 Kenneth A. Getz
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Industry sponsors have long focused their attention on accelerating cycle times and on reducing drug development inefficiencies.
There is no shortage of opportunities to streamline activities—from protocol design to CRO and site identification, to subject
recruitment and statistical analyses—inefficiencies abound. But up until now, attention and initiatives aimed at achieving
efficiency improvements have centered on activities within drug development phases. Scant attention has been paid to the breakdowns
that occur as clinical data and operations transition from one research phase to the next. As such, between-phase inefficiencies
may offer new opportunities for biopharmaceutical companies to accelerate drug development cycle time, improve overall performance,
and lower costs.
In-between opportunities
The impact of between-phase improvements in efficiency could be substantial. Between development phases, there is no defined
timeline in which key decisions have to be made. The treatment period is fixed within a given research phase. As a result,
the opportunity to drive efficiency within phases is limited by the amount of time it takes to run a study.
Transition efficiencies between phases also may be easier to achieve, as they are largely controlled internally. Within-phase
efficiency gains rely heavily on improvements in relationships with external service providers—a more difficult area to glean
process improvements. Based on discussions with drug development executives in pharmaceutical and biotech companies, there are three broad opportunity
areas to streamline inefficiencies during phase transitions. These between-phase opportunities are inextricably linked and
play a critical role in driving success within drug development phases. The three areas are:
- Decision making
- Data analysis and interpretation
- Planning and preparation.
According to the executives interviewed, transitional inefficiencies are in large part due to mistakes drug developers make
in gathering inappropriate and incomplete inputs into decision making late in the process and in failing to anticipate downstream
needs. Also, companies fail to build the appropriate level of internal consensus and alignment around key decisions.
"The Phase I to III mentality is a hindrance to efficiency by keeping drug developers thinking more about the means than the
end," says Evan Loh, MD, vice president of clinical research and development at Wyeth. "Companies generally know the goal
but fail to provide the necessary input to optimize decision making according to specific deliverables. Lacking that, companies
may face an interpretation nightmare trying to decide if a compound is or is not fit to move forward."
External inputs are cited as particularly important to phase transitions. "Unnecessary delays can occur between phases if
external input into decision making from scientific leaders and regulatory agencies is not sought early, when the trial is
being designed," explains Mark Bach, MD, PhD, vice president of worldwide clinical research operations for Merck & Co. "If
a company wants to register its drugs globally, then misunderstandings about the regulatory environments in various parts
of the world can cause delays."
Several executives suggest that companies are seeking more input from and expending more time on regulatory agencies during
phase transitions as a way of managing risk. "Time spent on between-phase interactions with the FDA on special protocol assessments
has been escalating while the scientific advice process of the European Agency for the Evaluation of Medicinal Products continues
to take the same length of time," says Alison Lawton, Genzyme's senior vice president of global regulatory affairs, global
policy programs, and corporate quality systems.
A number of interviewees noted that the uncertainty around reconciling multiple and diverse scientific and regulatory input
adds another element of inefficiency. "There is no commitment by regulatory agencies to offer joint advice," explains Dan
Bollag, Genzyme's vice president of regulatory affairs for biosurgery. "We literally have to make a formal appeal to each
agency."
Executives from several drug companies report that often their early phase studies are designed without later phase study
programs in mind. As a result, frequently their companies have had to resort to modifying and expanding later-stage programs
to cover for areas missed earlier.
"When it's necessary to look at Phase II results before designing a Phase III study, the key challenge is to do neither too
much nor too little advance preparation," explains Bollag. "Research sponsors usually go to one of two extremes: They may
not do any thinking about Phase III until all Phase II data is on their desk, or they may spend a lot of time figuring out
what Phase III trial to do and implement regardless of what the Phase II data tells them."