For the first time, the FDA will consider whether to approve a trio of drugs for tiny patient populations based on trials that are using biological signals as outcomes, rather than a placebo comparison.
It’s a crucial moment not just for the three companies and the drugs, but also a chance to remove what’s long been seen as a major roadblock to developing treatments for ultra-rare disease populations. It also comes as the FDA has signaled an openness to leaning on biomarkers, which would let companies prove treatments work with a single clinical trial and later confirmatory evidence.
“From a broader rare disease perspective, this would be something that, if I was looking at other drugs, it would serve as favorable precedent,” Stifel analyst Paul Matteis said.
The drugs come from Denali, Ultragenyx and Regenxbio, which will ask the FDA this year to grant them accelerated approval based on a biomarker that’s never been used as the basis of one. They are developing drugs that aim to correct two of the many single-enzyme mutations, which collectively affect
millions of patients worldwide
.
That’s why the potential blueprint from these companies could offer an economic lifeline for other biotechs that have struggled to make a financial case for developing rare disease medicines, especially those in demand
among the smallest patient populations
.
If accelerated approval is granted, the three companies would have to run a single trial and later get confirmatory data. That would be less than the typical requirement, which is at least two placebo-controlled trials. For some companies, the cost of running multiple placebo-controlled studies can be daunting, as can finding enough patients for them.
Biomarkers are used for all accelerated approvals and can be simple measurements, like the shrinking of tumors or lower cholesterol levels.
Historically, broad approaches to rare disease development have been difficult, said Scott Weintraub, senior VP of US business at Alexion. That’s because rare diseases are highly varied, both in genetics and prevalence. Sickle cell disease, Duchenne muscular dystrophy and n-of-1 disorders are all classified as rare diseases despite having few symptoms in common.
“There is no translational model for most of these diseases,” Weintraub said. “There is no developmental endpoint agreement with the FDA or any regulatory agency at first. The companies don’t know what endpoints are going to move clinically in a lot of these diseases at first.”
So far, the FDA has relied on biomarkers to grant accelerated approval for more common rare conditions, such as Sarepta’s gene therapy for Duchenne muscular dystrophy that’s indicated to treat many of the 250,000 patients in the
US with the disease
. (The FDA has since
broadened
the label and
converted
most of it to full approval.)
The three drugmakers aim to show that they’re reducing levels of heparan sulfate, a complex carbohydrate that builds up in toxic levels in a handful of deadly neurological diseases. Of those, Denali and Regenxbio are targeting Hunter syndrome, while Ultragenyx is going after Sanfilippo syndrome. All are expected to present updated data this week at the annual WORLD
Symposium
conference.
For patients with severe Hunter syndrome, an infant’s decline can begin as early as 18 months old. Many babies suffer frequent upper respiratory infections and swelling around the brain and spinal cord. It affects an estimated
2,000 patients worldwide
.
Sanfilippo syndrome type A, meanwhile, results in most patients dying before they turn 20. It’s estimated that there are fewer than 5,000 cases in “commercially accessible regions,”
according to Ultragenyx
.
Scientists have known of heparan sulfate’s existence since the 1940s, but its potential as a biomarker didn’t come into focus until recently.
The companies believe heparan sulfate is innately linked across MPS, or mucopolysaccharidoses, due to only a single enzyme being affected by the genetic mutations.
“For any of these single-enzyme diseases, you will have a substrate that can be measured,” Denali chief medical officer Carole Ho said. “Because it’s the driver of the disease, theoretically if you stop that, you know accumulation of that substrate, by correcting it, you will get clinical benefit.”
That could mean other drug developers will be able to create future drugs targeting other single-enzyme mutations. Drug developers’ approaches to these conditions — disorders like cystic fibrosis and Huntington’s disease both result from single genetic mutations — have historically been scattershot and tailored to disease pathology.
But every disease or mutation is different, meaning attempts to replicate what these companies are doing won’t be an exact 1-to-1 copy.
The companies’ efforts also come at a time when the
FDA is developing a policy to encourage so-called platform technologies
that allow drugmakers to simultaneously target multiple diseases. Drugmakers taking a multi-disease approach may one day be able to get accelerated approval, though that’s more hope than reality right now.
The path for Ultragenyx in particular is one that may make it more financially viable for drug developers to make rare disease treatments. The company acquired its potential Sanfilippo syndrome treatment after a partner, Abeona Therapeutics, halted development during a corporate restructuring. Among Ultragenyx’s challenges was finding enough patients to run a placebo-controlled clinical trial.
Instead, the FDA last year indicated it’s
open to accelerated approval
, based on the biomarker, to speed up testing.
It’s part of a broader shift at the agency, which last summer launched a Rare Disease Innovation Hub after failing to reach a consensus on the types of evidence and trial designs needed to evaluate therapies for such conditions. The idea is to align the two main divisions of drug evaluation, CDER and CBER, under a framework that can be used consistently.
But the FDA’s embrace of accelerated approvals hasn’t been without controversy. The Sarepta approval came only after CBER chief Peter Marks
overruled his deputies
, and industry watchdog ICER pushed back on the therapy’s potential
conversion to full approval
.
It’s also not yet clear how the new presidential administration under Donald Trump will affect the FDA’s shift. For now, most biopharma companies have been operating as usual.
Ultragenyx CEO Emil Kakkis said that patients’ heparan sulfate levels fall within two to three weeks, giving the drugmakers confidence that they’re treating the underlying cause of MPS diseases rather than a downstream effect.
“That’s the thing that needs to go to zero,” Kakkis said. “We need to look at heparan sulfate, because that’s the source of the disease, and we’ll make better decisions off of it.”
After the FDA signaled its support for the biomarker, Ultragenyx submitted its application for accelerated approval late last year.
Regenxbio plans to finish its application by the first quarter, and Denali plans to do the same early this year. All three companies say they expect the FDA to make decisions before the end of 2025.
Going the route of accelerated approval and following established models like in cancer and heart disease would make things much easier for drug developers — and potentially speed up development timelines.
“Looking at biomarkers based on validated biological pathways is a very reasonable way to go; that’s going to be a lot faster,” TD Cowen analyst Yaron Werber said.
In practice, the path to getting confirmatory data may vary by company — but all three already have their studies up and running, suggesting the FDA may want to see a clear path to obtaining such data before agreeing to accelerated approval. Denali expects to get their results from the second portion of a Phase 2/3 trial, while Ultragenyx and Regenxbio plan to do so from the final cohort of a Phase 1/2/3 trial.
Ultimately, all of the discussion from the last few years is going to spur more research into new biomarkers, Regenxbio CEO Curran Simpson said. Pharma companies and regulators will also need to continue working together to advance treatments, regardless of how rare the disease is.
“It will probably bring back some level of investment that might have been avoided or unfunded, if you will, in the past,” Simpson said.