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Background: Major codes of human research call for minimizing patient burden and maximizing knowledge gains. Some research activities may make better use of patients because their findings have a greater impact on care. In this report, we use a metric of efficiency, the number of patients needed to achieve an FDA approval, to estimate the impact of post-approval research compared to initial drug development that required 12,217 patients.
Methods: We created a sample of anti-cancer drugs approved by the FDA between 2012 to 2015. We searched clinicaltrials.gov to identify drug development trajectories launched after FDA approval. We identified the number of trajectories producing the following milestones: secondary FDA approvals, NCCN off-label recommendations and FDA approvals of substantial benefit by ESMO-MCBS. Using enrollment, we estimated the number of patients needed to obtain each milestone.
Results: Forty-two cancer drugs were approved, leading to 451 post-approval trajectories enrolling 129,548 patients. Fourteen secondary FDA approvals were identified, of which 4 met the ESMO-MCBS definition of substantial clinical benefit. Fourteen NCCN off-label recommendations were obtained. A total of 9253; 32,387 and 4627 patients were needed to attain an FDA approval, an approval with substantial clinical benefit on ESMO-MCBS, and an NCCN guideline recommendation, respectively. The number of patients needed to obtain a first secondary FDA approval was 16,596.
Conclusion: The number of patients needed to extend the label of approved drugs is comparable to developing new drugs. Our findings suggest that public policy and research oversight should not favour post-approval research since whatever advantages are present regarding prior knowledge about safety and pharmacology do not translate to lower patient burden or high research efficiencies.