Real Time Oncology Review (RTOR) – implications for launch and commercialization | Diaceutics

Real Time Oncology Review (RTOR) – implications for launch and commercialization

August 23rd, 2018



The FDA intends to make the development and review of cancer drugs more efficient under the Real Time Oncology Review (RTOR) pilot program. Under this supplemental applications pilot, launched last year, evaluation of clinical data begins as soon as clinical data becomes available and results are ‘locked’. This means that the FDA is in a position to approve a formal application much sooner. In July Kisqali (ribociclib combination treatment) was approved less than one month after the June submission date and many months ahead of the scheduled approval date.

A lag time between approval and commercial launch could cost businesses that are not prepared to launch millions of dollars in lost revenue when factors such as intellectual property protection, licensing and potential sales revenue are considered.

Even more consequential is the time that patients may lose when new, potentially life-saving therapies are not available. From a competitive perspective, being first to market or first to launch is a favorable outcome for manufacturers, but only if the manufacturer is launch ready and prepared for a potentially expedited approval.

The Diaceutics end to end strategic and tactical planning services can help organizations be ready to launch. We support any launch that includes biomarkers for patient stratification, safety and efficacy, including market access initiatives.

This week, the FDA granted approval for pembrolizumab in combination with chemotherapy for first-line treatment of metastatic non-squamous NSCLC, making it the second FDA approval using RTOR. Previous submissions from Merck have included the use of a PD-L1 companion diagnostic.

The process is certainly faster and more efficient, nonetheless there are implications for the manufacturer. Smarter launch strategies need to be designed to accommodate the shorter review times to prevent any delay to launch and commercialization. Complex submissions that include companion diagnostics may be excluded in the pilot program – the FDA are more interested in drugs likely to demonstrate substantial improvements over available therapy (‘Breakthrough Therapy’ designation) with simple study designs and easy to interpret clinical endpoints such as overall survival. The FDA claim that the new process is ‘good for patients, good for health care providers, good for product developers, and good for the FDA’ despite stipulating that studies conducted exclusively outside the United States are excluded from the RTOR program. No justification is provided for this ‘US clinical trials’ rule and there is a risk that this could lead to higher costs for clinical trials as manufacturers may need US, Chinese and Japanese specific trials for global launch. There are further implications for treatments for rare diseases because clinical trial recruitment could be delayed if insufficient patients with a particular disorder can be recruited in a timely way from the US patient population.

The new review process is reported to be piloted in a number of applications for expanded use of already approved cancer drugs and if the process succeeds (no timeline is given), it will be expanded to applications for new cancer treatments. If recent trends continue, we are likely to see a number of additional therapies and indications gaining rapid approval, highlighting the need for the manufacturer to be launch ready sooner in order to achieve commercial launch excellence.

https://www.fda.gov/AboutFDA/CentersOffices/OfficeofMedicalProductsandTobacco/OCE/ucm612927.htm

https://www.fda.gov/Drugs/InformationOnDrugs/ApprovedDrugs/ucm617471.htm

Webinars & Podcasts

August 9th, 2018
Podcast: Oncology Patient Research
Why do we need to talk biomarkers with patients? Senior Director of Market Research at Diaceutics, Marianne Fillion, recently spearheaded an effort to gather insights directly from oncology patients to get an understanding of what they know about ...
April 20th, 2018
Podcast: PM Readiness Report 2018
Peter Keeling discusses the landscape and challenges for precision medicine, companion diagnostics, CDx or biomarker and conduit diagnostics are discussed including global laboratory test data analysis and forecasts for budget impact and value.
View all

Expert Insights

April 19th, 2018
The CMS National Coverage Decision on NGS
I. Introduction On March 16, 2018, the Centers for Medicare and Medicaid Services (CMS) finalized a National Coverage Determination (NCD) that cove...
January 19th, 2018
What does the EU IVD Regulation mean for companion diagnostics and LDTs?
Dave Smart, PhD, Director at Diaceutics, discusses the introduction of the EU IVD Regulation. While it is considered a necessary step, the Regulati...
View all expert insights

Competitive Benchmarking Reports

March 16th, 2018
PM Readiness Report 2018 Summary
March 14th, 2017
Pharma Readiness for Diagnostic Integration 2017
View all reports

Publications

September 11th, 2018
BRAF mutation testing in melanoma – Poster presented at European Congress of Pathology 2018
BRAF mutation testing in melanoma: a study including Austria, Germany and UK, highlighting concordance for current technologies, and potential requirement of more sensitive technologies in future applications.
August 3rd, 2018
A Way Forward: Leveraging Advanced Diagnostic Testing to Unlock the Value of Precision Medicine
Read about how advanced diagnostic testing, ensuring that right patient gets the right therapy, at the right time, particularly with respect to therapies where the test result determines whether or not the therapy should be used (precision medicin...
View all publications
Facebook
Twitter
YouTube
LinkedIn