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A health care revolution threatened
“Personalized” medicines represent a health care revolution. Thanks to sophisticated and new diagnostic technologies, medical scientists have created hyper-targeted treatments keyed into the specific physiological traits of individual patients. These drugs are more effective than their conventional counterparts and less likely to cause adverse side effects. And they’ve proven valuable in the fight against diseases previously considered untreatable.
But drug developers need smart laws to flourish. Unfortunately, over just the last year, federal lawmakers have taken several steps that could smother pharmaceutical innovation and compromise private industry’s ability and willingness to pursue more lifesaving breakthroughs.
First, the good news. The market for personalized biopharmaceutical drugs is on track to double in size to $18 billion by 2019.
According to a recent industry survey from Tufts University, 94 percent of American biopharmaceutical companies are now investing in personalized treatments. Half of all drug prescription compounds now under development are personalized.
The sophisticated customization techniques deployed in the development of these treatments have proven particularly effective in the battle against “orphan” diseases – that is, illnesses afflicting fewer than 200,000 people.
There are 7,000 such diseases that affect more than 30 million Americans. In the 1970s, only 10 drugs were approved to treat orphan diseases. Today, there are more than 400, with an additional 450 are under development.
Most promisingly, federal authorities just approved the first drug ever to treat the underlying genetic flaw causing cystic fibrosis. Just a few decades ago, a child with cystic fibrosis was lucky to survive preschool. Today, the average patient lives well into their 40s.
These breakthroughs in personalized drugs are fundamentally changing how health care providers treat disease. But all that progress is now under acute threat from government.
For starters, Uncle Sam recently started up a “comparative effectiveness” research wing. This work is designed to determine if new, more expensive drugs are worth covering in programs like Medicare and Medicaid.
The fundamental flaw of comparative effectiveness research is that there is no such thing as an “average” patient. A treatment that might not make much of a difference for most patients could prove to be a life-saver for others.
If effectiveness research leads to more constrictive public insurance policies, enrollees that could benefit from advanced personalized drugs will be forced to pay for them on their own. Most simply can’t afford to do that. In effect, the government will be denying them access to this revolution in medicine.
Second, the government has created a new “academic detailing” program. It’s now sending its own representatives (usually local nurses) to doctors’ offices to provide an “academic” counterbalance to input from industry. Problem is, how and where these public representatives get their information is largely opaque. And, if a doctor treats publicly insured patients, these detailing officers have a perverse incentive to get her to choose less expensive drugs to save the program money. That’s not academic detailing – it’s government detailing.
Finally, the Federal Trade Commission is trying to micromanage the process by which new personalized medicines get named. This isn’t a minor issue. And approval delays could threaten the financial health of developers. They depend on sales to recoup their investment costs.
Drug developers will continue to make breakthrough, life-saving treatments as long as federal officials don’t needlessly intrude on their work. The year 2014 could be a banner year for drug development. But we need to get the policy right.
Peter J. Pitts is president of the Center for Medicine in the Public Interest and a former associate commissioner of the U.S. Food and Drug Administration.
The Food and Drug Administration is studying whether disclosure limited only to serious side effects would improve consumer understanding, according to an agency document. To cover lesser side effects, the FDA proposed simply adding a line about “potential additional risks.”
“Our hypothesis is that, relative to inclusion of the full major statement, providing limited risk information along with the disclosure about additional risks will promote improved consumer perception and understanding of serious and actionable drug risks,” the FDA said in its document.
The FDA plans to survey 1,500 study participants about ads with varying ranges of side-effect disclosure, and then measure their understanding of risk.
The underlying problem is that risk information is hidden in plain sight by not being in plain English. Risk information is neither designed nor delivered to be user-friendly. At present it is designed to be “in compliance.” And that has to change.
When it comes to DTC print ads, the joke inside the FDA (and in many regulated industry review offices) is that the Brief Summary is like the Holy Roman Empire – it is neither brief nor a summary. So, when it comes to TV ads, hopefully the agency is asking the right questions. Fair Balance and Adequate? “Fair” for whom and “Balanced” how? Adaquate Provision? Doesn'tlook like it.
Working together, the FDA and industry can make a difference. DTC can be a more potent, precise, and persuasive tool on behalf of the public health. And rather than rubbing the lamp and wishing, we need to burn the midnight oil and work harder to make it a reality—because an educated consumer is not only a better customer, but a more compliant and adherent patient.
