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Last updated: Nov 12, 2025


The latest guidance urges sponsors and investigators to consider the many dimensions of clinical trial diversity. See the top 10 tips on how to craft a successful action plan.


June 2024 saw updated guidance released by the FDA in relation to diversity in clinical trials. In accordance with the latest FDA guidance, Diversity Action Plans must:

  • Specify the sponsor’s rationale and goals for clinical study enrollment (separated by the age group, ethnicity, sex, and race of clinically relevant study populations)
  • Describe how the sponsor intends to meet those goals

The latest guidance also urges sponsors and investigators to consider the many dimensions of clinical trial diversity, even those that extend beyond age, ethnicity, sex, and race to enroll populations that represent the patients who will be treated if the product is approved.

Top tips for building a diversity action plan

Integrate diversity considerations early in the clinical development process. Define enrollment goals for underrepresented populations at the beginning of the study design phase.

Analyze the disease's epidemiology across different racial and ethnic groups. Use this data to set realistic and meaningful enrollment targets that reflect the disease's impact on these populations.

Ensure that your study designs, eligibility criteria, and endpoints support the inclusion of diverse populations. Consider geographic locations and community engagement strategies to enhance participation.

Leverage various data sources, such as published literature, real-world data (RWD), and social determinants of health (SDOH), to inform and justify your enrollment goals. This helps address potential challenges in setting goals based on limited epidemiological data and race and ethnicity categories following the Office of Management and Budget (OMB) standards.

Select study sites that are accessible to diverse populations. Ensure the sites are located in areas with high concentrations of underrepresented racial and ethnic groups.

Identify and mitigate barriers to participation, such as cultural differences, mistrust of the medical system, and logistical challenges. Tailor your recruitment and retention strategies to address these specific issues.

Establish metrics to track enrollment progress and be prepared to adjust strategies if goals are not being met. Continuous monitoring and proactive problem solving are crucial to maintaining diversity in participant enrollment.

Discuss your diversity plans with the FDA early in the development process and seek feedback during milestone meetings. Keep the FDA informed of your progress and any adjustments to your plan.

Communicate with participants about the study's goals and progress. Provide regular updates and seek feedback from the community to improve ongoing and future recruitment efforts.

Form strategic partnerships with reputable data providers and consulting services specializing in epidemiology, demographic analysis, and clinical trial diversity. These experts can offer valuable insights, advanced analytics, and tailored strategies to enhance your diversity action plan. They can help identify underrepresented populations, refine recruitment tactics, and ensure compliance with regulatory requirements. Leveraging their expertise will not only streamline the execution of your plan but also increase the likelihood of achieving diverse and representative clinical trial enrollment.

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