The success of the new US FDA “qualification” pathway for biomarkers and other drug development tools will hinge on how outside groups – and internal agency reviewers – adapt to a new requirement to agree on a formal plan to develop the new tool.
Under the 2016 21st Century Cures Act, there is now a three-step process for outside groups to use to obtain FDA “approval” of a novel biomarker or clinical outcomes assessment for use in drug development: an initial letter of intent (LoI), then a formal “qualification plan” (QP) outlining the necessary information to support the new tool for its intended use in drug development, and then a formal submission (the FQP or final qualification package)
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