FDA Commissioner Peggy Hamburg visits India and confirms that honesty is the best policy. The feeling is not entirely reciprocated.
It boils down to a simple, foundational question: Can there be more than one global standard of pharmaceutical quality?
“If I have to follow U.S. standards in inspecting facilities supplying to the Indian market,” G. N. Singh, India’s top drug regulator, said in a recent interview with an Indian newspaper, “we will have to shut almost all of those.”
Does that mean US standards are too high or that Indian ones are too low? Well, where you stand depends on where you sit. And if you’re sober and sitting up straight, the answer is obvious.
According to a May 2012 article in The Lancet,
“To say that India's drug regulatory authority, the Central Drugs Standard Control Organisation (CDSCO)-whose remit includes new drug approval, licensing of manufacturing facilities, and regulation of drug trials-is not fit for purpose seems a gross understatement.”
The CDSCO has a staff of 323, about 2 percent the size of the FDA, and its authority is limited to new drugs. According to a report in the New York Times, “The making of medicines that have been on the market at least four years is overseen by state health departments, many of which are corrupt or lack the expertise to oversee a sophisticated industry. Despite the flood of counterfeit drugs, Mr. Singh, India’s top drug regulator, warned in meetings with the FDA of the risk of overregulation.”
Hardly.
Per the Times, “This absence of oversight, however, is a central reason India’s pharmaceutical industry has been so profitable. Drug manufacturers estimate that routine F.D.A. inspections add about 25 percent to overall costs. In the wake of the 2012 law that requires the F.D.A. for the first time to equalize oversight of domestic and foreign plants, India’s cost advantage could shrink significantly.”
This profits-over-patients philosophy is entirely consistent with earlier “passing the rupee” comments of India’s Deputy Drug Controller, S. Eshwar Reddy.
When asked if Indian manufacturers -- which produce more than 40 per cent of the API used in the US and Europe -- should be more sympathetic with Western guidelines and regulations, Reddy said the opposite should be true.
He said any additional requirements made are the sole responsibility of the authority that issues them.
“If the importing country has specific GMP requirements, that is their responsibility to audit the facilities. It is the responsibility of the importing country not the exporting country.”
Per the Times, “The unease culminated Tuesday when a top executive at Ranbaxy — which has repeatedly been caught lying to the F.D.A. and found to have conditions such as flies “too numerous to count” in critical plant areas — pleaded with Dr. Hamburg at a private meeting with other drug executives to allow his products into the United States so that the company could more easily pay for fixes. She politely declined.”
How do you say chutzpah in Hindi?
Or Chinese? Or Arabic? Or Russian? Or Zulu?
New research conducted by CVS Caremark and Brigham and Women's Hospital (and published online in Health Affairs) identifies five key features of popular Value-Based Insurance Design (VBID) plans that are associated with the greatest impact on medication adherence. The study, which will also appear in the journal's March issue, was funded by a grant from the Robert Wood Johnson Foundation's Changes in Health Care Financing and Organization (HCFO) Initiative.
The philosophy is sound – but the factors are a bit fuzzy. And this isn’t surprising as the VBID model is still in in its design infancy.
Rather than encouraging patients to actively consider and bear the cost of prescription medications via copayments, co-insurance and deductibles, VBID plans reduce the cost to the patient for medications that offer higher clinical benefit.
The theory is that using medication that actually improves health outcomes will reduce overall health care spending. Correct! For example, patients in a VBID plan who have a chronic disease such as high blood pressure would have their out-of-pocket costs (e.g., copay) significantly reduced or eliminated for essential medications to treat their condition.
This is important – but it’s not new. As I wrote almost exactly four years ago in an op-ed:
Over the past several years, insurance companies have become increasingly reluctant to foot the bill for brand-name medications. Indeed, since 2000, co-pays have increased four times faster than prescription drug prices.
Patients respond to higher co-pays by skipping their meds more often. In 2003, researchers at the University of Oregon studied the effects of introducing a $2 to $3 co-pay for prescription meds among 17,000 patients. Adherence to treatment dropped by 17 percent.
Some insurers are even refusing to cover new prescription drugs. According to a study from Wolter Kluwer Health, insurers’ denial rate for brand-name meds was 10.8 percent at the end of 2008 — a 21 percent jump from the year before.
