We are closely monitoring the impact of COVID-19 on our industry and aim to bring you the very latest news from the Regulatory Agencies around the world. This page will be updated as soon as these updates are announced.
June 2nd, 2020
The FDA published today a new guidance titled Institutional Review Board (IRB) Review of Individual Patient Expanded Access Requests for Investigational Drugs and Biological Products During the COVID-19 Public Health Emergency Guidance for IRBs and Clinical Investigators.
FDA is issuing this guidance because of the substantial increase in the number of requests by physicians seeking to treat their patients with investigational drugs under the agency’s individual patient expanded access (EA) pathway during the COVID-19 public health emergency. The agency also is aware that IRBs seek clarity regarding the key factors and procedures to consider when they review requests for individual patient EA — including reviews conducted by a single member of the IRB — to fulfill obligations under 21 CFR Part 56.
The recommendations in the guidance address establishing procedures for single IRB member review in response to physician waiver requests for exemption from full IRB review, as well as factors to consider when assessing benefits and risks for a particular patient being treated under expanded access.
The FDA takes steps to streamline development of tests with at-home sample collection, by including a voluntary EUA template for at-home sample collection kits to its website.
April 20th, 2020
The National Institutes of Health (NIH) announced on April 18th a new initiative to accelerate the development of treatments for COVID-19 involving the US Food and Drug Administration (FDA) and other US health agencies, the European Medicines Agency (EMA) and 16 drugmakers in order to develop a coordinated research strategy & coordinate clinical trials and regulatory processes. More info here.
The American Medical Association (AMA) has also issued recommendations to address COVID-19 pandemic, such as:
- Expand telemedicine, by allowing coverage of telemedicine, permit telemedicine for first-time visits and providing coverage and payment for COVID-19 related telemedicine visits.
- Expand Medicaid coverage, by establishing special enrolment periods to any uninsured state resident with COVID-19 related diagnoses or symptoms and by requiring insurers/employers to continue coverage for employees under group policies even if the employee would others be ineligible due to decrease in hours worked.
- Access to medication, by waiving time restriction on prescription refills and authorize payment to pharmacies for up to 30 days’ supply, by removing restrictions on the Medicaid preferred drug lists to help avoid medication shortage
- Reduce patient out of pocket regarding access to care for treating COVID-19 symptoms, by ensuring coverage for the cost of care related to COVID-19 (diagnostic testing and care), by covering the costs of vaccination with no cost-sharing when vaccines will be available
FDA updated the COVID-19 related Guidance Document that includes Guidance for Industry, Investigators, and IRBs today 16 April 2020.
From what we can tell, the body of the text was maintained with only minor editorial changes including change of the term “Pandemic” to “Public Health Emergency” and some additional abbreviations were defined.
7 Questions and Answers were added to the document beginning on page 16 – Pasted below for your quick scan of applicability to your projects:
- Q11. How do I obtain informed consent from a patient unable to travel to a clinical trial site where electronic informed consent is not an option?
- Q12. What factors should sponsors consider when deciding whether to implement remote performance outcome (PerfO) assessments or interview-based clinician-reported outcome (ClinRO) assessments during the COVID-19 public health emergency?
- Q13. I am a study monitor and am unable to conduct on-site monitoring visits due to the COVID-19 public health emergency. May I remotely perform the site monitoring visit? What recommendations does FDA have for how I can remotely perform source document review?
- Q14. I am a sponsor of commercial INDs and electronic common technical document (eCTD) requirements cannot be met due to the COVID-19 public health emergency. Who do I contact for assistance?
- Q15. During the COVID-19 public health emergency, certain patients may no longer be able to travel to a central location for protocol-based treatment that is scheduled on a recurring basis. Can the investigational product intend for infusion to be shipped to a local health care provider who is not a sub-investigator to administer the infusion to a patient while still maintaining the integrity of the trial? If so, what else would be needed regarding trial monitoring and institutional review board (IRB) oversight?
- Q16. If a subject is unable to receive the investigational drug from the trial site but the product is FDA-approved for other uses, can the patient or health care provider secure the product commercially or is this considered the sponsor charging for the investigational drug under 21 CFR 312.8? Can the sponsor reimburse trial subjects for their out of pocket expenses in getting the drug commercially?
