AUTHOR OF THIS BLOG

DR ANTHONY MELVIN CRASTO, WORLDDRUGTRACKER

DRUG DISCOVERY STARTUP

 

Setting up a drug discovery and development program sin academic, non-profit and other life science research companies require careful planning. This chapter contains guidelines to develop therapeutic hypothesis, target and pathway validation, proof of concept criteria and generalized cost analysis at various stages of early drug discovery. Various decision points in developing a New Chemical Entity (NCE), description of the exploratory IND and orphan drug designation, drug repurposing and drug delivery technologies are also described geared toward those who intend to develop new drug discovery and development programs.

Background

Medical innovation in America today calls for new models for collaborations that span government, academia, industry and disease philanthropy. Barriers to translation and ultimate commercialization will be lowered by bringing best practices from industry into academic settings, and by training not only a new generation of ‘translational’ scientists prepared to move a therapeutic idea forward into proof of concept in humans, but by developing a new cadre of investigators skilled in regulatory science.

As universities begin to focus on commercializing research, there is an evolving paradigm for drug discovery and early development focused innovation within the academic enterprise. The innovation process — moving from basic research to invention and to commercialization and application — will remain a complex and costly journey. New funding mechanisms, the importance of collaborations within and among institutions, the essential underpinnings of public-private partnerships that involve some or all sectors, the focus of the new field of regulatory science, and new appropriate bridges between federal health and regulatory agencies all come to bear in this endeavor.

This guideline serves to assist academic investigators in advancing new therapies from the discovery phase into early drug development, including evaluation of therapies in human and/or clinical proof of concept. It outlines necessary steps required to identify and properly validate drug targets, define the utility of employing probes in the early discovery phase, medicinal chemistry, lead optimization, and preclinical proof of concept strategies, as well as address drug delivery needs through preclinical proof of concept. Once a development candidate has been identified, the guideline provides an overview of human and/or clinical proof of concept enabling studies required by regulatory agencies prior to initiation of clinical trials.

To guide academic researchers, collaborators and start-up companies through the drug discovery, lead optimization and early phases of regulated drug development, we have developed Drug Discovery and Early Development Guidelines. The guidelines also help to ensure quality project plans are developed and projects advanced consistently. These guidelines outline the expected intellectual property required at key decision points and the process by which decisions may be taken to move a project forward.

Purpose

The purpose of this document is to define the three practical drug discovery and early development paths to advancing new cancer therapies to early stage clinical trials, including:

1.
Discovery and early development of novel, new compounds (NCE)

2.
Discovery of new, beneficial activity currently marketed drugs possess against novel cancer drug targets, also referred to as “drug repurposing”

3.
Application of novel platform technology to the development of improved delivery of currently marketed drugs

Within each of the three strategies, Decision Points must be identified along the commercial value chain. To move forward in the development process, key data required at each Decision Point must be gathered to meet the targets and expectations required to support further development. An estimate of the financial resources needed to generate the data at each Decision Point should also be determined as well as the opportunities available to outsource activities to optimally leverage strengths within the Institution. It is important to integrate these activities with the intellectual property management process Potential Decision Points which:

  • Offer opportunities to initiate meaningful discussions with regulatory agencies to define requirements for advancement of new cancer therapies to human evaluation
  • Afford opportunities to license technologies to university start-up, biotechnology and major pharmaceutical companies
  • Define potential role(s) the National Institute of Health SBIR programs may play in advancing new cancer therapies along the drug discovery and early development path.

Scope

The scope of drug discovery and early drug development within the scope of these guidelines spans Target Identification through Human (Phase I) and/or Clinical (Phase IIa) Proof of Concept. This document describes an approach to Drug Discovery and Development for Treatment, Prevention, and Control of Cancer. The Guidelines and Decision Points described herein may serve as the foundation for collaborative projects with other organizations in multiple therapeutic areas.

Assumptions

1.
These guidelines are being written with Target Identification as the initial Decision Point although the process outlined here applies to a project initiated at any of the subsequent points.

2.
The final Decision Point referenced in this document is Human and/or Clinical Proof of Concept. Although the process for New Drug Approval is well defined, it is very resource intensive and beyond the focus of most government, academic, and disease philanthropy organizations conducting drug discovery and early drug development activities.

3.
The Decision Points in this document are specific to development of a drug for the treatment of relapsed or refractory late stage cancer patients. Many of the same criteria apply to the development of drugs intended for other indications and therapeutic areas, but each disease should be approached with a logical customization of this plan. Development of compounds for the prevention and control of cancer would follow a more conservative pathway as the benefit/risk evaluation for these compounds would be different. When considering prevention of a disease one is typically treating patients at risk, but before the disease has developed in individuals that are otherwise healthy. The development criteria for these types of compounds would be more rigorous initially and would typically include a full nonclinical development program to support the human studies. Similarly, compounds being developed to control cancer suggest that the patients may have a prolonged life expectation such that long term toxicity must be fully evaluated before exposing a large patient population to the compound. The emphasis of the current document will focus on the development of compounds for the treatment of late stage cancer patients. The authors are planning a companion document that will address the specific challenges associated with the development of chemoprevention agents.

4.
Human and/or Clinical Proof of Concept strategies will differ dependent upon the intent of the product (treatment, prevention, or control). The concepts and strategies described in this document can be modified for the development of a drug for prevention or control of multiple diseaes.

5.
These Decision Points are specific to the development of a small molecule drug. Development of large molecules will require the evaluation of additional criteria and may be very specific to the nature of the molecule under development.

6.
This plan is written to describe the resources required at each Decision Point and does not presume that licensing will occur only at the final Decision Point. It is incumbent upon the stakeholders involved to decide the optimal point at which the technology should move outside the University.

