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Social Disease

  • 11.23.2010

From the pages of Medical Marketing & Media:

Patients taking a medication and looking online for health information tend to avoid pharmaceutical company sites, according to an online survey conducted by Accenture.

Just over two-thirds of surveyed respondents said they go online for health information, according to the data. Of that group, nearly half (48%) said they use medical websites like WebMD most often, and just 6% said they use social media sites like Facebook or Twitter most often for health information. Eleven percent of the respondents said they use a pharma company website most often – the same percentage that reported using an online community, like a disease-specific patient site, most often.

Tom Schwenger, global managing director for Accenture's Life Sciences sales and marketing practice, said he “acknowledges the regulatory hurdles that exist in two-way dialogue” between pharmaceutical companies and patients, but that “the gap between the hurdles and what we're seeing represents a large opportunity” for pharma marketers. “What's ironic is that industry cost pressures are greater than ever before, so it makes sense to reevaluate digital and online strategies” with respect to patient communications, said Schwenger.

The survey also found that 69% of respondents “expect pharmaceutical companies to provide information about an illness or condition,” and only 28% of respondents said they are more likely to ask their doctor about a drug after seeing an advertisement. However, 46% of respondents said drug ads increased their awareness of symptoms and possible treatments. Ten percent of respondents said their drug choice had been influenced by coupons, and 47% said it had not, but could be in the future, according to survey data.

The survey's sample was 852 adults in the US, and was conducted between August 30 and September 3, 2010.

At a recent meeting of the Generic Pharmaceutical Association, CDER Director Janet Woodcock said that the FDA is discussing tightening the equivalence limits of generic medicines "so there is less variability.”

In April, the Pharmaceutical Science and Clinical Pharmacology Advisory Committee, voted 11-2 that the agency’s equivalence requirements aren’t’ sufficient for certain medicines. They didn’t offer an alternative, and suggested the FDA list “critical dose drugs or drugs where a small difference in concentration can change patients’ reaction, that may need new standards.

The Pharmaceutical Science and Clinical Pharmacology Advisory Committee voted unanimously, with one abstention, that critical dose drugs do constitute a distinct group and voted unanimously that FDA should develop a formal list of those drugs - although the terminology of "narrow therapeutic index" may be more appropriate. And in an 11-2 vote, the committee concluded that current bioequivalence standards are not sufficient for drugs in the narrow therapeutic index group.

Critical dose drugs have a narrow therapeutic index, meaning that "small changes in blood concentration have the potential to result in serious therapeutic failures and/or serious adverse drug reactions." FDA is consulting the committee on the need to establish separate bioequivalence criteria for these drugs given continuing debate about whether critical-dose drugs require special consideration, the agency explained.

(Currently, the "sameness" of a brand product and a generic version is evaluated based on two-treatment crossover study to prove bioequivalence, the aim being to show that the 90 percent confidence intervals of the geometric mean test/reference ratios for both maximum plasma concentration and the area under the plasma concentration-time curve fall within a range of 80 percent to 125 percent.)

Last month the FDA responded to a request from New Jersey State Senator Joseph Vitale concerning pending New Jersey state legislation that, if enacted, would require pharmacists to dispense epilepsy drugs from the same manufacturer as previously dispensed for certain patients, unless otherwise prescribed. 

In its response to Senator Vitale, FDA comments that “[t]o date, we have not seen any scientific evidence that demonstrates a problem with therapeutic equivalence for this group of products or any other class of generic drug products.  Those who are questioning the quality of generic epilepsy products have produced only anecdotal evidence.” 

And, further:

“[W]e believe that the concerns of some of those raising questions (in particular, physician groups) cannot be dismissed lightly.  Because of FDA’s respect for these groups and the concern that patients may lose confidence in their prescribed medications, we have sought to conduct further study.  Our decision to further study this issue does not stem from doubt within the agency about data we currently have on approved generic epilepsy products.  Rather, it is based on a desire to obtain further independent scientific evidence that might address these concerns.”

Condescending? I suppose it depends how you choose to read it. Does the agency really mean to dismiss the concerns of practicing physicians who see these problems first hand? Maybe PDUFA V funds should be earmarked for FDA staff to attend more neurology conferences to hear about the "scientific evidence” first hand.

More peculiar still is that such statements seem at total counterpoint to the comments of Dr. Woodcock and the unambiguous votes of the advisory committee.

