[e-drug] Public misinformed about seal of approval from US drug agency

E-DRUG: Public misinformed about seal of approval from US drug agency
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Between 2005 and 2011, nearly half of all new drug formulations in the US
were approved without companies having to demonstrate a tangible benefit.

*Public misinformed about seal of approval from US drug agency (23 January 2014)*
https://theconversation.com/public-misinformed-about-seal-of-approval-from-us-drug-agency-22319

Between 2005 and 2011, nearly half of all new drug formulations in the US
were approved without companies having to demonstrate a tangible benefit,
such as relieving disease symptoms, extending life, or improving someone’s
ability to go about normal activities.

What patients really want is evidence that the drug they are taking will
actually improve their condition. But the FDA, the American drug regulator,
doesn’t routinely consider this for new molecular entities (NMEs) – drugs
that have innovative chemical structures that have never been marketed
before.

The findings come in a new paper by Nicholas Downing of Yale University and
colleagues, part of a series on the drug approval process published in the
Journal of the American Medical Association (JAMA), that found there was
wide variation in the quality of evidence considered by the FDA. They also
found that nearly two out of five drugs approved by the FDA was brought to
market after a single pivotal trial.

A second paper in the series documented the lack of data required by the
FDA when it considers approvals for medical devices – the study found that
only 14% of high-risk medical devices, such as pacemakers and other
cardiovascular implants, were assessed in one randomised control trial.

Both studies strongly suggest that the FDA is approving products that may
not have accurate risk-benefit profiles, which could place patients at risk.

*Sleeping watchdog?*

While patients and physicians rely on the FDA to serve as an appropriate
gatekeeper and watchdog, opinion polls reveal the public is misinformed as
to what the FDA seal of approval actually means. For example, a national
randomised trial conducted in 2011 found that 39% of US adults believe the
FDA approves only “extremely effective” drugs, and 25% believe the agency
only approves drugs that do not have serious side effects.

In addition to debunking these commonly held myths, the Downing paper is
part of a long line of comprehensive studies that have highlighted the
limitations of the FDA’s review process for new drugs before they hit the
market.

Because pre-market studies are limited in duration and scope, they often
fail to capture later adverse events, or adverse effects that only happen
to a small percentage or sub-population of patients. At the same time,
pre-market studies often include research subjects who are not
representative of “real-world” patients. For example, studies typically
don’t include patients who are taking multiple medications.

The findings also affirm what commentators and FDA Commissioners have long
argued – that the FDA should take a more proactive role in reviewing drugs
and medical devices once they hit the market, to make sure adverse events
are logged and considered.

No one wants an approval process that drags on for a long time. So when it
comes to catching later problems, the only meaningful alternative is to
require that drug and medical device manufacturers actively review
post-market data and report their findings to the FDA – something that
needs manufacturers to actively engage with.

*Inside the FDA*

Since the 1960s, the total number of drugs approved has been falling on
average, according to data collated by The Conversation. This is happening
at the same time as the cost of research and development is going up. In
another study in the JAMA series, six FDA scientists looked at the reasons
why approvals for drugs might be delayed or denied. According to the paper,
between 2000 and 2012 a half of NMEs were approved when first submitted to
the agency and nearly 75% were ultimately approved. Some of the reasons why
new compounds failed to earn FDA approval included inadequate performance
and problems with doses.

It’s a hugely important paper because information from the FDA on why drugs
aren’t approved is limited, due to data sharing issues (despite
recommendations from its own transparency taskforce).

The study is sure to provide meaningful guidance to pharmaceutical
companies as they contemplate, prepare or conduct pre-market studies. At
the same time, however, the article raises complex questions as to the
proper role of the FDA as regulator, industry collaborator, and promoter of
public health. In many respects the FDA and industry are collaborators –
industry’s responses to new regulations are taken seriously by the agency,
and lobby groups have long had significant influence over the legislation
that sets the legal limits of FDA’s authority. Yet, the agency’s primary
mission is to ensure that marketed products are safe and effective, though
the FDA characterises itself as a public health agency that must “promote
health, prevent illness, and prolong life”.

As Marcia Angell, former editor of the New England Journal of Medicine, has
observed, “there is growing evidence that … [the FDA] has become the
servant of the industry it regulates.”

Taken together, the articles support calls for the FDA to be more robust in
the surveillance of marketed drugs and medical products. Simply stated, we
need to know if the products we are using actually work. As the Downing
study shows, the FDA’s pre-market review process isn’t clear on this and
the public remain none the wiser.

Jurgen Hulst
PSM Specialist
JHulst <hulst.jurgen@gmail.com>

E-DRUG: Public misinformed about seal of approval from US drug agency (2)
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Dear All

I found the original message on this topic a bit misleading to the
extent that I felt the need to follow-up - and it does provide a pointer
to useful papers.

The original posting was the text of an article written on 'The
Conversation'
(https://theconversation.com/public-misinformed-about-seal-of-approval-from-us-drug-agency-22319)
an Australian-based news-site that uses the catch-phrase 'Academic
rigour, journalistic flair' and describes itself as " independent source
of news and views, sourced from the academic and research community" and
which is funded by may Australian universities and the national public
scientific research organisation (CSIRO).

