The FDA’s Magic Meeting

Can you shed three years of pipeline flab with this one simple trick?

"There’s no trick to it ... it’s just a simple trick!" -Brad Goodman

Getting a drug to market is hard. It is hard in every way a thing can be hard: it takes a long time, it's expensive, it involves a process that is opaque and frustrating, and failure is a much more likely outcome than success. Boston pioneers pointing their wagons west in 1820 had far better prospects for seeing the Pacific Ocean than a new drug, freshly launched into human trials, will ever have for earning a single dollar in sales.

Exact numbers are hard to come by, but the semi-official industry estimates are: about 6-8 years, a couple billion dollars, and more than 80% chance of ultimate failure.

Is there a secret handshake? Should we bring doughnuts?
(We should probably bring doughnuts.)

Finding ways to reduce any of those numbers is one of the premier obsessions of the pharma R&D world. We explore new technologies and standards, consider moving our trials to sites in other countries, consider skipping the sites altogether and going straight to the patient, and hire patient recruitment firms* to speed up trial enrollment. We even invent words to describe our latest and awesomest attempts at making development faster, better, and cheaper.

But perhaps all we needed was another meeting.

A recent blog post from Anne Pariser, an Associate Director at FDA's Center for Drug Evaluation and Research suggests that attending a pre-IND meeting can shave a whopping 3 years off your clinical development timeline:

For instance, for all new drugs approved between 2010 and 2012, the average clinical development time was more than 3 years faster when a pre-IND meeting was held than it was for drugs approved without a pre-IND meeting. 

For orphan drugs used to treat rare diseases, the development time for products with a pre-IND meeting was 6 years shorter on average or about half of what it was for those orphan drugs that did not have such a meeting.

That's it? A meeting? Cancel the massive CTMS integration – all we need are a couple tickets to DC?

Pariser's post appears to be an extension of an FDA presentation made at a joint NORD/DIA meeting last October. As far as I can tell, that presentation's not public, but it was covered by the Pink Sheet's Derrick Gingery on November 1.  That presentation covered just 2010 and 2011, and actually showed a 5 year benefit for drugs with pre-IND meetings (Pariser references 2010-2012).

Consider the fact that one VC-funded vendor** was recently spotted aggressively hyping the fact that its software reduced one trial’s timeline by 6 weeks. And here the FDA is telling us that a single sit-down saves an additional 150 weeks.

In addition, a second meeting – the End of Phase II meeting – saves another year, according to the NORD presentation.  Pariser does not include EOP2 data in her blog post.

So, time to charter a bus, load up the clinical and regulatory teams, and hit the road to Silver Spring?

Well, maybe. It probably couldn't hurt, and I'm sure it would be a great bonding experience, but there are some reasons to not take the numbers at face value.

• We’re dealing with really small numbers here. The NORD presentation covers 54 drugs, and Pariser's appears to add 39 to that total. The fact that the time-savings data shifted so dramatically – from 5 years to 3 – tips us off to the fact that we probably have a lot of variance in the data. We also have no idea how many pre-IND meetings there were, so we don't know the relative sizes of the comparison groups.
  
• It's a survivor-only data set. It doesn't include drugs that were terminated or rejected. FDA would never approve a clinical trial that only looked at patients who responded, then retroactively determined differences between them.  That approach is clearly susceptible to survivorship bias.
  
• It reports means. This is especially a problem given the small numbers being studied. It's entirely plausible that just one or two drugs that took a really long time are badly skewing the results. Medians with quartile ranges would have been a lot more enlightening here.

All of the above make me question how big an impact this one meeting can really have. I'm sure it's a good thing, but it can't be quite this amazing, can it?

However, it would be great to see more of these metrics, produced in more detail, by the FDA. The agency does a pretty good job of reporting on its own performance – the PDUFA performance reports are a worthwhile read – but it doesn't publish much in the way of sponsor metrics. Given the constant clamor for new pathways and concessions from the FDA, it would be truly enlightening to see how well the industry is actually taking advantage of the tools it currently has.

