Breakthrough Therapy Designation is among the most sought-after FDA expedited programs, but sponsors often overestimate what it provides. How BTD relates to priority review, rolling submission and the review clock bears directly on submission planning, resourcing and launch forecasting. The Commissioner's National Priority Voucher program now gives teams a second, newer route to faster FDA action, and the two need to be weighed against each other.
The analysis below looks at notable FDA approvals since 2020 that carried BTD, using CDER's annual novel-approval counts and cumulative BTD approval data. It covers how often BTD products also received priority review, how submission-to-action timelines played out, and where BTD products still received complete response letters. It then compares BTD with the Commissioner's National Priority Voucher program on eligibility, the benefits each provides, and when each applies.
Breakthrough Therapy Designation since 2020: notable approvals, review timelines, and how BTD compares with the Commissioner's National Priority Voucher
Key findings
- Breakthrough Therapy Designation (BTD) remains a regular feature of FDA novel approvals. CDER reports that 14 of 50 novel approvals in 2021 (28%), 13 of 37 in 2022 (35%), 9 of 55 in 2023 (16%), 18 of 50 in 2024 (36%) and 15 of 46 in 2025 (33%) carried BTD 223224222217218. CDER counts 337 cumulative BTD approval actions through December 31, 2025, and another 15 in the first half of 2026. These counts include supplements, so they are approval actions, not distinct products 215220.
- BTD does not confer priority review. FDA guidance states that a BTD product is eligible for priority review only if it separately meets the priority review criteria when the application is submitted 56. Most BTD approvals reviewed here did receive priority review, but several went through on a standard clock (Olinvyk, Camzyos, Krazati, Rivfloza, Pombiliti + Opfolda, Redemplo, Jideytro, Leqselvi) 1204140154688482.
- In practice, BTD shortened the time before submission more than it shortened the review. Most BTD products used rolling submission, and many BTD/priority applications reached action about 8 months after the final component arrived, which matches the priority NME clock of 60-day filing plus 6 months 9115923821221014189.
- BTD does not protect against a complete response. Kisunla, Tzield and Olinvyk each needed two cycles, and FDA rescinded or moved to rescind BTD for Fintepla, Leqselvi and Olinvyk 18319817511782177.
- The Commissioner's National Priority Voucher (CNPV), announced June 17, 2025, works differently. It is a nontransferable voucher with a target of 1 to 2 months from filing to action, reviewed through a "tumor board-style" council, and eligibility rests on five national-priority criteria that include domestic manufacturing and affordability 373836. A Hernexeos (zongertinib) first-line expansion was approved 44 days after a January 13, 2026 filing, and Foundayo (orforglipron) 50 days after filing 4244. Hernexeos's original approval was August 8, 2025.
What BTD provides, and what it does not
BTD may be granted to a drug intended to treat a serious condition when preliminary clinical evidence indicates it may demonstrate substantial improvement over available therapy on one or more clinically significant endpoints. This is not the approval standard 4762. The preliminary evidence generally comes from Phase 1 or Phase 2 trials. Comparative data are preferred, but a persuasive single-arm study against a well-documented historical control can suffice when the difference is large 54.
Designation brings all Fast Track features plus 4855:
- intensive FDA guidance on an efficient development program, from as early as Phase 1;
- organizational commitment, meaning senior managers and experienced review staff are involved, with a cross-disciplinary project lead where appropriate;
- rolling review of portions of the marketing application before the full application is submitted.
Sponsors may request BTD with the IND or at any time afterward. FDA prefers to receive the request before the trials that will provide primary efficacy evidence begin, and ideally no later than the end-of-phase 2 meeting. FDA responds within 60 calendar days 4959221. Designation can be rescinded if later data no longer support it, for example when a newly approved therapy removes the "substantial improvement" margin or a confirmatory trial fails 5163.
Priority review is a separate decision made at filing. It applies when the drug, if approved, would significantly improve the safety or effectiveness of treatment for a serious condition 91. For NME NDAs and original BLAs, FDA's goal is to act on 90% of applications within 6 months of the 60-day filing date under priority review, compared with 10 months under standard review. Non-NME NDAs run from receipt 91. These are goals for FDA to review and act, and the action may be an approval or a complete response letter 91. One Division's BTD review states directly that BTD "does not guarantee priority-review status" 67.