7.
The plan described here does not assume that the entire infrastructure necessary to generate the data underlying each decision criterion is available at any single institution. The estimates of financial resource requirements are based on an assumption that these services can be purchased from an organization, (or funded through a collaborator) that has the necessary equipment, instrumentation, and personnel to conduct the necessary studies.

8.
The costs associated with the tasks in the development plan are based on the experiences of the authors. It is reasonable to assume that variability in the costs and duration for specific data-generating activities will be dependent upon the nature of the target and molecule under development.

Definitions

At Risk Initiation – The decision by the project team to begin activities that do not directly support the next unmet Decision Point, but will instead support a subsequent Decision Point. At Risk Initiation is sometimes recommended to decrease the overall development time.

Commercialization Point – In this context, the authors use the term to describe the point at which a commercial entity is involved to participate in the development of the drug product. This most commonly occurs through a direct licensing arrangement between the University and an organization with the resources to continue the development of the product.

Counter-screen – A screen performed in parallel with or after the primary screen. The assay used in the counter-screen is developed to identify compounds that have the potential to interfere with the assay used in the primary screen (the primary assay). Counter-screens can also be used to eliminate compounds that possess undesirable properties, for example, a counter-screen for cytotoxicity. (1)

Cumulative Cost – This describes the total expenditure by the project team from project initiation to the point at which the project is either completed or terminated.

1 Decision Point– The latest moment at which a predetermined course of action is initiated. Project advancement based on decision points balances the need to conserve scarce development resources with the requirement to develop the technology to a commercialization point as quickly as possible. Failure to meet the criteria listed for the following Decision Points will lead to a No Go recommendation.

False positive – Generally related to the ‘‘specificity’’ of an assay. In screening, a compound may be active in an assay but inactive toward the biological target of interest. For this Review, this does not include activity due to spurious, non-reproducible activity (such as lint in a sample that causes light-scatter or fluorescence). Compound interference that is reproducible is a common cause of false positives, or target-independent activity. (1)

Go Decision – The project conforms to key specifications and criteria and will continue.

High-Throughput Screen (HTS) – A large-scale experiment in which collections of compounds are tested for activity against a biological target or pathway. “Screen” for short. (1)

Hits – Slang for putative activity observed during the primary high-throughput screen, usually defined by percent activity relative to control compounds. (1)

Incremental Cost – A term used to describe the additional cost of activities that support decision criteria for any given Decision Point, independent of other activities that may have been completed or initiated to support decision criteria for any other decision point.

Library – A collection of compounds. (1)

New Chemical Entity (NCE) – A molecule emerging from the discovery process that has not previously been evaluated in clinical trials.

No Go Decision – The project does not conform to key specifications and criteria and will not continue.

Off-Target Activity – Compound activity that is not directed toward the biological target of interest but can give a positive read-out, and thus can be classified as an active in the assay. (1)

Orthagonal Assay – An assay performed following (or in parallel to) the primary assay to differentiate between compounds that generate false positives from those compounds that are genuinely active against the target. (1)

Primary Assay – The assay used for the high-throughput screen. (1)

Qualified Task – A task that should be considered, but not necessarily required to be completed at a suggested point in the project plan. The decision is usually guided by factors outside the scope of this document. Such tasks will be denoted in this document by enclosing the name of the tasks in parentheses in the Gantt Chart, e.g. (qualified task).

Secondary Assay – An assay used to test the activity of compounds found active in the primary screen (and orthogonal assay) using robust assays of relevant biology. Ideally, these are of at least medium-throughput to allow establishment of structure-activity relationships between the primary and secondary assays and establish a biologically plausible mechanism of action. (1)

Section 1 Discovery and Development of New Chemical Entities (NCE)

The Gantt chart below illustrates the scope of this document . The left-hand portion of the chart includes the name of each Decision Point as well as the incremental cost for the activities that support that task. The black bars on the right-hand portion of the figure represent the duration of the summary task (combined criteria) to support a Decision Point as well as the cumulative costfor the project at the completion of that activity. A similar layout applies to each of the subsequent figures; however the intent of these figures is to articulate the activities that underlie each Decision Point.

The submission of regulatory documents, for the purpose of this example, reflects the preparation of an Investigational New Drug (IND) application in Common Technical Document (CTD) format. The CTD format is required for preparation of regulatory documents in Europe (according to the Investigational Medicinal Product Dossier [IMPD]), Canada for investigational applications (Clinical Trial Application) and is accepted by the United States Food and Drug Administration (FDA) for INDs. The CTD format is required for electronic CTD (eCTD) submissions. The advantages of the CTD are that it facilitates global harmonization and lays the foundation upon which the marketing application can be prepared. The sections of the CTD are prepared early in development (at the IND stage) and then are updated, as needed, until submission of the marketing application.

Decision Point 1 – Target Identification

Target-based drug discovery begins with identifying the function of a possible therapeutic target and its role in the disease (2). There are two criteria that justify advancement of a project beyond Target Identification. These are:

  • Previously published (peer-reviewed) data on a particular disease target pathway or target, OR
  • Evidence of new biology that modulates a disease pathway or target

Resource requirements to support this initial stage of drug discovery can vary widely as the novelty of the target increases. In general, the effort required to elucidate new biology can be significant. Most projects will begin with these data in hand, whether from new or existing biology. We estimate that an additional $100,000 may be invested to support the Target Identification data that may already exist . However, as reflected in  if Target Validation activities proceed at risk, the total cost of the project at a “No Go” decision will reach $190,000 (estimated).

