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Benefit-Risk Assessment for New Drug and Biological Products

FinalCenter for Biologics Evaluation and Research Center for Drug Evaluation and Research10/17/2023
Benefit-Risk AssessmentREMSBenefit-Risk Framework

Description

The intent of this guidance is to clarify for drug sponsors and other stakeholders how considerations about a drug’s benefits, risks, and risk management options factor into certain premarket and postmarket regulatory decisions that the Food and Drug Administration (FDA or Agency) makes about new drug applications (NDAs) submitted under section 505(c) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) as well as biologics license applications (BLAs) submitted under section 351(a) of the Public Health Service Act (PHS Act). This guidance first articulates important considerations that factor into the Center for Drug Evaluation and Research’s (CDER) and the Center for Biologics Evaluation and Research’s (CBER) benefit-risk assessments, including how patient experience data can be used to inform the benefit-risk assessment. It then discusses how sponsors can inform FDA’s benefit-risk assessment through the design and conduct of a development program, as well as how they may as well as how they may present benefit and risk information in the marketing application.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

4
New Drug

Subject of the benefit-risk assessment guidance

Biological Products

Requires analytical comparability per ICH Q5E

Controlled Substances

drugs that are scheduled under the Controlled Substances Act

Rare Diseases

A higher degree of uncertainty is common in drug development programs for rare diseases.

Stakeholders

2
Sponsor

Entity responsible for submitting applications under section 524B

Advisory Committee

Convened to provide advice on withdrawal issues

Regulatory Context

Regulatory Activities

6
NDA

New Drug Application

End of Phase 2 meeting

Critical timepoint for discussions on benefit and risk considerations

BLA

Biologics License Application

PDUFA VI

Sixth authorization of the Prescription Drug User Fee Act

Efficacy Supplements

Table 1 provides considerations for premarket benefit-risk assessment of NDAs, BLAs, and Efficacy Supplements.

Accelerated Approval

Pathway for drugs and biologics for serious conditions; Regulatory pathway supported by surrogate or intermediate endpoints; Regulatory pathway based on surrogate or intermediate endpoints; Pathway for products based on surrogate or intermediate clinical endpoints

Document Types

9
Patient Experience Data

Data intended to provide information about patients' experiences with a disease

PBRER

Periodic Benefit-Risk Evaluation Report; Periodic Benefit-Risk Evaluation Report used for safety reporting.; Periodic Benefit-Risk Evaluation Report used for benefit-risk assessment

Value Tree

A graphical or tabular summary of results for benefits and risks.

Patient preference information

Captures the value patients place on important attributes of a medical product

Boxed Warning

Specific labeling requirement for safety

Product Labeling

Inclusion of PRO data in the prescribing information

Clinical Review Template

CBER integrated the Benefit-Risk Framework into its clinical review template.

Medication Guide

FDA-approved patient labeling

Prescribing Information

The primary section of drug labeling where SLCs are implemented

Attributes

3
Substantial Evidence

Standard required for drug effectiveness approval

Fit-for-purpose

Status of PRO instruments for regulatory decision-making.

Unmet Medical Need

Condition where patients lack treatment options

Technical Details

Testing Methods

4
Clinical Outcome Assessment

Tools used to measure neurologic function and daily life functioning

Patient Preference Studies

Studies designed to elicit patient values and tradeoffs; studies used to define the context of benefit-risk tradeoffs

Biomarkers

Section 8.6 trial assessments

Patient-Reported Outcomes

Examples of COAs including work productivity

Processes

2
Manufacturing Process

Changes to this process may affect the identity and NDI status of an ingredient.; Changes to this process may create an NDI; you should describe the manufacturing process and provide detailed information; includes fermentation as an intrinsic part of identity

Structured benefit-risk planning

Purposeful activity to incorporate benefit-risk assessment throughout the lifecycle

Clinical Concepts

3
Adverse Events

Reporting adverse events when engaging with patients.; changes may be related to benefits, tolerability, and/or unintended effects

Adverse Event Reports

Information relevant to safety of animals with IGAs

Serious adverse events

Anticipated risks that must be outweighed by benefits

Identified Hazards

Hazards

2
Misuse and Abuse

Risks incorporated into benefit-risk assessments for controlled substances

Safety Signal

Information suggesting a new potentially causal association or a new aspect of a known association between an intervention and an event.

Standards & References

Specifications

1
Primary efficacy endpoint

Efficacy endpoints in Phase 3 trials

ICH References (2)

ICH E2C(R2)

Periodic Benefit-Risk Evaluation Report (PBRER) standard for marketed products; Periodic Benefit-Risk Evaluation Report guidance; The primary guidance document for Periodic Benefit-Risk Evaluation Reports.; Periodic Benefit-Risk Evaluation Report (PBRER) guidance

ICH M4E(R2)

The Common Technical Document (CTD)—Efficacy.

Related CFR Sections (6)

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)

Benefit-Risk Assessment for New Drug and Biological Products | Guideline Explorer | BioRegHub