Latest Drugwonks' Blog

The Wall Street Journal, reports that,  “Amid studies showing the anti-clotting drug Plavix may not be effective for 30% of cardiac patients, federal regulators are considering updating the drug's label to include data on genetic factors that could interfere with the medicine.”

(Nearly 25 million prescriptions were written in the U.S. in 2007.)

“The issues concerning Plavix show the promise and problems with the new area of "personalized medicine," where drugs are tailored to certain people based on their genetic makeup. In Plavix’s case, the three studies pinpointed a likely genetic factor inhibiting the drug's efficacy -- but that finding has opened up more unanswered questions.”

“Unanswered questions” are a good thing – it means that we’re now being forced to think hard about how to address these new facts.  Nobody said personalized medicine was going to be easy.

Three studies last week -- two in the New England Journal of Medicine and one in the Lancet -- identified a genetic abnormality in some heart patients that could interfere with their liver's ability to completely process Plavix in the bloodstream, but they differed on the number of patients affected.Two of the studies suggested the drug was less effective in about 30% of the population that has the mutated gene from one parent, while one study indicated the drug is less effective in the 5% of the population that has the gene from both parents.

According to Larry Lesko, director of the FDA's office of clinical pharmacology, "What I think we're struggling with is what is the label going to say in light of all the ambiguous data out there."

That’s a key point to remember – that “personalized” labeling is not a black-and-white proposition.  And it’s the FDA’s job to review all of the information (much of it vague and contradictory) and then make the best choice on behalf of the public health.  Larry Lesko’s honesty acknowledges some tough truths about drug regulation – like the nascent nature of the agency’s understanding of pharmacogenomics relative to “safe use” and the dearth of 21st regulatory tools to explore it. 

These new studies mean "life just got very confused and much more complex" for cardiologists and patients, said Dr. James Calvin, director of cardiology at Rush University Medical Center in Chicago. He added, "We have to start to become very, very aware of how big an issue this is."

Indeed, not “safety” per se, but “safe use.”

According to Dr. Lesko, the agency is considering amending the Plavix label to recommend that patients get a genetic test to screen them for the gene mutation.  This is similar in concept to the FDA’s change to the Warfarin label – but with one big difference ... at present there aren't any alternatives to Plavix approved for use in the United States. "Once you know the answer, what do you do?" said Douglas Weaver, president of the American College of Cardiology.

Good question – and one that the FDA should acknowledge and take into consideration as it reviews the various safety profiles of new medicines that could fill this gap.

Dr. Paul Gurbel, who authored one of the first studies showing that many heart patients don't process Plavix effectively, said, "Clearly I think just the blind administration of these drugs is rapidly coming to an end."

Dr. Grubel’s comment is a clarion call that the era of “trial-and-error” medicine is over.  One size does not fit all.  Not for anti-clotting drugs, not for cancer medications, not for statins.

The Journal article opines that, “The new Plavix studies may give a boost to personalized medicine as a cost-saving measure under President-elect Barack Obama. As an Illinois senator, he introduced a bill in Congress encouraging genomic research and personalized medicine that would "target the delivery of health care." Insurance companies might be able to limit prescriptions for Plavix based on patients' genetic makeup, as they do now with some cancer drugs.”

First of all, news articles shouldn't opine.  Secondly, personalized medicine is not about denying care.  It’s about providing the right care.  The four rights (right medicine at the right time to the right patient in the right dose).  And as far as “cost-savings” are concerned, not providing Plavix to some subset of patients (and particularly one as potentially large as 30%) doesn’t mean these patients don’t need treatment – it means they need alternate treatment, newer therapy, therapy that may cost more than Plavix does today – and considerably more once it goes off-patent.

And as far as former Senator Obama’s “Genomics and Personalized Medicine Act,” goes – I look forward to hearing about its passage during his first State of the Union address.

Earlier we commented on the future path of Britain’s National Health Service as spelled out in the “Darzi Report.”  (“Do you deny it, Mr. Darzi”)
 
One of Lord Darzi's recommendations is that NICE work faster so that the fine and timely work of the MHRA (the FDA’s sister agency in the United Kingdom) isn’t wasted.

