Each of the 3 final guidance documents focuses on a specific category of criteria in which the OCE has identified opportunities to expand eligibility.
How does each guidance modify eligibility criteria?
The final guidance on performance status addresses the use of performance status, which is a common measure of how well a patient can perform ordinary tasks and carry out activities of daily living.2 According to the FDA, many trials exclude participants based on 1 of 2 scales: ECOG and Karnofsky.2 The guidance raises questions about applying performance status as a rigid eligibility criterion, noting that some patients may have a low performance status due to cancer making them sick, which could improve once they are enrolled and receiving treatment. Overly strict performance-status cutoffs can therefore exclude patients who might benefit from and safely tolerate an investigational agent.
FDA Trial Eligibility Criteria Guidance: Key Points
- The performance status guidance questions reliance on performance status as a rigid cutoff, noting that a low score driven by cancer may improve after a patient begins treatment.
- The washout and concomitant medications guidance asks sponsors to justify whether time-based washout periods are necessary and makes allowances for patients taking other medications.
- The laboratory values guidance calls for a more scientific, safety-focused approach to the test thresholds used to determine eligibility.
Furthermore, the FDA outlined recommendations for alternative trial designs, which could include prespecified cohorts of patients with lower performance status. Assessments of functional status given during a study could also help better characterize the functional status of patients at baseline and during the course of treatment.
The final guidance on washout periods and concomitant medications encourages sponsors to evaluate whether time-based washout periods are necessary for a given study.3 The document also makes some allowances for patients who are taking other medications, an accommodation intended to avoid excluding patients whose comorbidities require ongoing treatment.
The laboratory values final guidance overviews a more scientific and safety-based approach to the laboratory tests commonly used to determine whether a patient qualifies for a study.4 Rather than defaulting to conventional thresholds, the guidance directs sponsors toward laboratory-value criteria grounded in the safety profile of the investigational drug and the biology of the disease under study, an approach designed to avoid unjustified exclusions.
Additionally, the FDA outlined that eligibility criteria regarding laboratory values should be adjusted based on clinical experience. For example, first-in-human studies of first-in-class drugs or platforms should include conventional eligibility criteria as a precautionary measure, with subsequent studies of drugs or platforms within the same class using adjusted criteria based on prior experience.4
References
- Final guidances to expand participation in cancer clinical trials. FDA. Updated July 27, 2026. Accessed July 27, 2026. https://www.fda.gov/about-fda/oncology-center-excellence/oncology-center-excellence-guidance-documents
- Cancer clinical trial eligibility criteria: performance status. FDA. July 2026. Accessed July 27, 2026. https://www.fda.gov/media/178018/download
- Cancer clinical trial eligibility criteria: washout periods and concomitant medications. FDA. July 2026. Accessed July 27, 2026. https://www.fda.gov/media/178016/download
- Cancer clinical trial eligibility criteria: laboratory values. FDA. July 2026. Accessed July 27, 2026. https://www.fda.gov/media/178013/download