Expanded Access Policy
General Policy Statement
The
US Food and Drug
Administration (FDA) has established criteria for the provision of
investigational medicines to patients outside of clinical trials, called “Expanded
Access”, “Compassionate Use”, “Early Access”, or “Emergency Use”. Patients who
seek access to investigational medicines outside of an established clinical
study and prior to health authority marketing authorization may wish to do so
because standard treatments have failed, they cannot tolerate already approved
medicines, because they are unable to participate in a clinical study, or
because there are no comparable or satisfactory therapy options available
outside of clinical trials.
The
policy below sets forth the general guidelines that Cartesian Therapeutics
(Cartesian) will apply to its Expanded Access Program to ensure that requests
for access to our investigational medicines are considered and processed in
accordance with applicable legal and regulatory requirements, as well as in alignment
with principles consistent with the Company’s policies and procedures. Further
information about Cartesian’s clinical trials is available at
Clinicaltrials.gov.
Policy
Cartesian Expanded Access Programs: The best route to enable the broadest number
of patients to have access to a medicine for a particular condition is by
making it commercially available through an established health authority
approval process. Prior to health authority approval, clinical trials are the
preferred mechanism by which patients would be able to obtain access to an
investigational medicine due to the controlled environment and associated
safeguards. However, there may be circumstances in which a patient may not be
eligible to participate in a clinical trial. In these cases, Cartesian may be
able to provide access under certain defined conditions through an established,
company-planned Expanded Access Program, accessible by sending an email
to EAP@cartesiantx.com. These conditions include:
- Sufficient data must exist for
particular serious diseases or conditions to anticipate that the potential
benefits outweigh the potential risks of the investigational medicine.
- Patients who may possibly
obtain access must:
- have a serious or life-threatening
disease or condition;
- have no appropriate,
comparable, or satisfactory alternative treatment available, or have
tried such alternatives without clinical success;
- be unable to participate in a
clinical trial for the disease or condition; or
- be in a situation where the
potential benefit justifies the potential risks of treatment.
- Providing access must not
significantly jeopardize the clinical development program intended to
support regulatory approval, registration, or commercialization of the
investigational medicine. Development may be jeopardized if access could:
- interfere with the initiation,
conduct, or completion of clinical trials, including participant
availability and enrollment; or
- result in insufficient drug
supply or the requisite medical and other internal expertise needed to
support the clinical trials necessary for regulatory approval.
- The treating physician must be
licensed and otherwise qualified to:
- safely administer the
investigational medicine;
- comply with local regulations
for expanded access; and
- monitor and report adverse
events, as required by law and by company requirements.
Cartesian
will acknowledge receipt of Expanded Access inquiries within five (5) business
days of receipt.
Closing of Expanded Access Program: Cartesian may consider closing a program for
various reasons, including but not limited to:
- Commercial availability of the
medicine for a particular need or condition, at which point it would be
more broadly available to these patients in need;
- A negative regulatory decision,
or a Company decision not to proceed with and/or the discontinuation of
clinical trials, or commercialization for a particular disease or
condition. In this instance, patients on expanded access treatment at the
time of such a decision may be allowed to continue to access therapy until
disease progression;
- New information becomes
available about the activity or safety of a medicine that could
substantially change its benefit/risk profile; or
- Limited product supply or other
manufacturing issues.
This policy is subject to change and is not intended
to create or imply any contract. The
posting of this policy by Cartesian shall not serve as a guarantee of access to
any specific investigational medicine by any individual patient.