Decision Point 2 – Target Validation

Target Validation requires a demonstration that a molecular target is directly involved in a disease process, and that modulation of the target is likely to have a therapeutic effect (2). There are seven criteria for evaluation prior to advancement beyond Target Validation. These are:

  • Known molecules modulate target
  • Type of target has a history of success (e.g. Ion channel, GCPR, nuclear receptor, transcription factor, cell cycle, enzyme, etc.)
  • Genetic confirmation (e.g. Knock-out, siRNA, shRNA, SNP, known mutations, etc.)
  • Availability of known animal models
  • Low-throughput target validation assay that represents biology
  • Intellectual property of the target
  • Determine marketability of the target

The advancement criteria supporting Target Validation can usually be completed in approximately 12 months by performing most activities in parallel. In an effort to reduce the overall development timeline, we recommend starting Target Validation activities at risk (prior to a Go decision on Target Identification).  illustrates the dependencies between the criteria supporting the first two decision points. The incremental cost of the activities supporting decision-making criteria for Target Validation is approximately $162,000. However, a decision to initiate Target Validation prior to completion of Target Initiation (recommended) and subsequent initiation of Identification of Actives at risk would lead to a total project cost (estimate) of $380,000 if a No Go decision were reached at the conclusion of Target Validation.

Decision Point 3 – Identification of Actives

An Active is defined as a molecule that shows significant biological activity in a validated screening assay. By satisfying the advancement criteria listed below for Identification of Actives, the project team will begin to define new composition of matter by linking a chemical structure to modulation of the target. There are five (or six if invention disclosure occurs at this stage) criteria for evaluation at the Identification of Actives decision point. These are:

  • Acquisition of screening reagents
  • Primary HTS assay development and validation
  • Compound library available to screen
  • Actives criteria defined
  • Perform high-throughput screen
  • (Composition of Matter invention disclosure)

The advancement criteria supporting Identification of Actives can be completed in approximately 12 months in most cases by performing activities in parallel.  illustrates the dependencies and timing associated with a decision to begin activities supporting Identification of Actives prior to a Go decision on Decision Point #3. The incremental cost associated with Decision Point #3 is estimated to be $232,000 (assuming the assay is transferred and validated without difficulty). The accumulated project cost associated with a No Go decision at this point is estimated to be $640,000. This assumes an at risk initiation of activities supporting Decision Point #4.

Decision Point #4 – Confirmation of Hits

A Hit is defined as consistent activity of a molecule (with confirmed purity and identity) in a biochemical and/or cell based secondary assay. Additionally, this is the point at which the project team will make an assessment of the molecular class of each of the Hits. There are six (or seven if initial invention disclosure occurs at this stage) criteria for evaluation at the Confirmation of Hits decision point. These are:

  • Confirmation based on repeat assay, concentration response curve (CRC)
  • Secondary assays for specificity, selectivity, and mechanisms
  • Confirmed identity and purity
  • Cell-based assay confirmation of biochemical assay when appropriate
  • Drugability of chemical class (reactivity, stability, synthetic feasibility, solubility)
  • Chemical Intellectual Property (IP)
  • (Composition of Matter invention disclosure)

The advancement criteria supporting Decision Point #4 can usually be completed in approximately 18 months depending upon the existence of cell-based assays for confirmation. If the assays need to be developed or validated at the Screening Lab, we recommend starting that activity at risk concurrent with the CRC and mechanistic assays.  represents the dependencies and timing associated with the decision to begin activities supporting Confirmation of Hits prior to a Go decision on Decision Point #3. The incremental cost of Confirmation of Hits is $291,000. The accumulated project cost at a No Go decision on Decision Point #4 can be as high as $855,000 if a proceed at risk decision is made on Identification of a Chemical Lead (DP#5).

Decision Point 5 – Identification of Chemical Lead

A Chemical Lead is defined as a synthetically feasible, stable, and drug-like molecule active in primary and secondary assays with acceptable specificity and selectivity for the target. This requires definition of the Structure-Activity Relationship (SAR) as well as determination of synthetic feasibility and preliminary evidence of in vivo efficacy. (Note: projects at this stage may be eligible for Phase I SBIR). Characteristics of a chemical lead are:

  • SAR defined
  • Drugability (preliminary toxicity, hERG, Ames)
  • Synthetic feasibility
  • Select mechanistic assays
  • In vitro assessment of drug resistance and efflux potential
  • Evidence of in vivo efficacy of chemical class
  • PK/Toxicity of chemical class known based on preliminary toxicity or in-silico studies.

In order to decrease the number of compounds that fail in the drug development process, a drugability assessment is often conducted. This assessment is important in transforming a compound from a lead molecule into a drug. For a compound to be considered drugable it should have the potential to bind to a specific receptor; however, also important is the compound’s pharmacokinetic profile regarding absorption, distribution, metabolism, and excretion. Other assays will evaluate the potential toxicity of the compound in screens such as the Ames test and cytotoxicity assay. When compounds are being developed for indications where the predicted patient survival is limited to a few years, it is important to note that a positive result in the cytotoxicity assays would not necessarily limit the development of the compound and other drugability factors (such as the pharmacokinetic profile) would be more relevant for determining the potential for development.

The advancement criteria supporting Decision Point #5 will most likely be completed in approximately 12-18 months due to the concurrent activities. We recommend that SAR and drugability assessments begin at risk prior to a Go on Confirmation of Hits. Synthetic Feasibility and PK assessment will begin at the completion of the previous Decision Point (#4). The cost of performing the recommended activities to support Identification of a Chemical Lead is estimated to be $243,500 . The accumulated project costs at the completion of Decision Point #5 are estimated to be $1,110,000 including costs associated with at risk initiation of activities to support Decision Point #6.

