BACKGROUND
The development, review and approval process of therapeutic biological products in the United States presents two primary challenges: time and cost. Advancing a biotherapeutic from concept to market may take an average of twelve years with costs exceeding one billion dollars. Even after significant time and resources have been invested in a therapy, the product may still fail the U.S. Food and Drug Administration (FDA) approval process. A subset of advocacy groups and experts in drug regulations and policies are demanding a more rapid approval and release of bio-products. Despite the FDA’s practices to expedite the approval of new therapies, seeking FDA approval remains a long, costly, and risky process.
OBJECTIVE
The objective of this paper is to explore the factors and gaps related to the FDA review and approval process which contribute to process inefficiencies and complexities, as well as proposed methods and solutions to address such gaps. This paper aims to investigate the available modeling efforts for the FDA approval process of therapeutic biological products.
METHODS
A scoping review of the literature was conducted to understand the scope of published peer-reviewed knowledge about challenges, opportunities, and specific methods to address these factors and gaps related to the review and approval of new drugs, including therapeutic biological products. Relevant peer-reviewed journal articles, conference proceedings, official reports from public policy professional centers, and official reports and guidelines from the FDA were reviewed.
RESULTS
To the best of our knowledge, none of the articles identified in this scoping literature review have modeled the current FDA review and approval process structure to address issues related to the robustness, reliability, and efficiency of its operations from an external point of view. While several studies summarize the FDA approval process with clarity, in addition to bringing to light the problems and challenges that the regulatory agency is facing, only a few attempts to provide solutions for the problems and challenges identified. In addition, while several reform models were discussed, broadly stated, these models lack the application of scientific methodologies and modeling techniques in understanding FDA as a complex sociotechnical system. Furthermore, tools and methods to assess the models’ efficacy before implementation are largely absent.
CONCLUSIONS
Findings suggest the efficacy of Model-Based Systems Engineering (MBSE) approaches for identifying opportunities for significant improvements to the FDA review and approval process. Using this holistic approach will serve several investigative purposes: (1) identify influential sources of variability that cause major delays including individual, team, and organizational decision-making, (2) identify the human-system bottlenecks, (3) identify areas of opportunity for design-driven improvements, (4) study the effect of induced changes in the system, and (5) assess the robustness of the structure of the FDA approval process in terms of enforcement and information symmetry.