This strikes a very personal note for me.  One of my sons has Juvenile Myoclonic Epilepsy.  His condition is wonderfully controlled via his meds – and I’d like it to stay that way.

Vytorin Victory

  • 11.22.2010
Recently a drug developed by Merck and Schering Plough was found to reduce arterial plaque, preventing angioplasty and stenting, as well as strokes in a study of 9000 patients with kidney disease and diabetes.  According to Merck's research czar Peter Kim: The SHARP (Study of Heart and Renal Protection) study showed that "the investigational use of the drug significantly reduced the risk of these events in a spectrum of patients with chronic kidney disease -- and this was the first demonstration that an LDL-cholesterol lowering medicine could do so."

So what was the response to this study?

"This drug doesn't work. Period. It just doesn't work," said Steven Nissen, head of cardiology at the Cleveland Clinic. U.S. Rep. Bart Stupak, a Michigan Democrat helping to lead a congressional investigation of the study, said, "It is easy to conclude that Merck and Schering-Plough intentionally sought to delay the release of this data." Investors voted with their feet, pushing Schering-Plough (nyse: SGP - news - people ) shares down 8% and Merck (nyse: MRK - news - people ) shares off 1%. "

www.forbes.com/2008/01/14/enhance-merck-schering-biz-healthcare-cx_mh_0115bizenhance.html

Oops that was 2008, when Nissen was leading the charge and making charges that a study about Vytorin was flawed and that the two companies were engaged in -- what else -- a coverup of the shoddy research and its conclusions.  At least that was the narrative shaping the stories from Matt Herper, Steve Nissen's Boswell...   Here is a laundry list of Matt's articles regarding the 'coverup' of the Vytorin debacle.

Sept. 3, 2008: Top Statistician Says Vytorin Cancer Risk 'Not Ruled Out'
May 19, 2008:
Should Schering-Plough's Chief Give Back His Bonus?
April 15, 2008:
Vytorin's Man In The Middle
March 30, 2008:
Vytorin Backlash
March 25, 2008:
More Questions About Vytorin Panel
March 21, 2008:
Vytorin On Trial
Jan. 11, 2008:
Inside Schering And Merck's Secret Panel
Nov. 19, 2007: The Vytorin Question

Herper went so far as to misconstrue Eric Topol's measured response to the study:  One person who won't be convinced by ENHANCE: Eric Topol, the noted chief of translational medicine at Scripps Health in La Jolla, Calif. He still wants to see clear data on how Zetia affects heart attacks, strokes and deaths, and doesn't understand why it took so long to embark on a big study to prove it. Doctors have been "hanging in suspense for years, unnecessarily," Topol says. "It's still conceivable there would be improvement in outcomes. Until we have that data, the jury is out."

Dr. Topol emphasized the need for a larger study with outcomes data.  The recent study about Vytorin is consistent with Topol's broader work on genomics and heart disease:

That driving down LDL alone is not sufficient for reducing the risk of stroke or invasive procedures in both primary care and high-risk populations.  Further, the mechanism by which Vytorin did achieve a reduction in plaque build up and stroke are still not completely clear.  LDL levels fell but it will be interesting to see how that decline is biologically linked with the clinical outcomes observed.  Finally,  linking hard clinical endpoints to reductions in plaque remains an exciting and interesting area of research in cardiology when paired with genomic research that can tailor treatments to populations with different forms of the disease.

And what did Nissen say about the SHARP results?  Matt Herper channel's him:

"Without a group of patients who received just Zocor, it’s impossible to determine whether Vytorin worked any better than Zocor would have alone, says Steven Nissen of the Cleveland Clinic, another critic of the drug. "blogs.forbes.com/matthewherper/2010/11/20/finally-a-win-for-vytorin/

But let's repeart what Peter Kim said:" the investigational use of the drug significantly reduced the risk of these events in a spectrum of patients with chronic kidney disease -- and this was the first demonstration that an LDL-cholesterol lowering medicine could do so."

We are making strides in developing a preventative and personalized approach to heart disease.  That's the good news.  Too bad, some people don't see it that way.

Anyone who has been diagnosed with cancer knows the importance of having an arsenal of therapeutic weaponry. So why are federal officials asking patients with advanced breast cancer to unilaterally disarm?

