Drug Review Processes

Understanding Drug Review Processes (PART 02) 

this is the second series of the blog on the FDA’s drugs reviews process, here visit for part 01. Explore here:

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Considerable steps:
  1. How Animal Testing Is Conducted 
  1. How To Write an Investigational New Drug Submission 
  1. Phase 1 Trials: Getting the First FDA Approval 
  1. Phase 2 Study for Leading Multiple Sclerosis Drug Shows Promising  
  1. Pharmaceutical companies often conduct Phase 3 studies involving several hundred to about 3,000 people. 
  1. A time of communication between a drug sponsor and the FDA before an NDA is submitted. 
  1. The official submission of an NDA is the formal step in the approval process for new drug marketing. 
  1. Once an NDA is submitted, the FDA has 60 days to decide whether to file it and begin a review. 
  1. When the FDA files an NDA, it assigns a review team to evaluate the sponsor’s research. 
  1. The Food and Drug Administration (FDA) requires manufacturers to submit a Professional Labeling (package inserts and Medication Guides) to accompany each drug. 
  1. FDA inspectors examine the manufacturing facilities where the drug will be made before approving a generic drug application. 
  1. After reviewing an application for a new medical device, the Food and Drug Administration (FDA) will either approve it or issue a complete response letter. 

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Role of FDA in Drug Approval Process 
How The FDA Reviews Drug Applications:  

The FDA reviewers are heavily involved with a drug’s development from the moment it is first tested on humans. The official review time for a new drug application begins when the FDA issues an action letter informing the drug sponsor of its decision, but it is preceded by many months of internal communication within the agency. 

The FDA reviews the manufacturer’s application for the drug. The agency uses a system to grade drugs. Drugs that are more effective and better studied receive higher grades. Lower-grade drugs may be approved for use only if there is no comparable alternative. 

A study’s results and conclusions are reviewed by a team of experts from outside the study. This team looks for possible problems with the way the study was designed and conducted, such as weaknesses in the study’s design or analyses. The reviewers determine whether they agree with the sponsor’s results and conclusions, or whether they need any additional information to make a decision. 

Application reviewers prepare written reports containing conclusions and recommendations. These reports are considered by the evaluators’ team leaders, division directors, and other managers to determine whether an application is accepted or rejected. 

FDA reviewers receive training that helps them make consistent decisions about the approval of new drugs, and agency officials place great importance on conducting well-written reviews. 

The FDA consults with advisory committees on a regular basis. Although boards of medical specialists occasionally provide opinions, the FDA usually relies on scientific experts within individual fields to provide its advice. Some guidelines are set by internal FDA scientists and managers; others are made by FDA advisory committees. 

If a drug is new, has never been tried before, or if there are unresolved safety questions, the FDA may ask an advisory committee to look at the drug and offer suggestions. The FDA will listen to the committee’s advice but is not required to do so. 

Bumps When Meeting Challenges 

If the Food and Drug Administration determines that a new drug’s benefits outweigh its known risks, the drug may be approved for marketing in the United States. However, if there are unresolved issues with a new drug application (NDA) or if further information is necessary to make that determination, the FDA may send a complete response letter to the applicant. 

When approval of a new drug is delayed, it is usually because the drug must be manufactured in accordance with standards called good manufacturing practices. If a manufacturing facility isn’t ready for inspection by the FDA, approval can be delayed. Known manufacturing deficiencies must be corrected before approval can be given. 

Manufacturers of new drugs are expected to show that their manufacturing processes for large-scale production will deliver the same product as when drug trials were conducted. 

John Jenkins, MD, director of the FDA’s Office of New Drugs, says that drugs often fail to receive approval because of a combination of factors. “Innovative drug development will require good supervision and close communication with the FDA early on in a drug’s development,” he says. “This can reduce the chances that an application will have to go through more than one cycle of review.” However, he adds, “It’s no guarantee.” 

When the FDA finds deficiencies in a drug application, the drug sponsor has an opportunity to meet with FDA officials and address those issues before a final decision is made. After this meeting, the sponsor can choose to have a hearing at which both sides present their arguments, correct any remaining deficiencies, or withdraw the application. 

Role of FDA in user fees 

The Prescription Drug User Fee Act, passed in 1992, has allowed the Food and Drug Administration to approve more than a thousand new drugs, including therapies that fight cancer, HIV, cardiovascular diseases, and life-threatening infections. 

The Prescription Drug User Fee Act authorizes the FDA to collect user fees from pharmaceutical companies, which are then used to support FDA staff scientists in reviewing new drug applications. The agency has moved toward an electronic system for accepting and reviewing new drug applications, as it now accepts more electronically-generated applications and archives review documents electronically. 

As defined by PDUFA, applications reviewed by the FDA include original new human drug and biological applications; resubmissions of original applications; and supplements to previously approved applications. In 1997, PDUFA II extended the user fee program through September 2002. In 2002, PDUFA III was reauthorized and extended the user fee program through Sept. 30, 2007. 

The Prescription Drug User Fee Act III (PDUFA III) allowed the Food and Drug Administration to spend some user fees on improving the safety of drugs during their first two years on the market, or three years for particularly dangerous medications. It is during this initial period that the agency is best able to identify and counter adverse side effects that did not appear during clinical trials. 

On September 27, 2007, President Bush enacted the Food and Drug Administration Amendments Act of 2007, which included the reauthorization and expansion of the Prescription Drug User Fee Act. PDUFA was originally passed by Congress in 1992 to streamline and expedite the drug approval process. The reauthorization improves this process by providing greater protection for consumers, as well as expediting the development and review of new medications. 

Quality clinical data is essential for any research project. 

The Food and Drug Administration relies on data that drug sponsors submit to decide whether a drug should be approved. In order to protect the rights and welfare of clinical trial participants, and to verify the quality and integrity of data submitted, the FDA’s Division of Scientific Investigations conducts inspections of clinical investigators’ study sites. The FDA also determines whether institutional review boards are fulfilling their role in patient protection by reviewing their study records. 

FDA investigators review how clinical investigators documented adverse events in source documents such as medical records and lab results, says consumer safety officer Carolyn Hommel. 

The Department of Scientific Integrity (DSI) seeks to ensure that all adverse events are documented and that investigators follow the protocols established for each study. 

When a deficiency is noted during a pre-approval inspection, FDA investigators prepare a report, which includes the number and severity of deviations. The investigator classifies the inspection as “official action indicated” if serious violations are found. The inspector then sends a warning letter or Notice of Initiation of Disqualification Proceedings and Opportunity to Explain (NIDPOE) to the clinical investigator, specifying the observed deviations. 

Every year, the NIDPOE conducts about 300-400 inspections of clinical investigators who are administering investigational drugs. About 3 percent of these inspections result in an official action being taken against the investigator. 

The Division of Scientific Investigations begins the administrative process to determine whether the clinical investigator should remain eligible to receive investigational products and conduct clinical studies. 

The FDA’s Office of Clinical Investigation performs administrative surveillance to evaluate the qualifications of clinical investigators who are participating in investigations that involve investigational products. It also evaluates clinical investigators’ facilities and procedures, as well as their compliance with regulatory requirements. 

Points to consider 

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