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CMPI at Columbus Circle from CMPI on Vimeo.
The European Medicines Agency (EMA) and MIT’s Center for Biomedical Innovation (CBI) and Center for International Studies (CIS) are launching a collaborative research project with a focus on enhancing regulatory science in pharmaceuticals.
Specific questions addressed by this project include how to:
* adapt current regulatory requirements to support the efficient development of safe and effective drugs;
* incorporate patient valuation of health outcomes and benefit-risk preferences into regulatory decision-making;
* implement 'staggered' and 'progressive' approaches to drug approval;
* improve fulfillment of post-marketing regulatory requirements.
The project will explore the feasibility of, priorities for and practical considerations of implementing demonstration projects on some of the issues addressed during the course of the research.
Sound familiar? It's what the FDA's Critical Path program was designed to do -- that is until it hit Congressional treacle embodied by a certain member who will shortly lose her majority status.
The data and recommendations from this project are expected to link to implementation of the Agency's Roadmap to 2015 and the CBI's New Drug Development Paradigms (NEWDIGS) research program.
The project is scheduled to be completed by December 2011.
Hopefully with a new chair at the helm of the House Agriculture (and FDA) Appropriations Committee, funding for the Reagan/Udall Center can be released and FDA can, once again, take a leadership role in developing the tools for 21st century regulatory science.
Industry is anxiously awaiting guidance from FDA on the development of companion diagnostics for drugs that will inform efforts to move towards personalized medicine. The agency has vowed to release a draft guidance on companion diagnostics by the end of the year. But the initial document will address development of companion diagnostics for drugs already on the market, not simultaneous drug/diagnostic development for new drugs.
According to Vicki Seyfert-Margolis, FDA’s senior advisor for science innovation and policy:
“One challenge is that multiple centers have to be involved – CDRH and CDER/CBER. The challenge is internal to determine the mechanism for how the applications will come in and how the review is done. I think we are well on our way to figuring out that process between the different centers. With respect to how one designs and qualifies a diagnostic versus a clinical trial, the study design aspects are another challenge.”
“We are also concerned that we will have markers and use patient selection strategies in a clinical trial and then that marker may turn out to be a disease prognostication marker and you may have selected a set of patients that have different metabolisms. There are a myriad of possibilities one could think of that may or may not completely relate to the drug. We just have to be very thoughtful. I think we will evaluate a lot on a case-by-case basis, but we are trying to at least get some information out about what the paths are.”
And then there’s the issue of the “open kimono.”
Ms. Seyfert-Margolis: “One thing I think would be a big win in helping drive personalized medicine and co-development and companion diagnostics will be to open the data. We need to open the data in-house and also strive to get industry to be more transparent and work with us on this. If we took rheumatoid arthritis, for example, and looked across all the trials that have been done with TNF-alphas and evaluated who are the true responders, who are the non-responders, is there anything we can find in all that data that might point to some marker or some diagnostic that could be used, then we could begin to get at least hints about things that could open up new scientific areas for predictive diagnostics.
Amen. Sounds like a good way to involve the Reagan/Udall Foundation.
Case in point: The WaPo piece on Provenge tinyurl.com/36pvsyn makes two major mistakes.. Actually three. Naw, make that four.
1. It gets the price of Provenge wrong. It is a vaccine that is administered three times at a retail price of $93k. Not $270K as cited in the article.
2. To suggest that the total price of the drug equals a quality adjusted life year (QALY) is absurd. The chart that goes along with the article is inaccurate and misleading. Moreover, a QALY is a rule of thumb developed back in 1985 to estimate the value of dialysis care for Medicare. To write as if $50K or $100K is a cutoff and a scientific one at at is misleading. Wrong on both counts then.
3. The article states: " In a study involving 512 patients with advanced prostate cancer, Provenge increased median survival from 21.7 months to 25.8 months." Way wrong and way misleading. There are patients who have lived for more than five years after Provenge. And as a legal brief from CareToLIve notes: " Appellee attempts to underwhelm the Court by stressing a 4.5 month “average” extension in survival to Provenge patients. That understates the effectiveness. Average is different from median. It’s an important distinction because misuse of the term "median survival" is one of the deceptive arguments used by those who are against Provenge approval (FDA). When anti-Provenge forces use the "average" terminology and attribute it to the median, they are undercutting the total Provenge beneficial effect. At the time of the committee meeting it is estimated that the actual average survival benefit in the 9901 trial was in the 10-12 month range, judging from the likely survival through Feb/Mar 2007 of 20 out of the 28 three-year survivors from 10/04. These 20 Provenge arm survivors would have lived anywhere from 5.5 to 7 years after their randomization between 1/00 and 10/01. underwhelm the Court by stressing a 4.5 month “average” extension in survival to Provenge patients. That understates the effectiveness. Average is different from median. It’s an important distinction because misuse of the term "median survival" is one of the deceptive arguments used by those who are against Provenge approval (FDA). When anti-Provenge forces use the "average" terminology and attribute it to the median, they are undercutting the total Provenge beneficial effect. At the time of the committee meeting it is estimated that the actual average survival benefit in the 9901 trial was in the 10-12 month range, judging from the likely survival through Feb/Mar 2007 of 20 out of the 28 three-year survivors from 10/04. These 20 Provenge arm survivors would have lived anywhere from 5.5 to 7 years after their randomization between 1/00 and 10/01.
