BIO represents an industry that is devoted to discovering new treatments and ensuring patient access to them. Accordingly, we closely monitor changes to Medicare’s reimbursement rates and payment policies for their potential impact on innovation and patient access to drugs and biologicals.As a threshold matter, we raise our concern with the implementation of a policy that can have such impacts in limiting access for beneficiaries in MA via the application of step therapy, as detailed in the Administration’s August 7th memo.2 As detailed in our letter to the Administration, we are particularly concerned with the lack of specificity or detail in this memo around critical patient protections and appropriate implementation, including ensuring: sufficient oversight by CMS; clear clinical criteria for step therapy policies; transparency into, and communication of, step therapy policies to beneficiaries and robust beneficiary protections; timely exceptions and appeals processes; sufficient protections for those on existing therapies; and protection for beneficiaries from higher cost-sharing.

BIO submitted comments on the Food and Drug Administration’s (FDA) Draft Guidance, Patient-Focused Drug Development: Collecting Comprehensive and Representative Input. In the comments, BIO applauds the FDA’s initiative to advance the use of patient-experience data (PED) to inform drug development and regulatory review. BIO sees this first draft guidance, addressing comprehensive and representative input, as an important tool for strengthening our collective understanding of the evidence needed to support the FDA regulatory process with PED. BIO says the guidance presents standards that adhere to established standards for good research practice and provides enough information to gain insight into what is needed to compose an appropriate research study, but BIO strongly believes future guidance documents should emphasize the FDA’s willingness to exercise regulatory flexibility and acceptance of innovative designs and approaches for collecting PED. BIO’s comments provide suggestions for changes to the guidance to encourage broader adoption of PED.

The Biotechnology Innovation Organization (BIO) is pleased to provide comment on the U.S. Environmental Protection Agency’s (EPA’s) proposed rule on the Renewable Fuel Standard Program: Standards for 2019 and Biomass-Based Diesel Volume for 2020 (proposed rule).

Re: Docket No. FDA-2018-D-2032: The Biotechnology Innovation Organization (BIO) is pleased to submit the following comments on the Food and Drug Administration (FDA) Draft Guidance, “Limited Population Pathway for Antibacterial and Antifungal Drugs (LPAD); Draft Guidance for Industry.” 

BIO submitted comments on the Food and Drug Administration’s (FDA) Draft Guidance, Considerations for the Inclusion of Adolescent Patients in Adult Oncology Clinical Trials. The draft guidance is an important step towards ensuring stakeholders understand FDA’s expectations regarding the inclusion of adolescents in clinical trials for oncology products. BIO asks the FDA to consider reviewing and discussing the draft guidance with other global health authorities during pediatric cluster calls and asks for educational efforts directed towards institutional review boards (IRBs), which will be critical for successful implementation of the draft guidance. In addition, BIO asks for clarification on how the draft guidance relates to the Pediatrics Research Equity Act (PREA) and the FDA Reauthorization Act of 2017, Section 504, Development of Drugs and Biological Products for Pediatric Cancers. BIO requests case examples demonstrating circumstances in which adolescents have different physiology and/or psychology relative to adults. BIO’s comments include general suggestions as well as line edits.

As the U.S. Environmental Protection Agency (EPA) begins its work to develop the proposed 2019 Renewable Fuel Standard (RFS) Renewable Volume Obligation (RVO), we encourage the agency to take a renewed look at commercial-ready cellulosic biofuels.