Abandoning treatment — a practice known as "non-adherence” — has serious consequences for patient health. For instance, people with hypertension who neglect their meds are more than five times more likely to experience a poor clinical outcome than those who don’t. Heart disease patients are 1.5 times more likely.
It also results in higher medical costs, as patients who go off their meds often end up in the hospital. Minor conditions that might have been controlled by inexpensive medications can sometimes balloon into life-threatening illnesses that require surgery or other costly treatments.
This makes sense. After all, a daily cholesterol-lowering drug is far less expensive than emergency heart surgery.
(My complete op-ed can be found here.)
Now, as to the “factors.”
According to Niteesh Choudhry, MD, PhD, associate physician, Division of Pharmacoepidemiology and Pharmacoeconomics, Brigham and Women's Hospital and associate professor, Harvard Medical School and the lead author of the study, "The results show that several specific features can improve adherence from between two to five percentage points and this information can help influence how future copayment reduction plans are structured for optimal benefit."
The researchers evaluated 76 VBID plans provided by CVS Caremark to 33 unique plan sponsors and involving more than 274,000 patients. Based on the analysis, five key features were found to have a greater impact on adherence. These included:
- More generous VBID plans (e.g., those plans that had no cost-sharing for generic drugs and low monthly copayments of < or = $10 or co-insurance rates of < or = $15 for brand-name medications),
- Plans that targeted high-risk patients,
- Plans that had concurrent wellness programs,
- Plans that did not have concurrent disease management programs, and
- Plans that made the benefit available only by mail order, offering 90 day prescriptions.
That’s a lot of work by a lot of smart folks to develop some pretty fuzzy factors. But it’s a good start.
As for the future, your task is not to foresee it, but to enable it.
-- Antoine de Saint-Exupery
Conflict of Interest (COI)? Only for thee but not for PCORI.
From the pages of Current Medicine:
Industry conflicts arise at PCORI threatening any real comparative effectiveness research
The Patient Centered Outcome Research Institute (PCORI) was created by the PPACA “ObamaCare” law in 2010. Well-funded with approximately $3 Billion over ten years, the mission was, among other things, supposed to be to conduct comparative effectiveness research (CER) that would determine whether costly therapies are any better than cheaper alternatives.
The rise of CER has been one of the most feared developments by the drug and device industries. To avoid powerful lobbying efforts that could have resulted in de-funding and the death of PCORI before it got started, the institute steered away from even hinting at conducting CER. Now, almost four years later, PCORI is finally funding CER research. However, critics, such as former White House Director of Office of Management and Budget, Peter Orzag, say that the money spent by PCORI on CER is still not enough.
Meanwhile, a leading doctor in charge of PCORI research strategies, Harlan Krumholz, MD, a cardiologist at Yale, helped create The Yale University Open Data Access project, or “YODA”, and is the Principal Investigator. The YODA mission is to make clinical trial data more open and accessible to researchers.
Medtronic was one of the first corporations to pay YODA to analyze clinical data on the spine fusion growth factor product called InFuse. Recently, Johnson and Johnson (JNJ) signed up as the next large corporate client of YODA.
The drug and device industries have long been adept at muting the regulatory influences of healthcare agencies, such as the FDA, AHRQ, and CMS, using a variety of tactics. The “golden revolving door” hires former government regulators into lucrative jobs at JNJ, etc. Also, academic medical center “institutes” designed to keep the industry honest then become corrupted by accepting industry funding.
Since Dr. Krumholz is the senior clinical decisionmaker for both the Yale YODA, and the ObamaCare-created PCORI, conflicts of interest would arise if the industry began funding YODA. For examples, PCORI could be conducting CER on the various hip implant products and conclude that the JNJ DePuy device is no better than a less costly hip implant, or a Medtronic coronary stent might be found by PCORI research to be harmful and ineffective. But if Medtronic and JNJ began to pay millions of dollars to Yale’s YODA, then Dr. Krumholz would have a significant biasing force against initiating any CER at his other job, PCORI, that might harm sales of JNJ or Medtronic products.
In a brief interview with Dr. Krumholz about how he is managing these conflicts of interest, he replied, “Right – (there is) no direct connection (between YODA and PCORI research)– just a potential COI. All I can say is that it is disclosed. And I note that PCORI has people with different relationships. And that most of what PCORI does is in public view so people can assess for themselves.”.