As Gingery wrote in his article, "Data showing that the existing FDA processes, if used, can reduce development time is interesting given the strong effort by industry to create new methods to streamline the approval process." Gingery also notes that two new official sponsor-FDA meeting points have been added in the recently-passed FDASIA, so it would seem extremely worthwhile to have some ongoing, rigorous measurement of the usage of, and benefit from, these meetings.

Of course, even if these meetings are strongly associated with faster pipeline times, don’t be so sure that simply adding the meeting will cut your development so dramatically. Goodhart's Law tells us that performance metrics, when turned into targets, have a tendency to fail: in this case, whatever it was about the drug, or the drug company leadership, that prevented the meeting from happening in the first place may still prove to be the real factor in the delay.

I suppose the ultimate lesson here might be: If your drug doesn't have a pre-IND meeting because your executive management has the hubris to believe it doesn't need FDA input, then you probably need new executives more than you need a meeting.

[Image: Meeting pictured may not contain actual magic. Photo from FDA's Flikr stream.]

*  Disclosure: the author works for one of those.
** Under the theory that there is no such thing as bad publicity, no link will be provided.

Our New Glass House: GSK's Commitment to AllTrials

No stones, please.

Yesterday, Alec Gaffney was kind enough to ask my opinion on GSK's signing on to the AllTrials initiative to bring full publication of clinical trial data. Some of my comments made it into his thorough and excellent article on the topic. Today, it seems worthwhile to expand on those comments.

1. It was going to happen: if not now, then soon

As mentioned in the article, I – and I suspect a fair number of other people in the industry -- already thought that full CSR publication was inevitable.  In the last half of 2012, the EMA began moving very decisively in the direction of clinical trial results publication, but that's just the culmination of a long series of steps towards greater transparency in the drug development process. Starting with the establishment of the ClinicalTrials.gov registry in 1997, we have witnessed a near-continuous increase in requirements for public registration and reporting around clinical trials.

It's important to see the AllTrials campaign in this context. If AllTrials didn't exist, something very much like it would have come along. We had been moving in this direction already (the Declaration of Helsinki called for full publication 4 years before AllTrials even existed), and the time was ripe. In fact, the only thing that I personally found surprising about AllTrials is that it started in the UK, since over the past 15 years most of the advances in trial transparency had come from the US.

2. It's a good thing, but it's not earth-shattering

Practically speaking, releasing the full CSR probably won't have a substantial impact on everyday clinical practice by doctors. The real meat of the CSR that doctors care about has already been mandated on ClinicalTrials.gov – full results posting was required by FDAAA in 2008.

There seems to be pretty clear evidence that many (perhaps most) practicing physicians do not read the complete articles on clinical trials already, but rather gravitate to abstracts and summary tables. It is highly doubtful, therefore, that a high percentage of physicians will actually read through a series of multi-hundred-page documents to try to glean fresh nuances about the drugs they prescribe.

Presumably, we'll see synopsizing services arise to provide executive summaries of the CSR data, and these may turn out to be popular and well-used. However, again, most of the really important and interesting bits are going to be on ClinicalTrial.gov in convenient table form (well, sort-of convenient – I admit I sometimes have a fair bit of difficulty sifting through the data that’s already posted there).

3. The real question: Where will we go with patient-level data?

In terms of actual positive impact on clinical research, GSK's prior announcement last October – making full patient-level data available to researchers – was a much bigger deal. That opens up the data to all sorts of potential re-analyses, including more thorough looks at patient subpopulations.

Tellingly, no one else in pharma has followed suit yet. I expect we’ll see a few more major AllTrials signatories in fairly short order (and I certainly intend to vigorously encourage all of my clients to be among the first wave of signatories!), but I don’t know that we’ll see anyone offer up the complete data sets.  To me, that will be the trend to watch over the next 2-3 years.

[Image: Transparent abode courtesy of flikr user seier+seier.]

