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Expanded Access to Investigational Drugs for Treatment Use: Questions and Answers

FinalCenter for Drug Evaluation and Research10/22/2025

Description

This guidance provides information for industry, researchers, physicians, institutional review boards, and patients about the implementation of FDA’s regulations on expanded access to investigational drugs for treatment use under an investigational new drug application (21 CFR part 312, subpart I), which went into effect on October 13, 2009. FDA received numerous questions concerning implementation of the regulatory requirements for expanded access. As a result, FDA issued the guidance for industryExpanded Access to Investigational Drugs for Treatment Use: Questions and Answers(June 2016, updated October 2017), providing recommendations in a question-and-answer format, addressing the most frequently asked questions. Since 2017, FDA has received additional questions concerning implementation of the regulatory and statutory requirements of expanded access to investigational drugs, including those added by the 21st Century Cures Act and the FDA Reauthorization Act of 2017.

Scope & Applicability

Product Classes

1
Investigational Drug

drug or biological product not yet approved for marketing; Drugs used for treatment use under expanded access categories.; Drug used for treatment under expanded access; The product being provided through expanded access; Drugs provided under expanded access.

Stakeholders

10
Institutional Review Board

Governs top dose in clinical studies

doctor

Clinical staff member responsible for medical care and informing the patient of risks.

legally authorized representative

Person authorized to provide consent on behalf of the patient if needed.

patient

individual receiving expanded access treatment; The individual receiving the investigational treatment and providing consent.

distributor

Entity involved in investigational drug supply chain

manufacturer

Entity required to conduct postmarket surveillance; entity responsible for submitting postmarket surveillance plans; Entity holding the approved PMA, HDE, or cleared 510(k); The entity responsible for conducting postmarket surveillance and submitting reports.; Entity that can use the checklist as a reference for submissions.

Sponsor

Entity responsible for submitting applications under section 524B

Physician

Allowed value for reporter qualification

Sponsor-Investigator

A licensed physician who submits an expanded access IND and administers the drug.; Physician acting as a sponsor for an individual patient IND; An individual who both initiates and conducts a clinical investigation.; Role that may authorize expanded access protocols

licensed physician

Typically submit individual patient expanded access requests; The individual responsible for treating the patient under expanded access.; Healthcare provider seeking information for patients; doctor or clinical staff whom the patient can contact

Regulatory Context

Attributes

6
30-day period

Waiting period before an IND goes into effect

risk classification

reasonably foreseeable risks or side effects

waiting period

Time required before treatment may begin after submission

Benefit-Risk Assessment

Evaluation used to determine if expanded access is appropriate

5 working days

Timeframe to report emergency use to IRB

15 working days

Timeframe to submit written IND after emergency authorization

Related CFR Sections (20)

Related Warning Letters (10)

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See Also (8)

Expanded Access to Investigational Drugs for Treatment Use: Questions and Answers | Guideline Explorer | BioRegHub