I must apologize for being a little tardy in writing the
blog. I wanted to wait until the last of
three important meetings had taken place before writing. Warning – this is an unusually long blog.
The three meetings in
question were the
· A
New Pathway for Antibiotic Innovation: Exploring Drug Development for Limited
Populations,” on January 31st
at Pew Charitable Trust.
·
“Incentives for Change: Addressing the
Challenges in Antibacterial Drug Development” on Wednesday, February 27 at the
Brookings Institution.
I did not attend the FDA public hearings believing that much
of what was discussed would have been covered at the Pew meeting where I was a
rapporteur. The Pew meeting was perhaps
the most important one for me. The
highlight of the meeting was the presence of various payers including a
consultant who works closely with medicare.
The agenda first attempted to define IDSA’s proposed Limited Population
Antibiotic Development (LPAD)
pathway for approval for antibiotics effective in patients where resistance (or
other circumstances such as drug allergies) results in few or no other
available options for therapy. This
development pathway would be similar to that proposed
by PhRMA called tier C development. Here, very limited clinical studies in
patients with serious infections caused by highly resistant pathogens would be
carried out. These studies would
demonstrate, in probably only a few patients, that the new antibiotic could
cure such infections. Such data would be
bolstered by other evidence such as in vitro studies, animal studies of
efficacy and pharmacokinetic and pharmacodynamics data all supporting the
proposed use of the new antibiotic. The
approval would be a limited one covering the use of the new product only in the
kinds of patients studied. Such a pathway would be less expensive and might be
more rapid that the usual pathway for an antibiotic. Further, for some drugs such as one only
active against Pseudomonas aeruginosa for
example, such a pathway would be the only feasible way forward to
approval.
While most experts at the Pew meeting agreed that it would
be beneficial to have LPAD inscribed in law by legislation, there was
considerable disagreement as to whether, from a statutory point of view, the
FDA did not already have the authority to institute such a pathway without
legislation.
One aspect of the discussion that I found particularly
interesting was that around stewardship and empiric therapy. I believe that this is an area that deserves
further thought. But basically, in
clinical use, antibiotics are used mostly empirically – 80% of use in today’s
hospitals is empiric. That is, when a
physician prescribes the antibiotic in the hospital, he/she is responding to a
patient’s need for treatment but without knowing the pathogen causing the
infection and sometimes not knowing the origin of the infection (urinary tract,
respiratory tract, etc). For an LPAD product, in hospitals or in
particular units like intensive care units, where highly resistant organisms
are common, physicians might choose to treat seriously ill patients with the
LKPAD agent empirically. What frequency
does such resistance have to achieve to alter physician behavior? I’m guessing that occurs as you start to get
to levels of 10% and higher. But – as we
are about to discuss, these drugs will be EXPENSIVE. So stewardship takes on a critical role here
– not only in terms of preserving the utility of these precious new antibiotics
but also in saving our healthcare dollars.
This gets us into a discussion of what stewardship is as was
raised at the Brookings meeting. The fact
is that there are very few studies of the effect of stewardship on patient
outcomes like length of stay in hospital, readmission rates, resistance rates
and mortality that have any controls other than sort of a before and after
intervention approach. Virtually all
studies agree that stewardship lowers pharmacy costs and does not harm patients. But better, controlled studies are desperately needed (are you listening NIH?).
When the Pew examined the populations that might be treated
with various types of LPAD-approved antibiotics, in order for companies to make
some reasonable return on investment, they tried to estimate (with the help of
Lew Barrett – see his previous blog
on this) the price that would be required.
The estimates ranged from $2000 per course for a drug that had relatively
broad use to $20-30,00 per course for a drug that would specifically target
resistant Pseudomonas for example. These price estimates were reviewed by
payers. Given the amounts they now pay
for oncology drugs that often add little real benefit for patients, payers were happy
to pay these prices for a potentially life-saving therapy. So – not only were there no heart attacks
among the payers – but they basically embraced the concept. They all wanted to see
data showing that the drugs did provide value such a decreased length of stay,
less time on ventilators, lower readmission rates etc. But all agreed that this approach of limited
use and high reimbursement makes sense.
They all also hesitated about the empiric therapy aspect. Medicare is kind of a special case that I won’t
go into here – but such an approach is ultimately feasible for medicare as
well. A question that was raised at the
Brookings was how such a product should be implemented from the payer point of
view. Some suggested that prior approval
might be the way to go. I dislike that
since it might delay therapy. I would rather
pre-qualify hospitals to use a drug based on active and effective stewardship
programs.
So I understand how the high price strategy might work in
the US and Europe. I do not understand
how this translates to the rapidly growing markets of the emerging economies
like India, China and a number of others.
Is there anyone out there willing to take this on in either a comment or
a guest blog?
The Brookings meeting discussed strategies to de-link
reimbursement from volume of use. Most
of the suggestions revolved around various ways of providing a government funded
guaranteed market with a number of methods to pay for this. I won’t be able to
go into the details of the discussion here – you’ll have to wait for the
summary on the Brookings website. But –
my conclusion about all such plans is, GET REAL. Has anyone been looking at what is going on
in Washington lately? I believe that the
only form of de-linking that is currently feasible is price and therefore
market based.
Antibiotics are medicine that kills bacteria or slows the growth of bacteria. They are used to cure diseases. Antibiotics do not harm people. Penicillin is a popular antibiotic. Antibiotics started to be produced in 1939. Antibiotics cannot stop a virus. Antibiotics are not the same thing as antibodies.
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