Decision Point 6 – Selection of Optimized Chemical Lead

An Optimized Chemical Lead is a molecule that will enter IND-enabling GLP studies and GMP supplies will be produced for clinical trials. We will describe the activities that support GLP and GMP development in the next section. This section focuses on the Decision process to identify those molecules. (Note: projects at this stage may be eligible for Phase II SBIR). Criteria for selecting optimized candidates are listed below:

  • Acceptable in vivo PK and toxicity
  • Feasible formulation
  • In vivo preclinical efficacy (properly powered)
  • Dose range finding pilot toxicology (DRF)
  • Process chemistry assessment of scale up feasibility

The advancement criteria supporting Decision Point #6 can be completed in approximately 12 months. As indicated above, we recommend commencing activities to support Selection of an Optimized Chemical Lead prior to a “Go” decision on Decision Point #5. In particular, the project team should place emphasis on 6.3 (in vivo preclinical efficacy). A strong lead will have clearly defined pharmacodynamic endpoints at the preclinical stage and will set the stage for strong indicators of efficacy at Decision Point #11 (Clinical Proof-of-Concept). The cost of performing the recommended activities to support Decision Point #6 is estimated to be $195,000. The accumulated project costs at the completion of Decision Point #5 are estimated to be $1.3 million including costs associated with at risk initiation of activities to support Decision Point #7.

Decision Point 7 – Selection of a Development Candidate

A Development Candidate is a molecule for which the intent is to begin Phase I evaluation. Prior to submission of an IND, the project team must evaluate the likelihood of successfully completing the IND-enabling work that will be required as part of the regulatory application for first in human testing. Prior to Decision Point #7, many projects will advance as many as 7-10 molecules. Typically, most pharma and biotech companies will select a single development candidate with one designated backup. Here, we recommend that the anointed “Development Candidate” be the molecule that rates the best on the five criteria below. A failure to address all of these by any molecule should warrant a “No Go” decision by the project team. The following criteria should be minimally met for a development candidate:

  • Acceptable PK (with a validated bioanalytical method)
  • Demonstrated in vivo efficacy/activity
  • Acceptable safety margin (toxicity in rodents or dogs when appropriate)
  • Feasibility of GMP manufacture
  • Acceptable drug interaction profile

The advancement criteria supporting Decision Point #7 are estimated to be completed in 12 months, but may be compressed to as little as 6 months. The primary rate limiter among the decision criteria is the determination of the safety margin as this can be affected by the formulation and dosing strategies selected earlier. In this case the authors have presented a project that includes a 7-day repeat dose in rodents to demonstrate acceptable safety margin. If the development plan requires a longer toxicology study at this point, costs can be two-fold (approximately $190,000 for a 14-day repeat dose study in rats and $225,00 in dogs). The incremental costs of the activities to support Selection of a Development Candidate (as shown) are estimated to be approximately $230,000. The accumulated project cost at this point is approximately $1.65 million

Decision Point 8 – Pre-IND Meeting with FDA

Pre-IND advice from FDA may be requested for issues related to data needed to support the rationale for testing a drug in humans; the design of nonclinical pharmacology, toxicology, and drug activity studies, including design and potential uses of any proposed treatment studies in animal models; data requirements for an Investigational New Drug (IND) application; initial drug development plans, and regulatory requirements for demonstrating safety and efficacy (1). We recommend that this meeting take place after the initiation, but before the completion of tasks to support Decision Point 7 (Selection of a Development Candidate). The feedback from FDA may necessitate adjustments to the project plan. Making these changes prior to Candidate Selection will save time and money. Pre-IND preparation will require the following:

  • Prepare pre-IND meeting request to FDA, including specific questions
  • Prepare pre-IND meeting package, which includes adequate information for FDA to address the specific questions
  • Prepare the team for the pre-IND meeting
  • Conduct Pre-IND meeting with FDA
  • Adjust project plan to address FDA comments

The advancement criteria supporting Decision Point #8 should be completed in 6 months. We recommend preparing the pre-IND meeting request approximately 3 to 6 months prior to Selection of a Development Candidate (provided that the data supporting that Decision Point are promising). The cost of performing the recommended activities to support Decision Point #8 is estimated to be $37,000. The accumulated project costs at the completion of Decision Point #5 are estimated to be $1.65 million including costs associated with at risk initiation of activities to support Decision Point #9.

Decision Point 9 – Preparation and Submission of an IND Application

The decision to submit an IND Application presupposes that all of the components of the application have been addressed. The largest expense associated with preparation of the IND is related to the CMC activities (manufacture and release of GMP clinical supplies). A “Go” decision is contingent upon all of the requirements for the IND having been addressed and that the regulatory agency agrees with the clinical plan. (Note: projects at this stage may be eligible for SBIR BRIDGE Awards): The following criteria should be addressed, in addition to addressing comments from the Pre-IND meeting:

  • Acceptable clinical dosage form
  • Acceptable preclinical drug safety profile
  • Clear IND regulatory path
  • Human Proof of Concept(HPOC)/Clinical Proof of Concept (CPOC) plan is acceptable to regulatory agency (Pre-IND meeting)

The advancement criteria supporting Decision Point #9 are estimated to be completed in 12 months, but may be compressed to as little as 6 months if necessary. We recommend initiating “at risk” as long as there is confidence that a qualified development candidate is emerging before completion of DP #7 and the plan remains largely unaltered after the pre-IND meeting (Decision Point #8). The incremental costs of completing DP #9 are estimated to be $305,000. The accumulated Project Cost at this point will be approximately $1.8 million

Decision Point 10 – Human Proof of Concept

Most successful Phase I trials in oncology require 12-18 months for completion due to very restrictive enrollment criteria in these studies, in some cases. There is no “at risk” initiation of Phase I; therefore, the timeline cannot be shortened in that manner. The most important factors in determining the length of a Phase I study are a logically written clinical protocol and an available patient population. A “Go” decision clearly rests on the safety of the drug, but many project teams will decide not to proceed if there is not at least some preliminary indication of efficacy during Phase I (DP #10d below). Proceeding to Phase I trials will depend on:

  • IND clearance
  • Acceptable maximum tolerated dose (MTD)
  • Acceptable dose response (DR)
  • Evidence of human pharmacology
  • Healthy volunteer relevance

We estimate the incremental cost of an oncology Phase I study will be approximately $620,000. This can increase significantly if additional patients are required to demonstrate MTD, DR, pharmacology and/or efficacy. Our estimate is based on a 25 patient (outpatient) study completed in 18 months. The accumulated project cost at completion of DP #10 will be approximately $2.45 million

Decision Point 11: Clinical Proof of Concept

With acceptable Dose Response and Maximum Tolerated Dose having been defined during Phase I, in Phase II the project team will attempt to statistically demonstrate efficacy. More specifically, the outcome of Phase II should reliably predict the likelihood of success in Phase III randomized trials.

