The FDA's new pathway for rare disease drugs, based on causal biology, is scientifically promising. However, the name "plausible mechanism" is a critical flaw. The term sounds weak, creating doubt for patients and giving payers powerful leverage to deny coverage by implying a lower standard of evidence.
Breakthrough drugs aren't always driven by novel biological targets. Major successes like Humira or GLP-1s often succeeded through a superior modality (a humanized antibody) or a contrarian bet on a market (obesity). This shows that business and technical execution can be more critical than being the first to discover a biological mechanism.
The FDA incentivizes animal drug development by granting years of market exclusivity to companies that prove a generic human drug works for a novel use in animals. This avoids the "aspirin problem" in human medicine, where no one will fund trials for off-patent drugs because they can't be profitably marketed.
While the FDA is often blamed for high trial costs, a major culprit is the consolidated Clinical Research Organization (CRO) market. These entrenched players lack incentives to adopt modern, cost-saving technologies, creating a structural bottleneck that prevents regulatory modernization from translating into cheaper and faster trials.
An ideologically driven and inconsistent FDA is eroding investor confidence, turning the U.S. into a difficult environment for investment in complex biologics like gene therapies and vaccines, potentially pushing innovation to other countries.
The 'FDA for AI' analogy is flawed because the FDA's rigid, one-drug-one-disease model is ill-suited for a general-purpose technology. This structure struggles with modern personalized medicine, and a similar top-down regime for AI could embed faulty assumptions, stifling innovation and adaptability for a rapidly evolving field.
Abivax's drug has a novel, not fully understood mechanism (miR-124). However, analysts believe strong clinical data across thousands of patients can trump this ambiguity for doctors and regulators, citing historical precedents like Revlimid for drugs that gained approval despite unclear biological pathways.
The Orphan Drug Act successfully incentivized R&D for rare diseases. A similar policy framework is needed for common, age-related diseases. Despite their massive potential markets, these indications suffer from extremely high failure rates and costs. A new incentive structure could de-risk development and align commercial goals with the enormous societal need for longevity.
Renowned gene therapy pioneer Jim Wilson was forced to spin out ultra-rare disease programs into a new company after his initial venture failed to attract VC funding. This demonstrates that even elite scientific leadership cannot overcome investor disinterest in this segment without powerful, predictable government incentives like transferable priority review vouchers.
The FDA is shifting policy to no longer allow reliance on immunogenicity data (immunobridging) for approving new or updated vaccines. This move toward requiring full clinical efficacy trials will make it harder to combat evolving pathogens and would have prevented past approvals of key vaccines like those for HPV and Ebola.
The success of Praxis's small molecule for a genetic epilepsy presents a strategic alternative to cell and gene therapies. In an era where complex modalities face funding, safety, and commercial hurdles, advanced small molecules offer a viable and potentially more practical path for treating genetic disorders.