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Tissue Agnostic Treatment - Review
Tissue Agnostic Treatment - Review
Tissue Agnostic Treatment - Review
Development of
Tissue-Agnostic Treatments for
Patients with Cancer
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147
INTRODUCTION
Tissue-agnostic approvals represent a recent development in oncology, with the first approval
occurring in 2017. Currently, the FDA (US Food and Drug Administration) has approved tissue-
agnostic indications for four drugs: pembrolizumab, for microsatellite instability–high (MSI-H)
or mismatch repair–deficient (dMMR) tumors and tumors with high tumor mutational burden
(TMB-H); dostarlimab for dMMR tumors; larotrectinib; and entrectinib. Tissue-agnostic ap-
provals have also been granted by regulatory authorities outside of the United States. The tissue-
agnostic indications are described in detail in the following sections of this review, followed by
sections on ongoing or future clinical development and US regulatory considerations.
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Biology
Scientists at Johns Hopkins University first identified microsatellite instability (MSI) as a target
for anti-PD-1 (programmed death 1) therapy following the observation of a patient with an excep-
tional response to nivolumab among 33 patients with colorectal cancer (CRC) (no other patients
with CRC responded) (Brahmer et al. 2010, Poh 2017, Topalian et al. 2012). This patient experi-
enced a prolonged complete response (CR); following the response, the investigators evaluated the
patient for the presence of MSI (Lipson et al. 2013, Poh 2017). Subsequently, study KEYNOTE-
16 was initiated to investigate the effects of pembrolizumab in patients with MSI-H or dMMR
solid tumors (Le et al. 2015). Although many non-MSI-H tumors may respond to anti-PD-1 ther-
apy, responses in CRC to date (with few exceptions) have been limited to MSI-H tumors (Eng
et al. 2019, Lipson et al. 2013, O’Neil et al. 2017).
dMMR usually occurs due to a mutation (somatic or germline) in one of four genes (MLH1,
MSH2, MSH6, or PMS2). These four genes code for proteins that repair mismatches or certain
insertion/deletion errors during DNA replication or recombination, or through methylation of
the MLH1 promoter (Flaherty et al. 2017, Li 2008). MSI occurs via the accumulation of errors
in short repetitive sequences in DNA called microsatellites (Flaherty et al. 2017, Marcus et al.
2019). MSI-H/dMMR cancers share common histopathologic characteristics, such as a hypermu-
tated phenotype, lymphocytic and other immune cell infiltration, medullary histology, and poorly
differentiated histology (Alexander et al. 2001, Cancer Genome Atlas Netw. 2012, Dolcetti et al.
1999, Grogg et al. 2003, Kim et al. 2013, Lin et al. 2015, Ruemmele et al. 2009, Shia et al. 2008,
Shia et al. 2003, Timmermann et al. 2010, Zhao et al. 2014). MSI-H cancers are TMB-H, which
has been linked to an increased probability of expressing neoantigens, some of which may serve
as targets for the immune system (Gubin et al. 2014, Howitt et al. 2015, Schumacher & Schreiber
2015). This mutation burden in MSI-H cancers is among the highest of any anatomically or his-
tologically defined cancers, including melanoma or non-small-cell lung cancer (NSCLC), which
have high mutation burden due to UV radiation or smoking and have derived the most benefit
from immune checkpoint inhibitor (ICI) therapy (Alexandrov et al. 2013, Vogelstein et al. 2013,
Yarchoan et al. 2017). Although MSI-H/dMMR tumors may express neoantigens, upregulation of
the PD-1 ligand may occur, inhibiting active T cell–mediated killing of the tumor cells. ICI thera-
pies, such as PD-1 inhibitors, can block the PD-1/PD-LI (programmed death ligand) interaction,
resulting in immune cell killing of tumor cells (Keytruda® 2020, Opdivo® 2017).
