sleeping dog lie…

Posted on Sunday 4 January 2015

From the beginning, and in the decade since, APA has protested the warning, predicting that it would prevent parents from seeking care for their children – and clinicians from prescribing antidepressants – and insisting that by far the greater danger was untreated depression. “We are concerned that the publicity surrounding this issue may frighten some parents and discourage them from seeking help for their children,” child psychiatrist David Fassler, M.D., told the 2004 panel. “The most important point that I can make is that the biggest risk for a child with depression is to be left untreated.”

Shortly after the FDA issued the Black Box Warning of possible suicidality in adolescents on antidepressants, the American Psychiatric Association and the American Academy of Child and Adolescent Psychiatry jointly established a website, ParentsMedGuide.org [Updated 2010], that said:
Do antidepressants increase the risk of suicide?
Suicidal thoughts and behaviors are more common during adolescence than at any other time, but suicide is more common among adults. In any year about 16 percent of high school students think about suicide and about 3-8 percent show suicidal behaviors. Fortunately, very few of them commit suicide. Children and adolescents with depression are much more likely to think about suicide and to attempt it than other children. Although not all suicidal children have depression, untreated depression increases the risk of suicide.

The Food and Drug Administration [FDA] described an increase in reports of suicidal thoughts and/or behaviors in children and adolescents taking antidepressants. But, there were no suicides in the cases they studied. Autopsies of teenagers who have committed suicide show that very few of them had traces of an antidepressant, making the link between antidepressant use and suicide even weaker.

Between 1992 and 2001, there was a large increase in the number of adolescents being prescribed SSRI antidepressants. But, during that time the rate of suicide among American youth ages 10–19 actually dropped by more than 25 percent. This was the first time in nearly 50 years that the suicide rate declined in young people.

What is a black box warning?
…The FDA did not ban the use of antidepressant medications for youth. The purpose of the warning was to alert physicians and parents to watch children and adolescents to see if their symptoms got worse, or if they showed unusual changes in behavior. The FDA also specifically said that “depression and other serious mental illnesses are the most important causes of suicidal thoughts and actions”.

Why did the FDA issue a black box warning?
In 2004, the FDA reviewed 23 clinical trials involving more than 4,300 child and adolescent patients. These patients received any of nine different antidepressant medications. No suicides occurred in any of these studies. … A more recent study found that the risk was even smaller—around 3% in those on medication and 2% in those on placebo. Most of these events were increases in suicidal thoughts. Only a few were actual suicide attempts, and NONE were suicide completions.

Through careful monitoring, the development of a safety plan, and the combination of medication with psychotherapy, the risks for increased suicidal thoughts can be managed. For moderate to severe depression, there is benefit in the use of medication because of a higher rate of relief, and more complete relief, from depressive symptoms than not using any medication.

Since the FDA issued the black box warning, there has been a decline in antidepressant use, but an increase in completed suicides in adolescents in both the US and the Netherlands. Although it is not yet clear how these trends may be related, this has been the first increase in the adolescent suicide rate reported in over a decade.
And on the American Academy of Child and Adolescent Psychiatry website under the Depression FAQ, we read:
What should treatment consist of?
When possible, treatment for depression childhood depression should include both psychotherapy and medication. In milder forms of depression, it is reasonable to start with a psychotherapy, but treatment with a medication and psychotherapy should be considered for moderate to severe forms of major depression. Before starting treatment, a doctor will discuss it’s risks and benefits, as well as how the treatment should be monitored.

Are medications safe? Do they increase risk of suicide?
When prescribed and monitored carefully, medications are both safe and effective ways to treat of depressed youth. Fluoxetine or Prozac, a selective serotonin reuptake inhibitor, is the medicine that so far has proved most safe and effective. There are times, however, when other medications can and should be used. While medications have been associated with a small increase in thoughts of suicide, there is no evidence that antidepressants actually increase the risk of suicide. For moderate to severe depression, the potential benefits from medication treatment seem to outweigh the potential risks.
They get some credit for "Through careful monitoring, the development of a safety plan, and the combination of medication with psychotherapy, the risks for increased suicidal thoughts can be managed." But I’m afraid that, "the potential benefits from medication treatment seem to outweigh the potential risks" is actually a major flaw in this whole argument. Prozac® was approved early for adolescent depression, before the Black Box Warning was issued [top two graphs], but that was the only approval. Paxil® had the infamous Study 329 [lower left] and two other unpublished negative studies. And Zoloft® only eked out minimal significance at ten weeks by combining two negative studies [lower right]. So none of them support a claim of the kind of "potential benefits" their argument advertises [see tuning the quartet…]