- Q17. Throughout the guidance, FDA recommends that sponsors consult with the review division for certain changes to ongoing clinical trials. For drugs and biologics, is this a reference to scheduling a Type A meeting? How should sponsors contact the FDA regarding device clinical trials?
More info here: https://www.fda.gov/media/136238/download
April 09, 2020
How does COVID-19 impact payers and HTA decision-making processes around the world? What are the consequences for companies currently developing drugs that undergo pricing and reimbursement appraisals?
Here is a summary of the latest updates for HTA and pricing assessments from key international markets:
EU 27: EunetHTA The European HTA network will prioritize the needed resources to be used in their various national settings in order to respond to the current emergency on COVID-19.
Therefore, Assessments or Early Dialogues might face delays or suspension of new requests.
France: Haute Autorité de Santé (HAS), Ministry of Health
The HAS will prioritize COVID-related drug and medical devices assessments for its HTA assessment and continues review of other products based on the criteria of importance to patient care.
When it comes to new product pricing, the French government’s Economic Committee for Health Products (CEPS) ensures the continuity of its pricing activities and economic regulation of health products.
Germany: Gemeinsamer Bundesausschuss (G-BA), Ministry of Health
The G-BA has not announced any prioritisations or limitations to early benefit assessment processes (drugs & devices) – virtual meetings and written decision making are employed to support continuity.
However, potential capacity problems to review and set up pre-AMNOG early advice sessions for manufacturers have been identified:
- Potential for delays for new applications
- G-BA is aiming to keep all scheduled sessions (via teleconference)
At the same time, the Ministry for Health is planning to push ahead of the introduction of the digital health reimbursement process as scheduled for this summer.
Italy: Agenzia Italiana del Farmaco (AIFA)
The Italian Medicines Agency keeps to its scheduled committee meetings including pricing and reimbursement meetings (Price and Reimbursement Committee [CPR], Comitato Tecnico Scientifica ([CTS]). The meetings will be schedule remotely, and a Coronavirus crisis committee with CTS support will prioritize the COVID-19 appraisals (guidance, treatment, etc).
The minutes of the latest Price and Reimbursement Committee (CPR) meeting of April 1st have just been made available this week
Spain: Agencia Espanola de Medicamentos y Productos Sanitarios (AEMPS), Ministerio de Sanidad
The AEMPS Coordination group for therapeutic positioning assessment (IPT group) does not report delays or cancellations of meetings to review a new product or indication use at this moment.
The AEMPS has also established a series of special measures to speed up and prioritize the evaluation procedures for biocide products. These measures aimed at simplifying the authorization procedure respond to the need to avoid the shortage of this type of hydroalcoholic solutions in the health centers of our country
Equally, to support continuity, the Ministry of Health pricing commission (Comisión Interministerial de Precios de Los Medicamentos [CIPM]) does not report any delays or cancellations for the pricing/reimbursement.
UK: National Institute for Health and Care Excellence (NICE)
NICE has announced that only therapeutically critical assessment, COVID 19 diagnostic or therapeutic and cancer medicine will be undertaken. The technology appraisal committee meeting is continuing to be held virtually.
The agency also provides free fast track scientific advice for companies developing novel diagnostics or therapeutics for COVID-19.
ICER assessment is still ongoing but with timelines delayed by 3 months due to external stakeholders involved in the COVID-19 pandemic. Some public meetings are postponed indefinitely (Sickle Cell Disease and Cystic Fibrosis).
To support appropriate care in the COVID19 crisis, CMS puts in place various waivers and flexibilities for hospitals, other healthcare facilities, providers enrollment (advance payment), state Medicaid agencies (1135 waivers), 1915 (c) Appendix K Waivers.