The incidence of MSI-H/dMMR varies across tumor types with rates of over 15% in endome-
trial cancer to less than 1% among glioblastomas or soft-tissue cancers (Le et al. 2017). Further-
more, across many cancer types, incidence of MSI-H/dMMR is stage specific, generally (but not
always) with lower rates of MSI in the metastatic setting (Le et al. 2017). In CRC, approximately
Testing
The optimal testing strategy for MSI-H/dMMR may depend upon the clinical scenario, including
frequency of MSI-H/dMMR in a particular cancer population and the availability of tissue. For
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example, challenges in obtaining sufficient tissue (e.g., in cholangiocarcinoma) may preclude the
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ability to conduct extensive tumor testing. In such scenarios, it may be preferable to use a single
testing platform such as next-generation sequencing (NGS) to identify several potential aberra-
tions at once. Multiple studies have reported high (e.g., >95%) sensitivity, specificity, or concor-
dance using different NGS tests to detect MSI (Kautto et al. 2017, Middha et al. 2017, Salipante
et al. 2014, Trabucco et al. 2019, Zhu et al. 2018). In addition to assessing microsatellites, NGS
panels may also directly sequence the four proteins involved in mismatch repair.
In patients with CRC, mismatch repair status has been assessed for decades using immunohis-
tochemistry (IHC) for the dMMR proteins. Even prior to immunotherapy, testing was conducted
either to assess patients for Lynch syndrome (a cancer predisposition syndrome) or to assist
in treatment decisions following complete resection. In patients with CRC, for example, the
American Society of Clinical Oncology (ASCO) guidelines recommend testing for germline
mutations if there is loss of MLH1/PMS2 and the absence of a BRAF mutation or if MLH1
promotor methylation is not identified (Stoffel et al. 2015). Loss of other proteins (MSH2, MSH6,
or PMS2) would also trigger a recommendation for germline genetic testing (Stoffel et al. 2015).
In addition to IHC- and NGS-based tests, traditionally, MSI was assessed using polymerase
chain reaction (PCR)-based methodology that focused on predefined microsatellites (Boland
et al. 1998). In general, PCR and IHC selected concordant populations with respect to
MSI-H and dMMR status (Bartley et al. 2012); however, differences in test results can occur due
to technical factors (e.g., problems with staining, fixation, or processing for IHC) or for uncom-
mon biological reasons (Bartley et al. 2012). For example, some patients with MSH6 germline
mutations are microsatellite stable when assessed via PCR due to a functional redundancy in the
MMR system. Depending on the PCR assay selected (and selected microsatellites), there have also
been reports of differences in positivity in MSI-H results when comparing CRC with endome-
trial tumors (Wang et al. 2017). There are also reports of patients with missense mutations (e.g.,
in MLH1 or MSH6) that produce nonfunctional proteins which stain positive by IHC; however,
the tumors are MSI-H when assessed by PCR (Hampel et al. 2007, Klarskov et al. 2011, Pino &
Chung 2011, Zhang & Li 2013).
Given the factors described above, and the need for accurate test results across a wide spec-
trum of tumors, approval of pembrolizumab for MSI-H/dMMR tumors included postmarketing
commitments to support the availability of an immunochemistry assay to detect dMMR, as well
as a nucleic acid–based assay to detect MSI.
Clinical Data
The initial results of trial KEYNOTE-16 in 2015 reported an immune-related objective response
rate (ORR) for pembrolizumab of 40% (4 of 10 patients) for dMMR metastatic CRC versus 0%
(Marcus et al. 2019). The latter study also enrolled separate cohorts of rare tumor types. The
tissue-agnostic approval of pembrolizumab for the treatment of advanced and refractory MSI-
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H/dMMR solid tumors was based on data from these three studies, as well as on data from
11 retrospectively identified patients with PD-L1-positive (and MSI-H/dMMR) solid tumors
from KEYNOTE-12 and KEYNOTE-28. In total, the approval of pembrolizumab for patients
with MSI-H/dMMR solid tumors was based on data from 149 patients (90 with CRC and 15 total
tumor types), which showed an independently reviewed ORR of 39.6% (95% CI: 31.7–47.9) with
7% of patients experiencing a CR (Marcus et al. 2019). Duration of response was 6 months or
longer in 78% of responding patients (Marcus et al. 2019).
Since the May 2017 approval of pembrolizumab, other results of immune checkpoint inhibition
in patients with MSI-H/dMMR cancers have been published. For pembrolizumab, Le et al. (2020)
reported updated results of KEYNOTE-164 that followed 124 patients with CRC for a median
of 31.3 months. The reported response rate per independent central review was 33% with 6%
experiencing a CR and median duration of response was not reached. Marabelle et al. (2020b)
reported updated results of KEYNOTE-158 that followed 233 patients with 27 tumor types other
than CRC and a median follow-up of 13.4 months. The reported response rate was 34.3% with
9% of patients experiencing a CR. The authors stated that in a Kaplan-Meier analysis, 77.6% of
responding patients had response durations of 24 months or longer (Marabelle et al. 2020b).