The World's Worst Coin Trick?

Ben Goldacre – whose Bad Pharma went on sale today – is fond of using a coin-toss-cheating analogy to describe the problem of "hidden" trials in pharmaceutical clinical research. He uses it in this TED talk:

If it's a coin-toss conspiracy, it's the worst
one in the history of conspiracies.

If I flipped a coin a hundred times, but then withheld the results from you from half of those tosses, I could make it look as if I had a coin that always came up heads. But that wouldn't mean that I had a two-headed coin; that would mean that I was a chancer, and you were an idiot for letting me get away with it. But this is exactly what we blindly tolerate in the whole of evidence-based medicine. 

and in this recent op-ed column in the New York Times:

If I toss a coin, but hide the result every time it comes up tails, it looks as if I always throw heads. You wouldn't tolerate that if we were choosing who should go first in a game of pocket billiards, but in medicine, it’s accepted as the norm. 

I can understand why he likes using this metaphor. It's a striking and concrete illustration of his claim that pharmaceutical companies are suppressing data from clinical trials in an effort to make ineffective drugs appear effective. It also dovetails elegantly, from a rhetorical standpoint, with his frequently-repeated claim that "half of all trials go unpublished" (the reader is left to make the connection, but presumably it's all the tail-flip trials, with negative results, that aren't published).

Like many great metaphors, however, this coin-scam metaphor has the distinct weakness of being completely disconnected from reality.

If we can cheat and hide bad results, why do we have so many public failures? Pharmaceutical headlines in the past year were mostly dominated by a series of high-profile clinical trial failures. Even drugs that showed great promise in phase 2 failed in phase 3 and were discontinued. Less than 20% of drugs that start up in human testing ever make it to market ... and by some accounts it may be less than 10%. Pfizer had a great run of approvals to end 2012, with 4 new drugs approved by the FDA (including Xalkori, the exciting targeted therapy for lung cancer). And yet during that same period, the company discontinued 8 compounds.

Now, this wasn't always the case. Mandatory public registration of all pharma trials didn't begin in the US until 2005, and mandatory public results reporting came later than that. Before then, companies certainly had more leeway to keep results to themselves, with one important exception: the FDA still had the data. If you ran 4 phase 3 trials on a drug, and only 2 of them were positive, you might be able to only publish those 2, but when it came time to bring the drug to market, the regulators who reviewed your NDA report would be looking at the totality of evidence – all 4 trials. And in all likelihood you were going to be rejected.

That was definitely not an ideal situation, but even then it wasn't half as dire as Goldacre's Coin Toss would lead you to believe. The cases of ineffective drugs reaching the US market are extremely rare: if anything, FDA has historically been criticized for being too risk-averse and preventing drugs with only modest efficacy from being approved.

Things are even better now. There are no hidden trials, the degree of rigor (in terms of randomization, blinding, and analysis) has ratcheted up consistently over the last two decades, lots more safety data gets collected along the way, and phase 4 trials are actually being executed and reported in a timely manner. In fact, it is safe to say that medical research has never been as thorough and rigorous as it is today.

That doesn't mean we can’t get better. We can. But the main reason we can is that we got on the path to getting better 20 years ago, and continue to make improvements.

Buying into Goldacre's analogy requires you to completely ignore a massive flood of public evidence to the contrary. That may work for the average TED audience, but it shouldn't be acceptable at the level of rational public discussion.

Of course, Goldacre knows that negative trials are publicized all the time. His point is about publication bias. However, when he makes his point so broadly as to mislead those who are not directly involved in the R&D process, he has clearly stepped out of the realm of thoughtful and valid criticism.

I got my pre-ordered copy of Bad Pharma this morning, and look forward to reading it. I will post some additional thoughts on the book as I get through it. In the meantime,those looking for more can find a good skeptical review of some of Goldacre's data on the Dianthus Medical blog here and here.

[Image: Bad Pharma's Bad Coin courtesy of flikr user timparkinson.]