The Expanded Access Navigator – Helping Patients In Need of Potentially Life-Saving Drug Treatments

By: Richard A. Moscicki, M.D.

Patients with serious or immediately life-threatening diseases or conditions who have no comparable or satisfactory alternative therapy and who seek access to potentially life-saving investigational drugs will have another option to guide them through the process – thanks to the launch today of a new online tool called the Expanded Access Navigator. The development of the Navigator was a team effort led by the Reagan-Udall Foundation in collaboration with patient advocacy groups, the pharmaceutical industry, FDA, and others in the Federal government.

Dr. Richard MoscickiWhen a patient has a serious or immediately life-threatening disease or condition for which there is no FDA-approved treatment, they may be able to gain access to an investigational drug under the FDA Expanded Access process. Expanded Access permits the product’s manufacturer, with the authorization of FDA, to provide an investigational drug for a patient, even though the drug is still in development or under review for FDA approval. Each year FDA receives more than 1,000 applications requesting authorization of expanded access through individual patient, intermediate or large-size expanded access programs. FDA has worked to streamline the process, particularly with a simplified application for individual patient expanded access; however, it can still be challenging and time-consuming for patients, family members, caregivers, and health care professionals to navigate the system.

The Expanded Access Navigator helps to educate patients and physicians about the process. Most of what they need to seek expanded access is now available in this single online location, including a directory where companies can submit public links to their expanded access policies, criteria used by companies to determine whether to make a drug available through expanded access, and contact information. While not a portal for applications, the directory is the first consolidated starting point for researching available investigational therapies. To help users find information quickly, the Navigator is separated into one section for patients and caregivers, and another for physicians.

  • The patient and caregiver section provides links to resources such as how to determine if a patient can participate in a clinical trial, the difference between an intermediate-size or larger expanded access program and a single-patient expanded access program, and their physician’s role in helping them obtain an investigational drug. Patients also can reach out to FDA’s Office of Health and Constituent Affairs’ Expanded Access Team.
  • Physicians can use the tool to identify investigational treatment options for their patients, explore clinical trials on behalf of their patients, learn how to engage with FDA and pharmaceutical companies as part of the process, and read about important factors to discuss with patients when considering expanded access. After using the Navigator and deciding on an investigational drug treatment option, physicians may contact FDA’s Division of Drug Information for assistance with their expanded access application.

photo of patient and doctorThe site is a valuable resource for information about obtaining access to an investigational drug through an expanded access program, but it also offers a great deal of useful information about participation in clinical trials, which is the preferred option. Clinical trials help to ensure adequate patient protection and may provide the evidence of safety and effectiveness required to support approval of a marketing application.

The Partners who contributed to the website’s development, in addition to FDA, include the American Cancer Society, the American Society of Clinical Oncology, the Biotechnology Innovation Organization, the Pharmaceutical Research and Manufacturers of America, Foundation Medicine, Susan G. Komen, Bristol-Myers Squibb, Genentech, Janssen, Lilly, Merck, and Pfizer.

Using an investigational drug will always come with risk – and the expanded access process helps to assess whether the potential risks are appropriate for a patient. But the last thing a patient and their loved ones coping with serious or life-threating illness needs is an overly burdensome process for access to potential treatment options. The Navigator helps to reduce that burden.

We are pleased to have worked collaboratively with others to witness the launch of the Expanded Access Navigator, and are thankful for everyone’s hard work and dedication. We hope the tool will be a help to many and improve the experience for patients, their caregivers, and physicians who are seeking expanded access.

Richard A. Moscicki, M.D., is FDA’s Deputy Center Director for Science Operations, Center for Drug Evaluation and Research

Important steps toward streamlining access to investigational drugs for patients in need

By: Richard A. Moscicki, M.D.

FDA is only too aware that there are many patients who have a serious or life-threatening medical condition for which there is no available FDA-approved therapy. For such patients, one option may be to obtain access to an investigational drug that has not yet been approved by FDA. To do this, a physician submits an application to the FDA requesting authorization to use the investigational drug in the treatment of their patient. This is called expanded access to investigational drugs.

Dr. Richard MoscickiWhile FDA has been helping physicians navigate the system for many years, we are aware there have been physician and patient concerns about this process, which can be time consuming and difficult to understand. Consequently, FDA has recently made significant changes to streamline and simplify the process for single patient expanded access requests.

To make the expanded access process more efficient, we’ve just introduced a much simpler application form called the Form FDA 3926, which will be the form doctors now will typically fill out when they want to provide an investigational drug for a patient through expanded access. While the Form 1571 had 26 information fields and seven attachments, the new Form 3926 has fewer fields (11) and only one attachment. With this streamlined format, we estimate that physicians will be able to complete the form in just 45 minutes, as compared to the more difficult and time consuming effort required previously.

Also, as part of our commitment to streamlining the expanded access process, on May 16, 2016, the FDA and the Reagan-Udall Foundation held a meeting with interested stakeholders to explore additional options that might help patients and their physicians understand the process to request access to unapproved drugs. A common theme of the meeting was that navigating the expanded access process really does take a village. The physician, the drug company, FDA, and the institutional review board (IRB) all have important roles and must work together for the expanded access process to succeed.

The FDA and Reagan-Udall Foundation convened this forum to listen to the public express their needs about expanded access and to discuss ideas with stakeholders on ways that the complex process can be made more efficient and effective. Much work on the details remains, but in general there was agreement on the need for a central repository or clearinghouse where useful and relevant information could be stored in one place — a sort of “one-stop-shop” for physicians and patients to seek information about the expanded access process. As our thinking about this resource develops, we’ll keep the public informed.

For physicians seeking more information about expanded access to an investigational drug, we have developed an educational webinar to help them become familiar with the new application form. This live webinar will occur on July 12 at 1:00 PM EDT and will offer one hour of Continuing Education (CE) credit. The webinar will be recorded for viewing without CE credit. We also have released a guidance regarding Form FDA 3926, a guidance with Questions and Answers on expanded access, as well as a guidance directed at industry addressing questions regarding charging for investigational drugs.

Expanded access is designed for seriously ill patients who have exhausted other options.  The last thing a patient suffering from a serious or life-threatening condition needs is red tape. For many years, FDA has dedicated staff to assist physicians and patients in navigating our system. We expect these important steps will help us continue our efforts to serve patients in need and to advance public health.

Richard A. Moscicki, M.D., is FDA’s Deputy Center Director for Science Operations, Center for Drug Evaluation and Research