4. And WaPo has yet to correct these facts. It did correct the name of the individual who got the Provenge math wrong.
And a bonus: It quotes Sean Tunis and Alan Garber without noting they both were on the Institute of Medicine committee setting comparative effectiveness priorities as well as recipients of CER dough. (If Garber had his way back in 1992, there would have been no new cancer or orphan drugs since he wrote then that the Orphan Drug Act allows the development of drugs that “do not meet traditional cost effectiveness criteria." See Benefits vs. profits: has the Orphan Drug Act gone too far? Pharmacoeconomics, 5:88- 92, 1994 and Gaucher Disease Edited by Anthony H. Futerman and Ari Zimran, Chapter 28.
The situation in Puerto Rico just gets stranger.
The latest news is that some leaders of the Commonwealth’s labor movement asked the legislature (on Friday) to amend Law 154 and impose a fixed tax of between seven to ten percent on foreign companies doing business on the island .
(Law 154 imposes a special tax of four per cent on non-resident companies. That means all of the “Big Pharma” firms doing business on the island. It was enacted minus any public input or comment.)
The head of the Workers Federation of Puerto Rico, and representatives of the Puerto Rico Central Workers Union and the Brotherhood of Ports Authority Workers claim that a permanent 7 percent corporate tax provide the funds to hire back some of the 20,000 public employees fired due to the island’s economic malaise.
To put that into immediate perspective -- According to a 2006 survey, the biopharma sector supports over 94,000 jobs in Puerto Rico. Talk about fuzzy math. Put 94,000 private sector jobs at risk to rehire 20,000 government workers? What’s wrong with this picture?
Surprising for many reasons, not the least of which is the recent commitment to the Molecular Sciences Center, the BioProcess Training and Development Center, and the Puerto Rico Cancer Center -- part of a larger effort by Puerto Rico to attract research and development in the life sciences. Raise taxes to increase corporate investment? Where’s that economic theory being taught? Faber College?
As Patrician Van Arnum wrote in Pharmaceutical Technology, “Puerto Rico competes with other established areas for pharmaceutical manufacturing investment such as Singapore and Ireland. And China and India, although still emerging areas for pharmaceutical investment, are a consideration for future development.”
Someone should mention this to Governor Luis Fortuño.
Unintended Consequences of Health Care Reform: Everyone's a Criminal But Nobody Cares
Posted: 07 Nov 2010 08:59 AM PST
Proposed diabetes changes leave sour taste
By Theresa Flaherty Managing Editor - 10.29.2010
BALTIMORE - When it comes to diabetes treatment, one size doesn't fit all, stakeholders told CMS medical directors at an Oct. 26 public hearing on the proposed changes to the benefit.
The changes, outlined in a draft local coverage determination (LCD) issued in September, would limit the number of allowed strips, based on frequency of injections, to six per day for insulin-dependent beneficiaries. It would limit the number of allowed strips to one per day for non-insulin dependent beneficiaries.
"It's not that cookie cutter," said Chris Smith, director of policy and regulatory affairs for the National Community Pharmacists Association. "Every individual has different variables that may require them to test more frequently on some days than others."..
But CMS really doesn't care...
"There's a large number of patients we serve that are testing above the (proposed) limits," said Belmonte. "By limiting and not allowing any overages, there could be some clinical implications."
If Medicare won't pay for additional strips, beneficiaries probably won't either, especially those on fixed incomes, Belmonte said.
"I honestly feel that many would choose to sacrifice their health (if they can't) test at what their healthcare provider recommends," she said.
The draft LCD also seeks to require additional documentation regarding physician-beneficiary contact and a testing log maintained by the beneficiary that demonstrates the prescribed frequency for 70% of the testing times.
"(DME providers) can't control what (physicians document) in the record, but without the proper documentation, you are going to have claims denied," said Smith.
Bending the cost curve = sticking it to diabetics, especially those who are poor.
I predict an oversight hearing in January...
www.hmenews.com/