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Assessing Information Gaps Associated with Initial Pediatric Study Plans for New Oncology Drug and Biological
Daphne Guinn1, Marilyn Gafford2, Gilbert J Burckart1
1Office of Clinical Pharmacology, Office of Translational Sciences, Center for Drug Evaluation and Research, US Food and Drug Administration, Silver Spring, Maryland, USA.
Insights
The Research Acceleration for Cure and Equity (RACE) for Children Act mandates pediatric study plans (PSPs) for new cancer drugs. Analysis of initial PSPs revealed common information gaps, particularly in waiver justifications and clinical study details.
Area of Science:
- Oncology
- Pediatric Drug Development
- Regulatory Science
Background:
- The Research Acceleration for Cure and Equity (RACE) for Children Act mandates the submission of Pediatric Study Plans (PSPs) for new molecularly targeted drugs and biologics intended for adult cancers.
- These plans must either propose a pediatric investigation or provide justification for a waiver or deferral.
- Ensuring pediatric patient consideration in drug development is a key objective.
Purpose of the Study:
- To conduct a landscape analysis of information gaps in initial Pediatric Study Plan (iPSP) submissions for oncologic new molecular entities in 2021.
- To identify trends in US Food and Drug Administration (FDA) comments during the iPSP review process.
- To provide direction for sponsors in preparing adequate iPSPs.
Main Methods:
- A landscape analysis was performed on initial PSP (iPSP) submissions for oncologic new molecular entities received in 2021.
- Comments from the FDA review process were categorized using nine distinct flags.
- Analysis focused on identifying common information gaps and trends.
Main Results:
- For iPSPs requesting a full waiver, the primary information gap was inadequate justification regarding molecular target relevance.
- Other iPSP plans (deferral, partial waiver, or investigation) frequently showed information gaps in clinical study features, clinical pharmacology, or missing clinical/nonclinical data.
- Trends in FDA comments during initial review were identified.
Conclusions:
- Initial PSP submissions often contain information gaps that require sponsor attention.
- Clearer justification for molecular target relevance is crucial for waiver requests.
- Sponsors need to ensure comprehensive data for clinical study features and pharmacology to meet regulatory requirements for pediatric drug development.
Abstract:
The Research Acceleration for Cure and Equity (RACE) for Children Act requires sponsors to submit a Pediatric Study Plan (PSP) with a proposed pediatric investigation of new molecularly targeted drugs and biologics that are intended for treatment of adult cancers, and whose target is relevant to pediatric cancer or provide a justification for a plan to request a deferral or waiver of the required investigation. A landscape analysis was performed to identify trends in information gaps associated with a sponsor's first initial PSP (iPSP) submission for oncologic new molecular entities received in 2021. Comments sent to sponsors by the US Food and Drug Administration (FDA) during the review process of each evaluated iPSP were categorized using nine flags relating to different portions of the PSP. For iPSPs that included a plan for a full waiver request, the most common information gap was inadequate justification based on molecular target relevance. All other sponsor proposed plans (deferral and/or partial waiver or investigation) were found to have information gaps related to clinical study features, clinical pharmacology, and/or missing clinical or nonclinical data. This landscape analysis of iPSPs shows the trends in comments that often occur during initial review and may help to provide sponsors with more direction for preparing an adequate iPSP to fulfill statutory requirements aimed at ensuring pediatric patients are considered in the development of new molecularly targeted drugs.
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