A notable finding from the update of the KEYNOTE-158 trial was that 0 of 13 patients with
primary brain cancers responded to pembrolizumab. Glioblastoma may be unique in that MSH6
mutations, and hypermutant phenotype, appear to occur in a subset of glioblastomas during temo-
zolomide therapy (Cancer Genome Atlas Res. Netw. 2008, Maxwell et al. 2008, McCord et al.
2020, Yip et al. 2009). As these mutations are not present pretreatment, and given they may be
heterogeneously distributed in the tumor, patients with these mutations may have a lower proba-
bility of responding compared to patients with de novo dMMR tumors. Durable responses to ICIs
have been reported in pediatric patients with congenital dMMR gliomas, where the hypermutant
phenotype was present prior to temozolomide (AlHarbi et al. 2018, Bouffet et al. 2016). Based on
the emergence of these data, pembrolizumab labeling was updated in June 2020 to recommend
testing for MSI/dMMR in primary tumor specimens obtained prior to initiation of temozolomide
(Keytruda® 2020). Additional data to assess central nervous system tumors are expected.
The benefit of PD-1 inhibition across MSI-H tumors has also been demonstrated in tumor-
specific studies including in a randomized trial in advanced MSI-H/dMMR CRC. KEYNOTE-
177, a randomized controlled trial, demonstrated an improvement in progression-free survival
(hazard ratio: 0.60; 95% CI: 0.45–0.80) when pembrolizumab was compared to standard-of-care
chemotherapy in the first-line treatment of patients with metastatic CRC (Andre et al. 2020).
This led to an FDA approval of pembrolizumab in the first-line metastatic setting for patients
with MSI-H/dMMR CRC in 2020.
cer based on data from 71 patients demonstrating an independently confirmed response rate
of 42% (95% CI: 31–55), with median duration of response not yet reached with a median
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follow-up for duration of response of 14.1 months ( Jemperl® 2021, Oaknin et al. 2020). Other
studies have reported response rates of 25% or more in patients with endometrial cancer or
in patients with different tumor types who have received different anti PD-(L)1 inhibitors
( J. Chen et al. 2020, Konstantinopoulos et al. 2019). Finally, in August 2021, dostarlimab-gxly
also received accelerated approval for dMMR recurrent or advanced solid tumors based on data
from 209 patients with 15 different tumor types (ORR 41.6%, 95% CI: 34.9–48.6).
tified cases in children with infantile fibrosarcoma, a rare cancer commonly associated with the
ETV6-NTRK3 fusion (Pavlick et al. 2017). Other extremely rare cancers in which the presence of
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NTRK fusions is generally considered synonymous with the disease include mammary analog se-
cretory tumors, secretory breast cancer, and congenital mesoblastic nephroma (Cocco et al. 2018).
Testing
NTRK fusions can be detected using different methodologies including fluorescence in situ hy-
bridization (FISH), IHC, reverse transcription PCR, or massive parallel sequencing, including
RNA-based assays (Demetri et al. 2020). Recommendations for testing may depend on the pa-
tient’s underlying tumor type, availability of tissue, or other factors. In general practice, testing
tumors that commonly harbor NTRK fusions such as infantile fibrosarcoma is recommended in
all settings, and a negative test may need to be followed up with testing using a different method-
ology (Demetri et al. 2020).
In pivotal clinical trials of larotrectinib and entrectinib, patients were identified using a central
lab (entrectinib) or local labs (entrectinib and larotrectinib) using FISH or other nucleic acid–
based tests. Due to the rarity of NTRK fusions and unmet need (with identification at local sites
with referral to clinical trial sites), the complexity of developing the companion diagnostic devices
(e.g., due to multiple fusion partners), and clinical results, the FDA approved larotrectinib and en-
trectinib without contemporaneously approving a companion diagnostic device. In each case, post-
marketing commitments were issued to support the future use of a companion diagnostic device.
