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Government Facade Clinical Trial Reporting

Over and over again we find fašade regulations.  This is a corporatist state and thus the corporations voluntarily follow the regulations.  Below is a typical example of self-enforcement.  This is the way things are done.  Don’t fault the doctors, the FDA, the Congress; FAULT the shadow government.  This article is about a regulation requiring registering of clinical trials.  It lacks enforcement penalties, and the FDA wouldn’t if there were penalties.  The article makes it sound as though they don’t do as see fit with the raw data, not simply not publish some studies.  And things haven’t changed since 2007 

WHAT GOOD IS THE REPORTING OF CLINICAL TRIALS WHEN THE RAW DATA REMAINS HIDDEN, AND BIAS IS THE NORM???

Consumer Report has done an article on the fašade of regulation http://www.healthfully.org/id8.html

As noted in the comment by Audrey at bottom of articles "A Clinical Trial register already exists and has existed for at least two decades. ...That very register kept information about drug safety secret and inaccessible, and colluded in the hiding of results from negative trials (take GSK SSRI studies as a great example)."

http://clinpsyc.blogspot.com/2007/10/clinical-trial-registry-of-what.html

Clinical Psychology and Psychiatry   October 04. 2007

Clinical Trail Registry of What?

Clinical Trial Registry of WHAT?

Worried about data being hidden in clinical trials, with negative data regarding a drug's safety and/or efficacy being buried? Worry no longer. At least that's what the super-optimistic authors in the New England Journal of Medicine would have us believe. Here's what they wrote:

Of special interest to us, an additional provision of the act requires sponsors of all clinically directive therapeutic trials to register their studies, at inception, in a public database sponsored by the National Library of Medicine. Although some aspects of this provision are not ideal, such as the delayed public availability of registration information on device trials and the non-inclusion of phase 1 trials, mandatory registration represents a critical advance in making clinical trials of new treatments public knowledge.

AND

A decade ago a clinical trial could be conducted in secret. The trial’s sponsor, claiming proprietary rights, could keep all information about it, including its very existence, private. Thus, if a drug had important adverse effects, this information might never be made public. Legislators believed that such a possibility was not in the best interests of the American people. Once a clinical trial is mounted, the sponsor has an ethical obligation to publicly acknowledge the contribution of the participants and the risk they have taken by ensuring that information about the conduct of the trial and its principal results are in the public domain. With the FDA Revitalization Act, the United States joins other countries in recognizing that the human volunteers needed to complete a trial are more precious than the money required to mount it.

Wow, everything is looking up now! All data will be reported and all will be well. I read what I think is a relatively updated version of said legislation, and I did not really see anything that requires that all results are reported for every trial. Nothing even close to that is described, unless I missed something. Data reporting requirements should be pretty simple: Data on every single efficacy and safety measure must be reported in full. Nothing less is acceptable. Otherwise, sponsors can continue to fund research from which the positive data are reported and the negative data are minimized.

The Present System is Broken. Here's an example of why the present Clinical Trials database is close to useless for learning about study results. First come snippets from a
registered clinical trial, then comes the publication based upon the results. Snippets from trial protocol (what was going to happen in the study):

This is a study of the effectiveness of adding Abilify (aripiprazole), an atypical antipsychotic medication, to ongoing SSRI antidepressant treatment for depressed outpatients who are not responding fully to SSRI treatment alone. It is hypothesized that patients’ functioning will improve after 12 weeks of treatment with Aripiprazole and SSRI medication...

Total Enrollment: 15
...

Primary Outcome Measures:

  • Hamilton Depression Rating Scale (HDRS)

Secondary Outcome Measures:

  • Clinical Global Impressions Scale (CGI)
  • Global Assessment of Functioning Scale (GAFS)
  • Beck Depression Inventory (BDI)

Study chairs or principal investigators


David J. Hellerstein, MD, Principal Investigator, NY State Psychiatric Institute, and St. Luke's - Roosevelt Hospital Center

Publications
Hellerstein DJ. Aripiprazole as an adjunctive treatment for refractory major depression. Prog Neuropsychopharmacol Biol Psychiatry. 2004 Dec;28(8):1347-8. No abstract available.

Clinical Trial Entry vs. The Publication. You can see the details above. 15 patients to be enrolled in the study using four measures of outcome. Let's see what that cited publication had to say about the results...

Ms. V. is a 46-year-old single female with a 5-year history of severe depression... What about the 14 other patients?

At that point [venlafaxine + mirtazapine not working], aripiprazole was added, initially at 15 mg/day then increased to 30 mg/day. Within a month, Ms. V. noted that her mood and concentration were improved, and she was no longer anhedonic. She began socializing with family members again, began gardening and was able to concentrate on reading and movies. After 3 months on the venlafaxine extended-release, mirtazapine, and aripiprazole, Ms. V. noted that her appetite remained good, she was sleeping 7 h per night, her mood was much better, and she had begun to seek a new job, sending resumes and phoning prospective employers... What happened to those measures of outcome mentioned above?

The linked publication discusses one case though the trial was to study 15 people. Did the other 14 all jump off a bridge? What happened? If we are going to have a clinical trial registry that requires reporting of results, is this what you want? I hope not. Next, the obligatory pro-Abilify propaganda, such as...

