From: Trail to a Texas Trial
It hasn’t happened before. I was given a MISSION, if I chose to accept it, to explain some new developments in regards to Sarizotan (Newron) and Anavex 2-73 (Anavex) receiving FDA Rare Pediatric Disease Designation: “Mel Lancaster have you posted about these announcements or am I just behind on things? Have you deciphered it for parents who are new and may not get all of this yet?” Let me just say I was quite flattered! So, never one to step away from a challenge… Here we go.
One of the first hurdles for these companies and drugs to get past is Orphan Drug Designation. “The Orphan Drug Designation program provides orphan status to drugs and biologics which are defined as those intended for the treatment, prevention or diagnosis of a rare disease or condition, which is one that affects less than 200,000 persons in the US or meets cost recovery provisions of the act.” (From the FDA website)
A “Rare Pediatric Disease”, in contrast, is a rare disease “and one where the disease is serious or life-threatening with the serious or life-threatening manifestations primarily affecting individuals from age zero to 18.” (From the FDA website). Also, if a rare disease begins in childhood but doesn’t become life threatening until adulthood, it doesn’t qualify. If a disease is rare, begins in childhood, but isn’t life-threatening, it also does not qualify.
So, this is a subtle difference, but important. Now, Orphan Drug status and Rare Pediatric Disease may seem synonymous to a degree, however they are not, nor are the incentives for the companies. And this difference in incentives is the BIGGEST reason this new designation for these companies is so important.
In order to understand what is such a big deal about this, one must have a basic understanding of the different designation/statuses that these drugs/companies have or may already have. And before anyone asks, yes Trofinetide/Neuren has most if not all of the following.
From the FDA website:
Fast Track status: Fast track is a process designed to facilitate the development, and expedite the review of drugs to treat serious conditions and fill an unmet medical need.
- More frequent meetings with FDA to discuss the drug’s development plan and ensure collection of appropriate data needed to support drug approval
- More frequent written communication from FDA about such things as the design of the proposed clinical trials and use of biomarkers
- Eligibility for Accelerated Approval and Priority Review, if relevant criteria are met
- Rolling Review, which means that a drug company can submit completed sections of its Biologic License Application (BLA) or New Drug Application (NDA) for review by FDA, rather than waiting until every section of the NDA is completed before the entire application can be reviewed. BLA or NDA review usually does not begin until the drug company has submitted the entire application to the FDA
Priority Review: A Priority Review designation means FDA’s goal is to take action on an application within 6 months. (instead of 10 months) *This is the BIG DEAL about Rare Disease Designation*
Orphan Drug Status: An orphan drug is a drug meant for a rare disease or condition. With this designation, the company receives incentives to continue to develop this drug. Some of the incentives include:
• 7-year marketing exclusivity
• Tax credits (up to 50% of clinical development costs)
• Exemption/Waiver of application (filing) fees
• OOPD assistance during the development process
Rare Pediatric Disease Designation: “The Rare Pediatric Disease designation provides incentives to advance the development of rare disease drugs and biologics. Additionally, the FDA’s Rare Pediatric Disease Priority Review Voucher Program states that a sponsor with a Rare Pediatric Disease designation who receives marketing approval for a rare pediatric disease may be eligible for a voucher that can be redeemed to obtain priority review for any subsequent marketing application.” (From Business Wire)
And, therein lies the biggest part of this news. Having drugs be given Rare Pediatric Disease Designation makes it POSSIBLE to apply for the priority review. A priority review means the FDA must take action on a MARKETING application within 6 months instead of 10. IF a company already received a priority review through another process (i.e. Fast Track Status- which is then specific for THAT drug only), this is theirs to do, in particular, one of two things. 1. They can keep it and use it for another drug, even if it is not rare or even for a pediatric disease, OR 2. they can sell it for tens of MILLIONS of dollars and more. If they DON’T have it already and get it through this program, then they can use it to speed up the time from the application submission to when they can begin to market the drug.
Priority Review is important to US, because it gets a drug, if approved, to our children approximately 4 months faster (give or take). But, if a drug already has priority review and then it gets ANOTHER through the Rare Pediatric Disease (RPD) Designation Program, it’s theirs to keep or sell. For the company/ies this is a tremendous monetary advantage .