Clinical Data
Following an early report of a patient with an NTRK-fusion soft-tissue sarcoma with widespread
pulmonary metastases responding to larotrectinib (Doebele et al. 2015) and early reports of
patients with NTRK1-fusion-positive lung or CRC responding to entrectinib (Farago et al. 2015,
Sartore-Bianchi et al. 2016), multiple reports have described antitumor responses in NTRK-fusion
tumors to either larotrectinib or entrectinib (Doebele et al. 2020; Drilon et al. 2017, 2018; DuBois
et al. 2018; Laetsch et al. 2018). Labeling for the initial approval of larotrectinib described efficacy
results among 55 patients analyzed across three clinical trials (LOXO-TRK-14001, SCOUT,
NAVIGATE); however, the FDA review also assessed preliminary efficacy data in additional
patients with NTRK-fusion tumors (CDER 2018, Viktravi® 2018). More than 10 solid tumor
types and 15 different NTRK fusions were represented among the first 55 patients. The most
common tumor types enrolled were salivary gland (22%), soft-tissue sarcoma (20%), infantile
fibrosarcoma (13%), and thyroid cancer (9%) (Viktravi 2018). The ORR among the 55 patients
per a blinded independent review committee was 75% (95% CI: 61–85), with 22% of the 55
experiencing a CR (Viktravi 2018). Response duration was at least 6 months in 73% of patients.
vary gland (13%), breast cancer (11%), thyroid cancer (9%), and CRC (7%) (Marcus et al. 2021,
Rozlytrek® 2019). The ORR among the 54 patients per a blinded independent review committee
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was 57% (95% CI: 43–71), with 7.4% of the 54 experiencing a CR (Rozlytrek 2019). Response
duration was at least 6 months in 68% of patients (Rozlytrek 2019).
The NTRK-fusion approvals for larotrectinib and entrectinib differ in that entrectinib is ap-
proved for patients age 12 years and older whereas larotrectinib is approved for adult and pedi-
atric patients. This difference was due to the lack of information regarding an appropriate dose in
younger children for entrectinib (Marcus et al. 2021).
Other NTRK-fusion inhibitors are also under development, including drugs designed to treat
patients with acquired resistance to prior NTRK-fusion inhibitors (Lin et al. 2019). In some pa-
tients, this resistance appears to occur via acquired kinase domain mutations, including solvent-
front or gatekeeper mutations (Drilon 2019).
Biology
TMB represents the overall somatic genomic burden of mutations in a tumor. Multiple reports
have described an association between increasing mutation burden and tumor responses to ICIs,
either within specific tumors such as NSCLC and melanoma or across multiple tumor types (E.X.
Chen et al. 2020, Lu et al. 2020, Rizvi et al. 2015, Rozeman et al. 2021, Samstein et al. 2019, Snyder
et al. 2014, Wang et al. 2019, Yarchoan et al. 2017). A high TMB within a tumor has been linked to
an increased probability of expressing neoantigens, some of which may serve as targets for the im-
mune system (Gubin et al. 2014, Howitt et al. 2015, Schumacher & Schreiber 2015). A threshold of
10 mut./Mb has been identified in literature and in multistakeholder meetings either as a thresh-
old for an increased chance of forming a neoantigen or as a threshold that could be used to study
response to ICIs (Friends Cancer Res. 2020, Schumacher & Schreiber 2015). In the absence of
immunotherapy, it has been reported that TMB does not predict improvements in overall survival
(OS) across tumor types, albeit data were limited for some of the tumor types (Shao et al. 2020).
Clinical Data
The approval of pembrolizumab for the TMB-H indication was based on data from a prospectively
planned retrospective analysis of patients enrolled in a multicohort clinical trial (KEYNOTE-158)
www.annualreviews.org • Tissue-Agnostic Cancer Treatments 153
Table 1 Response rates by tumor type in the application supporting the approval of
pembrolizumab: KEYNOTE-158
Tumor type N ORR (95% CI)
TMB ≥ 10 mut./Mb F1CDx
Endometrial 15 47 (21–73)
Neuroendocrine 5 40 (5–85)
Cervical 16 31 (11–59)
Small-cell lung 34 29 (15–47)
Vulvar 12 17 (2–48)
Anal 14 7 (0.2–34)
Salivary 3 PR, SD, PD
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Thyroid 2 2 CRs
Mesothelioma 1 PD
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Abbreviations: 95% CI, 95% confidence interval; CR, complete response; F1CDx, FoundationOne companion diagnostic;
Mb, megabase; mut., mutations; ORR, overall response rate; PD, progressive disease; PR, partial response; SD, stable
disease; TMB, tumor mutation burden.
