Specificity of Food and Drug Administration postmarketing requirements and associations with timely submissions and regulatory decisions for oncology accelerated approvals, 2011–2023: a cross-sectional analysis

Objectives To assess the specificity of postmarketing requirement (PMR) statements and associations between PMR statement specificity and PMR study characteristics, timeliness and regulatory decisions.Methods and analysis This was a cross-sectional analysis of publicly available Food and Drug Admini...

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Main Authors: Steven Joffe, Ronac Mamtani, Ravi B Parikh, Holly Fernandez Lynch, William J Ferrell, Martin Kurian, Ernesto Ulloa Perez, Rebecca Hubbard
Format: Article
Language:English
Published: BMJ Publishing Group 2025-05-01
Series:BMJ Oncology
Online Access:https://bmjoncology.bmj.com/content/4/1/e000659.full
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author Steven Joffe
Ronac Mamtani
Ravi B Parikh
Holly Fernandez Lynch
William J Ferrell
Martin Kurian
Ernesto Ulloa Perez
Rebecca Hubbard
author_facet Steven Joffe
Ronac Mamtani
Ravi B Parikh
Holly Fernandez Lynch
William J Ferrell
Martin Kurian
Ernesto Ulloa Perez
Rebecca Hubbard
author_sort Steven Joffe
collection DOAJ
description Objectives To assess the specificity of postmarketing requirement (PMR) statements and associations between PMR statement specificity and PMR study characteristics, timeliness and regulatory decisions.Methods and analysis This was a cross-sectional analysis of publicly available Food and Drug Administration (FDA) databases to characterise PMR statements for oncology accelerated approvals (AAs) between January 2011 and July 2023. Characteristics of trials supporting AA and PMR studies were identified from product labels on the Drugs@FDA database and ClinicalTrials.gov. Main outcomes and measures included PMR statement characteristics, PMR study submission timeliness (on-time vs late) and regulatory decision (regular approval vs withdrawal).Results We analysed 181 PMR statements for 161 oncology indications. Most PMR statements specified target population (98%), endpoints (81% (44% included clinical endpoints; 37% surrogate endpoints only)), use of randomisation (63%) and comparator (54%). Fewer PMR statements specified a particular trial or protocol (45%), follow-up duration (30%), enrolment targets (26%), multicentre trial (24%), double-blinding (13%) or enrolment diversity (8%). PMR statements for indications granted regular approval were more likely than those for withdrawn indications to specify follow-up duration <1 year (27% vs 0%, p<0.001), allow endpoints other than overall or progression-free survival (27% vs 4%, p=0.01) and mention a specific trial or protocol (71% vs 36%, p=0.003). Compared to those submitted late, on-time PMR studies had fewer sites (110 vs 156, p=0.03), less use of blinding (20% vs 42%, p=0.02), more use of a continuous trial for AA and PMR (37% vs 8%, p=0.003) and more use of primary endpoints other than overall or progression-free survival (37% vs 6%, p<0.001).Conclusion PMR statement specificity for oncology AAs varies substantially. Less rigorous PMR statement and study characteristics were associated with timely PMR study submission and transition to regular approval but with important trade-offs. Given that AAs are granted without demonstrated clinical benefit, improving the balance between PMR study timeliness and rigour should be a priority when negotiating PMR statements.