Dr. Krumholz is correct in pointing out that many other members of the PCORI executive team and board have reported conflicts of interest accepting financial support from drug and device companies. We will have more on that in future reports.
The Executive Director of PCORI, Joe Selby, MD PhD, did not reply to our emails in time for this publication.Think governments can set prices and interfere in markets with no consequences? Think again.
According to a just released analysis by the United States Government Accountability Office, the FDA is doing a better job preventing drug shortages.
Per CDER Deputy Director, Doug Throckmorton’s Congressional testimony, new shortages declined in 2012 for the first time in a number of years and 2013 data indicated a similar downward trend. He said the agency’s new authorities (granted under a 2012 law) have allowed the FDA to manage shortages more aggressively.
In addition to new actions, the FDA has been more willing to demonstrate regulatory flexibility.
For example, in some cases where particles were found to be contaminating a drug that was in short supply, the agency allowed the company to filter the drug to avoid disrupting supplies instead of shutting down the production line altogether.
But, according to the New York Times,
Economic factors are also a contributing factor. Narrow profit margins are making some drug companies reluctant to invest in fixing old production facilities. Changes in Medicare reimbursement and the role of group purchasing organizations, which buy drugs on behalf of hospitals, could also be contributing, by further reducing prices that producers get for the drugs.
(This is almost a direct citation from the June 2012 Center for Medicine in the Public Interest, "Fixing Drug Shortages.")
While the FDA’s new authorities are both timely and important, there are many pieces to the drug shortages problem – not the least of which is that (when it comes to hospital injectables) 30% of manufacturing capacity is off-line due to FDA inspection issues.
That’s a lot of capacity. In fact, according to the agency, 43% of reported potential shortages were due to manufacturing problems. Safety is non-negotiable and alleviating a shortage by shorting GMPs is a bad and dangerous pathway. Expediency causes as many problems as it solves.
That being said, regulatory discretion must be part of the solution – and per Throckmorton, it is. With 30% of production capacity off-line because of FDA issues, the agency must continue to work with manufacturers to find creative, science-based solutions. If you create a "science- and risk-based action plan," industry can often address quality issues without disrupting supplies of essential drugs.
But who inspects the inspectors? Per that 30% of manufacturing capacity off-line due to FDA issues, perhaps the FDA should undertake an agency audit to see why there’s been such a jump in GMP issues. It’s hard to believe that year-over-year, production quality control has suffered such a significant lapse. Is there something wrong in the way FDA inspectors (many of them still wet behind the ears and eager to please) are doing their jobs? It’s a question worth asking – and answering.
But the real headline (alluded to but not directly addressed in the New York Times article) is that artificially low prices are the major cause drug shortages.
Most of the drug shortages that occur in the U.S. arise in the generics market, where profitability is fairly low For many of these drugs the market can only sustain a handful of manufacturers -- sometimes just one or two. So, when supply disruptions occur -- caused by manufacturing violations, production delays, shipping problems or ingredient issues -- there aren't a lot (or in many cases any) additional producers in the market to pick up the slack.
But the key factors behind drug shortages are perverse economic incentives. Consider the October 2011report by the US Department of Health & Human Services, Economic Analysis of the Causes of Drug Shortages.
HHS (the Obama HHS) mostly blames a dysfunctional marketplace for drug shortages. In fact the HHS report does more than blame a 'dysfunctional market', it explains what is behind the problem:
"...drugs that subsequently experienced a shortage are those in which the volume of sales was declining in the 2006-2008 period prior to the shortages."
It goes on to note that, "Analysis of average sales prices shows that shows that oncology sterile injectable drugs that experienced shortages since 2008 decreased in price from $56.17 per unit in Q1 2006 to $37.88 per unit in Q1 2011. Oncology sterile injectable drugs that have not experienced shortages have had relatively stable prices over this period."
In plain English: artificially low prices caused the manufacturing decline of the drugs that are in shortage and a variety of perverse government regulations (ranging from Medicaid reimbursement rates to the benighted 340B program) are causational.
Where there is still a profit left, you rarely see shortages.
Congrats to the FDA for a job well begun. But the issue of drug shortages (and particularly the economic issues that must be addressed) mustn’t be left half done.