and supportive tumor response data from patients with whole-exome sequencing (WES)-derived
TMB scores across several global studies that assessed different tumor types. KEYNOTE-158
was an open-label, nonrandomized, multicohort trial of pembrolizumab for several types of
unresectable or metastatic cancers that had progressed following prior treatment in patients
who had no satisfactory alternative treatments (Marabelle et al. 2020a). TMB was assessed using
the F1CDx test and the cut-off for TMB-H was determined prior to testing patient tissue
samples from KEYNOTE-158. Among the 102 patients with TMB-H tumors (≥10 mut./Mb)
in KEYNOTE-158, the independently reviewed ORR was 29.4% (95% CI: 20.8–39.3) versus
6.3% (95% CI: 4.6–8.3) in the 688 patients with TMB-low tumors (<10 mut./Mb). Responses
were observed across eight tumor types (Table 1). Based on the data cutoff, median duration
of response had not been reached (Kaplan-Meier estimation) in the TMB-H population (range:
2.2+ to 34.8+ months). In an exploratory analysis using prespecified cutoffs, antitumor responses
appeared to increase with increasing TMB values among patients with TMB-H tumors: The
response rate was 13% (95% CI: 4–29) for TMB ≥ 10 mut./Mb and TMB < 13 mut./Mb patients
(32) and 37% (95% CI: 26–50) for TMB ≥ 13 mut./Mb patients (70).
The biologics licensing application (BLA) also included tumor response data obtained from
12 studies across 24 tumor types that were sequenced using WES (Cristescu et al. 2020). The ap-
plicant determined that 175 mut./exome was approximately equivalent to 10 mut./Mb using the
F1CDx test. A total of 1,772 patients with WES TMB results had received pembrolizumab as a
single agent, with 433 being TMB-H. Among patients who were both TMB-H and microsatellite
Prostate 11 9 (0–41)
Other 14 21 (5–51)
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Abbreviations: 95% CI, 95% confidence interval; HNSCC, head and neck squamous cell carcinoma; Mb, megabase; mut.,
mutations; NSCLC, non-small-cell lung cancer; ORR, overall response rate; TMB, tumor mutation burden; TNBC, triple-
negative breast cancer; WES, whole-exome sequencing.
stable, ORR per independent review was 30.3%, versus 52.4% among 21 patients with MSI-H
tumors, which were all TMB-H. In specific tumor types, ORR was higher in TMB-H tumors
compared with the TMB-low tumors (Table 2). Additionally, the WES data set included tu-
mors not represented in the KEYNOTE-158 data set, including head and neck squamous cell
cancer (HNSCC), gastric cancer, triple-negative breast cancer, and bladder or urothelial cancer.
Finally, the application also contained supportive exploratory analyses of ORR, progression-free
survival (PFS), and OS when subgrouped by WES TMB in three trials of pembrolizumab versus
chemotherapy (Cristescu et al. 2020).
Following the approval of pembrolizumab for TMB-H tumors, data related to immunotherapy
treatment across TMB-H tumors have been published. One group used a different assay than was
used to support the FDA approval to assess TMB status and concluded that survival was not dif-
ferent between TMB-H and TMB-low tumors among patients with mismatch repair–proficient
CRC treated with various ICIs (Rousseau et al. 2021). They also found that the upper bounds of the
95% CIs for the hazard ratios for death comparing treatment effects in TMB-H versus TMB-low
tumors across multiple tumor types crossed one; these were reported as TMB-insensitive tumors.
Importantly, these were not randomized analyses and there were important potential differences
between TMB-H and TMB-low patients (e.g., differences in tumor sidedness for CRC). Addi-
tionally, there were limitations in the numbers of patients in the analyses (e.g., 13 patients with
TMB-H and microsatellite-stable CRC), and the point estimates for each of the tumor types were
less than one (favoring the TMB-H groups). Another publication reported that TMB-H tumors
et al. 2021). Although the authors found that the response rate among tumor types with a suffi-
cient sample size was generally higher among TMB-H tumors, they indicated that the variability
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of response rate by tumor types may favor different TMB thresholds for different tumor types.