According to NICE Chairman Sir Michael Rawlings, "Our ambition is to make sure guidance is available within three to six months.” He said this could be achieved by increasing the number of advisory committees and starting the evaluation process a year before a drug company expects to obtain a license. (Not a bad idea for similar action by CMS right here at home.)

That’s good news.  What’s better news is that Sir Michael seems to be almost, kind of, sort of ready to reconsider NICE’s inflexible devotion to the Holy QALY.

According to the NICE chairman, "People attach a special importance to extending the lives of [those with] mortal illnesses, even for a few months, and we appreciate these extra weeks and months can be very special.”

Further, "We are proposing to provide our advisory bodies with supplementary advice ... which will have the effect of extending the threshold range of what we would normally regard as cost-effective."

Good golly!  Miss QALY?

However, "We are not proposing to extend this to all conditions. Frankly, it would cost the NHS hundreds of millions of pounds."

Well, heaven forbid that the NHS should provide the best care when adequate care is available.  That’s cost-based versus patient-centric care.  That’s NICE.

In other words, when Sir Michael’s political masters feel the heat – NICE sees the light.  This is a case (one not unknown in American politics) of the squeaky wheel getting the oil.  And now that British citizens with “mortal illnesses” will finally be treated like human beings, it’s only a matter of time until every other segment of the British population figures out that where their best chances for best treatment lies – in public activism.

Is this any way to run an airline?

Per yesterday’s blog, “Diagnostical Materialism,” have a look at the latest article in the New York Times’ “Evidence Gap” series, “Patient’s DNA May Be Signal to Tailor Medication.”

Here’s a paragraph to whet your appetite:

“Many policy experts are calling for more studies to compare the effectiveness of different treatments. One drawback is that such studies tend to be one size fits all, with the winning treatment recommended for everybody. Personalized medicine would go beyond that by determining which drug is best for which patient, rather than continuing to treat everyone the same in hopes of benefiting the fortunate few.”

A worthwhile read.
Hasn't the New York Times ever heard of retail health clinics?
Molecular diagnostics are what make medicines personal. Diagnostics are how drugs can be made “safer” -- through “safe use.” They make the “four rights” (right medicine for the right patient in the right dose at the right time) possible.  And the four rights lead to lower costs through better outcomes.

Case in point:  Warfarin, the most widely used anti-coagulant medication in the world. Prescribed to over 2 million people a year to prevent blood clots, heart attacks and strokes, patients can display markedly different responses to the drug. Doses vary enormously between individuals; so achieving the correct dose is critical, as patients who receive too high a dose are at risk of severe bleeding, while those who receive too low a dose may remain at risk of life-threatening blood clots. Via molecular diagnostics specifically called out in the amended FDA label, physicians will prevent 85,000 serious bleeding events and 17,000 strokes annually – and that’s just in the United States. And this “safer use” is estimated to save $1.1 billion annually.  And that’s the mid-range.

But diagnostics are in trouble.  And that trouble comes in the form of skittish reimbursement and ambiguous regulation.

On the reimbursement front, many payers aren’t ready to accept the up front expense – even though the longer-term savings can be substantial.

Case in point:  Herceptin. Studies show that Her2 testing for breast cancer delivers savings that are 65x its cost.  For a very powerful presentation on the economics of the Her2 test and molecular diagnostics in general see here.

In short, reimbursement should be based on value rather than activity.  This is an essential (you should excuse the expression) paradigm shift. 

On the regulatory front clarity and predictability are required. FDA approved the molecular diagnostic for warfarin based on a broad range of published literature together with the results of a study, conducted by the manufacturer, on hundreds of DNA samples.  But guidance on diagnostic approvals are vague as is the pathway.  To reinforce the agency’s commitment to personalized medicine, the FDA should embrace ever-greater clarity and commitment to diagnostic tool review.  This should be a top priority of the agency’s Critical Path program.