Excellent cover story in today’s edition of BioCentury on the February 4th FTC hearing on competitiveness issues surrounding biosimilars.
Steve Usdin calls it like he sees it – and he sees it pretty clearly.
Agendas. Agendas. Agendas.
The headline reads, Biosimilar schism.
Some choice quotes:
For years, innovator biologics manufacturers battled companies that wanted to create an American biosimilars industry, skirmishing over the scientific and legal standards for demonstrating similarity.
Now, however, the biggest conflicts are among biosimilars developers. The growing ranks of biosimilars developers and manufacturers have split roughly into two camps. One is pursuing a business model based on branded biosimilars that will require substantial investment in marketing and sales, and the other is hoping to create interchangeable biologics that could be substituted for innovator products with little or no marketing.
While supporters of the principles for state substitution laws portray them as applying equally to innovator and interchangeable products, that view was rebuffed by companies advocating for a biosimilars market that would allow them to avoid marketing costs and compete primarily on cost.
Bruce Leicher, SVP and general counsel at Momenta Pharmaceuticals Inc., told FTC that the substitution principles are an effort to ask “states to join in a commercial marketing campaign to disparage interchangeable biologics.”
Notification requirements would “restrict substitution and provide notice to doctors to intervene and be concerned about FDA approved biologics,” he said. Leicher accused supporters of the state legislation proposal of attempting to blur the distinction between biosimilars and interchangeable biologics. “The notification provisions are really designed to make the point that interchangeable biologics really aren’t interchangeable, they’re different,” he said.
What Leicher doesn’t seem to understand (or what he understands but wants to purposely obfuscate) is that interchangeable biologics are different from their innovator priogenitors – but bioequivalent enough to be therapeutically interchangeable (as per the FDA).
That's not a "scare tactic," that’s just a fact. Another fact is there can be more than one winner – the most important being the patient. The FTC hearing often sounded like the Biosimilar Hunger Games.
Here’s a link to Usdin’s complete Biosimilar schism.
For more on the FTC hearing, see The Sic et Non of Biosimilars and be sure to tune in to BioCentury This Week, where Usdin will interview with Geoff Eich, Amgen’s Executive Director of R&D Policy and Craig Wheeler, CEO of Momenta. The show will be broadcast and available on the web on Sunday
Dr. Michael Weber, Chairman of the Center for Medicine in the Public Interest (among other appointments), is the chief author of new guidelines for the treatment of hypertension, perhaps the most common life-threatening risk factor around the World. The guideline is an official statement of the American Society of Hypertension and the International Society of Hypertension.
Dr. Rick Turner, senior fellow at CMPI (the least of his many accomplishments), has penned (along with Philip Galtry is Vice President and Cardiovascular Therapeutic Strategy Head, Cardiovascular and Metabolic Therapeutic Delivery Unit, Quintiles) a primer to the ASH/ISH guidelines. It appears in the current issue of the Journal for Clinical Studies.
Turner and Galtry’s commentary can be found here.
The ASH/ISH guidelines can be found here.
The Center for Medicine in the Public Interest has heart and is in the heart of the battle for better, more personalized CVD diagnosis and treatment, and outcomes.
Representative Rosa DeLauro once again demonstrates her ignorance.
According to a press release, “Congresswoman Rosa DeLauro (D-CT) today outlined her concerns over accelerated drug approval in a letter to Food and Drug Administration (FDA) Commissioner Margaret Hamburg. She also asked Hamburg for details on device safety to ensure that women and families can rely on safe and effective drugs and medical devices that improve health and wellness. DeLauro is a former chairwoman of the subcommittee responsible for funding the FDA.”
Didn’t she vote for PDUFA V, which put into place many of the accelerated approval pathways she is now criticizing?
If Representative DeLauro believes no drug should be introduced into the marketplace until it is completely understood then there would be no drugs in the marketplace. When it comes to serious and life-threatening diseases, that is nothing short of a death sentence for tens of thousands of Americans.
It should also be noted that patient groups tend to be the most ardent supporters of the accelerated approval pathways and patients with more dangerous diseases are more willing to accept taking treatments that may have higher risks
The good news is that Peggy Hamburg once again demonstrates both her knowledge and her ability to share it in a politically palatable manner.