  • Meeting the IND objectives
  • Acceptable human PK profile
  • Evidence of human pharmacology
  • Safety and tolerance assessments

We estimate the incremental cost of an oncology Phase IIa study will be approximately $1.5 million. This cost is largely dependent on the number of patients required and the number of centers involved. Our estimate is based on 150 outpatients with studies completed in 24 months. The accumulated project cost at completion of DP #11 will be approximately $3.95 million.

Section 2 Repurposing of Marketed Drugs

Drug repurposing and rediscovery development projects frequently seek to employ the 505(b)(2) drug development strategy. This strategy leverages studies conducted and data generated by the innovator firm which is available in the published literature, in product monographs, or product labeling. Improving the quality of drug development plans will reduce 505(b)(2) development cycles time, and reduce the time and effort required by the FDA during the NDA review process. Drug repurposing projects seek a new indication, in a different patient population, and perhaps a different formulated drug product, than what is currently described in the product label. By leveraging existing nonclinical data and clinical safety experience, sponsors have the opportunity to design and execute novel, innovative clinical trials to characterize safety and efficacy in a different patient population. The decision points for drug repurposing are summarized in 

Decision Point 1: Identification of Actives

For drug repurposing, actives are identified as follows

  • Acquisition of compounds for screening
  • Primary HTS assay development, validation
  • Compound library available to screen
  • Actives criteria defined
  • Perform high-throughput screen
  • Submit Invention Disclosure and consider Use patent

Decision Point 2: Confirmation of Hits

Hits are confirmed as follows for a drug repurposing project

  • Confirmation based on repeat assay, concentration response curve (CRC)
  • Secondary assays for specificity, selectivity and mechanisms
  • Cell-based assay confirmation of biochemical assay when appropriate
  • (Submit Invention Disclosure and consider Use patent)

Decision Point 3: Gap Analysis/Development Plan

When considering the 505(b)(2) NDA approach, it is important to understand what information is available to support the proposed indication and what additional information may be needed. The development path is dependent upon the proposed indication, change in formulation, route, and dosing regimen. The gap analysis/development plan that is prepared will take this information into account in order to determine what studies may be needed prior to submission of an IND and initiating first-in-man studies. A thorough search of the literature is important in order to capture information available to satisfy the data requirements for the IND. Any gaps identified would need to be filled with studies conducted by the sponsor. A pre-IND meeting with FDA will allow the sponsor to present their plan to FDA and gain acceptance prior to submission of the IND and conduct of the first in man study

  • CMC program strategy
  • Preclinical program strategy
  • Clinical proof of concept strategy
  • Draft clinical protocol design
  • Pre-IND meeting with FDA

Decision Point 4: Clinical Formulation Development

The clinical formulation development will include the following

  • Prototype development
  • Analytical methods development
  • Prototype stability
  • Prototype selection
  • Clinical supplies release specification
  • (Submit Invention Disclosure on novel formulation)

Decision Point 5: Preclinical Safety Data Package

Preparation of the Gap Analysis/Development Plan will identify any additional studies that may be needed to support the development of the compound for the new indication. Based on this assessment, as well as the intended patient population, the types of studies that will be needed to support the clinical program will be determined. It is possible that a pharmacokinetic study evaluating exposure may be an appropriate bridge to the available data in the literature

  • Preclinical oral formulation development
  • Bioanalytical method development
  • Qualify GLP test article
  • Transfer plasma assay to GLP laboratory
  • ICH S7a & S7b core battery
  • Toxicology bridging study

Decision Point 6: Clinical Supplies Manufacture

Clinical supplies will need to be manufactured. The list below provides some of the considerations that need to be made for manufacturing clinical supplies

  • Select cGMP supplier and transfer manufacturing process
  • Cleaning validation development
  • Scale-up lead formulation at GMP facility
  • Clinical label design
  • Manufacture clinical supplies

Decision Point 7: IND Preparation and Submission

Following the pre-IND meeting with FDA, and conduct of any additional studies, the IND is prepared in Common Technical Document format to support the clinical protocol. The IND is prepared in 5 separate modules which include administrative information, summaries (CMC, nonclinical, clinical), quality data (CMC), nonclinical study reports and literature, and clinical study reports and literature. Following submission of the IND to FDA, there is a 30-day review period during which FDA may ask for additional data or clarity on the information submitted. If after 30-days FDA has communicated there is no objection to the proposed clinical study, the IND is considered active and the clinical study can commence

  • Investigator’s brochure preparation
  • Protocol preparation and submission to IRB
  • IND preparation and submission

Decision Point 8: Human Proof of Concept

Human proof of concept may commence following successful submission of an IND (i.e. and IND that has not been placed on ‘clinical hold’). The list below provides some information concerning human proof of concept:

  • IND Clearance
  • Acceptable maximum tolerated dose (MTD)
  • Acceptable dose response (DR)
  • Evidence of human pharmacology