Unless and until the reimbursement and regulatory issues are addressed, investment in developing these tools will languish, patients will needlessly suffer and our healthcare system will continue to be burdened by unnecessary costs.

If the popular culture clarion call is for “safer drugs,” then the path forward shouldn’t include beating up Big Pharma or reversing FDA preemption authority – it’s via molecular diagnostics. 

“President Bush leaves office with a health care legacy in bricks and mortar: he has doubled federal financing for community health centers, enabling the creation or expansion of 1,297 clinics in medically underserved areas.”

Says who?  The New York Times.  (Ergo, it must be true.)  The article, “Expansion of Clinics Shapes a Bush Legacy.” All the news that’s fit to print?  Well almost.  It’s pretty amazing that the Gray Lady opted to leave out any mention of Part D in the President's legacy.  But maybe that article’s on the way.

But to give credit where credit is do, it’s a good article that raises some important questions -- one of the most important raised by House majority whip Representative James E. Clyburn (D, SC).  Mr. Clyburn makes the very important point that reducing the number of uninsured will be meaningless if the newly insured cannot find medical homes.

This is a key policy point for many reasons, not the least of which is the successful management of chronic disease.  Minus a warm and welcoming (and e-tized) medical home, we cannot seriously advance prevention initiatives (i.e., early detection) or improve our abysmal compliance/adherence rates. Minus a medical home we remain an acute care culture.  Minus a medical home, even community health centers are but Potemkin villages.

Last year over 80,000 Americans had a foot amputated because of undiagnosed and untreated diabetes. Hundreds of thousands of heart attacks and strokes, caused by undiagnosed or untreated high blood pressure and high cholesterol, cost the American health care system billions of dollars a year while the cost in terms of human suffering cannot even begin to be measured.

Lack of early detection?  Sure.  Lack of compliance/adherence?  Definitely. Lack of a medical home?  Shameful. 

When it comes to healthcare reform, we cannot leave patients home alone.

When it comes to FDA reform, if you don't ask the right questions, you won't get the right answers.

It’s been widely reported this week that the FDA approved more “first-of-a-kind” drugs in 2008 (21) than it did in 2007 (18).  During that same period fewer “black box” warnings (both new and updated) were awarded in 2008 (46) than in 2007 (62).  What do these numbers mean?

To some (and you know who you are) they signal an agency that isn’t as concerned with safety as it was only twelve months earlier.  More drugs approved?  Fewer black boxes?
And why, these same FDA watchers wonder, isn’t DDMAC sending out more warning and untitled letters to curb the abuses of pharmaceutical marketing – particularly of the off-label variety?

These are some of the questions they would ask.  The media-friendly questions.  The staff-prepared hearing questions.  The trial lawyer questions. The politics before public health questions.  The "tabloid medicine" questions. And they are the wrong questions.

For those who actually understand what’s going on there is a different set of queries altogether:  Why did the FDA miss review deadlines for at least 15 drugs?  Why are a growing number of complete response letters sounding more and more like the old-style not-approvable variety?  And why are more and more complete response letters requesting information that was never discussed during the review process or at advisory committee meetings?  Savvy pharmacenti also want to know what in Hell’s Bells is going on with “early safety” communications and signal-to-noise ratio issues.

But the big question those who know are asking is, Why is ambiguity trumping predictability in the regulatory process? This is the key issue that must be addressed by the new FDA Commissioner.  That’s the question.  The fear is Precautionary Principle creep.  If the FDA adopts the position of doing nothing until it knows everything -- that will send a chilling message to the pharmaceutical industry to dial back R&D unless the program looks like a sure thing.

And there are no “sure things” in pharmaceutical discovery and development.

Industry seeks clarity. They want bright lines. They want to know the rules. They want predictability. This may sound simple and fair, but inside the FDA it has proven to be a fractious bureaucratic kulturkampf.  “Change is not required,” as management guru W. Edwards Deming once said. “Survival is not mandatory.”  And that doesn’t mean change for show, for politics – it  means thoughtful, timely, strategic change that enhances the public health.  And that kind of change requires not walking on egg shells – but breaking them.  Andy von Eschenbach learned that the hard way.