Ultimately, additional data are necessary to verify and describe the effects of pembrolizumab
as a treatment for patients with TMB-H tumors. The FDA approved pembrolizumab as an ac-
celerated approval for patients with unmet medical need (without satisfactory available therapy)
with a requirement to collect additional prospective data that will allow for an assessment of the
drug’s effects in patients with different tumor types. As with any accelerated approval, the possi-
bility exists for future modification or withdrawal of the indication. For the TMB-H indication,
this could include an assessment of whether a different TMB threshold would be appropriate, or
whether specific tumor information is warranted. Although there may be tumor-specific effects
(e.g., mutations caused by UV light or MSI may have a differential ability to result in a neoanti-
gen), ultimately, for an approval, an effect at a specific cut-point (i.e., 10 mut./Mb) should predict
sufficient benefit across the spectrum of tumors (understanding benefit may be greater for some
tumors than others).
Testing
Concomitant with the approval of pembrolizumab for the TMB-high indication, the FDA
approved F1CDx to select patients for treatment with pembrolizumab. DNA isolated from
formalin-fixed paraffin-embedded tumor tissue is used to conduct testing. The original approval
of the F1CDx as a companion diagnostic occurred on November 30, 2017 for the detection of
genetic mutations for the selection of 1 of 15 FDA-approved therapies for NSCLC, melanoma,
breast cancer, CRC, and ovarian cancer. Several premarket approval supplements have been
approved since the original approval of F1CDx to select for treatment of patients with additional
drugs. To assess TMB, the F1CDx test counts all synonymous and nonsynonymous variants
present at the 5% allele frequency or greater after filtering. For the review of the CDx, the
applicant submitted data from KEYNOTE-158, as well as concordance data using WES and
repeatability/reproducibility studies.
In addition to F1CDx, other in vitro diagnostic tests include an assessment of TMB as part of
their platforms, which can be assessed using different methods including NGS and WES. These
tests are not approved for selection of patients for treatment with pembrolizumab based on TMB.
Importantly, the TMB value and its correlation to treatment response can be influenced by nu-
merous factors, including but not limited to sample type, tumor heterogeneity, input material
quality, capture region, panel size, depth of sequencing, mutation types, whether germline or tu-
mor mutation variants are excluded, cut-offs, and the source of reference transcripts (Stenzinger
et al. 2019). One multistakeholder effort to standardize TMB assessed results of 11 laboratories
using distinct NGS panels. The analysis found variability between the assessments and increased
FUTURE DEVELOPMENT
Trials such as NCI-MATCH and ASCO TAPUR (Targeted Agent and Profiling Utilization Reg-
istry) are investigating the use of multiple drugs across different biomarkers using a single pro-
tocol with multiple single-group subprotocols. These innovative trial designs can facilitate effi-
cient assessment of the effects of drugs across several tumor types, including indications defined
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on the basis of a biomarker and agnostic to tumor site or histology (FDA 2018). For example,
published reports from the NCI-MATCH trial to date include results of ado-trastuzumab em-
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tissue-agnostic approvals that are being investigated in tissue-agnostic clinical trials include RET,
ALK, FGFR, DNA repair deficiency, and ROS1 (Seligson et al. 2021). Other targets are expected
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REGULATORY CONSIDERATIONS
To provide a scientific rationale supporting a tissue-agnostic approval there should be strong evi-
dence of a molecular aberration–drug match, allowing for extrapolation to diverse tumors, and an
understanding of resistance mechanisms. Also needed is for the effects across multiple histologies
to be homogeneous, without one tumor type driving response. In addition, to allow for the use
of response rate as an endpoint, and if an accelerated approval is pursued, there should be an ad-
vantage compared to alternatives, for example, with a dramatic effect in an indication with unmet
need. Tissue-agnostic approvals to date have been granted under the accelerated approval path-
way with requirements that sponsors enroll additional patients to verify and describe the effects of
these drugs in patients with various biomarker-positive tumor types. It is important to stress that
these accelerated approvals have been granted in settings where patients do not have adequate
available therapy; hence, the approvals address an unmet medical need with the understanding
that uncertainties will be further investigated in the postapproval setting.
