SDD Wiki

Session XI — Federal Perspectives

The FDA Is Moving Faster Than You Think — and NIH Is Rewriting How Science Gets Done

Five senior federal officials on structural shifts in the regulatory and funding environment.


One Trial Is Now the Default

  • FDA formalized in NEJM (Feb 2026): one adequate, well-controlled trial + confirmatory evidence is the basis for marketing authorization
  • Commissioner’s National Priority Voucher: median approval time 54.5 days (vs. 10-month PDUFA clock)
  • CDER 100% compliant with all PDUFA deadlines as of April 2026
  • Real-time clinical trials announced: FDA receives safety/efficacy data continuously via EMR

Plausible Mechanism Framework

  • Regulatory pathway for bespoke therapies (e.g., custom CRISPR for CPS1 deficiency — “baby KJ”)
  • No population-level trial required if: known molecular abnormality, characterized natural history, confirmed target engagement
  • Recent examples: Avlayah (Hunter syndrome), Loargys (Arginase 1 deficiency), Zycubo (Menkes disease)

BMD Surrogate Endpoint

  • Dec 2025: total hip BMD qualified as validated surrogate for osteoporosis approval
  • SABRE Project: 52 RCTs, 160,000+ patients, over a decade
  • Fracture trial: 10K-15K patients, 2-5 years → BMD trial: hundreds of patients, ~2 years
  • Opens door to many new osteoporosis drugs

Devices & AI (CDRH)

  • RAPID program (April 2026): CMS sits at FDA table during IDE → national coverage 60-90 days after authorization (vs. ~1 year)
  • Home as Health Care Hub: >400 OTC devices; TEMPO pilot for unapproved digital health
  • Agentic AI: foundational models outpacing draft guidance; benchmarks being defined with NIST, ONC

NIH Pivot to Human-Based Science

  • Funding opportunities exclusive to animal models will no longer be issued
  • COMPLEMENT program (Common Fund): 7 technology development centers for human-based models
  • Standardized Organoid Modeling Center ($87M; Frederick National Laboratory)
  • Cross-agency real-world data network: NIH + CMS + VA + CDC

Cross-Agency Fluency

  • RAPID (FDA + CMS), COMPLEMENT (NIH + FDA + EPA), real-world data (NIH + CMS + VA + CDC)
  • “One government” posture — substantively new in scope and formality