Monday, December 7, 2015

Best Practices for Communication Between IND Sponsors and FDA During Drug Development

In December 2015, FDA issued a draft guidance for industry and review staff describing best practices and procedures for communication between investigational new drug application (IND) sponsors and FDA at critical junctures in drug development.

The draft guidance describes:
  • FDA’s philosophy regarding timely interactive communication with IND sponsors as a core activity
  • The scope of appropriate interactions between the review team and the sponsor
  • The types of advice appropriate for sponsors to seek from FDA in pursuing their drug development program
  • General expectations for the timing of FDA response to IND sponsor inquiries
  • Best practices and communication methods to facilitate interactions between the FDA review team and the IND sponsor during drug development
  • Expectations for appropriate methods, including the frequency, of such communications

FDA’s recommendations particularly relevant to RPI’s areas of expertise include:
  • Because sponsors are ultimately responsible for managing the overall development program for their proposed drug, sponsors should closely monitor for advances in the field and/or changes in FDA guidance, and inquire if those changes may necessitate changes in prior FDA recommendations for their development program.
  • Sponsors should only submit milestone meeting requests when drug development has progressed to the point where a full discussion of issues germane to that development stage is possible. Premature meeting requests are often denied by FDA.
  • Sponsors should submit a limited number of clearly worded and targeted questions that directly address concerns about the drug and development program. The number of questions in a meeting package should not exceed what can be reasonably discussed within the duration of allotted meeting time.
  • Sponsors should provide sufficient data to support the questions being asked. If the meeting package is determined to be inadequate or too voluminous, the meeting may be rescheduled.
  • Sponsors’ meeting packages should be well-organized and indexed to enhance the readability of the background information both before and during the meeting.

Find out more about how RPI can optimize your communication with FDA.