The approvals have been based on results in nonrandomized trials that assessed effects on
durable ORRs. Response rates to a drug can be attributed to the drug in a nonrandomized trial
because, in general, tumors do not shrink in the absence of therapy (Lemery et al. 2017). Although
randomized trials have clear strengths in that they provide a comparative assessment of risks and
benefits and are necessary to assess effects on important time-to-event endpoints such as OS and
PFS, randomized trials would be difficult to conduct in the tissue-agnostic setting due to the
heterogeneity of tumor types and resulting rarity in the biomarker-positive populations. As an
example, although both infantile fibrosarcoma and NTRK-fusion adult lung cancers harbor NTRK
fusions that render them susceptible to entrectinib or larotrectinib, these would not be expected to
behave as the same disease with respect to non-TRK-directed treatments or prognosis. For NTRK-
fusion tumors, given the unprecedented durable responses in most patients (including a subset
with CRs), the rarity of the fusions, and the unmet medical need, it was not considered feasible
or ethical to require randomization to either a placebo or ineffective cytotoxic chemotherapy.
Although the response rates in MSI-H or TMB-H tumors were not as high as observed with
NTRK inhibitors, the FDA considered the totality of evidence to support approval including the
known safety profiles of pembrolizumab, broad efficacy across multiple tumor types, complete
responses in a subset of patients, and the long durations of response.
An important concept for the tissue-agnostic approach is an understanding that some hetero-
geneity may still exist between tumors regarding the treatment effects of the drug. For example,
numerically, response rates of pembrolizumab for CRC appeared lower than for non-CRC
158 Lemery et al.
tumors. Such differences, if related to biological factors, could occur due to multiple reasons
including differential upregulation of other immune checkpoints or differential effects of prior
therapies on immune function. What is important for the tissue-agnostic approach is that it is
reasonably likely that the effect in the different tumor types predicts or provides benefit across tu-
mor types considering the observed heterogeneity of effects of the drug, which may be real or due
to chance. If, however, there is clear resistance of one or more tumor types, then either the drug
should not be considered for a tumor-agnostic approach or labeling may need to address the lack
of responses/benefit in a tumor type. This information may be collected after approval, and thus
indications for tissue-agnostic approvals may be subsequently modified as information emerges.
Of the approvals to date, only two (TMB approval and dostarlimb-gxly) were supported by a
concurrently FDA-approved test to identify patients. In the cases where a contemporaneous ap-
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proval of a companion diagnostic device was not possible, it was determined that the benefit out-
weighed the risk of approving without a companion diagnostic. Although not FDA approved as a
Annu. Rev. Cancer Biol. 2022.6:147-165. Downloaded from www.annualreviews.org
companion diagnostic, testing of tumor specimens for MSI-H with a PCR-based test or dMMR
with an IHC-based test was used for decades to guide chemotherapy use in patients with re-
sectable CRC. For NTRK, the rarity of the mutation and the challenges with enrolling based on
a central test prevented contemporaneous approval. For all these cases there was agreement with
the companies to develop a test as part of postmarketing commitments. As more biomarkers are
determined to have therapeutic value across tumors, the need for tests (e.g., NGS platforms) that
can accurately assess multiple biomarkers at the same time will be increasingly important. Never-
theless, there may also be value in having accurate IHC tests in some situations (e.g., MSI-H for
CRC), as these are widely available and can produce a result with limited turnaround time.
For all the tissue-agnostic approvals, there have been certain tumor types that are more rep-
resented in the approval data sets. Furthermore, given caps on the number of patients in clinical
trials for certain tumor types, the number of patients enrolled in clinical trials to support a market-
ing application may not mirror the distribution of patients with the biomarker in the real-world
setting. Nevertheless, tissue-agnostic approvals were justified based on scientific and mechanistic
evidence in the context of an effect considered reasonably likely to predict clinical benefit. Uncer-
tainties in less represented tumor types can be balanced against the unmet medical need for the
populations, as well as addressed by the requirement to obtain additional data in more diverse tis-
sue types in the postmarketing requirements. Ultimately the indication may be modified through
emerging data, but with initial broad labeling, more patients with incurable malignancies without
satisfactory treatment options may benefit during the time the data are collected.
DISCLOSURE STATEMENT
The authors are not aware of any affiliations, memberships, funding, or financial holdings that
might be perceived as affecting the objectivity of this review.
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