^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
The panel, they added, never
discussed much
about the way Sprout used patient-reported data to establish an increase in
sexual desire for the primary efficacy endpoint, switching from a daily diary
to a questionable four-week recall method using a desire subscale of the Female
Sexual Function Index [FSFI] in a follow-up study.
JAMA. Published online July 06, 2015.
doi:10.1001/jama.2015.8405
http://jama.jamanetwork.com/article.aspx?articleid=2389384
Evaluation
of Flibanserin: Science and Advocacy at
the FDA
Walid
F. Gellad, MD, MPH1,2;
Kathryn E. Flynn, PhD3; G.
Caleb Alexander, MD, MS4,5
On June 4, 2015, the US Food and Drug Administration
(FDA)
convened a scientific advisory committee meeting to review the efficacy and
safety of flibanserin, a new molecular entity for the treatment of hypoactive
sexual desire disorder (HSDD) in premenopausal women. This was the second such
meeting of the committee regarding a product that had twice been rejected by
the FDA due to an unfavorable risk-benefit profile. After the day-long hearing,
the advisory committee voted 18 to 6 in favor of recommending approval of the
drug, provided certain risk management options were implemented. The FDA is not
bound to this recommendation and has indicated that it will rule on the
product’s application by the end of August. Regardless of the outcome, the
FDA’s decision is certain to join other controversial regulatory decisions at
the intersection of science, policy, and advocacy. In this Viewpoint, we
discuss the history of flibanserin and provide insight about the regulatory
process from the point of view of 3 of the advisory committee members at the
FDA meeting.
Flibanserin was initially
developed as an antidepressant, but it
failed to demonstrate efficacy.
In phase 2 trials of patients
with depression, the drug was more effective than placebo in terms of study
participants’ responses to the question “How strong is your sex drive?”1 Development of the drug then
shifted to a potential treatment for HSDD, defined as “persistently or
recurrently deficient or absent sexual fantasies and desire for sexual
activity” accompanied by “marked distress and interpersonal difficulty” that is
not accounted for by a nonsexual mental disorder, medication, severe
relationship stress, or general medical condition.2 In 2013, the Diagnostic
and Statistical Manual of Mental Disorders, 5th edition, combined HSDD with female sexual arousal disorder into female sexual
interest/arousal disorder. The disorder has no FDA-approved treatments, and the
FDA has recognized the condition as an area of unmet medical need.3
In the original FDA application for use of
flibanserin for HSDD in
2009, both pivotal phase 3 trials failed
to show statistically significant improvement [about 20%, more in a small
trial] compared with placebo in a
primary end point assessing sexual desire using a single item in a daily
electronic diary. Although the other primary end point (the reported number
of satisfying sexual events) and the secondary end point (the desire subscale
of the Female Sexual Function Index [FSFI]) met pre-established efficacy
thresholds [slightly better than a placebo], the FDA denied approval after a unanimous
advisory committee vote
against approval.
The drug was resubmitted to the FDA for review
in 2013 with
results from a new phase 3 trial using FSFI desire as the co-primary desire end
point instead of the daily diary, showing statistically significant but
numerically small treatment differences at 24 weeks compared with placebo (an
increase of 0.3 on the FSFI desire subscale [range, 1.2-6.0] and an increase of
0.5 satisfying sexual events per month). In an FDA “responder analysis” of the
phase 3 trials, after accounting for the placebo effect, approximately 8% to 13%
of women were at least “much
improved” on at least 1 of the primary outcomes. [Would you take a drug if you
had merely a 10% chance of benefiting?]
A variety of safety concerns were raised
during the 2013 FDA
review, including a risk of hypotension, syncope, and somnolence among users of
the product, as well as the potential for adverse effects when flibanserin is
taken with alcohol or CYP3A4
inhibitors such as oral contraceptives [ethinyl estradiol, EE2] or fluconazole.
The drug is to be taken once daily at bedtime, which lowers the risk or
consequences of sedation-related adverse events. The risks of syncope were
relatively low in the pivotal clinical trials (0.5% flibanserin vs 0.3%
placebo), but the overall risks of
sedation or hypotension-related adverse events were substantially higher
with flibanserin vs placebo (28.6%
flibanserin vs 9.4% placebo). In addition,
the trials were limited to
generally healthy women not taking benzodiazepines, sleep aids, narcotics, or a
number of other medicines, and, as with many trials, they were of short
duration relative to the potential length of time that flibanserin could be
indicated. Given these concerns, as well as overall modest efficacy, the FDA
again rejected the product application and recommended additional safety
studies.
