Regulatory Open Forum

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  • 1.  Diversity Plans

    Posted 02-Feb-2024 17:44
    Hello all,

    There is currently a draft guidance on the inclusion of a diversity plan in INDs and marketing applications; Diversity Plans to Improve Enrollment of Participants from Underrepresented Racial and Ethical Populations in Clinical Trials. The need for a diversity plan to be included in an application is a relatively newer request. The guidance above suggests a diversity plan be placed in a meeting package no later than EOP2. My question is for applications that are more advanced, i.e., being prepared for NDA submission, where in the eCTD would a diversity plan be placed that describes a plan for the last Phase 3 study conducted for said program?

    Thank you!




  • 2.  RE: Diversity Plans

    Posted 05-Feb-2024 09:14
    Edited by Sheila Hittesdorf 05-Feb-2024 09:14

    For our IND submission, we were advised by our CBER point of contact to include the Diversity Plan in Module 2.5 Clinical Overview.

    Best,

    Sheila Hittesdorf




  • 3.  RE: Diversity Plans

    Posted 05-Feb-2024 09:25
    Thanks so much Shiela! I had an idea that module 2.5 could be a possible placement. Happy that the suggestion came from your CBER POC!





  • 4.  RE: Diversity Plans

    Posted 05-Feb-2024 11:46

    We filed our Diversity Plan in Mod 5 section 5.3.5.1 Study Reports of Controlled Clinical Studies Pertinent to the Claimed Indication.  We had already had our EOP2 meeting right around the time the FDA issued their Draft guidance in April 2022 so we ended up submitting about a year later despite our Phase 3 study already being underway.



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    Tom Stothoff
    Senior Director, Regulatory Affairs CMC
    Chicago
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  • 5.  RE: Diversity Plans

    Posted 05-Feb-2024 12:45
    Much appreciated Tom, thanks for your response!