Amol Akhade
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Amol Akhade: FDA’s New ‘Plausible Mechanism Pathway’

Amol Akhade, Senior Consultant at Fortis Hospitals Mumbai, shared a post on LinkedIn about a paper by Vinay Prasad et al. published in NEJM:

“NEJM: FDA’s New ‘Plausible Mechanism Pathway‘ — A Major Shift for Bespoke Therapies

The NEJM Sounding Board by Vinay Prasad and Martin Makary introduces the Plausible Mechanism Pathway (PMP)—a new FDA framework created for individualized, N=1 therapies where RCTs are impossible. This is a regulatory response to what modern biology can now achieve with rapid sequencing, gene editing, and RNA-based platforms.

The Baby KJ Case (CPS1 deficiency):

A newborn with a single-gene metabolic defect received a customized adenine base–editing therapy within one week—designed, manufactured, infused, and clinically effective. This example defines the type of disease PMP is built for.

The 5 Requirements of the Pathway:

  • A clear, single molecular abnormality
  • Therapy that directly targets that pathway
  • Well-understood natural history of the disease
  • Evidence of target engagement (animal/cell models)
  • Consistent and meaningful clinical improvement

If several such N=1 successes occur, the FDA may allow platform approvals using the same editing backbone with only the guide sequence changed.

Who benefits?

  • Ultra-rare genetic diseases
  • Fatal childhood-onset disorders
  • Single-gene metabolic defects
  • Rare pediatric cancers with a clear driver (future applications)

Who doesn’t?

  • Multifactorial diseases
  • Complex adult cancers
  • Diseases with unclear biology
  • Conditions with effective existing therapy

This pathway is not for broad or common diseases—it is meant for precisely defined biological targets.

FDA’s expectations

• Long-term safety & off-target monitoring
• Real-world evidence and registries
• Vigilance for developmental & immune effects

Given gene editing’s permanence, these safeguards are essential.

Key concerns raised by the authors

  • Potential industry overreach
  • Limited long-term safety data
  • Need for strict mechanistic criteria
  • Transparency in follow-up

Why this matters?

The Plausible Mechanism Pathway is a biology-first, logic-first regulatory shift that may accelerate therapies for ultra-rare diseases—and eventually influence precision oncology for small molecularly defined subsets.

A thoughtful evolution toward truly individualized medicine.”

Title: FDA’s New Plausible Mechanism Pathway

Authors: Vinay Prasad and Martin A. Makary

You can read the full article in NEJM.

Amol Akhade: FDA’s New 'Plausible Mechanism Pathway'

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