For the most recent FDA review, no new efficacy
data were
presented. Instead, the sponsor of flibanserin provided additional safety data,
including a study suggesting the absence of next-day driving impairments, a
comparison of the product’s adverse effect profile with that of other marketed
products, and an analysis confirming the potentiating effects of alcohol on
adverse events. Although the driving study was reassuring, isolated comparisons
of safety across products can be misleading because FDA product reviews are not
fundamentally comparative in nature. Notably, the alcohol interaction study
took place in a sample of 25 healthy volunteers, only 2 of whom were women.
Several additional features of
the regulatory path involving flibanserin are noteworthy. First, following the
FDA’s second rejection of flibanserin in
2013, an advocacy group called Even the Score was formed to advocate for what
it called “gender equality” in access to treatments for sexual dysfunction.4 The group, initially created
through the efforts of a consultant to flibanserin’s manufacturer who formerly
directed the FDA’s Office of Women’s Health, promoted the claim that there
are 26 approved medications for male
sexual dysfunction but none for women. The claim has been rejected by the FDA,
because there are no approved
products for low sexual desire in men, and the 26 medications include multiple
formulations of testosterone. Although flibanserin is not the first product
to be supported by a consumer advocacy group in turn supported by
pharmaceutical manufacturers, claims of gender bias regarding the FDA’s
regulation have been particularly noteworthy,
as have the extent of advocacy efforts ranging from social media campaigns to
letters from members of Congress.5
The second noteworthy feature
in the FDA application for flibanserin was the use of a patient-reported
outcome of sexual desire as the primary efficacy variable for approval. Sexual
desire is known only to the person experiencing it, and patient-reported outcomes
measure such concepts without interpretation from others. Patient-reported
outcomes are increasingly prioritized in research and other drugs have been
approved with these outcomes as primary end points (although none based on
sexual desire). Among all new molecular entities and biologic license
applications approved by the FDA from 2006-2010, Gnanasakthy et al6 identified 17% (20 of 116
products) that granted patient-reported outcome claims as the primary outcome
on the approved label. The complicating factor in evaluating flibanserin
centered around the switch in the primary desire end point from a daily diary
rating the person’s most intense desire in the first application to a 4-week
recall of the frequency and intensity of desire as measured by the FSFI desire
subscale. The FDA raised some concerns about the optimization of the FSFI for
assessing desire, including the content validity and recall period, but the
recent advisory committee did not focus discussion on either the switch in
primary end points or the validity of the FSFI.
A final concern regarding flibanserin relates
to its likely use in
clinical practice, and this was a major issue for the committee. Although there
are few reliable estimates of the prevalence of HSDD, the product, as with
others, is all but certain to be used off-label among a broader population of
women than has been studied, many of whom may not fulfill formal diagnostic
criteria for HSDD and many of whom may have conditions or concomitant
medication use that increases the risk of adverse events. The concerns about
off-label use were reinforced by public speakers at the meeting who expressed
their need for flibanserin, while at the same time reporting conditions that
may have excluded them from on-label treatment, such as a cancer diagnosis or
postmenopausal status.
The FDA regulates drug approval
and marketing, not the practice of medicine. The Committee’s discussions about
flibanserin and off-label use highlight the challenge that the FDA encounters
when considering a product that may help a subpopulation of patients, but also
has a risk-benefit profile that may make it unacceptable for broader use.
Despite the positive advisory committee vote, recommendations for approval were
accompanied by support for Risk Evaluation and Mitigation Strategies (REMS),
including potentially requiring prescriber and pharmacy certification to
prescribe or dispense the product. However, despite the Advisory Committee’s
emphasis on risk management after approval as a means to increase the product’s
safe use, there remains a paucity of
evidence about the ability of most REMS programs to fulfill this promise.7
These features of flibanserin—the Even
the Score advocacy
campaign, the shifting efficacy end points and use of a patient-reported
outcome measure, the tenuous risk-benefit balance among the studied population
and potential for widespread off-label use, and an unmet medical need—are not
totally unfamiliar territory for the FDA, but represent a challenge when they
occur simultaneously. What makes the approval process for flibanserin even more
unique is the politically charged atmosphere in which the FDA will decide how
all these trade-offs should best be navigated.
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
Without going into what has
been developed else as to the market science published in journal, I will
simply states that it is all market dressed up as science, what I call “tobacco
science.” As with all drugs that have a
neuroleptic action, the manufacturer of the drug claims that it produces a
beneficial balance of neural transmitters.