 

The weapon in jeopardy is Avastin, a biologic drug that cuts off the blood supply to tumors. Clinical studies prove that for women with stage 4 breast cancer, Avastin buys them weeks or months in which the cancer doesn't spread.

 

But the Food and Drug Administration isn't satisfied this time is “enough,” and will decide by Dec. 17 whether to revoke its approval of Avastin as a treatment for breast cancer.

 

Patients and their doctors have proclaimed they should decide what constitutes “enough.” Cancer treatment can't be one-size-fits-all. Some research has found, on average, Avastin doesn't prolong life. But scientists universally agree that it does prolong the quality of life. One study demonstrated that Avastin plus chemotherapy delayed tumor growth a median of about 11 months — five months longer than chemo alone.

 

Focusing only on averages ignores patients that are “super-responders.” Erin Howarth, was 31 when she learned her stage 4 breast cancer had spread to her spine, skull, pelvis and right leg.

 

“I got the impression that it was just like, ‘Well, you're going to come here for chemo every week . kind of until you die,'” Howarth told a newspaper.

 

But she sought out other doctors who put her on Avastin. Within seven months, her cancer was in remission. Labeling herself the poster child for Avastin, she concluded “it worked really well for me.”

 

Susan G. Komen for the Cure and Ovarian Cancer National Alliance wrote to the FDA urging them to preserve Avastin. They contended that removing it from the FDA's list of approved drugs for breast cancer could discourage future drug development.

 

Since the FDA fast-tracked approval of Avastin two years ago, it has been prescribed to about 17,500 patients a year with metastatic breast cancer.

This summer, a 13-member FDA advisory panel — with only two breast cancer oncologists — recommended that the FDA withdraw its approval of Avastin for breast cancer patients.

Doctors could still prescribe Avastin without FDA approval by going “off label.” But if the FDA revokes its breast cancer seal of approval for Avastin — insurance companies, Medicaid and Medicare are also likely to deny coverage.

 

The latest vote of confidence in Avastin comes from the National Comprehensive Cancer Network — a not-for-profit alliance of nearly two dozen of the world's top cancer centers. Last month, they announced it had reviewed and affirmed its guidelines for using Avastin to treat metastatic breast cancer.

 

The FDA should listen to these experts, and to patients. Avastin may well be the best weapon they've got to fight cancer — and the government shouldn't take it out of their hands.

Mind the Gap

  • 11.19.2010

Actions have consequences – often unintended ones.  And the same is true for inaction.

Remember the medical device “gap” of the 1990s?  That’s when Europe was outpacing the United States in bringing new medical technologies to market.  Well – the gap is back, it’s growing – and it has consequences.

The #1 consequence is that Americans don’t have access to new technologies that make a difference. It also means that American companies (and their investors) wonder whether continued investment in research and development is worth it. 

And what’s on the other side of the equation?  One would think, well, safety.  After all, nobody wants the FDA to approve unsafe medical technologies.  Sure enough.  But there’s no evidence that these newer options available in Europe are anything except safe and effective.  Hence, there is a gap in care but none is device safety.  What’s wrong with this picture?

All this while we debate reform to (among other things) the 510(k) process.  Reform?  Good.  Better?  Sure.  But we must also address the issues of better with faster. We must learn from Europe.  We must harmonize with Europe.  And we mustn’t ignore the reality that the medical technology gap is widening and that this fact has consequences for the public health in the United States today as well as for the competitiveness of the American medical technology industry in the future.

A new survey of medical technology companies and investors (by Josh Makower, MD Consulting Professor of Medicine, Stanford University; Aabed Meer MD-MBA, and Lyn Denend Research Associate, Stanford University – with support from the Medical Device Manufacturers Association, the National Venture Capital Association, and multiple state medical industry organizations) is important reading -- and not just for industry and investors, but for thought leaders and policy makers – and especially those at CDRH.

 

The full report can be found here.

FDA inhales DDT

  • 11.18.2010
FDA’s proposed process for qualifying drug development tools allows for the convening of advisory committee meetings or other public discussions about complicated submissions involving proposed biomarkers or patient-reported outcome instruments. A Center for Drug Evaluation and Research draft guidance on qualification of drug development tools (DDTs) states CDER “may choose to hold public discussions” for complex or controversial programs.
 
