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DATACC BY DIME PROJECT

Defining core digital measures for
Pediatric rare disease research & care

Navigate FDA’s and EMA’s rare disease acceleration pathways for regulatory success

FDA and EMA offer numerous programs to support and expedite the development of medicines for rare diseases. Use this guide to FDA & EMA’s rare disease acceleration guide for regulatory success for identification of the most suitable pathways and resources for your pediatric rare disease program.

Use this guide to identify the most suitable pathways and resources for your pediatric rare disease program.

Foundational designations & financial incentives

These are the primary designations that provide financial and market exclusivity benefits.

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Orphan Drug Designation Obtaining incentives (e.g., tax credits, fee waivers) to defray development costs.

Enacted in 1983, this designation provides the foundational regulatory and financial framework for rare disease development. It also established the Orphan Product Grants Program to provide funding.

Real-world precedent: Eteplirsen (Exondys 51) for DMD received ODD and orphan exclusivity, which supported development in a very small mutation-defined subset of DMD patients.

Pilot programs for trial design & evidence strategy

These are hands-on programs to get direct, accelerated FDA feedback on your specific study.

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START Pilot (Support for Clinical Trials Advancing Rare disease Therapeutics)

Gaining rapid, ad-hoc FDA communication (beyond formal meetings) to resolve specific development issues like clinical trial design, control groups, or patient populations.

This program (initiated in 2024) is designed to facilitate novel drug development and generate high-quality data to support an application.

Rare Disease Evidence Principles (RDEP)

Gaining approval for diseases with very small patient populations (and significant unmet need) where traditional trial evidence is difficult to generate.

This program (initiated in 2025) focuses on flexibility for drugs targeting a known genetic driver of the pathophysiology.

Rare Disease Endpoint Advancement (RDEA) Pilot

Collaborating with the FDA to develop and validate novel efficacy endpoints when you have an active IND/pre-IND or are initiating a natural history study. This program (initiated in 2023) is ideal for sponsors who need to create new ways to measure a drug’s effect.
Complex Innovative Trial Design (CID) Paired Meeting Program

Gaining expert statistical feedback on complex adaptive, Bayesian, or other novel clinical trial designs.

While not specific to rare diseases, this program is highly relevant for pediatric rare disease trials where traditional designs are often not feasible.

Strategic hubs & data resources

These are broader FDA centers and platforms that provide expertise, coordinate efforts, and manage data.

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Rare Disease Innovation Hub

Aligning on complex scientific challenges and novel trial approaches, especially for issues common to multiple diseases or classes of diseases.

This Hub (initiated in 2023) enhances collaboration between CDER and CBER, focusing on diseases with small populations or variable natural histories.
CDER Accelerating Rare disease Cures (ARC)

Accessing CDER’s collected expertise on innovative scientific design, regulatory policy, and stakeholder engagement.

This initiative (initiated in 2022) speeds development by consolidating CDER’s expertise and engaging with the entire rare disease community.
CBER Rare Disease Program

Ensuring the patient perspective is integrated into the regulatory review of biologics (e.g., cell and gene therapies).

This program focuses on:

  • Applying flexible and feasible regulatory approaches during review, 
  • Helping craft and implement relevant regulatory policies and procedures, and 
  • Collaborating across FDA centers, other federal agencies, international regulators, and external organizations on cross-cutting activities, programs, and initiatives.

RDCA-DAP (Rare Disease Cures Accelerator-Data and Analytics Platform)

Accessing shared, standardized patient-level data (from trials, registries, RWD) to better characterize a disease or inform clinical trial readiness.

This data platform, run by the Critical Path Institute, provides a centralized infrastructure to standardize and share data in the pre-competitive space.

The EMA and EU framework don’t have as many named “pilots” as FDA, but they too offer powerful levers for rare and pediatric programs.

Foundational designations & pediatric incentives

EU regulatory designations and authorisation pathways that define eligibility for rare-disease and pediatric incentives.

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Orphan Medicinal Product Designation (EU OMP / ODD)

Getting core rare-disease incentives (10–12 years exclusivity, fee reductions, protocol assistance) and signaling EU commitment to your program.

Based on Regulation (EC) 141/2000, orphan designation is granted via EMA’s COMP and confirmed by the European Commission. Incentives include 10-year market exclusivity (extendable to 12 years), reduced fees, and support for evidence generation.

Pediatric Investigation Plan (PIP) under the Pediatric Regulation Structuring your entire pediatric development strategy and unlocking pediatric rewards (including orphan exclusivity extensions).

A PIP is a mandatory development plan for new medicines (including orphans) that defines your pediatric studies, timelines, and waivers/deferrals, reviewed by the PDCO. Successful completion can extend orphan exclusivity from 10 to 12 years or grant other rewards and is a key pre-requisite for EU MAA.