Notable BTD approvals since 2020
The table shows a selection of original NDA/BLA approvals where the FDA review record explicitly documents BTD.
| Product (active ingredient) | Indication | Approval | Review designation | Review-process notes |
|---|---|---|---|---|
| Tepezza (teprotumumab-trbw) | Active thyroid eye disease | Jan 21, 2020 122 | Priority 122 | BTD granted July 29, 2016 122 |
| Tabrecta (capmatinib) | MET exon 14 skipping NSCLC | May 6, 2020 115 | Priority 115 | Two BTDs (2L/3L and 1L); rolling review granted Sept 2019 115 |
| Fintepla (fenfluramine) | Dravet syndrome seizures | Jun 25, 2020 117 | Priority 117 | Refuse-to-file, resubmission, then major amendment; BTD rescinded 213117 |
| Olinvyk (oliceridine) | Acute pain | Aug 7, 2020 170 | Standard 120 | Complete response in 2018; approved on second cycle 175 |
| Inmazeb / Ebanga | Ebola virus infection | Oct 14 and Dec 21, 2020 125111 | Priority 125111 | Both used rolling review 125111 |
| Evkeeza (evinacumab-dgnb) | HoFH | Feb 11, 2021 118 | Priority 118 | Rolling BLA in three segments 118 |
| Rybrevant (amivantamab-vmjw) | EGFR exon 20 NSCLC | May 21, 2021 108 | Priority 108 | Priority review granted Jan 2021 108 |
| Tezspire (tezepelumab-ekko) | Severe asthma | Dec 17, 2021 3 | Priority 3 | Approved in first-round assessment 3 |
| Camzyos (mavacamten) | Obstructive HCM | Apr 28, 2022 230 | Standard 19 | BTD, but not priority review; NDA received Jan 28, 2021; action on the Apr 28, 2022 goal date 231230 |
| Pluvicto (Lu 177 vipivotide tetraxetan) | PSMA+ mCRPC | Mar 23, 2022 189 | Priority 14 | Submitted Jul 29, 2021 14 |
| Tecvayli (teclistamab-cqyv) | RRMM, 4+ prior lines | Oct 25, 2022 161 | Priority 1 | REMS major amendment extended goal date by 3 months 163 |
| Tzield (teplizumab-mzwv) | Delay of stage 3 T1D | Nov 17, 2022 197 | Priority 5 | Complete response in 2021 over PK comparability and CMC 198207 |
| Krazati (adagrasib) | KRAS G12C NSCLC | Dec 12, 2022 187 | Standard 4 | RTOR participation granted 4 |
| Leqembi (lecanemab-irmb) | Alzheimer's disease | Jan 6, 2023 238 | Priority 159 | Rolling BLA completed May 6, 2022 159 |
| Zurzuvae (zuranolone) | Postpartum depression | Aug 4, 2023 144 | Priority 157 | Approved for postpartum depression, not MDD. FDA issued intent to rescind BTD in 2021 but did not rescind 144 |
| Rezdiffra (resmetirom) | NASH with fibrosis | Mar 14, 2024 210 | Priority 148 | BTD, rolling review and priority review all granted in 2023 148 |
| Kisunla (donanemab-azbt) | Alzheimer's disease | Jul 2, 2024 179 | Priority 81 | Complete response in Jan 2023 (safety database); resubmitted 183 |
| Leqselvi (deuruxolitinib) | Alopecia areata | Jul 25, 2024 82 | Standard 82 | BTD rescinded Mar 14, 2024; review moved to a standard clock 82 |
| Bizengri (zenocutuzumab-zbco) | NRG1+ PDAC and NSCLC | Dec 4, 2024 65 | Priority 65 | Rolling submission agreed 65 |
| Yeztugo (lenacapavir) | HIV-1 PrEP | Jun 18, 2025 73 | Priority 73 | Approved one day before the Jun 19, 2025 goal 73 |
| Inlexzo (gemcitabine intravesical) | BCG-unresponsive HR-NMIBC | Sep 9, 2025 89 | Priority 89 | Rolling review and RTOR both granted 89 |
| Jascayd (nerandomilast) | Idiopathic pulmonary fibrosis | Oct 7, 2025 76 | Priority 76 | BTD granted 2022 on Phase 2 data 76 |
| Avlayah (tividenofusp alfa-eknm) | MPS II | Mar 24, 2026 77 | Priority 77 | Major amendment extended goal by 3 months 86 |
| Jideytro (zidesamtinib) | ROS1+ NSCLC after 2+ TKIs | Jul 22, 2026 84 | Standard 84 | RTOR submission; priority review requested but not recorded 84 |
The pattern holds across therapeutic areas. Oncology BTDs often pair designation with Real-Time Oncology Review (RTOR) or rolling submission (Krazati, Rezurock, Inlexzo, Jideytro) 4118984. Rare-disease and non-oncology BTDs mostly rely on rolling BLA/NDA segments (Evkeeza, Nexviazyme, Xenpozyme, Nulibry, Zurzuvae) 1181015131157.
