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Innovative Designs for Clinical Trials of Cellular and Gene Therapy Products in Small Populations: Draft Guidance for Industry

DraftCenter for Biologics Evaluation and Research,Office of Therapeutic Products09/24/2025

Description

This guidance provides recommendations to sponsors who are planning clinical trials of cell and gene therapy (CGT) products intended for use in a disease or condition that affects a small population—generally one that meets the definition of a rare disease or condition under section 526(a)(2) of the FD&C Act (21 U.S.C. 360bb(a)(2)).  It describes FDA requirements and provides considerations for the use of various clinical trial designs and endpoints to generate clinical evidence to support product licensure.  This guidance expands on principles described in FDA’s existing guidance documents related to this topic, ,   by providing additional recommendations for the planning, design, conduct, and analysis of cell and gene therapy trials to facilitate FDA’s assessment of product effectiveness.

Scope & Applicability

Product Classes

1
Cellular and Gene Therapy Products

Guidance focuses on innovative designs for clinical trials of these products.; Innovative designs for clinical trials of CGT products.

Stakeholders

2
Institutional Review Board

Governs top dose in clinical studies

Sponsor

Entity responsible for submitting applications under section 524B

Regulatory Context

Attributes

1
Potency

Measurement of potency for biological products

Identified Hazards

Hazards

1
Regression to the mean

A challenge in interpreting trial results when symptoms return to stable levels after peaking.

Related CFR Sections (6)

Related Warning Letters (10)

  • Clinical Investigator

    Shirish M. Gadgeel, M.D.

    2025-09-09
  • Clinical Investigator

    Mark J. Savant, M.D

    2025-07-15
  • Bioresearch Monitoring Program/Institutional Review Board (IRB)

    United Health Products, Inc.

    2025-05-20
  • Clinical Investigator

    Americo F. Padilla, M.D.

    2025-03-25
  • Institutional Review Board (IRB)

    Armstrong County Memorial Hospital

    2024-11-05
  • Clinical Investigator

    Namita A. Goyal, M.D.

    2024-10-22
  • Institutional Review Board (IRB)

    Louisiana State University Health Science Center IRB

    2024-10-08
  • Bioresearch Monitoring Program/IRB

    Massachusetts Institute of Technology MIT

    2024-07-16
  • Institutional Review Board (IRB)

    New York State Psychiatric Institute IRB

    2024-03-26
  • Investigational Device Exemptions (Clinical Investigator)

    Mobeen Mazhar, M.D.

    2023-06-06

See Also (8)