Clarity Amid Capital Constraints: Reflections on FDA’s CGT Guidances

Contributing authors: Monika Swietlicka, Princapal Consultant and Mike Fusakio, Sr. Consultant.

Following the U.S. Food & Drug Administration’s (FDA) release of three new draft guidances on innovative trial designs, expedited programs, and post-market data collection for cell and gene therapy, most industry conversation has focused on what the guidances mean in practice. From my perspective, the guidances don’t radically change the playbook but, rather, memorializes what many in the industry have already been executing, and FDA is codifying expectations and providing necessary clarity. 

Clarity has always mattered in drug development, but in today’s capital-constrained environment, it has become the deciding factor. Programs that can demonstrate a clear and credible path through regulatory milestones are the ones most likely to secure investment and advancement. 

Here’s what stands out most: 

Trial Design – Flexibility with Guardrails 

FDA’s recognition of adaptive, Bayesian, and master protocol approaches reflects the realities of rare disease and small population studies. Flexibility is welcome, but it’s not a shortcut. Without rigorous endpoints, transparent statistical planning, and early FDA engagement, innovative designs risk undermining the very credibility they’re meant to build. 

CMC – The Double-Edged Sword 

The strongest signal comes in chemistry, manufacturing, and controls (CMC). FDA is clearly communicating that the products brought into first-in-human studies should look like the product that is intended to be commercialized. This requires investing in manufacturing early, even before it’s known if clinical efficacy will hold. It’s a double-edged sword: if efficacy doesn’t materialize, the spending is sunk. But if you wait, early data may not support approval. 

In today’s environment, credible CMC is not an afterthought; it’s the strategic entry point. Without it, you’re not in the game. For investors and boards, this isn’t just cost considerations, it’s risk management. 

Post-Approval – Building for Durability 

FDA’s emphasis on real-world evidence (RWE), registries, and electronic health records is pragmatic. But infrastructure can’t be bolted on at the last minute. Sponsors that plan post-market systems early by integrating data standards, registry design, and patient partnerships into their roadmap will be the ones positioned to deliver therapies that endure beyond approval. 

Closing Reflection 

What is most striking, is how these guidances mirror conversations many of us have been having across the field. They don’t lower the bar; they raise it in a way that demands both creativity and rigor. Execution now begins with vision – imagining therapies as they will exist in the real world and working backwards. That vision is strongest when it integrates science, regulation, and patient perspectives from the start. 

So where does FDA’s guidances fit in today’s capital-constrained market? They bring clarity—the kind that makes the path less vague, more consistent, and better harmonized with what many of us are already practicing and experiencing. And in this environment, clarity is as valuable as currency. It enables teams to execute with confidence, gives investors a sharper view of risk, and, most importantly, strengthens the path to delivering therapies with lasting impact.