Cost: The neglected adverse event / side effect in trials of for-profit pharmaceuticals and devices

Amid press releases and conference calls today pertaining to the release of data on two trials of the investigational drug pirfenidone, one analyst's comments struck me as subtly profound. She was saying that in spite of conflicting data on and uncertainty about the efficacy of the drug (in the Capacity 1 and Capacity 2 trials - percent change in FVC [forced vital CAPACITY] at 72 weeks was the primary endpoint of the study) IPF is a deadly and desperate disease for which no effective treatments exist (save for lung transplantations if you're willing to consider that an effective treatment) and therefore any treatment with any positive effect however small and however uncertain should be given ample consideration, especially given the relative absense of side effects of pirfenidone in the Capacity trials.

And I thought to myself - "absense of side effects?" Here we have a drug that, over the course of about 1.5 years reduces the decline in FVC by about 60ccs (maybe - it did so in Capacity 2 but not in Capacity 1) but does not prolong survival or dyspnea scores or any other outcome that a patient may notice. So, I'm picturing an IPF patient traipsing off to the drugstore to purchase pirfenidone, a branded drug, and I'm imagining that the cash outlay might be perceived by such a patient as an adverse event, a side effect of sorts of using this questionably effective drug to prevent an intangible decline in FVC. The analyst's argument distilled to: "why not, there's no drawback to using it and there are no alternatives", but this utterly neglected the financial hardships that many patients endure when taking expensive branded drugs and ignored alternative ways that patients with IPF may spend their income to benefit their health or general well-being.

This perspective is even more poignant when we consider the cases of "me-too" drugs that add marginally to the benefits or side effect profiles of existing drugs, and which are often approved on the basis of a trial comparing them to placebo rather than existing generic alternatives. One of the last posts on this blog detailed the case of Aliskiren, and I am reminded of the trial of Tiotropium published in the NEJM in October, among many other entire classes of drugs such as the proton pump inhibitors, antidepressants, antihistamines, inhaled corticosteroids, antihypertensives, ACE-inhibitors for congestive heart failure, and the list goes on.

Given todays economy, soaring healthcare costs, and increasing financial burdens and co-pays shouldered by patients especially those of limited economic means or those hit hardest by economic downturns, we can no longer afford (pun intended) to ignore the financial costs of "me too" medications as adverse events of the use of these drugs when cheaper alternatives exist.

In terms of trial design, we should demand that new agents be compared to existing alternatives when those exist, and we need to develop a system for evaluating the results of a trial that does not neglect the full range of adverse effects experienced by patients as a result of using expensive branded drugs. Marginally "better" is not better at all if it costs ridiculously more, and the uncertainty relating to the efficacy of a drug must be accounted for in terms of its value to patients, especially when costly.

"Off-Label Promotion By Proxy": How the NEJM and Clinical Trials are Used as an Advertising Apparatus. The Case of Aliskiren

In the print edition of the June 5th NEJM (mine is delivered almost a week early sometimes), readers will see on the front cover the lead article entitled "Aliskiren Combined with Losartan in Type 2 Diabetes and Nephropathy," and on the back cover a sexy advertisement for Tekturna (aliskiren), an approved antihypertensive agent, which features "mercury-man", presumably a former hypertensive patient metamorphized into elite biker (and perhaps superhero) by the marvels of Tekturna. Readers who lay the journal inside down while open may experience the same irony I did when they see the front cover lead article juxtaposed to the back cover advertisement.

The article describes how aliskiren, in the AVOID trial, reduced the mean urinary albumin-to-creatinine ratio as compared to losartan alone. There are several important issues here. First, if one wants to use a combination of agents, s/he can use losartan with a generic ACE-inhibitor (ACEi). A more equitable comparison would have pitted aliskiren plus losartan against [generic] ACEi plus losartan. The authors would retort of course that losartan alone is a recommended agent for the condition studied, but that is circular logic. If we were not in need of more aggressive therapy for this condition, then why study aliskiren in combination for it at all? If you want to study a new aggressive combination, it seems only fair to compare it to existing aggressive combinations.

Which brings me to another point - should aliskiren be used for ANY condition? No, it should not. It is a novel [branded] agent which is expensive, for which there is little experience, which may have important side effects which are only discovered after it is used in hundreds of thousands of patients, and more importantly, alternative effective agents exist which are far less costly adn for which more experience exist. A common error in decision making occurs when decision makers focus only on the agent or choice at hand and fail to consider the range of alternatives and how the agent under consideration fares when compared to the alternatives. Because aliskiren has only been shown to lower blood pressure, a surrogate endpoint, we would do well to stick with cheaper agents for which there are more data and more experience, and reserve use of aliskiren until a study shows a long-term mortality or meaningful morbidity benefit.

But here's the real rub - after an agent like this gets approved for one [common] indication (hypertension), the company is free to conduct little studies like this one, for off-label uses, to promote its sale [albeit indirectly] in patients who do not need it for its approved indication (BP lowering). And what better advertising to bring the drug into the sight of physicians than a lead article in the NEJM, with a complementary full page advertisement on the back cover? This subversive "off-label promotion by proxy", effected by study of off-label indications for which FDA approval may or may not ultimately be sought, has the immediate benefit of misleading the unwary who may increase prescriptions of this medication based on this study (which they are free to do) withouth considering the full range of alternatives.

My colleague David Majure, MD, MPH has commented to me about an equally insidious but perhaps more nefarious practice that he noticed may be occuring while attending this year's meeting of the American College of Cardiology (ACC). There, "investigtors" and corporate cronies are free to present massive amounts of non-peer reviewed data in the form of abstracts and presentations, much of which data will not and should not withstand peer review or which will be relegated to the obscurity of low-tier journals (where it likely belongs). But eager audience members, lulled by the presumed credibility of data presented at a national meeting of [company paid] experts will likely never see the data in peer-reviewed form, and instead will carry away the messages as delivered. "Drug XYZ was found to do 1-2-3 to [surrogate endpoint/off-label indication] ABC." By sheer force of repetition alone, these abstracts and presentations serve to increase product recognition, and, almost certainly, prescriptions. Whether the impact of the data presented is meaningful or not need not be considered, and probably cannot be considered without seeing the data in printed form - and this is just fine - for sales that is.

(Added 6/11/2008: this pre-publication changing of practice patterns has been described before - see http://jama.ama-assn.org/cgi/content/abstract/284/22/2886 .)

The novel mechanism of action of this agent and the scientific validity of the AVOID trial notwithstanding, the editorialship of the NEJM and the medical community should realize that science and the profit motive are inextricably interwoven when companies study these branded agents. The full page advertisement on the back cover of this week's NEJM was just too much for me.