Editorial
In this edition of the Journal, the outputs from two workshops provide an important
framework for the future development of a pipeline for new CF therapies. The workshops
considered drug development, clinical trial design, and regulatory pathways, in the
evolving and challenging research environment that has developed with clinical use
of CFTR modulation.
CFTR modulation has led to improved health outcomes for patients with CF, although
the benefits derived from CFTR modulation have also led to difficulties in the design
of clinical trials for new medicines. Established trial endpoints may not be as sensitive
to change in healthier populations, and new outcomes or biomarkers may be required.
Patients may be less inclined to stop effective treatment for clinical trials, and
this makes gold standard placebo-controlled trials more challenging. De Boeck et al.
provides the summary of discussions from a workshop held in November 2019 that focused
on drug trial design in the new era of CFTR modulation. The workshop included invited
clinical experts as well as representatives from pharmaceutical companies, the European
Medicines Agency (EMA), experts in Health Technology Assessment and patient organisations
[1]. There were welcome discussions on trials and approaches to drug development for
groups such as those with rare CFTR mutations and vulnerable groups such as infants
and young children. Infants and young children require special consideration as they
may derive the greatest benefit in the long term from early improvement of CFTR function,
although early exposure may also increase the potential for greater harm given the
developmental context. Measuring efficacy in uncooperative young children also presents
many challenges, and there are time constraints to understanding longitudinal safety
and outcomes.
Regulatory requirements for drug development vary between different countries. These
differences lead to barriers for drug development and contribute to reduced global
access and increased costs associated with drug development. Harmonization between
regulatory authorities should provide agreement on the technical and marketing requirements
for therapeutic products. This requires cooperation between the regulatory authorities
working with pharmaceutical companies to achieve an agreed pathway for the ethical
development of new therapies and reduce both duplication of effort, and the time taken
to bring a product from bench to bedside across different jurisdictions. Globally
there are those who are living without access to new CFTR modulation, or other new
medicines, because of regulatory issues as well as the cost of these expensive treatments.
Mayer–Hamblett et al. reflect the discussions and outcomes from a workshop of invited
international experts on clinical trials and trial networks that was held in October
2019 associated with the North American CF meeting [2]. The workshop focused on the
development of new therapies for CF and discussed the challenges and approaches to
regulatory requirements in the post CFTR modulator environment including treatments
for rare mutations. The workshop highlighted the crucial importance of clear communication
between all stakeholders. The workshop also provided strategies for the development
of new anti-infective, anti-inflammatory and other symptomatic treatments, as well
as for the development of new cellular therapies that would be impacted by the availability
of CFTR modulation.
Regulatory authorities have started to find solutions to some of the challenges raised
in both the workshops. The Food and Drug Administration (FDA) in 2017 took the step
of approving the potentiator ivacaftor for an extended list of CFTR mutations based
on laboratory studies rather than specific clinical trial evidence. The premise for
this decision was that clinical trials for many rare CFTR mutations would not be feasible,
and that cell models of functional CFTR responses were generally predictive of the
clinical benefits [3]. This approach will need careful consideration and agreement
on which cellular approaches are required, and for which therapies they are appropriate
in the future, but this has certainly opened a new door for drug development and regulatory
approval.
During the peer review process, an issue arose around the terminology used in both
manuscripts. This led to considerable debate between the authors, the reviewers and
the journal, and given the strong opinions around the terminology, it may be worthwhile
to reflect on this debate. Both manuscripts initially used the term “highly effective
CFTR modulators” to identify the exceptional outcomes from two CFTR modulators currently
in clinical use. The two CFTR modulators include ivacaftor in patients with CFTR gating
mutations [4], [5], and the triple combination elexacaftor, tezacaftor and ivacaftor
(Trikafta™) in patients aged 12 years and older who are either homozygous [6] or heterozygous
for F508del-CFTR
[7]. Two other CFTR modulator therapies in clinical use, Orkambi™, and Symdeko™ (also
known as Symkevi™), are associated with more modest improvement in CFTR function and
clinical outcomes [8], [9]. Given this background, and the growing common usage of
this terminology, why should there be any concern about the use of “highly effective
CFTR modulator” to differentiate these drugs in the scientific literature? Drugs are
classified based on their pharmacological effects, their chemical structures, molecular
targets or specific drug actions, and the recognised classification of “CFTR modulators”
fits nicely within this approach. As clinicians and scientists, we describe and compare
specific drugs in terms of their potency, effect or toxicity and such comparisons
and discussion are critical in developing appropriate clinical use. To date, however
the classification of drugs has not included adjectives that describe them. New CFTR
modulators are in development and, like other new drugs, may end up being equivalent
or may be more, or may be less effective for specific outcomes compared with the various
current clinically available CFTR modulators. If we start to differentiate within
the CFTR modulator class in the scientific world by the term “highly effective’, what
will we use to set the bar to achieve this accolade, and could there be consequences
to doing this? How will we account for variation in effects on different outcomes
or between individuals? Naming or labelling things is a very powerful tool that is
well recognised in the advertising world. In the clinical trial setting there has
been concern around the explosion in the use of acronyms for naming clinical trials
and the risks that positive sounding trial acronyms pose with regards to the therapeutic
misconception [10]. The language of science should be clear and objective while still
providing the opportunity for creative thought, but the labelling of drugs as “highly
effective” as part of their classification feels close to leaving objectivity behind.
The global SARS-CoV-2 pandemic emerged after both workshops. The pandemic has led
to substantial impacts on health and on the global economic outlook. It is likely
that there will be repercussions felt across all sectors of the economy, including
drug development and support for clinical research. What this means for CF research
and the pipeline of new treatments for CF specifically, or indeed for how clinical
trials will be conducted, or new therapies may be reimbursed in the future, remains
to be seen. The pandemic however has prompted urgent collaboration globally to develop
vaccination and treatments to combat COVID-19, the disease caused by SARS-CoV-2. In
June 2020, a great start was made in regulatory harmonization with a meeting chaired
by the FDA and EMA under the auspices of the International Coalition of Medicines
Regulatory Agencies (ICMRA,) which brought together experts from over 20 countries
and 28 regulatory authorities. The meeting led to broad agreement on the data required
from laboratory, animal and human research as well as aspects of Phase 3 clinical
trials aimed at the rapid development and regulatory approval for vaccines for COVID-19.
We can only hope that this example of global collaboration will lead to a more established
pattern of harmonization and more rapid development of other important medicines in
the future.
The outputs from the two workshops have provided a very helpful start in setting the
scene for clinical development of new treatments for CF in the CFTR modulator era.
There were some issues however that may benefit from further consideration in the
future. The high cost of new treatments and reimbursement remains a considerable concern
for CF care. This of course is a thorny global issue for all areas of health worldwide,
and while there are no easy solutions, we need to keep reconsidering the issues and
chip away at the problem. The other major area that deserves further thought includes
trials and regulatory pathways for new medicines in vulnerable groups such as pregnant
or lactating mothers, those with solid organ transplants, and those with severe liver
disease. These groups are almost always excluded from clinical trials and regulatory
packages although clinicians and patients may choose to use the medicines once they
are generally approved. There has been some encouraging progress recently with the
2018 FDA guidance on the issue of trialling and monitoring medicines during pregnancy
and lactation. Future collaboration and communication between regulatory authorities,
pharmaceutical companies, clinicians and patient groups will be needed to consider
how best to establish the clinical use of new CF medicines for these very challenging
populations. There has been enormous improvement and exciting development in CF care
especially with CFTR modulation, but much work remains to be done to ensure equitable
access to safe and appropriate use of medicines for all people with CF in the future.