According to Marc Walton, associate director of CDER’s Office of Translational Sciences, “We certainly envision that for some things a public workshop might be appropriate,” Walton said. “For other things a formal advisory committee might be appropriate. It’s conceivable there might be some other venues that might be suitable in some cases. I think we would very much choose the mechanism to best suit the individual case.”
 
DDTs that are qualified for a specific context of use will be made publicly available to any sponsor for that purpose, and CDER reviewers will not need to reconfirm the tool’s utility each time. A tool’s qualified context of use may be expanded through additional data submissions. Companies that are developing a DDT for their own proprietary use should submit the necessary information with their investigational new drug application, NDA or BLA, rather than using the qualification process outlined in the guidance.
 
The agency says it will consider qualifying other clinical trial outcome measurement tools developed to support labeling claims, such as clinician and caregiver rating scales.
 
The agency is developing a Manual of Policies and Procedures that will lay out all the internal steps involved in the qualification process and contain more concrete goals for timeframes.
 
DDT qualification is not an activity currently supported under the Prescription Drug User Fee Act. However, if FDA gets its way in the current round of PDUFA reauthorization negotiations, future user fee funds may help support the process.
 
Sounds like something worth paying for – if the FDA can deliver the goods.








Don Berwick's coming out party was a little over an hour long.  He was shepherded and sheltered by Finance Committee Dems who ate up the clock with softball questions about how Obamacare repeal would affect seniors.  Berwick said disastrous without explaining how  stoping cuts in hospice care and Medicare advantage and using comparative effectiveness to delay access to breakthroughs like Provenge are harmful.  Republicans didn't even have enough time to clear their throats before the hearing was adjourned.

Berwick recycled comments he has made since the story about his love affair with rationing, centralized decisioning making and the NHS was broke by yours truly: He told the Committee seniors should get   "all the care they want and need, when and where they want and need it."

He didn't mention that what people want and need will be limited by what government defines as quality care. 

And he already broke his promise by delaying access to Provenge and rationing diabetes strips. 
Linda Gorman explains survival rates:

With funding from the Commonwealth Fund, Peter A. Muenning and Sherry A. Glied have produced a Health Affairs study of 15 year survival rates for men and women aged 45 and 65 in 13 countries for each year from 1975 to 2005.
 
A country’s survival rate is the percent of people of a given age who are still alive after 15 years. The authors ranked each country’s survival rate in each year. Because the U.S. relative ranking fell over the period while its per capita health spending rose, the authors conclude that the U.S. has a relatively inefficient health care system.
 
They blame the inefficiency on a rising number of people with “inadequate health insurance” and the reliance on “unregulated fee-for-service and specialty care” which they speculate may be “choking off public funding on more important life-saving programs.”
 
Little evidence is adduced to support any of these conclusions. In fact, the authors seem to jump through a myriad of speculative hoops to force the facts to conform to their preconceived views.
As is well known, age-adjusted survival rates are not by themselves a useful measure of the success or failure of a country’s health care system.
 
One reason that survival rates are not good measures of health system quality is that individual behavior has a large influence on health and, as a result, the health outcomes that produce survival rates. The authors do consider trans-national differences in smoking, obesity, and traffic accidents/homicide, three behavioral risk factors that receive a great deal of popular coverage. Unfortunately, their analysis of those factors is difficult to defend. At the same time, the authors ignore such factors as suicide, alcoholism, illegal drug use, poisoning, drowning, burns, and accidents other than homicide and traffic accidents.

Read Linda’s entire blog post here.

His written testimony to the Senate Finance Committee is an exercise in bowing and scraping to avoid prosecution.  It is pathetic pablum and won't help.  I am sure senators will have plenty of questions about MEDCAC, AHRQ, cuts to hospice care, comparative effectiveness research, his religious belief in the Dartmouth Institute, his claim that half of all medical spending is wasteful or harmful…

Here is Berwick's testimony.

My article in the American Spectator today:
 
Are Medicare director Don Berwick and the Obama administration delaying or denying patients access to medical innovations? That's a question the Senate's Finance Committee should ask Berwick, who heads up the Center for Medicare and Medicaid Services (CMS), when he testifies November 17.
 
The timing couldn't be better. Medicare won't pay for Provenge, the first cancer vaccine, since it was approved in April. It's waiting for the Medicare Coverage Advisory Committee (MEDCAC) -- also meeting on the 17th -- to decide whether the Food and Drug Administration, the National Cancer Institute, and cancer experts are right in supporting Provenge use for prostate cancer patients.
 