So it’s hard to mount a rational explanation for why our two major professional organizations [APA and AACAP] are still making an assault on the Black Box Warning. Except for Prozac®, they’re advocating off-label prescribing for marginal efficacy at best. There’s unlikely much push from PHARMA now that the drugs are off-patent. In spite of the limitations, they’re still prescribing at a moderate pace. Seems to me they’d let this sleeping dog lie…

Review: See significant I…, significant II…, and significant III… about the NIMH TADS study…
Mickey @ 9:21 AM

a restrictive interpretation…

Posted on Saturday 3 January 2015

The campaign against the Black Box Warning has been relentless since it was added to the labeling of antidepressants in 2004. Here are a dozen major articles along the way opposing the Warning:

  1. Gibbons RD, Hur K, Bhaumik DK, Mann JJ.
    Arch Gen Psychiatry. 2005 Feb;62(2):165-72.
  2. Gibbons RD, Hur K, Bhaumik DK, Mann JJ.
    Am J Psychiatry. 2006 Nov;163(11):1898-904.
  3. Charles B. Nemeroff, Amir Kalali, Martin B. Keller, Dennis S. Charney, Susan E. Lenderts, Elisa F. Cascade, Hugo Stephenson, and Alan F. Schatzberg
    Arch Gen Psychiatry. 2007 Apr;64(4):466-472.
  4. Nakagawa A, Grunebaum MF, Ellis SP, Oquendo MA, Kashima H, Gibbons RD, Mann JJ.
    J Clin Psychiatry. 2007 Jun;68(6):908-16.
  5. Gibbons RD, Brown CH, Hur K, Marcus SM, Bhaumik DK, Mann JJ.
    Am J Psychiatry. 2007 Jul;164(7):1044-9.
  6. Gibbons RD, Brown CH, Hur K, Marcus SM, Bhaumik DK, Erkens JA, Herings RM, Mann JJ.
    Am J Psychiatry. 2007 Sep;164(9):1356-63.
  7. Brown CH, Wyman PA, Brinales JM, Gibbons RD.
    Int Rev Psychiatry. 2007 Dec;19(6):617-31.
  8. Gibbons RD, Segawa E, Karabatsos G, Amatya AK, Bhaumik DK, Brown CH, Kapur K, Marcus SM, Hur K, Mann JJ.
    Stat Med. 2008 May 20;27(11):1814-33.
  9. Barry CL and Busch SH.
    Pediatrics. 2010 125[1]:88-95.
  10. Gibbons RD, Mann JJ.
    Drug Saf. 2011 May 1;34(5):375-95.
  11. Robert D. Gibbons, Hendricks Brown, Kwan Hur, John M. Davis, and J. John Mann
    Arch Gen Psychiatry. 2012 Jun;69(6):580-587.
  12. Christine Y Lu, Fang Zhang , Matthew D Lakoma analyst, Jeanne M Madden, Donna Rusinak, Robert B Penfold, Gregory Simon, Brian K Ahmedani, Gregory Clarke, Enid M Hunkeler, Beth Waitzfelder, Ashli Owen-Smith, Marsha A Raebel, Rebecca Rossom, Karen J Coleman, Laurel A Copeland, Stephen B Soumerai
    BMJ. 2014 348:g3596.
Now we have the first of an advertised two-part series on the topic in the PSYCHIATRICNEWS. I was not aware that the American Psychiatric Association [APA] had been so active in its opposition to the Warning in 2004 and going forward:
PSYCHIATRICNEWS
by Mark Moran
12/30/2014

Abstract: This is the first of a two-part series on the 2004 FDA hearings on antidepressants and suicidality in adolescents. Part two will focus on the effect of the antidepressant label warning on prescribing and adolescent health.


From the beginning, and in the decade since, APA has protested the warning, predicting that it would prevent parents from seeking care for their children—and clinicians from prescribing antidepressants—and insisting that by far the greater danger was untreated depression.