Section 3

Development of Drug Delivery Platform Technology

Historically about 40% of new chemical entities (NCEs) identified as possessing promise for development based on drug-like qualities progress to evaluation in humans. Of those that do make it into clinical trials, about 9 out of 10 fail. Roughly 67% of that failure has been attributed to poor pharmacokinetics, undesirable metabolic properties, and/or toxicity. These fundamental challenges to the enablement of important, NCE-based therapies represent unfulfilled market potential for innovative drug delivery solutions to address. Moreover, drug delivery technology can provide a “second chance” for promising compounds that have consumed precious drug-discovery resources but were abandoned in early clinical trials due to unfavorable side-effect profiles. As one analyst observed, “pharmaceutical companies are sitting on abandoned goldmines that should be reopened and excavated again using the previously underutilized or unavailable picks and shovels developed by the drug delivery industry.” (SW Warburg Dillon Read) Although this statement was made more than 10 years ago, it continues to apply

Beyond enablement of new drugs, innovative approaches to drug delivery also hold potential to enhance marketed drugs (e.g., through improvement in convenience, tolerability, safety, and/or efficacy); expand their use (e.g., through broader labeling in the same therapeutic area and/or increased patient acceptance/compliance); or transform them by enabling their suitability for use in other therapeutic areas. These opportunities contribute enormously to the potential for value creation in the drug delivery field.

Decision Point 1: Clinical Formulation Development

  • Prototype development
  • Analytical methods development
  • Prototype stability
  • Prototype selection.
  • Clinical supplies release specification
  • (Submit Invention Disclosure on novel formulation)

 

Decision Point 2: Development Plan

Preparation of a development plan allows the sponsor to evaluate the available information regarding the compound of interest (whether at the development stage or a previously marketed compound) to understand what information may be available to support the proposed indication and what additional information may be needed. The development path is dependent upon the proposed indication, change in formulation, route, and dosing regimen. The development plan that is prepared will take this information into account in order to determine what information or additional studies may be needed prior to submission of an IND and initiating first-in-man studies. A thorough search of the literature is important in order to capture available information to satisfy the data requirements for the IND. Any gaps identified would need to be filled with studies conducted by the sponsor. A pre-IND meeting with FDA will allow the sponsor to present their plan to FDA and gain acceptance (de-risk the program) prior to submission of the IND and conduct of the first in man study

  • CMC program strategy
  • Preclinical program strategy
  • Clinical proof of concept strategy
  • Draft clinical protocol design
  • Pre-IND meeting with FDA

Decision Point 3: Clinical Supplies Manufacture

  • Select cGMP supplier and transfer manufacturing process
  • Cleaning validation development
  • Scale up lead formulation at GMP facility
  • Clinical label design
  • Manufacture clinical supplies

 

Decision Point 4: Preclinical Safety Package

Preparation of the Gap Analysis/Development Plan will identify any additional studies that may be needed to support the development of the new delivery platform for the compound. Based on this assessment, as well as the intended patient population, the types of studies that will be needed to support the clinical program will be determined. It is possible that a pharmacokinetic study evaluating exposure may be an appropriate bridge to the available data in the literature

Preclinical Safety Package

  • Preclinical oral formulation development
  • Bioanalytical method development
  • Qualify GLP test article
  • Transfer plasma assay to GLP laboratory
  • ICH S7a & S7b core battery
  • Toxicology bridging study

Decision Point 5: IND Preparation and Submission

Following the pre-IND meeting with FDA, and conduct of any additional studies, the IND is prepared in Common Technical Document format to support the clinical protocol. The IND is prepared in 5 separate modules which include administrative information, summaries (CMC, nonclinical, clinical), quality data (CMC), nonclinical study reports and literature, and clinical study reports and literature. Following submission of the IND to FDA, there is a 30-day review period during which FDA may ask for additional data or clarity on the information submitted. If after 30-days FDA has communicated there is no objection to the proposed clinical study, the IND is considered active and the clinical study can commence

 IND Preparation and Submission

  • Investigator’s brochure preparation
  • Protocol preparation and submission to IRB
  • IND preparation and submission

Decision Point 6: Human Proof of Concept

Human proof of concept may commence following successful submission of an IND (i.e. and IND that has not been placed on ‘clinical hold’). The list below provides some information concerning human proof of concept

 Human Proof of Concept

  • IND Clearance
  • Acceptable maximum tolerated dose (MTD)
  • Acceptable dose response (DR)
  • Evidence of human pharmacology

Decision Point 7:

Clinical Proof of Concept

With acceptable Dose Response and Maximum Tolerated Dose having been defined during Phase I, in Phase II the project team will attempt to statistically demonstrate efficacy. More specifically, the outcome of Phase II should reliably predict the likelihood of success in Phase III randomized trials

Clinical Proof of Concept

  • IND Clearance
  • Acceptable PK profile
  • Efficacy
  • Direct and indirect biomarkers
  • Safety and tolerance assessments

Section 4

Alternative NCE Strategy: Exploratory IND

The plans described previously in this guideline describe advancement of novel drugs as well as repurposed or reformulated, marketed drug products to human and/or clinical proof of concept trials using the traditional or conventional early drug development, investigational new drug (IND) approach. This section of the guideline outlines an alternative approach to accelerating novel drugs and imaging molecules to humans employing a Phase 0, exploratory IND strategy (Exploratory IND). The Exploratory IND strategy was first issued in the form of draft guidance in April, 2005. Following a great deal of feedback from the public and private sector, the final guidance was published in January, 2006.

Phase 0 describes clinical trials which occur very early in the Phase I stage of drug development. Phase 0 trials limit drug exposure to humans (up to 7 days) and have no therapeutic intent. Phase 0 studies are viewed by the FDA and NCI as important tools to accelerating novel drugs to the clinic. There is some flexibility in data requirements for an Exploratory IND. These requirements are dependent on the goals of the investigation (e.g., receptor occupancy, pharmacokinetics, human biomarker validation), the clinical testing approach, and anticipated risks.

