Guest Column | October 23, 2026

Policy Is Redefining Clinical Trials. Clinical Supply Must Respond.

By Kendra Orjada, Global Clinical Research Policy Leader, Merck & Co

Recent federal initiatives, including Operation TrialBlazer, are focused on strengthening U.S. competitiveness in clinical research by accelerating development timelines through a series of policy, regulatory, and programmatic initiatives.

The policy direction is clear: trials should be faster, more efficient, and less dependent on a small number of highly specialized academic centers. Policymakers, sponsors, and patient advocates have been emphasizing the need to expand access to clinical trials through decentralized approaches, community-based care, and greater engagement of rural healthcare systems. These changes can reduce participant burden and improve access, but they also require sponsors to rethink the operational infrastructure that makes a trial executable.

While much of the discussion has centered on regulatory processes, site activation, and patient recruitment, an equally important question remains: are clinical supply systems prepared for the next generation of clinical trials?

Bringing Trials Closer To Patients

The traditional clinical trial model was largely built around centralized investigative sites. Patients traveled to research centers, investigational products were shipped to a defined set of locations, and inventory management occurred within a controlled environment.

Today, that model is evolving. Decentralized elements and hybrid clinical trials are becoming more common. Community healthcare providers are participating in research activities that were once concentrated within large academic institutions. Efforts to expand rural healthcare access seek to reduce the geographic barriers that have historically limited participation in clinical research. Meanwhile, new trial designs increasingly emphasize flexibility and patient convenience.

These changes have the potential to improve enrollment, increase representativeness, and reduce participant burden. However, they also fundamentally alter how investigational products are distributed, monitored, and managed.

Clinical Supply As A Strategic Enabler

Moving clinical research closer to patients introduces a range of supply-related considerations that may not have been significant concerns in traditional site-centric studies. As mentioned, the traditional supply model was built around centralized investigative sites with predictable dispensing patterns and inventory management within controlled research environments.

Newer models shift complexity rather than eliminate it. When investigational product moves outside a research pharmacy and into a patient's home, a community provider's office, or a rural site, sponsors must rethink distribution, accountability, storage verification, deviation management, and chain of custody. Moving from depot-to-site distribution to depot-to-patient delivery across many individual locations also changes the required speed, urgency, transportation planning, and operational impact, requiring greater agility and courier-like capabilities, because clinical supply operations were not designed to function like consumer delivery networks. Questions that once had straightforward answers become more complicated. Who receives the product? Who maintains accountability? How are storage conditions verified? How are deviations documented and investigated?

Forecasting and inventory planning become especially important. Patient-centric models may involve more distribution points, smaller inventory pools, variable visit schedules, longer replenishment timelines, limited local storage capacity, and less frequent courier routes. Product may need to be held centrally, regionally, at community points of care, or in patient-specific shipments. Each choice carries trade-offs: too little local supply can create stockouts or missed visits, while too much can strand inventory in locations with uncertain utilization. For complex products with cold chain, handling, or accountability requirements, these decisions become strategic, not merely logistical.

Product integrity presents another challenge. Many modern therapies, particularly biologics, cell and gene therapies, and radiopharmaceuticals, have strict handling and temperature requirements. Maintaining chain of custody becomes more difficult as products move beyond research pharmacies and into community settings or patient homes.

Different Questions By Phase, Therapeutic Area, And Modality

The challenges also differ by phase. This distinction is particularly relevant as Operation TrialBlazer seeks to reduce friction in early-stage development and accelerate the transition from discovery to first-in-human studies. Faster development and regulatory timelines may place greater pressure on clinical supply organizations to support rapid manufacturing, labeling, release, and deployment activities without compromising quality or compliance.

Early-phase studies are often highly controlled because of safety monitoring, dose escalation, pharmacokinetic assessments, and specialized investigator requirements. Their supply challenges tend to center on speed, precision, limited product availability, release timing, and manufacturing readiness. Late-phase studies, by contrast, often involve larger populations, broader geography, multiple depots, hybrid models, community providers, and rural participation. Their complexity is driven less by product scarcity and more by operational scale, inventory visibility, resupply strategy, returns, reconciliation, and contingency planning.

For complex biologics and specialized modalities, manufacturing decisions may also need to be made earlier, sometimes before the final candidate, construct, or sequence is fully selected. Sponsors may need to evaluate more candidates in parallel or make earlier manufacturing commitments while balancing uncertainty, cost, and speed. Small molecules, biologics, vaccines, radiopharmaceuticals, and cell and gene therapies each bring different assumptions about forecasting, handling, storage, accountability, manufacturing readiness, and the feasibility of bringing research closer to patients.

Earlier Planning For Faster Development

Faster development cannot simply compress existing steps into a shorter calendar. It requires sponsors to identify dependencies sooner across protocol design, regulatory timing, manufacturing, CMC approval, ethics approval, site readiness, labeling, packaging, and distribution. Clinical supply must therefore be involved earlier in study planning.

Evolving standards of care, comparator expectations, regulatory feedback, or master protocol designs can rapidly change what product is needed, where it must be supplied, and how quickly it must be available. FDA’s revised draft guidance on master protocols underscores why this matters: master protocols can support umbrella, basket, and platform approaches, allowing therapies to be evaluated within a shared study infrastructure that may evolve over time. As arms are added, closed, modified, or compared against changing standards of care, regulatory expectations can create immediate supply requirements. Sponsors may need to secure new comparators, adapt labeling and distribution plans, or reposition inventory quickly across sites, depots, or community-based locations.

Building The Right Cross-Functional Muscle

The opportunity is to challenge inherited ways of working while preserving quality, traceability, and regulatory confidence. Cross-functional education will be essential. Organizational silos slow execution when teams do not understand how one function's decisions affect another. Sponsors need the right subject matter experts in the room early, including people who can explain not only what is done today, but how compliant processes could be performed differently or faster. Innovation in clinical supply should not be viewed as a departure from compliance.

Looking Ahead

The goals behind current clinical trial policy initiatives are compelling: improving the U.S. clinical trial landscape, reducing development timelines, expanding rural participation, and bringing research closer to patients. Achieving those objectives will require more than regulatory reform or new trial designs. It will require equally innovative approaches to clinical supply management, supported by operating models that break down organizational silos and make dependencies visible across functions. Teams will need to understand how one decision affects another.

Subsequent articles in this series will examine these considerations in greater depth from early- and late-phase perspectives and across therapeutic areas and modalities.

The future clinical trial ecosystem may look very different from today's. But one reality will remain unchanged: clinical research can only reach patients if the investigational product can reach them first.

About The Author:

Kendra Orjada leads Global Clinical Research Policy at Merck, where she develops and advances policy, regulatory, and stakeholder engagement strategies that support clinical trial innovation and patient access worldwide. She works across industry, government, and research ecosystems to address emerging challenges and opportunities shaping the future of clinical development.

With more than 23 years of experience spanning industry, government, academia, and clinical research operations, Kendra has held various roles supporting the FDA, NIH, Defense Health Agency, and major federally funded research programs. Prior to joining Merck, she spent 16 years at Booz Allen Hamilton advising federal health agencies on regulatory science, research policy, strategic planning, and innovation initiatives.

Kendra holds an MPH from Johns Hopkins University and a BA in Psychology from the University of Texas at Austin.