‘We are concerned that the publicity surrounding this issue may frighten some parents and discourage them from seeking help for their children,’ child psychiatrist David Fassler, M.D., told the 2004 panel. ‘The most important point that I can make is that the biggest risk for a child with depression is to be left untreated…’

Darrel Regier, M.D., M.P.H., who is the former director of the APA Division of Research and testified at the hearings against the warning, noted that there were in fact no actual suicides among the thousands of teens treated in clinical trials reviewed by the FDA panel. Moreover, the FDA data on suicidal ideation associated with SSRI use was based on spontaneous reports, not on studies prospectively designed to systematically define and identify the incidence of suicidal thoughts or behaviors in teenagers taking the medications.

Regier believes the extraordinary media attention the hearings attracted is a case study in how data pertinent to public health can be obscured or distorted by overinterpretation of spontaneous reporting. “I think it calls into question the FDA’s entire system of spontaneous reporting,” he said. Regier said a promising step is the agency’s adoption, for use in future phase 3 clinical trials, of the Columbia Suicide Severity Rating Scale for any drug that is thought to have some potential for suicidal ideation [including dermatologic drugs such as Accutane].

‘I think the solution is more systematic reporting, which the FDA will start to move toward as the agency begins to have access to electronic health records used by large health systems and HMOs,’ Regier said. ‘This will give the FDA access to phase 4–type data on the long-term effects of medication side effects and associations with suicidal attempts and mortality from all causes.’
It’s unlikely that anyone reading this is neutral on the topic – one that has pervaded our literature almost from the time of the introduction of the SSRIs a quarter of a century ago. Those who support the Black Box Warning rely on individual instances – their own experience as patients and clinicians or the case reports of others. People who oppose the Warning point to studies in populations that show no effect either way on suicide, but confirm that the prescription rate of SSRIs either fell or stopped rising in response to the Warning. It’s hard to find a discussion of this issue that doesn’t also make ad hominem accusations of bias towards the other camp. With that as an introduction, I’m sure not going to revive my own usual arguments, refutations, or accusations. I’d rather talk about an article I read yesterday [sent by literature maven, James O’neill] that seems to fit my take on all of this:
by Fava GA, Guidi J, Rafanelli C, and Sonino N
Psychotherapy and Psychosomatics. 2015 84:1-3.
It’s a short two paged article best read as a narrative rather than viewed in a couple of sound bytes, so I’ll skip any attempt at summary. It’s an article that talks about clinical judgement taking precedence over the tenets of evidence-based medicine. It’s a hard argument to make as it can be instantly met with "How do you know that?" or "But that’s just what you think." And I’ve actually never heard any two people have this argument with even slightly changed minds as a result.

My own opinions are embedded in my narrative. I came into the world equipped for science – aptitude, interest, a father who taught chemistry and geometry. After a degree in mathematics, I headed to medical school intending a medical research career and, in fact, wound up my training in a lab bench based NIH fellowship. I lived and breathed evidence-based medicine [I would like to think I still do]. My first post-training posting was as an general internist in an Air Force hospital overseas [by special invitation from the US government – AKA drafted]. I had been well trained as a clinician, but what I quickly realized was that in training, I had always been located somewhere in the hierarchy of a team of some sort, and when it was just me and a patient, medicine was a different game altogether. What Giovanni Fava is calling clinical judgement is as good a way as any to describe the difference.

I think of that three years as the most important and intense period of my own medical training. I became so interested in the individual illnesses and unique experience of my patients that I returned to a psychiatry residency and added a psychoanalytic training program that ran in parallel. My post academic career was as an individual psychotherapist in a world where clinical judgement was on the front burner of every day.

There was another important and intense period of my own medical training after my psychiatry residency. I directed a psychiatry training program for a decade before leaving for practice during the storm in psychiatry that followed the coming of the DSM-III. And I noticed something in my dealing with my residents during those days. I often found myself preaching the gospel of evidence-based medicine – quoting studies, handing out articles, sending a resident to the library. But at other times, my sermon was equally passionate, but was much more in the range of Fava’s clinical judgement. When I noticed that contrast, I quickly realized that the theme of my message depended on which resident I was talking to, and what I thought that particular resident needed to learn. The point being that I don’t slightly see evidence-based medicine and clinical judgement as a dichotomy – in opposition. Medicine as I know it is practiced at the interface of group data and unique human experience [including  my own].