Exploratory IND studies provide the sponsor with an opportunity to evaluate up to five chemical entities (optimized chemical lead candidates) or formulations at once. When an optimized chemical lead candidate or formulation is selected, the Exploratory IND is then closed, and subsequent drug development proceeds along the traditional IND pathway. This approach allows one, when applicable, to characterize the human pharmacokinetics and target interaction of chemical lead candidates. Exploratory IND goals are typically to:

  • Characterize the relationship between mechanism of action and treatment of the disease, in other words, to validate proposed drug targets in humans
  • Characterize the human pharmacokinetics
  • Select the most promising chemical lead candidate from a group of optimized chemical lead candidates (note that the chemical lead candidates do not necessarily have the same chemical scaffold origins)
  • Explore the biodistribution of chemical lead candidates employing imaging strategies (e.g., PET studies)

Exploratory IND studies are broadly described as “microdosing” studies and clinical studies attempting to demonstrate a pharmacologic effect. Exploratory IND or Phase 0 strategies must be discussed with the relevant regulatory agency before implementation. These studies are described below.

Microdosing studies are intended to characterize the pharmacokinetics of chemical lead candidates or the imaging of specific human drug targets. Microdosing studies are not intended to produce a pharmacologic effect. Doses are limited to less than 1/100th of the dose predicted (based on preclinical data) to produce a pharmacologic effect in humans, or a dose of less than 100 mcg, whichever is less. Exploratory IND-enabling preclinical safety requirements for microdosing studies are substantially less than the conventional IND approach. In the US, a single dose, single species toxicity study employing the clinical route of administration is required. Animals are observed for 14 days following administration of the single dose. Routine toxicology endpoints are collected. The objective of this toxicology study is to identify the minimally toxic dose, or alternatively, demonstrate a large margin of safety (e.g., 100x). Genotoxicity studies are not required. The EMEA, in contrast to the FDA, requires toxicology studies employing two routes of administration, intravenous, and the clinical route prior to initiating microdosing studies. Genotoxicity studies (bacterial mutation and micronucleus) are required. Exploratory IND workshops have discussed or proposed allowance of up to five microdoses administered to each subject participating in an Exploratory IND study, provided each dose does not exceed 1/100th the NOAEL or 1/100th of the anticipated pharmacologically active dose, or the total dose administered is less than 100 mcg, whichever is less. In this case, doses would be separated by a washout period of at least six pharmacokinetic terminal half-lives. Fourteen-day repeat toxicology studies encompassing the predicted therapeutic dose range (but less than MTD) have also been proposed to support expanded dosing in microdosing studies.

Exploratory IND clinical trials designed to produce a pharmacologic effect were proposed by PhRMA in May, 2004, based on a retrospective analysis of 106 drugs which supported the accelerated preclinical safety testing paradigm. In Phase 0 studies designed to produce a pharmacologic effect, up to five compounds can be studied. The compounds must have a common drug target, but do not necessarily have to be structurally related. Healthy volunteers or minimally ill patients may receive up to 7 repeated doses in the clinic. The goal is to achieve a pharmacologic response but not define the maximum tolerated dose (MTD). Preclinical safety requirements are greater compared to microdosing studies. Fourteen-day repeat toxicology studies are required, and conducted in rodents (i.e., rats), with full clinical and histopathology evaluation. In addition, a full safety pharmacology battery, as described by ICH S7a, is required. In other words, untoward pharmacologic effects on the cardiovascular, respiratory, and central nervous systems are characterized prior to Phase 0. In addition, genotoxicity studies employing bacterial mutation and micronucleus assays are required. In addition to the 14-day rodent toxicology study, a repeat dose study in non-rodent specie (typically dog) is conducted at the rat NOAEL dose. The duration of the non-rodent repeat dose study is equivalent to the duration of dosing planned for the Phase 0 trial. If toxicity is observed in the non-rodent specie at the rat NOAEL, the chemical lead candidate will not proceed to Phase 0. The starting dose for Phase 0 studies is defined typically as 1/50th the rat NOAEL based on a per meter squared basis. Dose escalation in these studies is terminated when: 1) pharmacologic effect or target modulation is observed, 2) a dose equivalent (e.g., scaled to humans on a per meter squared basis) to one-fourth the rat NOAEL, or 3) human systemic exposure reflected as AUC reaches ½ the AUC observed in the rat or dog in the 14-day repeat toxicology studies, whichever is less.

Early phase clinical trials involving terminally ill patients without therapeutic options, involving potentially promising drugs for life threatening diseases, may be studied under limited (e.g., up to 3 days dosing) conditions employing a Facilitated IND strategy. As with the Phase 0 strategies described above, it is imperative that this approach be defined in partnership with the FDA prior to implementation.

The reduced preclinical safety requirements are scaled to the goals, duration and scope of Phase 0 studies. Phase 0 strategies have merit when the initial clinical experience is not driven by toxicity, when pharmacokinetics are a primary determinant in selection from a group of chemical lead candidates (and a bioanalytical method is available to quantify drug concentrations at microdoses), when pharmacodynamic endpoints in surrogate (e.g., blood) or tumor tissue is of primary interest, or to assess PK/PD relationships (e.g., receptor occupancy studies employing PET scanning).

PhRMA conducted a pharmaceutical industry survey in 2007 to characterize the industry’s perspective on the current and future utility of exploratory IND studies (3). Of the 16 firms who provided survey responses, 56% indicated they had either executed or were planning to execute exploratory IND development strategies. The authors concluded that the merits of exploratory INDs continue to be debated, however, this approach provides a valuable option to advancing drugs to the clinic.

There are limitations to the exploratory IND approach. Doses employed in Phase 0 studies may not be predictive of doses over the human dose range (up to maximum tolerated dose). Phase 0 studies in patients raises ethical issues, compared to conventional Phase I, in that escalation into a pharmacologically active dose range may not be possible under the Exploratory IND guidance. Phase 0 strategy is designed to kill drugs early that are likely to fail based on PK or PK/PD. Should Phase 0 lead to a go decision, however, a conventional IND is required for subsequent clinical trials, adding cost and time. Perhaps one of the most compelling arguments for employing an Exploratory IND strategy is in the context of characterizing tissue distribution (e.g., receptor occupancy following PET studies) following microdosing.