Changing the minds of regulators to embrace bright lines rather than broad definitions is a challenging proposition -- because changed minds must begin with change agents. The new Commissioner must seek out and work with those career officials within the FDA who are smart, confident and gutsy enough to embrace new ways of doing business, who support bright lines over draft guidances, pragmatism over dogmatic doctrine.  And those people are there and are excited about the possibilities of an FDA that will lead rather than an agency that buffets from side-to-side based on gusting political winds.

FDA’s Critical Path initiative is a promising example of the agency’s desire to embrace change. Going forward, the agency’s stakeholders will be looking for other “surrogate markers” to gauge FDA’s willingness to continue the McClellan era’s aggressive determination to both protect and advance the public health.

Despite new draft guidances that attempt to draw bright lines, what is and is not “in compliance” remains more art than science. Industry is confused, and the public health is not served.  Predictability is power in pursuit of the public health. Predictability is the result of creative, forward-thinking leadership that rises above bureaucratic ambiguity.  Driving this philosophy won’t be easy for the new Commissioner -- because swimming against the tide of an entrenched bureaucracy never is. But if the Commissioner communicates this philosophy, leads by doing and empowers change agents within the FDA career staff, the tide will turn.

As Winston Churchill said, “Ease is relative to the experience of the doer.”


Another study showing that certain drugs used in combination when we are old don't always mix well. 

This on the heels of a NEJM study showing high and low responders among Plavix users based on genetics.

How long will it take HMOs to connect the dots, save lives and practice patient-centered medicine by using genetic testing on high risk populations?
Interesting story in today’s New York Times on Tom Daschle’s call for “Healthcare House Parties.”

In typical New York Times fashion, the event they chose as an example was peopled mostly by Obama campaign volunteers (including one person who works at the NIH and another who is “active in women’s health advocacy”).  So not your typical slice of America. 

Nevertheless, some interesting tidbits.

For example, here’s what one party member had to say about a government-sponsored plan, “similar to Medicare,” that would compete with private insurance companies -- “A public insurance plan would not take anything away. It just adds another option.”

Options are good. But would a government plan compete fairly?  Or would it ultimately drive private plans out of business by adopting, what in the free market world would be referred to as, a loss-leader strategy?  And we all know what happens once that happens.  A government run one-payer system that puts cost before care.  Options are good.  Naïvité is not.

And what might such a system cost?  According to the Times story, “The Obama transition team did not ask people how a new health care system should be financed, but several people here said that individuals and businesses should have to pay a small health care tax — some preferred to call it a ‘contribution’ — so that everyone could be covered.”

That’s nice.  A contribution.  Like buying Girl Scout cookies.  Well, not quite.  Consider the facts:

In the United Kingdom, British citizens pay 11 to 12 percent of their weekly income to finance the country’s healthcare system. And in Canada about a fifth of taxes collected in Canada go toward funding the country’s health system.  That's a lot of Thin Mints -- more than many Americans are willing to swallow.

In a recent poll  of over a thousand 18 to 24 year-old Americans – the so-called “millennial” generation -- conducted by the Center for Medicine in the Public Interest (the public policy home of drugwonks.com), 62% said they would not support any reforms that could increase physician wait times or restrict access to new medical treatments. Nearly two-thirds said they would not support additional government interference in the doctor-patient decision-making process.

Precisely the result of government healthcare. 

Oh, and a majority (51 percent) were not in support of any health care reforms that could raise their personal tax burden.

The Times reports that, The Obama transition team asked for ‘particularly poignant stories to highlight the need for health care reform,’ and such stories were abundant at the round table here.”

But can we afford healthcare reform by anecdote?


Ok to rate doctors and hospitals, but why are HMOs so reluctant to be rated in terms of how patient-centered they are? 

Blue Cross, Zagat to rank doctors
But the ratings will be based on nonmedical factors, and some question insurance link

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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