So how do I relate this little discourse to the issue of prescribing SSRIs to adolescents? First, I object to the "untreated depression" argument out of hand. The "depression" on the table here is, in my view, a symptom – not a disease. And there is no formula I know that says that the "treatment" of "adolescent depression" is "SSRIs" or, for that matter, medication. I see the drugs as symptomatic medications that may, at times, be helpful in the "treatment of a particular depressed adolescent." Second, I have no question that the SSRIs can occasionally cause a unique syndrome [called Akathisia by David Healy] characterized by agitation, aggression, disinhibition, and intensely lethal thought. I know that’s true because I did it to someone:
    I saw a seventeen year old who was very depressed with good reason. His mother had remarried a man who was a retired Drill Sergeant [really] and this kid and his step-father were oil and water – at war. The boy had an impending interview for a training program that would’ve paid his way to move 200 miles away and study something he had dreamed of all his life. His mother and I were both worried that he was so depressed that he wouldn’t "pass" the interview. So I prescribed an SSRI. In a few days, he developed the full Akathisia syndrome in spades, including being intensely suicidal [for the first time]. His mother stopped the medication, didn’t leave his side, and it cleared within 48 hours.
I’ve since seen other cases of Akathisia and know of two completed suicides from SSRIs, fortunately none cases of my own. But that first case was from around the time of the Black Box Warning and I hadn’t been warned. Worse, I hadn’t warned them. So for me, this issue started in the realm of evidence-based medicine, something I saw in person, and became part of my subsequent clinical judgement. Would I prescribe an SSRI to an adolescent now? I would and have done on some occasions, but with more than plenty of warnings, and only to those I was absolutely sure were going to be closely watched by someone I had talked to myself.

When I look at that dozen articles I listed above, or read what Dr. Regier has to say, I’m aware that I’m a total snob. There’s not anyone that I would consider to be a clinician on the bylines of the articles on the list, or speaking in the PSYCHIATRICNEWS article. They’re Statisticians, Academicians, Researchers, or Administrative types. Even putting aside all the Conflict of Interest and Methodological issues in those papers [which are prodigious], I’m sure that I still wouldn’t change my mind about this no matter how long that list of population studies gets. And, by the way, I sense that the PSYCHIATRICNEWS article is a harbinger of yet another assault on the Black Box Warning [as if what it says on a package insert defines the truth].

I personally take this issue as a microcosm of a much more general point. I most respect the opinions of people who are deeply steeped in the findings of evidence-based medicine, but who remain immersed in clinical medicine throughout their careers [and show the tell-tale signs of having developed clinical judgement]. I don’t think that’s a tall order – more a baseline requirement. Back in 1980, the people who brought the DSM-III revolution in psychiatry to my own neck of the woods saw themselves as the prophets of evidence-based medicine. I sure didn’t object to that, but they were specifically disdainful of anything that slightly smacked of clinical judgement [as in "How do you know that?" or "But that’s just what you think" ad nauseum]. They were followed by a second wave who were even worse, in the range of contemptuous – the generation that became what we now call the KOLs [some of whom inhabit those author bylines above in the flesh]. They came at a time when psychiatry may have needed an encounter over its reliance on matters subjective, but in the process they turned clinical judgement into an object of ridicule rather than one for examination and inquiry.

There’s a strong pressure pushing this same trend in medicine in general – simplifying medical practice into the rote application of large group findings to the care of individual patients based on averages and statistics. That pressure comes from third party carriers, pharmaceutical companies, hospital conglomerates, governments, even professional organizations, etc. – anyone who tries to quantitatively deal with the healthcare of populations. So the amount of allowed contact, the access to diagnostic tests, the available treatments, just about everything is regulated based on algorithms and guidelines derived from large group studies. Meanwhile, patients increasingly clamor for individual attention, and are driven to distraction along with their doctors by the hoops they have to jump through when they get sick. Dr. Regier’s comment is typical of this particular mindset, "I think the solution is more systematic reporting, which the FDA will start to move toward as the agency begins to have access to electronic health records used by large health systems and HMOs."