April 08, 2020
Since the end of March and the beginning of April, the EMA continues to perform discussions with medicines developers on potential treatments and on vaccines against COVID-19. EMA encourages industries to launch clinical trials to generate conclusive evidence in order to market as quickly as possible an effective treatment in Europe. In the same logic, still, to become more efficient in the management of the sanitary crisis, a new coordination group named COVID-19 EMA pandemic Task Force (COVID-ETF) was created. This Task Force group is helping the EU Member States and the European Commission to take quick and coordinated regulatory action on the development, authorization and safety monitoring of treatments and vaccines intended for the treatment and prevention of COVID-19. This working group will also assist the EMA’s scientific committees or take part on behalf of the scientific committee’s discussion with drug developers. The main functions of COVID-ETF are the following:
- the review of available scientific data on COVID-19 medicinal products and identify promising candidates;
- the request data from developers and engage with them in preliminary discussions;
- to be the scientific support in collaboration with the CTFG to facilitate clinical trials conducted in the EU for the most promising medicinal products for COVID-19;
- to provide feedback on development plans of COVID-19 medicinal products when formal rapid scientific advice is not feasible;
- to act as an advisor to the Scientific Advice Working Party (SAWP) or the CHMP for formal scientific advice and product-related assessment and contribute to the PRAC activities on emerging safety issues related to COVID-19;
- to ensure close cooperation with stakeholders and relevant European and international organizations.
In addition to the different reflection and working groups put in place, the EMA keeps releasing strong recommendations at the attention of developers regarding the conduction of clinical trials and compassionates uses. After the Guidance on the management of clinical trials during the COVID-19 (coronavirus) already highlighted by VCLS in a previous post, the new guidance on the conduction of the compassionate use of remdesivir for COVID-19 is a first relevant example which shows how the common approach regarding the criteria and use conditions is essential for driving a study. In another vein, as the pandemic affects the issue of printed certificates for human and veterinary medicines by the authority, the EMA decided to provide electronic and authenticated certificates. With its efforts to digitalize its administrative processes for all documents requiring a signature, the European agency is considering whether the electronic signature should be implemented instead of keeping the handwritten signature. In conclusion, we would like to reassure you, EMA decided to stay available during EMA’s Easter break from 9 to 13 April 2020.
From the US side, since April the FDA is really focused on the development of recommendations for keeping safe the blood collection/transfusion and derived blood product supply. The American agency published new guidance regarding blood Supply in the US: Alternative Procedures for Blood and Blood Components During the COVID-19 Public Health Emergency. This guidance proposes to ensure adequate protections for donor health and maintaining a safe blood supply. In the same line, specific recommendations to health care providers and investigators on the administration and study of investigational convalescent plasma collected from individuals who have recovered from COVID-19 are available. Indeed, the guidance for industry named: Investigational COVID-19 Convalescent Plasma raises and answers to the following points:
- which IND regulatory pathways should implement for Use of Investigational COVID-19 Convalescent Plasma;
- the different criteria which need to be fulfilled in term of patient eligibility;
- which information about COVID-19 Convalescent Plasma should be collected and reflected in IND application;
- how records for the COVID-19 convalescent plasma unit must be maintained.
In another topic, FDA issued as other agencies around the world, a policy to oversee serological tests development and to remind that developers must perform the appropriate evaluation to determine that their tests are accurate and reliable. In the emergency situation, no prior FDA review before marketing tests is mandatory certain conditions outlined in the guidance document are met.
Many other guidance to facilitate the availability of drugs and devices in specific areas was released. Regarding the repurposing of medicines, the FDA is the first agency that approved a marketing application for Hydroxychloroquine Sulfate in COVID-19. This first approval demonstrated that the repurposing of drugs should not be left out for the only benefit of new drugs development, but also be taken into account and used as a weapon in the COVID-19 fight.
Stronger together: International Coalition of Medicines Regulatory Authorities
VCLS also wants to underline that regulators have published a report highlighting their considerations on the development of potential COVID-19 therapeutics, clinical trials, and compassionate use programs. The report provided international positioning on progress on COVID-19 medicine development with a focus on the clinical trials and compassionate use ongoing and especially the availability of potential COVID-19 treatments. The complete report is available here.
April 1, 2020:
FDA updated the Guidance on Conduct of Clinical Trials of Medicinal Products during COVID-19 Pandemic on March 27, 2020 with an informative Q&A Appendix on clinical trial conduct, including questions and answers such as:
- What are some of the key factors that a sponsor should consider when deciding whether to suspend or continue an ongoing study or to initiate a new study during the COVID-19 pandemic?
- What key factors should sponsors consider when deciding whether to continue administering or using an investigational product that appears to be providing benefit to the trial participant during the COVID-19 pandemic?
- How should a sponsor submit a change in protocol that results from challenges related to the COVID-19 pandemic?
FDA has also created a special emergency program for possible therapies, the Coronavirus Treatment Acceleration Program (CTAP). It uses every available method to move new treatments to patients as quickly as possible. There is no equivalence in the EU yet, but some countries such as the ANSM proposed some dedicated pathways to expedite new treatment against COVID-19.
