The FDA has released the specifics of their rejection letter to Lykos Therapeutics’ MDMA-assisted therapy trial. The letter outlines several key reasons for its decision not to approve the potential therapy:
Inadequate Safety Data
The FDA found that Lykos failed to adequately collect and report data relating to important information on the specifics of events described as “positive” or “negative”. This data is necessary to assess both the impairment of an individual as a result of the therapy, as well as the addiction potential of the substance employed – in this case, MDMA. The FDA also expressed some concern that there had been cases of unreported negative outcomes or adverse reactions at some study sites.
Lack of Durability Data
The FDA determined that the application did not provide enough evidence to support their conclusion that the treatment remained effective following the 18-week assessment period of the study itself. The FDA also criticised the format of the follow-up study to form these conclusions. Variability in follow-up timing, the fact that it consisted of a single visit with no control of, or seeming interest in, any self-medication by participants in the meantime.
Potential for Bias
Approximately 40% of trial participants had already had experience using MDMA in a recreational context. This is a far higher rate than seen in the wider population of individuals suffering from PTSD. This, combined with high rates of failures when pre-screening participants, suggests potential issues with selection bias. This could limit the applicability of the study to individuals as a whole, rather than those already familiar with the drug’s effects.
The FDA has not outright rejected the study, but rather recommended means to remedy these perceived issues. They suggest Lykos conduct a new, randomised, double-blind clinical trial to assess the durability of the effects they studied as well as the safety profile of the substance administered. They also recommended an independent third-party audit of all the findings thus far, to assess whether or not they are, in fact, valid or representative.
Lykos Therapeutics expressed its disappointment with the decision, announcing its desire to meet with the FDA and appeal the decision. Lykos believes that the FDA’s concerns can be alleviated using the already existing data or with reference to other already existing scientific data. The delay caused by the necessity for a mult-year Phase 3 study could prove catastrophic to the viability of continuing research. Lykos also cited worries with the approval process itself, due to the perceived lack of experts in the subject matter present on the panel.
Rick Doblin, the founder of the Multidisciplinary Association for Psychedelic Studies (MAPS), now Lykos, has expressed dissatisfaction with the decision, claiming the FDA has “moved the goalposts”. Doblin says that the FDA’s concerns with the continued durability of the substance following treatment have not been a standard used to approve drugs previously, like those approved for use in cancer treatment, where relapses are common, for example. Doblin also explained that while Lykos had in fact submitted an amendment to their application to respond to the advisory committee’s concerns, the FDA did not take this into account when rejecting the study. Doblin did, however, praise the full release of the rejection letter, allowing for wider, constructive debate, with the hope Lykos may be able to push ahead following further discussion.
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