Why FDA Supports a Flexible Approach to Drug Development
Posted on February 6, 2014 by FDA Voice
By: Margaret A. Hamburg, M.D.
We all know that just as every person is different, so too is every disease and every drug.
so we weren’t surprised by the results of a new study published in the Journal of the American Medical Association. The study found that FDA used a range of clinical trial evidence when approving 188 novel therapeutic drugs for 208 indications (uses) between 2005 and 2012. These results are entirely consistent with our regulatory mandate. We believe varying approaches to clinical studies to support drug approval is good news, not bad.
Data to support the approvals studied were based on a median of two pivotal trials per indication. A pivotal trial presents the most important data used by FDA to decide whether to approve a drug.
But when the authors looked more closely, they found that more than a third of these drugs were approved on the basis of a single pivotal clinical trial, while still other trials involved only small groups of patients for shorter durations. Of the approvals studied, the new drug was compared with existing drugs on the market only about 40 percent of the time.
The authors concluded that, based on these results, the ways in which FDA arrived at those approvals “vary widely in their thoroughness.” Or, in the words of one study author, “Not all FDA approvals are created equally.” Although I don’t think it was actually the author’s intent, a number of commentators framed this as criticism. But I would be more troubled if FDA used a rigid, “one size fits all” approach.
People with serious or life-threatening illnesses, particularly those who lack good alternatives, have told us repeatedly that they are willing to make some trade-offs in order to gain access.
And, of course, “thoroughness,” such as whether a clinical trial is large enough, is in the eyes of the beholder. There is no reason to expect drugs to be tested on similar numbers of patients, regardless of the disease.
Variation in approach to clinical studies demonstrates FDA’s innovative and flexible approach to drug development and approvals. Such an approach was specifically adopted by Congress in the Food and Drug Administration Modernization Act in 1997 and, most recently, in the Food and Drug Administration Safety and Innovation Act in 2012.
The FDA of today works with sponsors of new drugs to design a development and review pathway for each drug that best reflects the disease and patients it is intended to treat, the drug itself, and other treatment options. Some of the factors that enter into our calculus include whether the drug treats a rare or serious disease or addresses an unmet need and any previous knowledge we might have about the drug.
Thus, for example, FDA approved Imbruvica (ibrutinib), a treatment for mantle cell lymphoma, last year based on an “open-label, single-arm trial,” which means that every patient received the treatment and both patients and researchers knew they were receiving it. The results were compared to how well the 111 participating patients had responded to previous treatment for their disease.
And Elelyso (taliglucerase alfa) – for Gaucher disease – was an orphan drug approved in 2012 based on two trials with 56 patients.
In contrast, some trials require large numbers of patients to demonstrate a drug’s effects. This is often the case in studies in patients with a chronic condition such as cardiovascular disease, where larger populations are studied to capture treatment effects.
No matter what clinical trial design is chosen, the Agency always applies the same statutory approval standards of safety and efficacy to all drugs seeking to be marketed in the United States.
Increased flexibility does not mean abandoning standards, and it certainly does not mean abandoning science. Just the opposite. We need to employ the best science in ways that will increase efficiency, productivity and our shared ability to find creative solutions to the challenges that confront us.
At the end of the day, that is just smart regulation – ensuring that patients can more rapidly have access to the best that science has to offer.
Margaret A. Hamburg, M.D., is the Commissioner of the Food and Drug Administration
Expectations for the FTC’s February 4th hearing on biosimilars were low and, by that measure, the meeting didn’t disappoint.
What was surprising was the degree of dissimulation and desperation portrayed by certain speakers. Also surprising (and not in a good way) was the unexpected naivety of the so many so-called “experts.” The term “dangerous idiots” comes to mind – not to put too fine a point on it. What was disappointing (but, alas, not surprising) was the one-sided nature of the presentations.
This really shouldn’t come as a surprise considering that the FTC’s excuse for holding this hearing was to focus on issues that might constrain competition. Unfortunately, too many of the presenters viewed safety and patient outcomes as a constraint to competition. Exactly zero FDA officials or physician organizations testified. Draw your own conclusions.
And, in a sort of twisted way safety and outcomes are a constraint to competition insofar as they have a direct impact on physician prescribing decisions. Nowhere was this more fiercely debated than in discussions of various examples of state legislation and the issue of biosimilar naming.
Let’s take each in turn.