Section 5

Orphan Drug Designation

Development programs for cancer drugs are often much more complex as compared to drugs used to treat many other indications. This complexity often results in extended development and approval timelines. In addition, oncology patient populations are often much smaller by comparison to other more prevalent indications. These factors (e.g., limited patent life and smaller patient populations) often complicate commercialization strategies and can, ultimately, make it more difficult to provide patient access to important new therapies.

To help manage and expedite the commercialization of drugs used to treat rare diseases, including many cancers, the Orphan Drug Act was signed into law in 1983. This law provides incentives to help sponsors and investigators develop new therapies for diseases and conditions of less than 200,000 cases per year allowing for more realistic commercialization.

The specific incentives for orphan-designated drugs are as follows:

  • Seven years of exclusive marketing rights to the sponsor of a designated orphan drug product for the designated indication once approval to market has been received from the FDA.
  • A credit against tax for qualified clinical research expenses incurred in developing a designated orphan product.
  • Eligibility to apply for specific orphan drug grants.

A sponsor may request orphan drug designation for:

  • A previously unapproved drug.
  • A new indication for a marketed drug.
  • A drug that already has orphan drug status—if the sponsor is able to provide valid evidence that their drug may be clinically superior to the first drug.

A sponsor, investigator, or an individual may apply for orphan drug designation prior to establishing an active clinical program or can apply at any stage of development (e.g., Phase 1 – 3). If orphan drug designation is granted, clinical studies to support the proposed indication are required. A drug is not given orphan drug status and, thus marketing exclusivity, until the FDA approves a marketing application. Orphan drug status is granted to the first sponsor to obtain FDA approval and not necessarily the sponsor originally submitting the orphan drug designation request.

There is no formal application for an orphan drug designation. However, the regulations (e.g., 21 CRF 316) identify the components to be included. An Orphan Drug Designation Request is typically a five- to ten-page document with appropriate literature references appended to support the prevalence statements of less than 200,000 cases/year. The Orphan Drug Designation Request generally includes:

  • The specific rare disease or condition for which orphan drug designation is being requested.
  • Sponsor contact, drug names, and sources.
  • A description of the rare disease or condition with a medically plausible rationale for any patient subset type of approach.
  • A description of the drug and the scientific rationale for the use of the drug for the rare disease or condition.
  • A summary of the regulatory status and marketing history of the drug.
  • Documentation (for a treatment indication for the disease or condition) that the drug will affect fewer than 200,000 people in the United States (prevalence).
  • Documentation (for a prevention indication [or a vaccine or diagnostic drug] for the disease or condition) that the drug will affect fewer than 200,000 people in the United States per year (incidence).
  • Alternatively, a rationale may be provided for why there is no reasonable expectation that costs of research and development of the drug for the indication can be recovered by sales of the drug in the United States.

Following receipt of the request, the FDA Office of Orphan Product Development (OOPD) will provide an acknowledgment of receipt of the Orphan Drug Designation Request. The official response will typically be provided within 1 to 3 months following submission. Upon notification of granting of an orphan drug designation, the name of the sponsor and the proposed rare disease or condition will be published in the Federal Register as part of public record. The complete Orphan Drug Designation Request is placed in the public domain once the drug has received marketing approval in accordance with the Freedom of Information Act.

Finally, the sponsor of an orphan designated drug must provide annual updates that contain a brief summary of any ongoing or completed nonclinical or clinical studies, a description of the investigational plan for the coming year, any anticipated difficulties in development, testing, and marketing, and a brief discussion of any changes that may affect the orphan drug status of the product

Conclusion

While many authors have described the general guidelines for drug development (4,5), etc., no one has outlined the process of developing cancer drugs in an academic setting. It is well known that the propensity for late stage failures has lead to a dramatic increase in the overall cost of drug development over the last 15 years. It is also commonly accepted that the best way to prevent late stage failures is by increasing scientific rigor in the discovery, preclinical, and early clinical stages. Where many authors present Drug Discovery as a single monolithic process, we intend to reflect here that there are multiple Decision Points contained within this process.

An alternative approach is the Exploratory IND (Phase 0) under which the endpoint is proof-of principle demonstration of target inhibition (6). This potentially paradigm-shifting approach may dramatically improve the probability of late stage success and may offer additional opportunities for academic medical centers to become involved in drug discovery and development.

References

  1. Pre-IND Consultation Program. US Food and Drug Administration. [Online] [Cited: August 17, 2010.] http://www.fda.gov/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/ApprovalApplications/InvestigationalNewDrugINDApplication/Overview/default.htm.
  2. Apparent activity in high-throughput screening: origins of compound-depedent assay interference. Thorne N, et al. 2010, Curr Opin Chem Biol, p. doi:10.1016/j.cbpa.2010.03.020. [PMC free article] [PubMed]
  3. Karara AH, Edeki T, McLeod J. et al. PhRMA survey on the conduct of first-in-human clinical trials under exploratory investigational new drug applications. J Clin Pharmacol. 2010;50:380–391. [PubMed]
  4. The price of innovation: new estimates of drug development costs. DiMasi, J.A., Hansen, R.W., and Grabowski, H.G. 2003, Journal of Health Economics, pp. 151-185. [PubMed]
  5. Mehta, Shreefal S. Commercializing Successful Biomedical Technologies. Cambridge : Cambridge University Press, 2008.
  6. Phase 0 Clinical Trails in Cancer Drug Development: From FDA Guidance to Clinical Practice. Kinders, Robert, et al. 2007, Molecular Interventions, pp. 325-334. [PubMed]

Additional References

  1. Eckstein, Jens. ISOA/ARF Drug Development Tutorial.

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