Euro Convergence: Early consultation critical in overcoming gene therapy hurdles

Regulatory NewsRegulatory News | 30 October 2020 |  By 

When it comes to advancing gene therapy products in the United States and Europe, the key is early consultation with regulators and identification of potential problems, experts said at the Euro Convergence 2020 virtual meeting.

“It is better to do it earlier and establish a collaborative and educational approach to discussions,” advised Mridula Shukla, director of global regulatory affairs at Arcutis Biotherapeutics in Palo Alto, Calif.  
Patrick Celis, PhD, head of the scientific secretariat of the Committee for Advanced Therapies at the European Medicines Agency (EMA), echoed that advice.

“Please talk to EMA and National Authorities early and frequently so that we can help you as much as possible to get these innovative products to the patients as soon as possible,” Celis said.

There are currently more than 10 gene therapy products approved globally and momentum has been building in this area since around 2015, Shukla said.

“Gene therapy seems to have potential as it offers the possibility of an actual cure instead of chronic treatment for rare diseases, hereditary diseases and cancer,” Shukla said. 

Despite the promise of the therapies, more than half of gene therapy clinical trials are in phase 1. Shukla said this is due to a combination of factors including the complexity of the therapies, the rare indications, the high price of the therapies and reimbursement issues, unique manufacturing and supply chain challenges and controversies surrounding the ethnics of the techniques.

There is guidance from the US Food and Drug Administration (FDA) to assist developers. In July 2018, FDA issued draft guidance on Human Gene Therapy for Rare Diseases, which was finalized in January 2020. The document offers advice on some common manufacturing challenges, including encouraging companies to establish critical process parameters (CPP) early on and establish and qualify a potency assay prior to conducting clinical trials.

The FDA recommends communication with its Office of Tissues and Advanced Therapies early in product development, even before submission of an investigational new drug (IND) application. The agency also offers an Initial Targeted Engagement for Regulatory Advice on CBER Products (INTERACT) meeting, which can be used to discuss specific product issues, Shukla said.

“Overall, the recommended approach is to front-load as much development as possible, preferably prior to Phase 1, and to hold early interactions and frequent interactions with FDA or EMA,” Shukla said.

In the US, there are also multiple options for expedited review of products, including:
  • Regenerative Medicine Advanced Therapy (RMAT) designation
  • Breakthrough Therapy designation
  • Fast Track designation
  • Accelerated Approval
  • Priority Review
The earliest possible pathway is through a Fast Track designation, which companies can apply for with non-clinical data and which can be submitted at the time of an IND submission, Shukla said.

These expedited processes are similar to programs available for advanced therapy medicinal products (ATMPs) in Europe, such as the priority medicines (PRIME) scheme, which offers early consultation and the potential for accelerated assessment.

Since 2009, the EMA has approved 17 ATMPs, of which 10 are gene therapy products, Celis said.

The common issues that come up with ATMP applications include a lack of experience with commercial manufacturing processes, finding a relevant potency assay, ensuring product consistency and challenges with consistent starting materials, according to Celis. Other problems that can lead to delays in authorization include a lack of randomization in trial design, an indication that doesn’t reflect the patients in the trial, and limited data on safety and durability of response.

The nature of gene therapies and the small number of patients in clinical trials mean that sponsors often have difficulty showing long-term safety and efficacy in a robust patient population. While regulators don’t expect the same level of data as with other traditional medicines, there is a need for early planning of post-authorization studies, Celis said.

The EMA is asking for a detailed post-authorization plan that can include follow-up of patients in the clinical trials, post-marketing trials, and post-authorization registry-based studies.

If a sponsor is using a registry, Celis said it is better to go with an established disease registry and to contact the registry early to find out what data is collected. Additionally, registries may not be a good basis for safety reporting, Celis said.  

There are support mechanisms in place for ATMP developers including scientific advice, a meeting with the EMA’s Innovation Task Force, and the PRIME program for medicines addressing unmet needs.

“We can help,” Celis said. “Make sure that you make best use of what we can do.”

For sponsors looking to market gene therapies globally, Celis said that the EMA and FDA are in frequent contact and are seeing many of the same issues as they review products. He encouraged developers to make use of this interaction between European and US regulators either formally, through parallel scientific advice, or informally. 

Euro Convergence 2020


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Tags: biologics, EMA, FDA

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