Furthermore, aripiprazole’s benign side effect profile [including minimal weight gain, sedation and parkinsonism, resulting from its low affinity for alpha-1-adrenergic, histamine (H1) and muscarinic (M1) receptors] suggests that it may be tolerable for refractory-depressed patients, who may need adjunctive treatment for a long period of time. The case of Ms. V. suggests the possible benefit of aripiprazole in treatment-resistant depression as an adjunct to other antidepressant medications.

When there is no clinical trial data to support your discussion, one can always fall back on discussing various receptors and how, theoretically, tweaking them in one way or another is going to lead to positive results.

The case study ends with:

Further studies of aripiprazole as an adjunctive medication for treatment-resistant depression are indicated.

Yeah, but what happened to the 14 other patients in this study?? I did a search on Medline to find if there were additional studies by Hellerstein using Abilify in depression and I could find nothing that seemed to fit the bill. Please alert me if I missed something in the search. One could argue that perhaps the study is in the midst of being written up for publication -- if so, it's sure taking a while...

There's More. If I had more time, I'd go through the clinicaltrials.gov registry and I'm sure I'd find more interesting discrepancies between clinical trial protocols (where researchers say what is going to happen) and what was actually published (the official record of what actually happened). In fact, I've done this before, in which I noted that a published study of Risperdal for depression was clearly changed in its data reporting somewhere between the clinical trial registry and the eventual publication. A rather thorough investigation into the topic found that:

"Overall, 50% of efficacy and 65% of harm outcomes per trial were incompletely reported. Statistically significant outcomes had a higher odds of being fully reported compared with nonsignificant outcomes for both efficacy (pooled odds ratio, 2.4; 95% confidence interval [CI], 1.4-4.0) and harm (pooled odds ratio, 4.7; 95% CI, 1.8-12.0) data. In comparing published articles with protocols, 62% of trials had at least 1 primary outcome that was changed, introduced, or omitted. Eighty-six percent of survey responders (42/49) denied the existence of unreported outcomes despite clear evidence to the contrary."

Who Cares? Well, if you don't mind receiving only part of the efficacy and safety data, then don't do anything. Send no emails, tell none of your friends, don't bother your local journal editor, and don't ask your doctor if he/she is aware that the so-called bedrock of evidence based medicine (i.e., results published in scientific journals) is based on selectively reported information.

The Kool-Aid. I'm really stunned that the folks at the New England Journal of Medicine would just rush off and publish an essay about how great things are now going to be. People have been calling out for data to be shared openly for quite some time, and now, magically, with the passing of some vague legislation, all data will be made publicly available. The drug industry is suddenly just going to publish all information on all of their clinical trials, overnight? And
some bigwigs at NEJM are willing to drink this Kool-Aid? That is pathetic.

1 comment:

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Aubrey Blumsohn said...

All excellent comments. To add one more:

A Clinical Trial register already exists and has existed for at least two decades.

It is called the FDA (and the MHRA over here). That very register kept information about drug safety secret and inaccessible, and colluded in the hiding of results from negative trials (take GSK SSRI studies as a great example).

Pity they didn't do their jobs last time around.

Aubrey

If Congress was really concerned about drug safety, they it legislate effective controls:  controls designed to make drug companies compete over the effectiveness of their drugs, and to permit only the test results sell their drugs. 

 

A measure of a system is to draw upon a set of regulations which would produce medical science in the public’s interest, and then compare it to what we have; see the list below.  . 

 

JK’s wish list which would change marketing science into medical science:

 

1)  Limit pharma’s activities to manufacturing of drugs, and thus eliminate the sales related activities including advertising, lobbying, and educational activities. 

2).  Pharma would fund clinical trials through taxes, but only medical colleges would set them up and run the clinical trials, and own the result; moreover, pharma’s input would be limited to a  list of suggestions. 

3). Clinical trial results would be available for free over the internet 

4).  For FDA approval, heads on-testing of drugs (rather than being more effective than a a sugar pill).

5).  Submissions to the FDA would be available on line.

6).  Key positions in the FDA be filled by researchers without ties to Pharma.

7).  Treatment guidelines would be established through medical colleges with the goal of serving the public.

8).  Long-term independent monitoring of side effects by independent researchers. This is easily done thought available data banks of Veterans Administration, Kaiser Permanente, HMOs, and Medicare.  Such studies cost about 1/1,000th that of a long-term clinical trial.

9). Require reporting of side effects with incentives and penalties administered through a university panel of professors.  

10).  All drugs would be followed in data banks for side effects. 

11)  Enforce laws against price gouging and monopoly price fixing.    

12).  FDA funding would come from taxes on pharma. 

13).  All medical science would be funded by pharma’s tax dollar or through charitable donations, and done in universities.  Results would be in the public domain.   

15)  Require independent accounting of pharma company books, as with all publically traded companies. 

16).  All imported lots of drugs would have quality control testing before marketing..

17).  Medical colleges would not be operated as business, but rather as public services.  They would be run by their faculty.

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Disclaimer:  The information, facts, and opinions provided here is not a substitute for professional advice.  It only indicates what JK believes, does, or would do.  Always consult your primary care physician for medical advice, diagnosis, and treatment. 




Positive bias averaged 32% (range 11 to 69%) in a NEJM article, 2008.  The study of neuroleptic drugs made a comparison of 74 journal articles to the raw data which was obtained by FOIA (Freedom of Information Act) from the FDA. See http://healthfully.org/index/id9.html, or http://content.nejm.org/cgi/content/short/358/3/252