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Basket Clinical Trials of Drugs Targeting Shared Molecular Etiologies in Multiple Rare Diseases (U44 Clinical Trial Required)

Description:

While there are thousands of rare diseases, the number of underlying etiologies is much smaller. Moreover, many disease etiologies underlie multiple traditional diseases. This is most readily seen for rare monogenic diseases, where the most common etiologies include premature termination codons, protein misfolding, and abnormal RNA splicing. Other examples of rare disease shared molecular etiologies include, but are not limited to, triplet repeat expansions, epigenetic dysregulation, and signallopathies (e.g., mTOR-opathy, RAS-opathy, etc.). Small businesses are developing drugs targeting shared molecular etiologies. However, the standard approach in clinical trials is to focus on one disease at a time, with the choice of diseases often based on prevalence. This approach inevitably results in clinical trials in only the most common rare diseases, with the exclusion of patients with the least common diseases, even though the scientific rationale for the use of the drug may be as strong, if not stronger, in the lower prevalence rare diseases. One potential solution to this problem is to adapt the basket trial approach that has been developed for tissue agnostic oncology drugs, i.e. for clinical trials of drugs that target molecular defects common to anatomically different cancers. Notably, this approach has already resulted in regulatory approvals from the US FDA (https://www.fda.gov/drugs/fda-approves-larotrectinib-solid-tumors-ntrk-gene-fusions). One potentially important difference between oncology and rare diseases, however, is the relative diversity of clinical outcome measures in rare diseases compared to cancer. NCATS seeks to facilitate rare diseases research by enabling efficient and effective movement toward clinical trials in multiple rare diseases. The purpose of this NOFO is to provide support for basket clinical trials of drugs targeting shared molecular etiologies in more than one rare disease, and in the process to identify and overcome challenges in adapting the oncology basket trial model to rare diseases. NCATS intends to support 1 2 clinical trials through this NOFO that could potentially provide options for multiple rare diseases. Projects proposed for this NOFO will require individuals with expertise in carrying out clinical trials in rare diseases. Applicants are expected to collaborate with investigators at academic institutions for carrying out the proposed clinical trials. NCATS encourages projects involving clinical investigators who are part of the Rare Disease Clinical Research Network (RDCRN) and which focus on diseases under study in the RDCRN. See https://www.rarediseasesnetwork.org/ for additional information. The funding opportunity will utilize a Small Business Innovation Research (SBIR) U44 cooperative agreement to support Investigational New Drug (IND) enabling studies, including translational bench/in vitro, and animal studies as necessary, to support the preparation and submission of the IND. This cooperative agreement will also support the subsequent small clinical trial, involving at least two different rare diseases. It is expected the immediate next steps following completion of the small clinical trial supported under this cooperative agreement will be: ? future clinical trial design decisions made based on the information and data collected; ? a larger clinical trial that will lead to a marketing application; or ? a marketing application if only a small clinical trial is needed. Applicants should provide a strong rationale supporting the use of the drug in the proposed clinical trial, including preliminary data. The application will in part be judged on presenting a credible path towards U.S. regulatory submission/Institutional Review Board (IRB) approval at the end of the SBIR. All projects must be Fast-Track applications which include both SBIR Phase I and Phase II components. Phase I of the Fast-Track will support translational activities leading to submission of an IND to the FDA, as well as an IRB application. Phase II of the project period will support the clinical trial in rare disease patients. The duration of Phase I of the Fast-Track will depend on the maturity of the project at entry. Only those Phase I projects that have met specific criteria (see below) will be eligible for transition to Phase II of the Fast-Track after NIH administrative review. Phase II of the Fast-Track will support a small clinical trial, as described above. The SBIR U44 cooperative agreement mechanism is milestone-driven and involves significant input from NIH program staff regarding project and milestone planning, monitoring of research progress, and go/no-go decision-making. NIH staff may also assist investigators in familiarizing them with the regulatory development process and the criteria needed to advance drugs targeting shared molecular etiologies in rare disease patients into clinical trials. Applicants are strongly advised to contact the Scientific/Research contact listed below prior to submission. B. Research Scope Projects must focus on a clinical trial of a single drug targeting a shared molecular etiology that underlies at least two different rare diseases. Examples of such shared molecular etiologies are given above. Including at least two different diseases in the clinical trial is a requirement for support under this NOFO. The drug to be studied may be a small molecule drug, biologic, or a single genetic therapy. The key point for this NOFO is that the identical drug is used for more than one disease. Entry criteria: For entry to the program, projects should have: Comprehensive supporting data based on bench, in vitro, and/or in vivo models supporting efficacy in the intended rare disease patient population and indication. Identified at least two different diseases for inclusion in the clinical trial. For both diseases, one or more valid outcome measures, based on input from both clinicians and patients, and / or supporting literature, should be specified. A compelling case for IND submission for the clinical trial at the end of SBIR Phase I. Applicants are encouraged, but not required, to consult with FDA via a Pre-Submission meeting prior to applying for funding through this grant mechanism. Fast-Track Phase I scope: Examples of studies that may be proposed during SBIR Phase I include, but are not limited to: ? Bench-top and animal testing to demonstrate proof of concept and safety. ? Activities to become current Good Manufacturing Practice (GMP) compliant. ? Regulatory activities, including pre-submission meetings with FDA. ? Limited clinical data, e.g. safety studies in human volunteers, is also allowable during SBIR Phase I if it is necessary to support the IND submission for the small clinical trial conducted in SBIR Phase II. Fast-Track Phase II scope: Phase II will support the clinical trial of a single drug targeting a shared molecular etiology, including patients from at least two different diseases. Other activities in Phase II may include: ? Setting up clinical trial site agreements ? Obtaining IRB approval for the clinical trial can be done during Phase II. Applications Not Responsive to this NOFO The following types of studies are not responsive to this NOFO. Applications proposing such studies will be considered non-responsive and will not be reviewed or considered for funding. Examples of activities non-responsive to this NOFO include: ? Basic research and studies of disease mechanisms. ? Development of outcome measures or natural history studies. ? A clinical trial of the drug in a single disease. ? Gene therapy projects involving the use of different therapeutic constructs for different diseases. However, a gene therapy project including a single therapeutic construct for multiple diseases would be responsive. ? Clinical trials to treat rare cancers. However, rare diseases which have an increased risk of cancer are allowed, as long as the primary clinical outcome measure is not carcinogenesis or tumor progression. ? Stand-alone SBIR Phase I or Phase II applications. ? Delayed onset studies that do not have a clinical trial described in the submission. C. Milestones Applications are expected to propose one or more milestones associated with each objective in each year of the project. Milestones are goals that measure success and efficacy that can be used for go/no-go decision-making for the project and should have quantitative criteria associated with them (see Section IV.2 for details). Obtaining regulatory approval from the U.S. Food and Drug Administration (FDA) to proceed with the clinical trial of more than one disease is the main criterion for transitioning from Phase I to Phase II, and this milestone must be included in the application. NIH program staff will contact the applicant to discuss and negotiate the proposed milestones and any changes suggested prior to funding the application. The final agreed upon and approved milestones will be specified in the Notice of Award (NoA). Progress towards achievement of the final set of milestones will be evaluated by NIH program staff. If justified, future milestones may be revised based on data and information obtained during the previous project period. If, based on the progress report, a funded project does not meet the milestones, funding for the project may be discontinued. In addition to milestones, the decision regarding continued funding will also be based on the overall robustness of the entire data package that adequately allows an interpretation of the results (regardless if they have been captured in the milestones), overall progress, portfolio balance and program priorities, competitive landscape, and availability of funds. Fast-Track Phase I to Phase II transition: An administrative review will be conducted by NIH program staff to decide whether a SBIR Phase I project will be transitioned into SBIR Phase II based on the following: Successful achievement of the defined milestones for SBIR Phase I of the project The most important criterion for the transition is submitting an IND for the clinical trial to the FDA, and receiving a safe to proceed notification. Likelihood of success in carrying out the clinical trial Distribution of rare diseases studied Submission of the final clinical protocol and supporting documents to NIH for administrative review, and notification of approval by NIH Agreement on updated timeline, milestones, and budget for the clinical trial. Availability of funds All award recipients will be required to submit a non-competing application two months prior to the phase 2 start date. These applications will be administratively reviewed by NIH Program staff. Recipients who have achieved the SBIR Phase I milestones will be considered eligible for funding consideration and transition to the SBIR Phase II phase. D. Pre-application Consultation As a U44 cooperative agreement, NIH program staff will be involved in the planning and execution of the projects. Applicants are strongly encouraged to consult with NIH Scientific/Research staff when planning an application. Early contact provides an opportunity for Scientific/Research staff to provide guidance on whether the proposed project meets the goals of the NOFO. Applicants should contact NCATS Scientific/Research staff at least 10 weeks before a receipt date.
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