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Impact of non-binding FDA guidances on primary endpoint selection in Alzheimer's disease trials
Jeffrey C Yu1,2, Jakub P Hlávka2,3, Elizabeth Joe4
1School of Pharmacy University of Southern California Los Angeles California USA.
Introduction:
The U.S. Food and Drug Administration (FDA)'s guidances help describe the agency's current thinking on regulatory issues and serve as a means of informal policymaking that is non-binding. This study examines the impact of two guidance documents for Alzheimer's disease (AD) trials. The first guidance in 2013 encouraged the use of cognitive/functional endpoints, while the second in 2018 modified such recommendation.
Methods:
Using pivotal trial data, we applied a regression discontinuity in time (RDiT) framework to examine trialist response to these guidance documents. Results were stratified by disease-modifying therapy (DMT) status, and controlled for disease staging, FDA registration status, and trial phase.
Results:
Among AD DMT trials, annual use of cognitive/functional composite endpoints significantly increased after the 2013 guidance (+12.9%, P < .001), and significantly decreased after the 2018 guidance (-19.9%, P = .022).
Discussion:
Although guidance documents do not set new legal standards or impose binding requirements, our findings indicate they are broadly followed by AD trialists.
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