So while Dr. Fava’s comments appear in a mental health journal, I think they can be generalized to all of healthcare:
    The conceptual model that has generated EBM and guidelines clashes with clinical reality and fosters a dichotomy between medical science and clinical judgment. EBM has certainly made an important contribution to questioning unsubstantiated therapeutic claims. The time has come, however, to become more aware of its considerable limitations, including overall reductionism, disregard of patient-physician relationships and patient preferences, and insufficient consideration of problems related to financial conflicts of interest. As an increasing body of literature indicates, EBM offers only a restrictive interpretation of the scientific approach to clinical practice.
Mickey @ 8:00 AM

and a happy new year…

Posted on Thursday 1 January 2015

Mickey @ 8:59 PM

why data transparency? III…

Posted on Thursday 1 January 2015

I looked at the ClinicalTrials.gov Results Database several years ago, and decided it was an improvement over just having the published paper because of its strucyure, but was far short of having the raw data  [see eyes wide shut open I…, eyes wide shut open II…, eyes wide shut open III…, and eyes wide shut open IV…]. But I have to say that it’s far more helpful to have it than not. And using it, you can get closer to knowing if you can trust the published article. So I’m all for Dr. Collins’ proposal to make it really non-optional, turning it into what it was intended to be [Honoring Our Promise: Clinical Trial Data Sharing and see promises, promises…].

I’m not going through the Results Section in detail for this study. It’s there for your perusal. In this case, there’s not much substantial differences between it and the paper. My contention would be that’s because it’s there. But look it over. It’s self explanatory. There’s nothing that makes all the site jockeying any clearer. Here’s the punch line as far as I’m concerned. First, from the paper:
    Weight and vital signs. Mean baseline-to-endpoint weight change [LOCF] was significantly greater for OFCtreated patients [4.4 kg, standard error [SE]=0.2] than placebo-treated patients [0.5 kg, SE=0.3; p<.001]. Using MMRM methodology to model expected weight gain if all patients completed the 8-week study, mean weight change from baseline to week 8 was 5.1 kg [SE=0.3] for OFC-treated versus 0.6 kg [SE=0.4] for placebo-treated patients [p<.001]. Baseline-to-endpoint mean change in body mass index was also significantly greater for the OFC group [1.5 kg/m2, SE=0.1] than the placebo group [0.1 kg/m2, SE=0.1; p<.001]. Incidence of gaining ≥7% of baseline body weight was significantly greater for the OFC group relative to placebo [52% vs. 4%, p<.001], as was incidence of gaining ≥15% of baseline body weight [14% vs. 0%, p<.001]. No placebo patients and 2 OFC-treated patients gained ≥25% of their baseline.
Then from the ClinicalTrials.gov database:
I’m not sure I would want to prescribe a 10+ pound mean weight gain over two months in return for the statistical but not very large gain in efficacy.
And then there’s this, meaning they just made it under the wire with their guest author:
As I said, I’m not contesting this study, but the ClinicalTrials,gov Results Database keeps them honest. For example, it’s easy to check out something like the stats on total aggressive acts in the SAEs.
If we had the a priori Protocol, accurate information about the CRO that did the study, the true story about the sites used, the completed ClinicalTrials.gov Results Database, and the FDA NDA [New Drug Approval] Medical Report, we could actually do a decent job of vetting these Clinical Trial articles. But if we found something suspicious, we’d still need access to the raw data – Individualized Participant Data [IPDs] and perhaps the Client Report Forms [CRFs] – to actually run down any problems found.

It sounds like a lot of hoops to make the trialists jump through, but it’s not. All of that information is already available. It would probably take them less time to put all that stuff up than it took me to write these three blogs. The pharmaceutical companies don’t want to do that because they want to be able to continue to accent the positive and eliminate the negative. And if they continue to act like they’ve acted in the last couple of decades, they’re going to lose the right to test their own products. Disease treatment is between the medical profession and our patients, not a playground for entrepreneurship and scientific deceit.