On the state legislation front, more than a few speakers made the point that physician notification was anti-competitive because it somehow besmirches the reputation of generic drugs (and would do the same to biosimilars). Bruce Leicher (Senior Vice President & General Counsel for Momenta Pharmaceuticals) called physician notification a “tactic” to scare physicians. And Krystalyn Weaver (Director of Policy and State Relations, National Alliance of State Pharmacy Associations), pointed specifically at a Tennessee law that requires physician notification for pharmacy-based switching of epilepsy medications. She cited data that showed this requirement results in increased state spending for epilepsy medications (translation: increased physician insistence on innovator products). What she did not discus was the fact that epilepsy drugs fall into the category of Narrow Therapeutic Index medications.
If there had been an FDA speaker, there might have been appropriate comments about the FDA's Pharmaceutical Science and Clinical Pharmacology Advisory Committee that debated and determined that the bioequivalence specifications should be tightened for, among other categories, generic versions of epilepsy medications – and that FDA officials presenting at that adcomm signaled strong agency support for the move.
Anti-competitive or pro-patient? You be the judge.
Steven Miller (Senior Vice President & Chief Medical Officer, Express Scripts), said he had research showing that physicians don’t want information from pharmacists telling them which patients have filled a prescription – one of the key stumbling blocks to addressing the quagmire of adherence. (Miller was unable to cite the source of this data point.) Thus, according to Miller’s logic, physicians will not care to be notified about a pharmacy-level switch of an innovator biologic to a biosimilar (interchangeable or otherwise).
Well, there are a lot of things “physicians don’t want” – like having to adjust to the world of electronic health records – but that doesn’t mean things can’t (indeed must!) change.
It’s also important to mention that, in it’s 1979 report on generic drug substitution, the FTC concluded, “increased communication (as well as lower prices) may explain why most pharmacists report that product selection laws have had a positive effect on their relations with patients”
(Or as Sumant Ramachandra, Senior Vice President & Chief Scientific Officer, Hospira, commented, “Communications fosters confidence.”)
Anti-competitive or pro-patient? You be the judge.
As Geoffrey Eich (Executive Director, R&D Policy, Amgen) commented, “Hubris is for the uninitiated.”
Eich was one of the few voices for patient safety as a tool for competitiveness. He warned against “overly narrow or false choices” and asked:
* Must we choose between increased access or the ability to monitor specific medicines reliably?
* Must we choose between lower cost medicines or for patients to have a complete and accurate medical record?
* Must we choose between vigorous competition or enabling manufacturers to voluntarily stand accountable to the patients we serve?”
Why not transparently label biosimilars to engender patient and physician confidence?
Why not ensure accurate patient medical records that clearly identify specific products?
Why not select distinguishable non-proprietary names for distinguishable drug substances?
Increased access to biologic medicines can and should include policies appropriate for these classes of medicines. We believe in “and” not “or.”
Let’s be clear – an inability to identify specific biologic medicines reliably jeopardizes all biologic programs equally. Such a preventable lapse would constitute an inexcusable, unsustainable, anti-consumer approach to policy.
Momenta’s Leicher’s called out Eich’s comments as representative of the “campaign against biologics” being used to “scare” physicians away from biosimilars. Even though Amgen is going to be in the biosimilars business?
Leigh Purvis (Senior Strategic Policy Advisor, AARP) pointed to both state legislation requiring physician notification of biosimilars as well as differential naming systems as “roadblocks to competition.”
Does the AARP really believe that safety and, well, knowledge are roadblocks to competition?
Amgen’s Eich spoke to “and not or.” The philosophical father of this concept is the “sic et non” (“yes and no”) of the 12th Century theologian Pierre Abélard. Abélard outlined rules for reconciling contradictions, the most important of which is noting the multiple significations of a single word.
In the case of biosimilars and the FTC, that word is “safety.”
Those who view physician notification and distinct naming as anti-competitive are addressing these issues through a single dimension.
And it just ain’t that simple.
As BioWorld Today reports,
In the end, the FDA will base its decision on what’s best for public health – not on commercial interests, Pitts said. “It isn’t a question of tactics or strategies trying to squash biosimilars in the womb,” he added, responding to some of the comments raised at the FTC workshop that suggested concerns about pharmacovigilance were simply an effort by brand companies to protect their market.
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.
