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External controls for rare disease drug development: Lessons for emerging and advanced therapeutic modalities
Samuel H Hughes1, Lauren A Beretich2, Matthew Fuller3
1Center for Experimental Neurotherapeutics, St. Jude Children's Research Hospital, Memphis, TN, USA.
Abstract:
External controls, particularly natural history studies, play an increasingly important role in rare disease therapeutic development where traditional randomized trials are often infeasible. This review examines regulatory acceptance patterns for gene and cell therapies approved between 2019 and 2025, analyzing successful cases like onasemnogene abeparvovec (Zolgensma) for spinal muscular atrophy and elivaldogene autotemcel (Skysona) for cerebral adrenoleukodystrophy alongside unsuccessful applications. Key success factors include systematic data collection, clinically meaningful endpoints, appropriate patient matching, and disease characteristics that preclude randomization. Recent FDA initiatives, including the Rare Disease Evidence Principles program, signal growing regulatory flexibility, although acceptance remains context-dependent and requires robust data quality standards.
Insights
External controls are vital for rare disease gene and cell therapy development when randomized trials are not feasible. Regulatory agencies increasingly accept these approaches, provided robust data and clear endpoints are presented.
Area of Science:
- Biomedical Science
- Regulatory Science
- Gene and Cell Therapy
Background:
- Randomized controlled trials are often infeasible in rare disease therapeutic development.
- External controls, especially natural history studies, are becoming crucial for rare disease drug approval.
- Gene and cell therapies represent a growing area of focus for rare disease treatment.
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