Drugs elude cookie-cutter approval process
The initiative, called TransCelerate BioPharma, is headed up by J&J alum Garry Neil. Its first project focuses on clinical trial execution and will include creating an investigator site, developing clinical data standards and establishing a comparator drug supply model, according to a statement. More tangible details were not forthcoming, other than the comment that the goal is to help speed drugs to market, but the news release quoted FDA Director Janet Woodcock as saying the collaboration “has the promise to lead to new paradigms and cost savings in drug development, all of which would strengthen the industry.”
In other words, it appears to be a project that tries to pin down the very thing that has roiled industry watchers when it comes to the FDA's review process: predictability and its seeming absence. Yet experts have told MM&M in the past that uniform standards won't create an if-then scenario in which the FDA will approve drugs based on meeting the demands of a checklist.
“Predictability assumes that you can approve drugs in a cookie-cutter kind of fashion and you just can't do that,” Dr. Steven Nissen, a frequent member of FDA advisory panels and chairman of the Cleveland Clinic's cardiology department, told MM&M. “It's always going to be a nuanced decision. It's always going to be a careful evaluation of benefit vs. risks,” he added.
The agency has come under a mixed review, with critics saying the FDA is approving drugs without adequately considering a drug's risks. Advocacy group Public Citizen is suing the agency over its approval of the Alzheimer's drug Aricept 23, an approval which its deputy director of the Health Research Group Michael A. Carome told MM&M was made even though the agency acknowledged that the drug didn't meet the standards the regulators demanded even before it came up for review. The drug, at a higher dose of the 5- and 10-mg versions which have gone generic, has been linked to nausea, vomiting and dizziness, but with little benefit, according to Carome and other critics.
“This represents an extreme example of the FDA's failure to properly weigh the evidence and only approve drugs when there's clear evidence [that] benefit outweighs the risk,” Carome said.
Nissen, who was not part of the Aricept 23 review and does not specialize in Alzheimer's, said that the risk-benefit equation had a degree of flex that depends on who's doing the calculation.
“I think the most salient example is cancer drugs. You're dealing with a disorder with often a lethal disorder. These drugs that are used to treat cancer are pretty toxic, but the disease is a pretty lethal disease,” he said.
Former FDA Associate Commissioner Peter Pitts said the FDA gets knocked in part because it doesn't do a very good job at explaining how the drug review and approval process works.
Among the steps is a clinical trial design that the FDA approves before it's kicked off. Pitts noted that hitting all the right design notes doesn't guarantee a panel's endorsement if the results raise questions.
“Those questions need to be answered.” Pitts highlighted two other components of the FDA's decision-making process which includes basing its decisions on “the twin pillars of safety and efficacy,” a balance he said is important because “you can't look at safety independent of benefit.” He also noted that the committees are comprised of experts that see data differently, which can add nuance to discussions.
But nuance or heated argument doesn't always mean pushback. The May debate over the blood thinner Xarelto was a contentious committee hearing, in which panelists took serious issue with the quality of the data presented. The drug passed with a panel endorsement despite the attacks on missing patients and an inability to state just how many patients may have died during the clinical trials.
Adding to the fuzziness is that what constitutes acceptable risk is also subject to change. Recent examples: weight-loss drugs Qsymia and Belviq which failed to clear the FDA the first time they were up to review, which was before the CDC declared obesity an epidemic.
Pitts said one way to provide continuity would be to use the same requirements for drugs that have the same purpose and said that this industry push is not about lower standards, but about making smart investments. He said ambiguity in that regard is "not fair and that's not good science." He said it could also help within the wider context of creating a single standard that can be used for both international and domestic regulatory review.
Such a change will not remove risk, and both Pitts and Nissen said results can't simply be accepted because panelists didn't know what to ask before results roll in. Even when a clinical trial meets expectations and has the FDA's go-ahead, Nissen noted that new risks are bound to surface because clinical trials are little more than real-world approximations. “You have done a series of studies with a drug in a few thousand people and the drug may be used in a million . . . there is no way to be absolutely certain whether a drug is going to be helpful or harmful,” he explained.
Nissen said he understands the drug industry's frustration with the case-by-case approach, but he said it can't be avoided. “It's about their investment and their bottom line and I completely understand that but the FDA has a different mission and that mission is to protect public health.”