How BTD affected priority review and review cycles
Priority review usually followed, but not always
Most BTD approvals in the sample received priority review, which is expected given that both designations rely on a serious condition and meaningful improvement. The exceptions show that the filing-stage decision is made separately:
- Krazati had BTD but a standard review classification. FDA had agreed the sponsor could propose priority review after the initial NDA review 4.
- For Redemplo, the Division indicated it was likely to grant priority review if requested, yet the application record shows standard review 68.
- Rivfloza, Pombiliti + Opfolda and Jideytro all carried BTD and were reviewed on standard timelines 14015484.
- Leqselvi lost its BTD before review. After FDA rescinded the designation on March 14, 2024, the agency planned and conducted a standard rather than priority review 82.
The time saving comes before and during submission, not in the review clock
Where the record shows both the date the final rolling component was received and the action date, BTD/priority applications generally reached action on the standard priority NME timeline:
| Product | Final component or submission received | Action | Elapsed |
|---|---|---|---|
| Leqembi | May 6, 2022 159 | Jan 6, 2023 238 | about 8 months |
| Rezdiffra | Jul 14, 2023 212 | Mar 14, 2024 210 | 8 months |
| Pluvicto | Jul 29, 2021 14 | Mar 23, 2022 189 | about 8 months |
| Yeztugo | Dec 19, 2024 (filed Feb 17, 2025) 73 | Jun 18, 2025 73 | about 6 months from final component |
| Tecvayli | Dec 28, 2021 164 | Oct 25, 2022 161 | about 10 months (REMS major amendment) 163 |
| Krazati (standard review) | Dec 14, 2021 188 | Dec 12, 2022 187 | about 12 months |
| Camzyos | Jan 28, 2021 231 | Apr 28, 2022 230 | about 15 months; standard NME clock from receipt, plus a 3-month extension to the April 28, 2022 goal |
The main contribution of BTD is therefore earlier, often multi-year, interaction on development plans. Rolling review then lets the sponsor lodge nonclinical and CMC modules months before clinical data are complete. For example, the Leqembi BLA was opened with nonclinical information in September 2021 and completed in May 2022 239. Once the application is complete, the PDUFA clock applies as usual. Major amendments can still extend it by three months, as happened with Tecvayli (REMS) and Avlayah 16386.
BTD does not prevent complete responses or rescission
- Kisunla: The original BLA received a complete response on its January 18, 2023 goal date because of an inadequate long-term safety database. After a Class 2 resubmission, FDA classified additional data as a major amendment, moving the goal date to March 12, 2024. Approval came on July 2, 2024 183184179.
- Tzield: A first-cycle complete response on July 2, 2021 cited lack of PK comparability between commercial and clinical product, together with product-quality and facility inspection deficiencies. FDA identified no clinical deficiencies. Approval followed the February 2022 resubmission 198207197.
- Olinvyk: FDA notified the sponsor in September 2018 of its intent to rescind BTD because Phase 3 data no longer showed substantial improvement over morphine. A complete response on November 2, 2018 cited the safety database and QT prolongation. The drug was approved on the second cycle in August 2020 177175170.
- Fintepla: The first submission was refused to file. BTD was rescinded after two other drugs were approved for Dravet syndrome and the sponsor had not shown superiority to both. A major amendment then pushed the goal date to June 25, 2020 213117.
For comparison, CDER's first-cycle approval rate for all novel approvals ranged from 74% to 86% between 2021 and 2025 223224222217218. The approvals reviewed here show that BTD programs are exposed to the same CMC, safety-database and comparability risks as any other application.
The Commissioner's National Priority Voucher
FDA announced the CNPV pilot on June 17, 2025. It is an ultra-accelerated review pathway for drug and biologic applications, including certain supplements, that serve U.S. national priorities. It does not change the statutory standards for approval 373839. Products are selected against five priorities 3637:
- response to a public-health crisis or emerging threat;
- innovative or transformative therapies;
- large unmet medical need;
- onshoring and supply-chain resilience;
- affordability or improved access.
Operationally, CNPV applicants are expected to engage early and support rolling review. CMC information and proposed labeling are due at least 60 days before the final module is submitted 363840. The outlined sequence is a 60-day presubmission phase, a 14 to 21 day filing period and a 30 to 60 day review phase 36373840. The Center's regular review team prepares its own recommendation and presents it to a multidisciplinary CNPV Review Council in a one-day tumor board-style meeting. The Council's recommendation is nonbinding, and the Center keeps the approval decision 36373840. Vouchers are nontransferable. FDA may issue them for a named product or, under the original announcement, as an undesignated voucher for a future product 373843. FDA reported 18 vouchers awarded by April 1, 2026 41.