Pediatric-Use Marketing Authorisation (PUMA) Repurposing or reformulating off-patent medicines exclusively for children with meaningful incentives.

PUMA is a dedicated MA for products intended only for pediatric use, typically for off-patent drugs needing pediatric-specific formulations/indications. Incentives include 10 years of data and market protection and partial fee exemptions, making pediatric reformulations viable even in small populations.

Early dialogue & design support

EMA mechanisms for early, iterative scientific and regulatory engagement to de-risk trial design, endpoints, analytics, and innovative approaches.

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Scientific Advice & Protocol Assistance De-risking your development plan, endpoints, and stats package, especially when you have or seek EU orphan designation.

Scientific advice gives EMA feedback on clinical, nonclinical and quality plans; protocol assistance is a special, incentivised version for orphan-designated medicines. Orphan sponsors (and some academic developers) can access fee reductions or waivers.

PRIME (Priority Medicines) Scheme High-potential, high-need rare/pediatric products that already have strong early data and need intense, continuous EMA engagement.

PRIME offers early and enhanced interaction (including a CHMP rapporteur, frequent SA, and iterative feedback) to optimize development and speed evaluation. It is particularly relevant for transformative rare-disease therapies (e.g., ATMPs, gene therapies) that can credibly address major unmet need in small populations.

Innovation Task Force (ITF) Briefing Meetings Very early, free-of-charge discussions on innovative modalities, digital endpoints, platform technologies, and complex analytics.

The ITF is EMA’s early-innovation front door, offering informal, science-focused dialogue on novel technologies (e.g., DHT-based endpoints, gene editing, AI-based diagnostics). These meetings are ideal before formal scientific advice, when you’re still shaping platform, endpoint, or DHT strategies in rare pediatric settings.

Qualification of Novel Methodologies (QoNM) Getting EMA-endorsed, re-usable biomarkers, digital endpoints, or modelling tools that can support your rare-disease trials (and others in the field).

EMA’s qualification pathway can lead to a CHMP opinion or advice on innovative methods (e.g., imaging biomarkers, composite COAs, digital mobility measures) with a defined context of use. They are especially valuable for shared disease platforms or consortia where multiple sponsors may rely on the same endpoint or modelling approach.

Accelerated & flexible marketing-authorisation routes

Regulatory pathways that allow earlier or faster approval for medicines addressing serious or unmet medical needs when traditional evidence generation is constrained by rarity, urgency, or feasibility.

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Conditional Marketing Authorisation (CMA)

Life-threatening rare diseases where you have promising but not yet comprehensive data and can commit to robust post-authorisation studies.

CMA allows earlier approval when benefit-risk is positive but data are incomplete, provided the medicine addresses an unmet medical need and you agree to specific obligations and timelines.

Accelerated Assessment Orphan or PRIME-level products with major public-health interest where speeding CHMP review from 210 to 150 days is critical.

EMA can grant accelerated assessment on request (typically 2–3 months pre-MAA); it’s reserved for medicines addressing unmet needs, often in rare diseases.

“Under Exceptional Circumstances” Authorisation Ultra-rare situations where comprehensive data can never be generated (e.g., extremely small or unstable populations).

EMA may grant MA “under exceptional circumstances” when comprehensive data cannot realistically be obtained, with ongoing obligations and annual reassessment.

Strategic EU hubs, networks & data resources

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ECRIN / EJP RD – Rare Diseases Clinical Trials Toolbox Practical “how-to” guidance for designing and running rare-disease trials in Europe, especially investigator-initiated and multicountry pediatric studies.

The Rare Diseases Clinical Trials Toolbox (ECRIN/EJP RD) provides structured guidance, checklists and examples on design options, registries, data standards, and feasibility in rare diseases. Designed explicitly to address scarce patients, fragmented expertise, and complex trial logistics across multiple EU states.

European Platform on Rare Disease Registration (EU RD Platform & ERDRI)

Making your registry and trial data interoperable across Europe and future-proof for RWE/external control use.

The EU RD Platform (JRC) tackles fragmentation of rare-disease registries, providing tools and the ERDRI “Set of Common Data Elements” to harmonise core data. By aligning to these CDEs, you make it easier to pool registry data, support external controls, and meet regulators’ expectations for interoperable RWD.

European Reference Networks (ERNs) Identifying expert centres and networks to act as high-performing trial sites and scientific partners.

24 ERNs connect over 1,600 specialised centres in 27 Member States and Norway, organised by disease clusters (e.g., ERN-RND, EURO-NMD, ERN Skin, metabolic ERNs). ERNs are ideal partners for site selection, feasibility, expert consensus on endpoints, and cross-border care logistics in pediatric rare-disease trials.

Next steps

Optimize the pediatric rare disease patient journey by integrating objective digital measures and holistic, cross-sector coordination into every stage of care, from initial signal detection to the transition into adulthood.