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spelling doaj-art-5c0f2e25bfc94c98b81b7cbefccc84962025-08-20T01:52:11ZengBMJ Publishing GroupBMJ Oncology2752-79482025-05-014110.1136/bmjonc-2024-000659Specificity of Food and Drug Administration postmarketing requirements and associations with timely submissions and regulatory decisions for oncology accelerated approvals, 2011–2023: a cross-sectional analysisSteven Joffe0Ronac Mamtani1Ravi B Parikh2Holly Fernandez Lynch3William J Ferrell4Martin Kurian5Ernesto Ulloa Perez6Rebecca Hubbard7Department of Pediatric Oncology, Dana-Farber Cancer Institute, Boston, Massachusetts, USA4 Department of Medicine, University of Pennsylvania Perelman School of Medicine, Philadelphia, Pennsylvania, USAEmory University Winship Cancer Institute, Atlanta, Georgia, USAassistant professor of medical ethics and lawPenn Center for Cancer Care Innovation, Abramson Cancer Center, University of Pennsylvania, Philadelphia, Pennsylvania, USAHospital of the University of Pennsylvania, Philadelphia, Pennsylvania, USAUniversity of Pennsylvania, Philadelphia, Pennsylvania, USAUniversity of Pennsylvania, Philadelphia, Pennsylvania, USAObjectives To assess the specificity of postmarketing requirement (PMR) statements and associations between PMR statement specificity and PMR study characteristics, timeliness and regulatory decisions.Methods and analysis This was a cross-sectional analysis of publicly available Food and Drug Administration (FDA) databases to characterise PMR statements for oncology accelerated approvals (AAs) between January 2011 and July 2023. Characteristics of trials supporting AA and PMR studies were identified from product labels on the Drugs@FDA database and ClinicalTrials.gov. Main outcomes and measures included PMR statement characteristics, PMR study submission timeliness (on-time vs late) and regulatory decision (regular approval vs withdrawal).Results We analysed 181 PMR statements for 161 oncology indications. Most PMR statements specified target population (98%), endpoints (81% (44% included clinical endpoints; 37% surrogate endpoints only)), use of randomisation (63%) and comparator (54%). Fewer PMR statements specified a particular trial or protocol (45%), follow-up duration (30%), enrolment targets (26%), multicentre trial (24%), double-blinding (13%) or enrolment diversity (8%). PMR statements for indications granted regular approval were more likely than those for withdrawn indications to specify follow-up duration <1 year (27% vs 0%, p<0.001), allow endpoints other than overall or progression-free survival (27% vs 4%, p=0.01) and mention a specific trial or protocol (71% vs 36%, p=0.003). Compared to those submitted late, on-time PMR studies had fewer sites (110 vs 156, p=0.03), less use of blinding (20% vs 42%, p=0.02), more use of a continuous trial for AA and PMR (37% vs 8%, p=0.003) and more use of primary endpoints other than overall or progression-free survival (37% vs 6%, p<0.001).Conclusion PMR statement specificity for oncology AAs varies substantially. Less rigorous PMR statement and study characteristics were associated with timely PMR study submission and transition to regular approval but with important trade-offs. Given that AAs are granted without demonstrated clinical benefit, improving the balance between PMR study timeliness and rigour should be a priority when negotiating PMR statements.https://bmjoncology.bmj.com/content/4/1/e000659.full
spellingShingle Steven Joffe
Ronac Mamtani
Ravi B Parikh
Holly Fernandez Lynch
William J Ferrell
Martin Kurian
Ernesto Ulloa Perez
Rebecca Hubbard
Specificity of Food and Drug Administration postmarketing requirements and associations with timely submissions and regulatory decisions for oncology accelerated approvals, 2011–2023: a cross-sectional analysis
BMJ Oncology
title Specificity of Food and Drug Administration postmarketing requirements and associations with timely submissions and regulatory decisions for oncology accelerated approvals, 2011–2023: a cross-sectional analysis
title_full Specificity of Food and Drug Administration postmarketing requirements and associations with timely submissions and regulatory decisions for oncology accelerated approvals, 2011–2023: a cross-sectional analysis
title_fullStr Specificity of Food and Drug Administration postmarketing requirements and associations with timely submissions and regulatory decisions for oncology accelerated approvals, 2011–2023: a cross-sectional analysis
title_full_unstemmed Specificity of Food and Drug Administration postmarketing requirements and associations with timely submissions and regulatory decisions for oncology accelerated approvals, 2011–2023: a cross-sectional analysis
title_short Specificity of Food and Drug Administration postmarketing requirements and associations with timely submissions and regulatory decisions for oncology accelerated approvals, 2011–2023: a cross-sectional analysis
title_sort specificity of food and drug administration postmarketing requirements and associations with timely submissions and regulatory decisions for oncology accelerated approvals 2011 2023 a cross sectional analysis
url https://bmjoncology.bmj.com/content/4/1/e000659.full
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