And as for Symbiax®, who needs it? no matter what the trial says. It’s a patent extending experimercial to treat a questionable disorder. And even if you do use it, as Dr. Varner pointed out, it costs $130/month more to take one pill a day instead of two. I’d like to thank Dr. DelBello and Eli Lilly for producing this fine example for my comments on Dr. Collins’ proposals. I hope that the JAACAP learns somewhere down the line that a ghost-written industry study with a guest author is still just an industry study, with all the conflict of interest problems that kept such studies out of our peer reviewed journals in our more scientifically honest past. Shame on Eli Lily and shame on the JAACAP…
Mickey @ 7:29 PM

why data transparency? II…

Posted on Thursday 1 January 2015

In why data transparency? I…, I was looking at the recently published RCT of Symbiax®, an Eli Lily COMBO drug with Prozac® and Zyprexa® in various doses [Olanzapine/Fluoxetine Combination in Children and Adolescents With Bipolar I Depression: A Randomized, Double-Blind, Placebo-Controlled Trial]. I was disappointed that the JAACAP was publishing such an obviously COI-laden experimercial with a guest author. I’d hoped we’d moved on a notch in that arena. I wandered the FDA sites looking at its approval, and I hope I got that part right. I’ve haunted the Drugs@FDA and Orange Book sites for several years, and while I’m glad they’re there, I find them difficult. Speaking of haunting, I’ve also hung around on ClinicalTrials.gov and that was going to be my next stop [NCT00844857]. I’ve actually been waiting for an RCT like this one to say some things about that site. The paper says:
    This was a phase 4, randomized, double-blind, placebo-controlled study conducted between March 2009 and February 2012 at 41 centers in the United States, Mexico, and Russia.
    and
    A total of 255 patients [170 OFC, 85 placebo] comprised the mITT population.
That comes out to 255÷41=~6 subjects/sit,e which seemed mighty thin to me. They use multiple sites to speed up recruitment, but… And on ClinicalTrials.gov, they listed sites in US California and five places in Russia. But then below that, they listed US, Russia, Mexico, and Turkey under regulatory authorities. Pretty confusing. But that gets me to a complaint I have about the ClinicalTrials.gov site in general. Five or six years ago when I first started looking at this site, they told us where the site actually was. But for the last several years, it has said stuff like this:

  • United States, California: For additional information regarding investigative sites for this trial, contact 1-877-CTLILLY (1-877-285-4559, 1-317-615-4559) Mon – Fri from 9 AM to 5 PM Eastern Time (UTC/GMT – 5 hours, EST), or speak with your personal physician. San Diego, California, United States, 92123
  • Russian Federation: For additional information regarding investigative sites for this trial, contact 1-877-CTLILLY (1-877-285-4559, 1-317-615-4559) Mon – Fri from 9 AM to 5 PM Eastern Time (UTC/GMT – 5 hours, EST), or speak with your personal physician. Lipetsk, Russian Federation, 399313
That feels like a trick to me. I want to know if it’s an academic center, or a flophouse on the Bowry, or a village in the third world. I’m not going to call Russia or San Diego, and they know that. As I’ll mention in a bit, NIH Director Collins wants to beef up the use of ClinicalTrials.gov, and this would be one place to do that – go back to telling us where the trial actually took place.

But where there’s a will, there’s a way. The ClinicalTrials.gov site includes a small link, History of Changes, with each trial up at the top of the opening page [go ahead, click it]. And when you get a pop-up window, there’s another link, ClinicalTrials.gov Archive Site [don’t be shy, click it too]. It has all the changes made over the course of the study. I’ve looked at a lot of these, but I’ve never seen one that looks remotely like this!

There are over thirty changes that have to do with recruitment and site location. If you have the energy, click on the second one [2009_03_16], then uncheck the box that says "Hide non-essential portions (contact info, locations, etc.)". You can scroll through the changes by clicking the arrow on the right. What you’ll see is them moving all over the world adding and shutting down different sites. The CRO must’ve had a hell of a time with recruitment and had to pull out all stops to find subjects. I want to know if that happened [and it ought to be easier to do]. It makes me think that the Pediatric Bipolar patients with a Depressive episode [or whatever these cases are] just aren’t that easy to find – but who knows?

