The FDA's critique of both CREST and Potomac trials highlights that while event-free survival (EFS) endpoints were met, the lack of improvement in overall survival or prevention of muscle-invasive disease makes the risk/benefit profile questionable for an early-stage cancer, where treatment-related harm is a primary concern.

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The CREST trial showed benefit driven by patients with carcinoma in situ (CIS), while the Potomac trial showed a lack of benefit in the same subgroup. This stark inconsistency demonstrates that subgroup analyses, even for stratified factors, can be unreliable and are a weak basis for regulatory decisions or label restrictions.

An advisory panel split 50/50 on a two-year immunotherapy regimen but voted 7-to-1 for a one-year drug with similar efficacy. This reveals that for adjuvant therapies in non-metastatic cancer, halving the treatment duration and toxicity exposure can decisively shift the risk/benefit calculation in favor of approval.

In muscle-invasive bladder cancer, cisplatin ineligibility is frequently due to renal insufficiency caused by large, aggressive tumors obstructing the ureter. This redefines this patient group as having more advanced local disease, rather than simply being unfit for chemotherapy, explaining their poor outcomes with surgery alone.

With highly active agents yielding 30% complete response rates, the immediate goal should be to cure more patients by exploring potent combinations upfront. While sequencing minimizes toxicity, an ambitious combination strategy, such as ADC doublets, offers the best chance to eradicate disease and should be prioritized in clinical trials.

An expert argues forcefully that the PD-L1 biomarker should be "ditched" in bladder cancer. Citing its repeated failure to predict overall survival benefit across multiple major trials, it is deemed an oversimplified and unreliable tool that leads to both over- and under-treatment of patients.

In the CREST trial, the FDA's critique heavily emphasized an overall survival hazard ratio above one. Though statistically insignificant and based on immature data, this single figure created a powerful suggestion of potential harm that overshadowed the positive primary endpoint and likely contributed to the panel's divided vote.

High relapse rates (~70%) in surgery-alone arms of recent trials suggest most patients with muscle-invasive bladder cancer (MIBC) already have micrometastatic disease. This reframes the disease, prioritizing early systemic therapy over immediate surgery to achieve control and potential cure.

The FDA's current leadership appears to be raising the bar for approvals based on single-arm studies. Especially in slowly progressing diseases with variable endpoints, the agency now requires an effect so dramatic it's akin to a parachute's benefit—unmistakable and not subject to interpretation against historical data.

In high-risk non-muscle invasive bladder cancer (NMIBC), trials like CREST and POTOMAC show adding a systemic immune checkpoint inhibitor to BCG therapy introduces significant toxicity. The benefit is primarily in local control, which may not justify the risk, especially with other effective intravesical options available.

An expert oncologist identified a pathological complete response (pCR) rate over 50% as the benchmark that would fundamentally alter treatment. The EV Pembro trial's 57% pCR rate crossed this threshold, forcing a shift from a surgery-centric model toward bladder preservation strategies and systemic therapy.