information Technology Infrastructure FDA looks forward to collaborating with
NCI building on its cancer bio-informatics infrastructure to streamline data
collection, integration and analysis for pre-clinical, pre-approval, and
post-approval research across all of the sectors involved in the development and
delivery of cancer therapies. We are hopeful that this collaboration may
ultimately reduce the reporting burden for clinical investigators and improve
the quality of reported data. Some proposals being considered are: creation of a
shared repository for clinical investigator Curricula Vitae (CVs) to keep
current and to eliminate the requirement of repeated submissions of such CVs.
Another proposal being explored is for development of templates for INDs and
clinical trial protocols to simplify the process of creating and submitting
these documents and improve the quality of submissions. NCI grantees may also be
product sponsors that FDA regulates. Given this dual role, there may be
duplicative reporting requirements that we may be able to streamline through
this collaborative effort.
Improving the Drug Development Process Tufts Center for the Study of Drug
Development has noted that faster development times, quicker decisions to
terminate unsuccessful compounds, and higher success rates would enable industry
innovators to reap substantial savings in the cost of new drug development. NCI
is the sponsor of many cancer studies regulated by FDA. They too can benefit
from faster development times, quicker decisions to terminate unsuccessful
products, and higher success rates.
CONCLUSION
The safety and effectiveness standards for drug review and approval in the
U.S. are viewed by many as the "gold standard." FDA is the recognized
world leader in both the quality and speed of regulatory review. The scientists
at FDA constantly strive to maintain these high standards and we believe that
the new NCI-FDA Interagency Oncology Task Force will further our goals of
providing new life-saving drugs to patients who need them as swiftly and
cost-effectively as possible.
I am happy to answer any questions you may have.