And I’ve never seen a change in the Protocol during a trial. That one at 2011_05_16 removes the Placebo Control from the Protocol! It made me wonder if that’s why they had the 2:1 ratio of subjects, maybe to recruit more easily – but again, who knows? So that brings me to another complaint about ClinicalTrials.gov. On the opening page, the describe the Protocol in a narrative, but they don’t post the a priori Protocol – the ones that go to the Institutional Review Board. They have it, and I think they ought to post it. I could then easily look at the Protocol and see if what they say in the paper is true …
    A 2:1 randomization ratio was used to reduce potential exposure to placebo.
… I come by that kind of paranoia honestly after looking at a lot of these trials.

If you’ve made it this far, you probably are wondering why I’m being so picky. Remember back in November, NIH Director Francis Collins announced that he was going to put teeth into the ClinicalTrials.gov website [Honoring Our Promise: Clinical Trial Data Sharing and see promises, promises…]. For one thing, the pharmaceutical companies and even academic researchers had just ignored the Results Section of ClinicalTrials.gov – a requirement for a lot of these trials [see transparency…]. They just didn’t ever get around to filing the results. And while the Results Section is pretty skimpy, it’s a right move in the right direction for DATA TRANSPARENCY. And part of that move was to enforce and even expand the Results Section. He put out a call for comments on his proposed plan, so I’ve been waiting for an industry RCT to come along so my comment will have example to show the why of my complaints – and this study is the very thing I’ve been waiting for. So the last blog, this one, and the nextl are my formulating what I want to say. Hope springs eternal in the new year. [This is the working link for comments: http://www.regulations.gov/#!documentDetail;D=NIH-2011-0003-0003 with a deadline of February 19, 2015].

And I’m in luck! Apparently Dr. Collins’ plan is already at work, because this study has uncharacteristically got a Results Section filled out, so on to my comments about that section [why data transparency? III…].
Mickey @ 10:22 AM

why data transparency? I…

Posted on Thursday 1 January 2015


PSYCHIATRICNEWS alert
[The Voice of the American Psychiatric Association and the Psychiatric Community]
December 30, 2014

A combination of the antipsychotic olanzapine and the antidepressant fluoxetine proved superior to placebo for acute treatment of bipolar I depression in patients aged 10-17 in a randomized control trial published online in the Journal of the American Academy of Child and Adolescent Psychiatry.

The double-blind study by researchers at Eli Lilly and Company randomized 170 young patients with bipolar I disorder experiencing an acute depressed episode to the olanzapine/fluoxetine combination [OFC] and 85 to placebo for up to eight weeks of treatment. The primary efficacy measure was mean change in the Children’s Depression Rating Scale-Revised [CDRS-R]…
The issue of the hour is DATA TRANSPARENCY in Randomized Clinical Trials [RTCs], mainly industry funded RTCs of medications, particularly those submitted for FDA Approval. This announcement in the PSYCHIATRICNEWS came out the same day the study was published [on-line] in the JAACAP. There are several reasons one might want to look into this announcement. First, the Pediatric Bipolar I diagnosis is controversial, to say the least. It was quite the rage for a time after being introduced by Dr. Joseph Biederman and colleagues at Harvard and swept through the Child Psychiatry world. In 2008, Dr. Biederman was on Senator Grassley’s list for undisclosed pharmaceutical income and later censured by Harvard, the fad began to pass. Many doubt that Bipolar Disorder in the pediatric age group even exists, or at least exists in any sizable number. Second, these are old drugs – Prozac® and Zyprexa®. Why is Lily promoting its combo version [Symbiax®] at this late date? Why are they publishing a trial in kids now when both Prozac® and Zyprexa® are off-patent? But the thing that struck me about this announcement is what it doesn’t say. It doesn’t say:
    The double-blind study by Dr Melissa DelBello with the Division of Bipolar Disorders Research, University of Cincinnati College of Medicine, randomized 170 young patients with Bipolar I disorder experiencing an acute depressed episode to the olanzapine/fluoxetine combination [OFC] and …
… even though she’s the only psychiatrist [and the only non-Lily employee] on the author byline. And, by the way, she was on Senator Grassley’s list too as an academic with undisclosed PHARMA income:
Olanzapine/Fluoxetine Combination in Children and Adolescents With Bipolar I Depression: A Randomized, Double-Blind, Placebo-Controlled Trial
by Holland C. Detke, Ph.D., Melissa P. DelBello, M.D., John Landry, M.Math, and Roland W. Usher, M.S.
Journal of the American Academy of Child and Adolescent Psychiatry. published online 12/24/2014