Recipients and early results
The first cohort (October 16, 2025) included teplizumab, DB-OTO, RMC-6236, bitopertin, cytisinicline, cenegermin-bkbj, Pergoveris, ketamine and Augmentin XR. The last two were selected for domestic manufacturing 34. The second cohort (November 6, 2025) included zongertinib, pediatric bedaquiline, dostarlimab for rectal cancer, Casgevy, orforglipron and Wegovy 2829. Awards made in December 2025 included a Tecvayli/Darzalex combination for relapsed/refractory multiple myeloma 3133.
FDA's program page lists ten CNPV approvals as of August 26, 2026 37: a U.S.-manufactured Augmentin XR (December 9, 2025), Hernexeos (February 26, 2026), Tec-Dara, teclistamab with daratumumab hyaluronidase (March 5, 55 days after filing), Wegovy 7.2 mg (March 19), Foundayo/orforglipron (April 1, the first new molecular entity approved under the program, 50 days after filing) 44, Otarmeni/lunsotogene parvec-cwha for OTOF-related hearing loss (April 23), Bizengri for NRG1-fusion cholangiocarcinoma (May 8), Casgevy for patients 2 years and older (July 1), Lipfendra/enlicitide (July 17) and Rasonque/daraxonrasib (August 26). Trade-press tallies from earlier in 2026 do not match this list (some included products FDA approved through standard review), so check product-level status against FDA's program page. Hernexeos was filed January 13, 2026 and approved 44 days later 3042.
A voucher guarantees neither approval nor the target timeline. Disc Medicine's bitopertin received a complete response on February 13, 2026, about four months into review 3033.
Critics have raised several concerns 30313233:
- selection criteria were unclear, and the Staff Manual Guide was published after most products had already been selected;
- the program lacks congressional authorization;
- non-scientific criteria such as pricing and manufacturing location influence selection;
- a 1 to 2 month review could strain reviewer resources and delay other applications.
BTD and CNPV side by side
| Dimension | Breakthrough Therapy Designation | Commissioner's National Priority Voucher |
|---|---|---|
| Legal basis | Statutory; created by FDASIA, July 9, 2012 221 | Commissioner-led pilot announced June 2025; critics note it lacks congressional authorization 3732 |
| Qualifying standard | Serious condition plus preliminary clinical evidence of substantial improvement on a clinically significant endpoint 47 | Alignment with one or more of five national priorities, which include onshoring and affordability; readiness and public-health impact also weighed 3637 |
| Timing | Requested from IND onward, ideally by end-of-phase 2; FDA decides within 60 days 4959 | Awarded by FDA to named or undesignated products; sponsor must support pre-submission and rolling review 3738 |
| Development-phase benefit | Intensive guidance and senior-management involvement from Phase 1 55 | Not designed as a development program; focus is on the marketing application 3638 |
| Review clock | Standard PDUFA goals: 6 months (priority) or 10 months (standard), from the 60-day filing date for NMEs/BLAs; priority review not automatic 9156 | Target of 1 to 2 months from filing to action, extendable 363726 |
| Review mechanics | Normal review division process, often with rolling review or RTOR 554 | Review team recommendation presented to a CNPV Review Council in a one-day tumor board-style meeting 3640 |
| Effect on approval standard | None; full evidence of safety and effectiveness still required 47 | None; voucher does not affect likelihood of approval 3637 |
| Transferability | Designation attaches to a drug for a specific use 47 | Nontransferable; cannot be bought or sold 3743 |
| Loss of benefit | Can be rescinded if later data no longer support it 51 | Clock may be extended for incomplete submissions, ambiguous pivotal data or complex reviews 3640 |
| Observed outcome | Priority/BTD approvals often about 8 months after final component; complete responses still occur 159238212183 | Hernexeos 44 days, Foundayo 50 days; bitopertin complete response at about 4 months 424430 |
Where the two programs overlap
The programs are complementary rather than alternatives, and several products have held both. Teplizumab received BTD in 2019 and was later selected in the first CNPV cohort 534. Teclistamab (Tecvayli) was approved with BTD in 2022, and a Tecvayli/Darzalex combination later received a CNPV 131. Zenocutuzumab (Bizengri) was first approved in December 2024 with BTDs for NRG1+ PDAC and NSCLC, then gained a CNPV approval for NRG1-fusion cholangiocarcinoma in May 2026 6530.
The regulatory implications for sponsors:
- BTD affects how quickly and efficiently a sponsor reaches a complete, reviewable application.
- CNPV compresses the time from filing to action, provided the dossier is complete early (CMC and labeling at least 60 days before final submission) 3840.
- A BTD program with a CNPV could combine both effects. Neither designation lowers the evidentiary bar, and the Kisunla, Tzield and bitopertin records show that CMC, comparability and safety-database gaps still lead to complete responses 18319830.