OnCo
ideasIdea

Diversity action plans with consequences: unmet targets trigger post-approval requirements

Companies now have to file a plan for enrolling a representative mix of patients. If the trial misses the plan, the label should say so and the company should be required to fill the gap after approval.

Under the US FDORA requirement for diversity action plans, sponsors set enrolment goals by race, ethnicity, sex and age. The proposal adds teeth: the approved label states enrolled demographics against disease incidence; shortfalls beyond a threshold trigger a post-marketing requirement for a supplementary study or registry in the under-enrolled group with a deadline; and repeat shortfalls are published in an annual sponsor scorecard.

Hypothesis
Attaching label statements and post-marketing requirements to missed diversity targets will raise representativeness of pivotal trials, measured by participation-to-prevalence ratios in FDA Drug Trials Snapshots, within five years.
Rationale
Goals without consequences have not moved enrolment demographics much over two decades. Post-marketing requirements are an existing, enforceable instrument.
What would test it
Compare participation-to-prevalence ratios for approvals before and after enforcement begins, and track completion of triggered post-marketing studies.
Maturity
being tested at scale
Who has to act
regulator
Cost to try
Small (under $1M)
Years to first evidence
3
Bottlenecks it attacks

Connected

3top

Pages like this

not linked directly; found by shared links