MEDCAC was established in 1998 so CMS could ask leading scientists and doctors to recommend what information should be collected to determine the best use of new technologies. But recently MEDCAC has -- under CMS direction -- begun evaluating whether innovations are cost-effective.
 
In November 2008 Medicare bureaucrats asked MEDCAC: At current Medicare prices, how confident are you that CTC has a similar ratio of cost per LYS (Life Years Saved) as optical colonoscopy? In 2009 CMS asked MEDCAC: What are the desirable measures of the cost-effectiveness of screening genetic tests for the prevention or early detection of illness or disability? By 2010 CMS was simply asking MEDCAC whether CMS should cover new technologies unless there was evidence of its cost and clinical effectiveness from long and expensive studies. As one speaker at a MEDCAC hearing about genetic tests noted, "if clinical outcomes as defined… become[] a requirement for reimbursement, it will reduce investment in new genetic tests and the market introduction of these tests, and ultimately their use. "
 
That's the goal. But given Provenge's high profile, asking about its cost-effectiveness would be controversial. Since the one-time treatment runs about $90,000, CMS thought it could ask if Provenge was effective without mentioning cost. Hence, Dr. Louis Jacques, the director of the Coverage and Analysis Group at Medicare, told Forbes: "We've been getting questions from people," says Jacques. "'Well, what's up with Provenge? Is it a drug? Is it a biologic? Is it something else? Does it really work? It has been interesting to look at the evidence around it."
 
Does it really work?!

Maybe Dr. Jacques didn't get the memo about the FDA approving Provenge. The FDA said Provenge "substantially improved survival to patients with a fatal disease. The risks… are minor relative to the benefit of improved survival." Or perhaps he didn't see the May 6 National Cancer Institute statement asserting: "The field of cancer immunotherapy received an important boost last week with the FDA's approval" of Provenge. On May 29 the National Comprehensive Cancer Network (NCCN) Drugs & Biologics Compendium added Provenge to its list of standard therapies. On June 15 Aetna said it would cover Provenge.
 
Federal law requires that CMS cover any cancer drug approved by the FDA or NCCN compendium therapy. Instead, on June 30, an anonymous individual requested that CMS hold a MEDCAD hearing on Provenge before it covered the drug. CMS immediately accepted the query from the secretive party. Perhaps the Finance Committee can find out who that was.
 
MEDCAC will render its decision based on a just released evaluation of the FDA data conducted by the Agency for Health Research and Quality (AHRQ). AHRQ tried to pretend it wasn't second-guessing the FDA and the NIH. In October, the report name was changed on AHRQ's website from "The Efficacy and Safety of Sipuleucel T" (Provenge) to "The Outcomes of Sipuleucel T." The reviewers determined the FDA data used to approve Provenge was "adequate" but not entirely convincing. You might wonder: What expertise in prostate cancer did the authors use to draw to that conclusion? The answer is none unless you count nursing, a master's degree in statistics, or a PhD in sociology. Apparently CMS believes AHRQ's collective wisdom towers over the oncology expertise of the FDA, NCI, and NCCN.
 
The AHRQ report understates the impact of Provenge on survival. First, it begrudges the fact that many patients receiving chemotherapy after taking Provenge live longer. It focuses on the median survival benefit of 4.5 months (which tells you the midpoint of patient survival but not how many patients lived longer and for how long). Then it raises doubts about safety. And finally the study glosses over the finding that terminal prostate cancer patients who received Provenge were 40 percent more likely to be alive in three years than those who did not receive it. The AHRQ report is ideology masquerading as medical facts. The routine and expanding using of AHRQ to guide life or death decisions undermines the legitimacy of real science.
 
MEDCAC meets this week but CMS can take months to decide. This callous and possibly illegal process reflects Berwick's stated belief that only a centralized entity should decide what's best for us. People with prostate cancer have died and will die waiting. If that's not a death panel, I don't know what is.

CMPI

Center for Medicine in the Public Interest is a nonprofit, non-partisan organization promoting innovative solutions that advance medical progress, reduce health disparities, extend life and make health care more affordable, preventive and patient-centered. CMPI also provides the public, policymakers and the media a reliable source of independent scientific analysis on issues ranging from personalized medicine, food and drug safety, health care reform and comparative effectiveness.

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