The FDA is taking steps to ensure that clinical trials are more representative of the diverse populations they aim to serve. This comes after the industry and the FDA's long-term recognition that clinical trials have often excluded underrepresented groups, leading to health disparities across the United States and the world.

The FDA’s draft requirements

The FDA has issued draft guidance requiring sponsors of certain clinical studies to submit a "Diversity Action Plan." 

This plan must include:

  • Enrollment Goals: Specific goals for enrolling participants from various demographic groups, including age, sex, race, and ethnicity.
  • Rationale: A clear explanation for why these goals were set.
  • Plan of Action: A detailed description of how the sponsor intends to achieve these goals.

Why is diversity in clinical trials and treatments important?

Underrepresentation in clinical trials can have far-reaching consequences for public health, particularly for marginalized groups. 

Here's a breakdown of how this issue contributes to health disparities:   

Misdiagnosis and delayed treatment

When clinical trials primarily involve a specific demographic, there can be a lack of baseline data on how diseases manifest in other populations. This can result in delayed diagnosis or misdiagnosis, especially for conditions that present differently in underrepresented groups. 

Additionally, treatments developed based on research that excludes certain groups may be less effective for them.   

Key examples of this include asthma inhalers in Latin American populations and heart medications in African American populations.

Limited access to new therapies

Drug approval processes often rely heavily on clinical trial data. If a drug is primarily tested on a specific population, its efficacy and safety may only be fully understood for some groups. This can limit access to potentially life-saving therapies.   

In addition, some insurance companies may be hesitant to cover treatments that have not been extensively studied in diverse populations, further exacerbating disparities.   

Perpetuation of stereotypes and bias

Sometimes, healthcare providers have implicit biases that influence their perceptions of patients from underrepresented groups. This can lead to disparities in treatment recommendations, referrals, and overall care quality.   

Historical mistreatment of marginalized groups in medical research (ex: Tuskegee syphilis studies, experimentation on Indigenous groups, etc.) can lead to distrust and reluctance to participate in clinical trials. This can hinder efforts to improve health outcomes for these communities.   

Increased health risks

Certain diseases may present differently in different populations due to genetic, environmental, and socioeconomic factors. Underrepresentation in clinical trials can limit our understanding of these variations and hinder the development of targeted prevention and treatment strategies.

  • Better Understanding of Health Disparities: Diverse clinical trials allow researchers to understand better how diseases and treatments affect different populations.
  • More Effective Treatments: By including a more comprehensive range of participants, researchers can develop more effective treatments for everyone.
  • Ethical Considerations: Ensuring all populations can access medical research's benefits is ethically essential.

What does this mean for the future of clinical trials?

More representative data:

Diverse clinical trials will allow researchers to understand better how diseases manifest and progress in different populations. This will lead to more accurate diagnoses and tailored treatment plans.

By including a more comprehensive range of participants, researchers can identify potential side effects and drug interactions that may be absent in inhomogeneous study populations. This will ultimately lead to safer and more effective medications.

Increased trust and participation:

Historically, underrepresented groups have been marginalized in medical research. By actively seeking their participation, the FDA's initiative can help rebuild trust and encourage future involvement in clinical trials. This move empowers underrepresented communities to have a voice in developing treatments that directly impact their health.

Advancements in precision medicine:

Diverse clinical trials can accelerate the development of precision medicine, where treatments are tailored to an individual's genetic makeup and other characteristics. This will lead to more effective and targeted therapies. 

In addition, by studying diverse populations, researchers can identify new biomarkers that can predict disease risk and response to treatment, leading to earlier diagnosis and more effective interventions.

Ethical considerations and social justice:

The FDA's initiative is a step towards addressing the historical inequities in healthcare and ensuring everyone benefits from medical advancements. It is ethically imperative to ensure that clinical research is inclusive and benefits all populations, regardless of race, ethnicity, gender, or socioeconomic status.

Putting it all together

Simply put, the FDA's new diversity requirements represent a significant milestone in evolving clinical trials. By promoting inclusivity and diversity, these regulations will ultimately lead to better health outcomes for all.

Stay tuned to this blog for more updates.

The FDA is still accepting public comments on this draft guidance. As the final guidance is developed, we'll update this article with the details, specific requirements for sponsors, and their impact.