March 30, 2020:
FDA has released a FAQ document (March 24th) regarding the investigational use of COVID-19 Convalescent Plasma in emergency INDs. From the FDA website:
“One investigational treatment being explored for COVID-19 involves the use of convalescent plasma collected from recovered COVID-19 patients. It is possible that convalescent plasma that contains antibodies to SARS-CoV-2 (the virus that causes COVID-19) might be effective against the infection.”
“FDA is facilitating access to COVID-19 convalescent plasma for use in patients with serious or immediately life-threatening COVID-19 infections through the process of single patient emergency Investigational New Drug Applications (eINDs) for Individual patients under 21 CFR 312.310.”
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Impact on ongoing clinical trials
If you are currently conducting clinical trials in the EU, please be informed that the EMA, in collaboration with the Clinical Trials Expert Group (CTEG) of the European Commission, the Clinical Trials Facilitation and Coordination Group (CTFG) and the GCP Inspectors’ Working Group, has published a harmonized guidance document on how to manage clinical trials during the COVID-19 pandemic, available here. In addition to this guidance document, Competent Authorities have already published specific instructions on how to conduct clinical trials in their countries during this time. In some cases, these national guidelines will take priority over the European harmonized recommendations.
Several Competent Authorities are asking sponsors to perform a risk assessment and prepare a mitigation plan for their ongoing studies, taking into consideration the following points:
- Initiation of new clinical trials or inclusion of new patients in ongoing clinical trials should be critically assessed
- Changes to the shipment of the IMP: shipment to the patient’s home when possible and allowed by national legislation and data protection regulations
- Changes to the treatment administration and study assessments
- Changes to monitoring: postponing source data verification, remote monitoring if no additional burden to the sites, etc.
- Temporary suspension of recruitment or treatment (when the sites are closed due to the quarantine measures, for instance).
- Discontinuation of study subjects, if they cannot complete the key evaluations or adhere to critical mitigation steps etc.
- Protocol deviations (which may occur more often in this period) should be thoroughly documented: some authorities have asked for a summary report on all deviations that occurred during the COVID-19 pandemic
- The circumstances in which the implementation of an Urgent Safety Measure may be deemed necessary.
Delays should be expected in the review timelines of initial applications and amendments not related to COVID-19 (which do not impact the safety of the subjects) due to the staff limitations in most of the Competent Authorities and Ethics Committees. Furthermore, some of them have started to accept and encourage electronic submissions in the context of the COVID-19 pandemic.
As the situation is evolving rapidly, VCLS is keeping an up-to-date list of the Competent Authorities and Ethics Committees having published specific recommendations both in Europe (EU and non-EU countries) and worldwide (USA, Canada, Israel, South-Africa, etc.). Most of these guidelines have been issued without prior public consultation, therefore some specific issues encountered by sponsors may not be covered. Our team at VCLS is ready to take a close look at your needs and create tailored solutions for preserving patient safety and data integrity on your studies in these challenging circumstances.
Learn more about our Clinical Submission and Operation capabilities.
Call for new treatments for COVID-19
At the same time, many authorities worldwide have emphasized the need to prioritize the development of new treatments against this public health threat, advising on including COVID-19 related endpoints to ongoing clinical trials or pooling research resources into large multi-center, multi-arm clinical trials to generate sound evidence (see EMA call here).
Some of the Competent Authorities and Ethics Committees are proposing a rapid assessment of clinical trial applications related to the prevention of the infection or to the management of COVID-19 patients.
Our experts are here to help you guide the planning, design, conduct and reporting of clinical trials in order to accelerate the development of potential COVID-19 treatments.
March 23, 2020:
Many of you may be concerned about the impact of COVID-19 in the testing for human cells, tissues, or cellular and tissue-based products (HCT/Ps). The FDA has released a Q&A document that can be beneficial to understand their recommendations at this time. At VCLS, we are monitoring the situation closely and we are providing recommendations to our clients based on our most recent experiences. We strongly advise following FDA’s recommendations on implementing screening measures as a precaution to patients and healthcare providers. Please see below the extracted information from the Agency:
Q: Can COVID-19 be transmitted through human cells, tissues, or cellular and tissue-based products (HCT/Ps)?
