Background
The United States (US) Food and Drug Administration (FDA) introduced an Accelerated Approval (AA) pathway to expedite patient access to new drugs. AA accepts less rigorous trial designs, including single arm studies (SAS), owing to perceived lack of feasibility of timely RCTs.
Methods
We designed hypothetical RCTs with endpoints of objective response rate (ORR), progression free survival (PFS), and overall survival (OS) for FDA approvals based on SAS for solid tumors during 2010–2019. Existing standards of care served as controls. RCTs were designed to detect a difference with power of 0.80, α-error of 5% (two-sided), and 1:1 randomization. Accrual duration was estimated based on participation by < 5% of eligible patients derived from cancer-specific incidence and mortality rates in the US.
Results
Thirty-one of 172 (18.0%) approvals during the study period were based on SAS. Median sample size was 104 (range = 23–411), and 77.4% were AA. All studies reported ORR, 55% reported duration of response, 19.4% reported PFS, and 22.5% reported OS. Median sample size needed to conduct RCTs with endpoints of ORR, PFS and OS were 206, 130, and 396 respectively. It would have been theoretically possible to conduct RCTs within duration comparable to that required by SAS for 84.6%, 94.1%, and 80.0% of approvals with endpoints of ORR, PFS and OS respectively.
Conclusion
An overwhelming majority of FDA approvals based on SAS should be feasible as RCTs within a reasonable time-frame. Given the collateral harms to patients and to scientific rigor, drug approval based on SAS should only be permitted under exceptional circumstances.