

The FDA just finalized three guidances that could reshape who gets into cancer clinical trials. Arbitrary exclusions around performance status, lab values, and washout periods are officially on notice, and biotech companies need to pay attention.
Imagine training for a marathon, showing up on race day, and being told you can't run because your shoelaces are the wrong color. That's roughly what cancer clinical trials have felt like for millions of patients. Arbitrary cutoffs, outdated rules, and copy-paste exclusion criteria have kept people out of potentially life-saving studies for decades.
The FDA just said: enough.
On July 28, the FDA's Oncology Center of Excellence finalized three guidances that target the most common gatekeepers in cancer trial enrollment: performance status (how well a patient functions day to day), laboratory values (blood counts and organ function thresholds), and washout periods and concomitant medications (how long patients must wait after stopping a prior drug, and which other meds disqualify them).
The core message across all three is blunt. If you're going to exclude someone from a trial, you'd better have a real scientific reason. "Because that's how we've always done it" no longer cuts it.
These aren't suggestions scribbled on a napkin. They finalize draft guidances issued in April 2024 and cap a multi-year campaign by the FDA, ASCO, and Friends of Cancer Research to modernize who gets into oncology trials.
Only about 2–8% of adult cancer patients in the U.S. enroll in clinical trials. That's a staggeringly small number for a country that pours billions into cancer research. And the biggest culprit, after simple lack of available trials, is restrictive eligibility criteria. One analysis found that 22% of patients who had a suitable trial nearby still couldn't enroll because the rules screened them out.
The exclusions hit hardest where you'd expect. Older adults, patients with common comorbidities like diabetes or heart disease, people living with HIV: all filtered out at disproportionate rates. As of 2015, a jaw-dropping 84.2% of commercial IND submissions across all therapeutic areas excluded patients with HIV/AIDS. Nearly of commercial cancer trial protocols excluded patients with known active or symptomatic brain metastases, though nearly half of those same protocols specifically allowed treated or stable brain metastases. These blanket bans often had no grounding in the actual safety profile of the drug being tested.

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The result? Trial populations that looked nothing like the real patients who'd eventually take the drug. Think of it like designing a winter coat and only testing it in San Diego. Sure, it works great there. But what about Chicago in January?
Let's walk through the three guidances.
Performance status is oncology's go-to yardstick for how a patient is doing physically, scored on the ECOG scale from 0 (fully active) to 4 (bedridden). Most trials have historically required ECOG 0–1, which effectively shuts out anyone who isn't in relatively good shape. The new guidance pushes sponsors to include patients with broader functional ranges, like ECOG 2 or even 3, unless there's a clear safety reason not to. This alone could open the door for older adults and patients with multiple chronic conditions.
Laboratory values get a similar treatment. Sponsors have long relied on default blood count and organ function cutoffs that exclude patients with mild-to-moderate impairments. The FDA now says those thresholds should reflect the specific drug's safety profile and the biology of the disease, not some inherited spreadsheet from a decade-old protocol. First-in-human studies can start conservative, but the expectation is that criteria loosen as safety data accumulates.
Washout periods and concomitant medications may be the most patient-friendly reform. Many cancer trials require patients to wait weeks (sometimes a month or more) after stopping a prior therapy before they can start the new one. For someone with aggressive, fast-moving cancer, that waiting period can be devastating. The FDA's guidance says time-based washouts should only exist when justified by the drug's pharmacology, and that recovery markers or lab normalization can substitute for arbitrary countdown clocks. On concomitant meds, the message is equally direct: don't ban a patient's blood thinner or antacid unless there's a real drug interaction at play.
If you're a biotech company designing an oncology trial right now, consider this a friendly but firm tap on the shoulder. Legacy exclusion criteria will need scientific justification, and "we copied it from the last protocol" won't satisfy regulators or increasingly assertive IRBs (the institutional review boards that approve trial designs at research sites).
The practical impact varies by modality. Immunotherapy sponsors can expect pressure to be more flexible around baseline illness burden and supportive medications, while still monitoring immune-related risks carefully. Targeted therapy programs with well-characterized safety profiles may be able to loosen washout windows and lab thresholds most aggressively. Cell therapy is trickier; broader eligibility is the goal, but the serious risks of cytokine release syndrome and neurotoxicity mean safety gating will remain tighter and more individualized.
For development teams, the operational trade-offs are real. More heterogeneous patient populations mean more complex stratification, more subgroup analyses, and potentially higher supportive-care costs at trial sites. Sample sizes may need adjustment. But the upside is equally tangible: faster enrollment, better diversity, and results that actually reflect the patients who'll use the drug in the real world.
These three guidances don't exist in a vacuum. They're the latest chapter in a story that started around 2017, when ASCO and Friends of Cancer Research published working-group recommendations for broadening cancer trial access. The FDA turned several of those into final guidances by 2020, covering HIV, brain metastases, organ dysfunction, and prior malignancies. Project Optimus reshaped dose optimization in 2023–2024. The 2022 guidance on including older adults tackled age-based exclusions head-on.
The August 2026 trio fills in the remaining gaps: the everyday eligibility criteria (performance scores, lab numbers, medication rules) that quietly exclude the most patients without anyone flagging the problem.
Taken together, the FDA's message to the oncology world is clear. Design your trials for the patients who actually have cancer, not just the ones who look perfect on paper. The coat needs to work in Chicago, too.
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