A: Respiratory viruses, in general, are not known to be transmitted by implantation, transplantation, infusion, or transfer of human cells, tissues, or cellular or tissue-based products (HCT/Ps). The potential for transmission of COVID-19 by HCT/Ps is unknown at this time. There have been no reported cases of transmission of COVID-19 via HCT/Ps.
Routine screening measures are already in place for evaluating clinical evidence of infection in HCT/P donors.
Q: Is the FDA recommending that establishments implement screening measures for the deferral of HCT/P donors of who may be at risk of having COVID-19?
A: The HCT/P establishment’s responsible person must evaluate a prospective donor and determine eligibility (21 CFR 1271.50). Based on the limited information available at this time, establishments may wish to consider the following donor history in the 28 days prior to HCT/P recovery for persons who have:
- traveled to areas with COVID-19 outbreaks, as defined by CDC
- lived with individuals diagnosed with or suspected of having COVID-19
- been diagnosed with or suspected of having COVID-19
More details are available here: FDA emergency preparedness and response to COVID-19
March 19, 2020
The FDA released a guidance for industry, investigators and institutional review boards conducting clinical trials during the coronavirus (COVID-19) pandemic.
From the Clinical Trials perspective:
If you are currently conducting clinical trials in the EU and especially in the UK, Italy and the Netherlands, please be informed that Authorities have recently released communications on recommendations to follow in clinical trials’ submissions and conduct.
We recommend our clients to take consideration of putting the following measures in place, and in many cases will need to be reported/submitted to Competent Authorities/Ethics Committees in a timely manner:
- IMP shipped to the patient’s home;
- Administrations performed at home;
- Visits/ assessments performed at home, including recording in source documentation;
- Modifications in monitoring (potentially remote);
- Temporary suspension of recruitment or treatment (e.g. if sites are entirely closed);
- Discontinuation of study subjects, if they cannot complete key evaluations or adhere to critical mitigation steps; etc.
Competent Authorities and Ethics Committees are progressively sharing information on the conduct of clinical trials during this period, and which submissions are required for the exceptional measures put in place.
At VCLS, we are monitoring the situation daily, including communications from the Competent Authorities/Ethics Committees on this topic, and its potential impact on your ongoing activities.
Learn more about our Clinical Trial Operation capabilities.
March 18, 2020
From the EU perspective:
- EMA has said as a precautionary measure, all EMA committee meetings and working parties will be held virtually until the end of April 2020. In addition, stakeholder events hosted by EMA which were planned to take place at the Agency’s premises in Amsterdam in March and April will either be held virtually or postponed until later in the year. Participants of these meetings will be informed directly about this decision.
- EU Regulatory Stakeholders may also adjust their activity accordingly. Further country-specific information can be found via the country specific links.
- Most EMA staff are working remotely, and this is expected to last until the end of April. These measures do not impact the EMA’s core activities so far. We shall keep you posted on any development on this front.
From the USA perspective:
- The FDA is postponing most foreign inspections through April, effective immediately. Inspections outside the U.S. deemed mission-critical will still be considered on a case-by-case basis. The FDA based this decision on a number of factors, including State Department Level 4 travel advisories in which travel is prohibited for U.S. Government employees, Centers for Disease Control and Prevention travel recommendations, access restrictions being imposed on foreign visitors by certain countries, guidance from the Office of Personnel Management and the importance of the health and safety of its employees.
- No one is traveling to the FDA for meetings. The meeting format was changed late last week to teleconferences call only. Our understanding is that most, if not all of FDA staff are working remotely. Our recent experience is that the FDA staff is calling from one line although they are all participating remotely. It gives them the possibility to conference call prior to calling the Sponsor and the option to put the Sponsor on hold, so they can have an internal discussion if needed.
March 13, 2020
Current events around the spread of the COVID-19 virus and its impact on the global economy continue to evolve. Voisin Consulting Life Sciences (VCLS) would like to reassure you that we continue to provide the same high-quality service during this difficult period.
We are monitoring the situation closely and constantly take appropriate actions to protect our employees to ensure business continuity. Please keep us informed of any steps or business restrictions your company takes that will impact the way we work with you so that we can make any necessary adjustments to our plans to stay on track.
Our focus, dedication and support are unwavering and we hope you and your closed ones remain safe and healthy.