Precision medicine is much in the news––and
the need to target the right drug to the right patient using genomic and other
information is clearly going to be major part of healthcare in the future. Today's
news included an announcement from
the FDA that it had expanded the approved indications for Kalydeco, a breakthrough drug for the treatment of
cystic fibrosis. The previous label
indication described Kalydeco as a
cystic fibrosis transmembrane
conductance regulator (CFTR) potentiator indicated for the treatment of cystic
fibrosis (CF) in patients age 2 years and older who have one of the following
mutations in the CFTR gene: G551D, G1244E, G1349D, G178R, G551S, S1251N,
S1255P, S549N, or S549R …[or] R117H
The new label, according to the FDA, expands the use of
Kalydeco from the 10 mutations above to include an additional 23 mutations, for
a total of 33. This is great news for
cystic fibrosis patients, as the clinical studies in the original population
showed that treatment with Kalydeco resulted in a significant increase in
patients’ lung function. From a precision medicine perspective the Kalydeco
expanded label could be viewed simply as yet another drug label with genomic
information about the drug’s appropriate use—after all, there are already well
over 200 drugs approvedby the FDA that include pharmacogenomic information. However, it isn’t just the dramatic increase
in the number of mutations in the Cystic Fibrosis Transmembrane Receptor gene
that makes the FDA’s announcement remarkable, it is the evidentiary basis on
which the dramatic expansion in the use of Kalydeco was approved. The FDA’s announcement also had this particularly
noteworthy statement:
Results from an in vitro cell-based
model system have been shown to reasonably predict clinical response to
Kalydeco. When additional mutations responded to Kalydeco in the laboratory
test, researchers were thus able to extrapolate clinical benefit demonstrated
in earlier clinical trials of other mutations. This resulted in the addition of
gene mutations for which the drug is now indicated.
In other words, the indication for
Kalydeco was approved solely on the basis of in vitro studies without
additional human clinical data (or animal data for that matter). Vertex Pharmaceuticals, the maker of
Kalydeco, was able to persuade the FDA that because there was a sufficiently high
correlation between the in vitro assays and clinical data for the previously
studied mutations, it was more than reasonable to allow the drug to be used for
patients with 23 additional mutations that showed a significant gain in
function in cell-based assays. I am
unaware of any similar action by the FDA. So the Kalydeco announcement is more than
another step in the targeting of drugs based on individual biomarkers, it is a
major step by the FDA in regulatory flexibility in streamlining drug development
as the science of predicting drug response evolves. We are indeed at the beginning of an
interesting journey on an uncharted road to the future of drug development.
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