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  • 1.  Investigator Initiated Trials

    This message was posted by a user wishing to remain anonymous
    Posted 28-May-2021 09:30
    This message was posted by a user wishing to remain anonymous

    I know a company sponsor can use an IIT -- independent investigator initiated trial for an investigational agent as the proof of concept for the basis of a phase 3 trial design, correct?  Drug is being supplied to the investigator. Does the company sponsor need to discuss this up front with the Agency if planning for use in designing a registration trial? Can a company assist in the protocol review or medical writing support?  What expectation to the data access after completion is there and in what form should the sponsor recommend to the investigator with assurance the study was conducted under  GCP.
    Meaning if this is independent and the investigator is inclined to do it but seeks a bit of advice from the co, how does this work?

    Thanks for any input from experience. 



  • 2.  RE: Investigator Initiated Trials

    Posted 29-May-2021 07:51
    Yes, your assumption that an investigator initiated trial can be used for proof of concept is correct. This is often done for a marketed product when the commercial or medical affairs side of the company is exploring a new indication and doesn't want to involve an operations organization.

    Keep in mind that anyone doing a study with an investigational agent anywhere in the world will need to obtain regulatory authority and ethics approvals. Such an investigator initiated trial is possible if the investigator submits an IND/CTA and IRB/EC applications in his/her own name and assumes legal responsibility for conduct of the study regardless of the source of funding for the trial. The investigator is responsible for conduct of the study under GCP, which any regulatory authority or ethics committee would require. There is no requirement that the company providing the investigational agent discuss the study with the regulatory agency. The company can design the trial, write the protocol, or provide whatever support is needed, including data collection and monitoring. All of the company's involvement should be detailed in a contract with the investigator as the basis for supplying the investigational agent. See the below definition of a Sponsor - the only requirement for being a Sponsor is taking responsibility and initiating a clinical trial.

    Quoting 21 CFR 312.3 Definitions and interpretations: Sponsor means a person who takes responsibility for and initiates a clinical investigation. The sponsor may be an individual or pharmaceutical company, governmental agency, academic institution, private organization, or other organization. The sponsor does not actually conduct the investigation unless the sponsor is a sponsor-investigator. A person other than an individual that uses one or more of its own employees to conduct an investigation that it has initiated is a sponsor, not a sponsor-investigator, and the employees are investigators.


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    Glen Park PharmD
    Vice President, Regulatory Affairs and Quality Assurance
    Scynexis, Inc.
    New York NY
    United States
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  • 3.  RE: Investigator Initiated Trials

    Posted 29-May-2021 10:14

     

     

    Good assessment from Glen.  I'll just add that the process is very much the same for devices (i.e., physician-sponsor IDEs).

     

    Also, there may be a need for the device manufacturer to make non-clinical safety data available for FDA review and approval of the PS-IDE.  Although these data could in theory be provided to the physician sponsor for use in their submission, in practice it's typically done by way of a device master file (MAF) or by reference to a company sponsored IDE.

     

    Best regards,

     

    Ted

     

     

     






  • 4.  RE: Investigator Initiated Trials

    This message was posted by a user wishing to remain anonymous
    Posted 01-Jun-2021 08:52
    This message was posted by a user wishing to remain anonymous

    You don't need an Agency meeting to to do a proof of concept trail under an IIT! If the company sponsor is confident that the POC design/trial results would translate into a successful Phase III trial outcome then its your choice! However, for designing pivotal phase 3 trial, once the safety/POC of the new drug is established via IIT, I would strongly recommend end of POC meeting with the regulatory authorities for agreement on population, choice of endpoints etc for the targeted indication! As far as the GCP, and other compliance related matters you should have an oversight on the IIT via an agreement between sponsor and the IIT including for the rights to publish or not to publish, GCP compliance, assisting IIT for medical write up/protocol review, etc.....

    Good luck!


  • 5.  RE: Investigator Initiated Trials

    Posted 01-Jun-2021 12:37
    Agree 100% with the Anon response above! NOTE: In oncology, the POC studies via IIT for investigational new drugs are very common not just for marketed drugs! 

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    GRSAOnline
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  • 6.  RE: Investigator Initiated Trials

    This message was posted by a user wishing to remain anonymous
    Posted 02-Jun-2021 18:06
    This message was posted by a user wishing to remain anonymous

    This is helpful information. FDA has stated in the past we could touch base with them on the data to see if there are gaps with CMC or safety - they had assumed that sponsor transfer might be required, however, to have full access to the data. 
    How does one gain access to an IIT database?  Is through an additional agreement with the investigator (who is the sponsor)? Thanks.


  • 7.  RE: Investigator Initiated Trials

    This message was posted by a user wishing to remain anonymous
    Posted 08-Jun-2021 08:38
    This message was posted by a user wishing to remain anonymous

    While an IIT can be used to support POC, its contribution to the totality of the data for an NDA/sNDA or BLA/sBLA review will be limited unless the study quality is high and the data are accessible and can be included in the application. Otherwise, the study can inform the company of the risks and study design for the confirmatory study, but the FDA and other HAs will not factor the IIT data into their assessment of the totality of the data.


  • 8.  RE: Investigator Initiated Trials

    This message was posted by a user wishing to remain anonymous
    Posted 08-Jun-2021 12:52
    This message was posted by a user wishing to remain anonymous

    " its contribution to the totality of the data for an NDA/sNDA or BLA/sBLA review will be limited unless the study quality is high and the data are accessible and can be included in the application."  Disagree with this statement

    The only contribution to the totality of the data at the time of NDA or BLA for POC or any other preliminary pk/pd etc studies would be from safety stand point! Approval is based on either one or two pivotal registration trials outcome. 

    "the study can inform the company of the risks and study design for the confirmatory study, but the FDA and other HAs will not factor the IIT data into their assessment of the totality of the data."  Agree fully with this statement