However, the assertion that half of 'innovative' new drugs approved in
the USA by the FDA did not have to show efficacy is not supported by the
research articles upon which it is based (the first one is available for
free from JAMA):
1. Clinical Trial Evidence Supporting FDA Approval of Novel Therapeutic
Agents, 2005-2012. Nicholas S. Downing et al. JAMA. 2014;311(4):368-377.
doi:10.1001/jama.2013.282034.
http://jama.jamanetwork.com/article.aspx?articleid=1817794
2. Scientific and Regulatory Reasons for Delay and Denial of FDA
Approval of Initial Applications for New Drugs, 2000-2012. Leonard V.
Sacks, et al. JAMA. 2014;311(4):378-384. doi:10.1001/jama.2013.282542.
http://jama.jamanetwork.com/article.aspx?articleid=1817795

The first paper provides a summary of the pivotal clinical trials used
to support New Drug Applications (NDAs) at the FDA during the period
2005-2012, looking at the number of pivotal trials, use of accelerated
procedures, clinical trial design, number of patients exposed, type of
endpoints used, duration, etc. The second examines reasons for delays or
non-awarding of approval of NDAs at the FDA.

The discussion of the results in the first paper starts by stating:

"Our characterization of pivotal efficacy trials—trials that serve as
the basis of FDA approval—for all novel therapeutic agents approved
between 2005 and 2012 demonstrates that the quality of clinical trial
evidence used by the FDA to make approval decisions varied widely across
indications. Although the vast majority of indications were supported by
at least 1 randomized, double-blinded trial, there was wide variation in
trials’ choice of comparators and end points, duration, size, and
completion rate. In addition, just more than one-third of indications
were approved on the basis of a single pivotal efficacy trial."

And the ultimate conclusion is:

"The quality of clinical trial evidence used by the FDA as the basis of
approvals of novel therapeutic agents between 2005 and 2012 varied
widely across indications. This variation has important implications for
patients and physicians as they make decisions about the use of newly
approved therapeutic agents and has the potential to inform current FDA
regulatory approval standards and postmarket surveillance initiatives."

The conclusion of the second paper is rather more nebulous and not
really worth quoting here.

Thus, while there may be concerns about the industry 'capture' of
regulatory authorities and that new drug registration compromises on the
assessment of safety and efficacy in order to get products onto the
market without too much delay (whether for commercial, political or
health-related reasons), the assertion in the news story that the FDA
does not examine efficacy of half of NDAs does not seem warranted (or
that the public is misinformed although they may well be poorly informed).

Regards

Douglas Ball
Pharmaceutical consultant
Public Health and Development
E-mail: douglasball[AT]yahoo.co.uk

E-DRUG: Public misinformed about seal of approval from US drug agency (3)
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Dr Ball is correct because of the wording but incorrect in other words. "...half of 'innovative' new drugs approved in
the USA by the FDA did not have to show efficacy..." puts the problem incorrectly in several ways. All drugs approved by the FDA "have to show efficacy" in some sense of that phrase. But a clinically small difference based on generating statistical significance for it by using a large sample, or by using a surrogate end point, or by being "non-inferior" has led several independent teams of physicians and pharmacists in several countries to conclude that 85-90 percent of drugs approved have few or no clinical advantages over existing drugs.

A summary of evidence and references was put together at the E J Safra Center for Ethics at Harvard last year and came out this fall. You can find it at
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2282014. Or at http://www.pharmamyths.net/the_myth_of_safe___effective_drugs__2013__120218.htm

The flood of clinically minor new drugs, to fill product sales lines, have produced over the years an epidemic of harmful side effects. The chances of serious harm from new drugs has been found to be 1 in 5, a huge risk when chances of added benefit is 1 in 10. Evidence of drugs being tied with stroke as the 3rd leading cause of death is also in the article.

Don Light
"Donald W. Light Jr." <dlight@princeton.edu>

E-DRUG: Public misinformed about seal of approval from US drug agency (3)
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Dr. Ball is correct because of the wording but incorrect in other words. "...half of 'innovative' new drugs approved in
the USA by the FDA did not have to show efficacy..." puts the problem incorrectly in several ways. All drugs approved by the FDA "have to show efficacy" in some sense of that phrase. But a clinically small difference based on generating statistical significance for it by using a large sample, or by using a surrogate end point, or by being "non-inferior" has led several independent teams of physicians and pharmacists in several countries to conclude that 85-90 percent of drugs approved have few or no clinical advantages over existing drugs.

A summary of evidence and references was put together at the E J Safra Center for Ethics at Harvard last year and came out this fall. You can find it at
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2282014. Or at http://www.pharmamyths.net/the_myth_of_safe___effective_drugs__2013__120218.htm

The flood of clinically minor new drugs, to fill product sales lines, have produced over the years an epidemic of harmful side effects. The chances of serious harm from new drugs has been found to be 1 in 5, a huge risk when chances of added benefit is 1 in 10. Evidence of drugs being tied with stroke as the 3rd leading cause of death is also in the article.

Don Light
"Donald W. Light Jr." <dlight@princeton.edu>