This is pure sales pitch; the science behind it is missing as to how
these putative changes produced the desired safe and beneficial results. The
system is too complex as the passage from
Wikipedia below demonstrates. “Flibanserin
acts as a full agonist of the 5-HT1A receptor (Ki = 1 nM) and, with lower affinity, as an antagonist of the 5-HT2A receptor (Ki = 49 nM) and antagonist or very weak partial agonist of the D4 receptor (Ki = 4–24 nM).[14][15][16][17 .... demonstrating regional selectivity, and
has been found to increase dopamine and norepinephrine levels and decrease
serotonin levels in
the rat prefrontal cortex, actions that
were determined to be mediated by activation of the 5-HT1A receptor.[14] As such, flibanserin
has been described
as a norepinephrine-dopamine
disinhibitor (NDDI).[17][20] The
proposed mechanism
of action refers to the
Kinsey dual control model of sexual response.[21] Various neurotransmitters, sex steroids, and other hormones have important excitatory or inhibitory effects on the sexual
response. Among
neurotransmitters, excitatory activity is driven by dopamine and
norepinephrine, while inhibitory activity is driven by serotonin. The balance
between these systems is of significance for a normal sexual response. By
modulating serotonin and dopamine activity in certain parts of the brain,
flibanserin may improve the balance between these neurotransmitter systems in
the regulation of sexual response.[22][23]“ So how can a drug which fails to
work get passed On June
18, 2010, a federal advisory panel to the
U.S. Food and Drug Administration (FDA) unanimously voted
against recommending approval of flibanserin,
citing an inadequate risk-benefit ratio. The Committee acknowledged the
validity of hypoactive sexual desire as a diagnosis, but expressed concern with
the drug's side effects and insufficient evidence for efficacy, especially the
drug's failure to show a statistically significant effect on the co-primary
endpoint of sexual desire.[26]” The latest clinical trial, the one
used by the FDA asked a very fuzzy the question about monthly satisfying sexual
experiences:
“There were two
ways that the sexual benefit was measured in the studies. The first was a daily
diary, the other was a monthly estimate. As a researcher, I think it’s
ridiculous to ask women to measure their sexually satisfying experiences based
on their memory of the past month. I can remember my daily experiences over the
last week, but couldn’t accurately remember them over the exact timeframe of
one month. The daily diary found no significant improvement compared to
placebo, but the monthly measure found a small improvement: an average of less
than one additional satisfying sexual experience per month. That small benefit
might be worthwhile for a drug without risks, but that is not true of Addyi [Flibanserin]”
In These
Times 2/3/16.
Given that the
drug is a downer, the memory of events a month out is bound to be inaccurate,
and given the phenomena known as breaking
blind, which means that those who are on the active drug know it, and those
on a sugar pill know it, the answers to the question don’t accurate report
their sexual satisfaction. Breaking
blind for a neuroleptic drug is over 80%[1] Thus asking a question about past
month’s
sexual performance based on memory and the expectations of benefit by those drugged
with Flibanserin will have satisfying sex, this method will produced more favorable
recollection than those receiving a sugar pill.
Given how poor positive the results for the question, the net effect
really was quite negative for Flibanserin.
Yes it is a
tranquilizer because it main side effects:
“The most commonly
reported adverse events included dizziness, nausea, fatigue, sleepiness, and trouble sleeping.
Flibanserin was originally developed as an antidepressant,[24][25] before being repurposed
for the treatment
of HSDD.” Wikipedia. Sleepiness and
fatigue are hallmarks of a tranquilizer and nearly all drug marketed as
antidepressants are sleep inducing tranquilizers.[2] Do you need to know
more?? Upcoming will be a section on Neuroleptic
drugs or read Prof. Gotzsche Deadly Psychiatry
and Organized Denial
or Prof. David Healy Pharmageddon.
And it gets worse, again and again pharma funds through so-called
consumer groups a pressure campaign. This provides an excuse for the very
pharma friendly FDA to approve the drug.
This is what happened: “The
approval was opposed by the National Women's Health Network, the National Center for Health Research and Our
Bodies Ourselves.[43] A representative of PharmedOut said "To approve this drug will set the worst
kind of precedent — that companies that spend enough money can force the FDA to
approve useless or dangerous drugs."[44] An editorial in JAMA noted that " Although flibanserin is not the
first product to be supported by a consumer advocacy group in turn supported by pharmaceutical
manufacturers, claims of gender
bias regarding the FDA’s regulation have been particularly noteworthy, as have
the extent of advocacy efforts ranging from social media campaigns to letters
from members of Congress"[45] Wikipedia. One last thing,
I recommend you read the letter from an insider on the drug approval committee. He
wrote first to Congress, then did an
interview which describes the conditions of work at the FDA. The FDA functions
as extension of pharma;
please click on link at
http://healthfully.org/rep/id14.html
[1]
“89 percent of patients givben the real antidepressants correctly figured out
that they were in the drug group”, Irving Kirsch, The Emperor’s New Drugs
Irving Kirsch, Ph.D. P 16.
[2]
Short term (in the 6 week phase iii clinical trial) those who sleep more are
less depressed. Moreover the standard
questions in the Hamilton Rating Scale, have 2 of 17 question on sleeping
better-more.