Objective: To assess the efficacy and safety of olanzapine/fluoxetine combination [OFC] for the acute treatment of bipolar depression in children and adolescents.
Method: Patients 10-17 years of age with bipolar I disorder [BP-I], depressed episode, baseline Children’s Depression Rating Scale-Revised [CDRS-R] total score ≥40, Young Mania Rating Scale [YMRS] total score ≤15, and YMRS-item 1 ≤2 were randomized to OFC [6/25-12/50 mg/day olanzapine/fluoxetine; n=170] or placebo [n=85] for up to 8 weeks of double-blind treatment. The primary efficacy measure was mean change in CDRS-R using mixed-model repeated measures methodology.
Results: Baseline-to-week-8 least-squares mean change in CDRS-R total score was greater for OFC-treated patients than for placebo-treated patients [-28.4 vs. -23.4, p=.003; effect size=.46], with between-group differences statistically significant at week 1 [p=.02] and all subsequent visits [all p<.01]. Rates of and times to response and remission were statistically significantly greater for OFC- than placebo-treated patients. The most frequent treatment-emergent adverse events in the OFC group were weight gain, increased appetite, and somnolence. Mean weight gain at patient’s endpoint was significantly greater for OFC- than placebo-treated patients [4.4 kg vs. 0.5 kg, p<.001]. Treatment-emergent hyperlipidemia was very common among OFC-treated patients. Abnormal increases in hepatic analytes, prolactin, and corrected QT interval [QTc] were also common or very common but generally not clinically significant.
Conclusion: OFC was superior to placebo and approved by the US Food and Drug Administration [FDA] for the acute treatment of bipolar I depression in patients 10-17 years of age. Benefits should be weighed versus the risk of adverse events, particularly weight gain and hyperlipidemia.
Unlike the industry RCTs in the past where the academic authors are mentioned up front, the announcement says "The double-blind study by researchers at Eli Lilly and Company randomized..." [at least they’re honest]. So this is an industry study inserted directly into the academic, peer reviewed literature. And who did the study? who wrote it? There’s probably an answer to that question in the acknowledgements in the paper:
    "The authors also thank Shannon Gardell, PhD, and Rodney Moore, PhD, of inVentiv Health Clinical [funded by Eli Lilly and Co.] for assistance in drafting/editing the manuscript."
inVentiv Health Clinical is a full service Clinical Research Organization [CRO] that likely both managed the study for Lily and wrote [ghost wrote] the paper. A glance at Dr. DeBello’s COI declaration tells us that she’s certainly still in the pharmaceutical orbit:
    Dr. DelBello has received grant or research support from … Amylin Pharmaceuticals, Eli Lilly and Co., Pfizer, Otsuka, Merck, Martek, Novartis, Lundbeck, Purdue, Sunovion, and Shire. She has served as a consultant to Bracket, Guilford, Pfizer, Dey Pharma, Lundbeck, Springer, Sunovion, and Supernus…
From its approval in 2003 to 07/26/2013, Symbiax® was not approved for Pediatric Use. At that time, the label was changed [Drugs@FDA] and the patent was extended [Pediatric Extension?FDA Orange Book]:
    Children and Adolescents — The efficacy of SYMBYAX for the acute treatment of depressive episodes associated with Bipolar I Disorder was established in a single 8-week, randomized, double-blind, placebo -controlled study of patients, 10 to 17 years of age [N=255], who met Diagnostic and Statistical Manual 4th edition-Text Revision (DSM-IV-TR) criteria for Bipolar I Disorder, Depressed.
The  FDA Approval in adolescents was apparently based on this study.

It’s not my intention to specifically challenge these results. But since the DSM-III, there has been a steady creep in diagnosing Bipolar Disorder from the classic Manic-Depressive Illness of Kraepelin’s days. And I see a remarkable number of people who announce that they’ve been "told they are Bipolar" and they simply don’t fit. Also, in reviewing the more papers on Pediatric Bipolar Disorder, my skepticism level hovers around DEFCON 1. Likewise, I see no reason for a COMBO medication. Taking two pills a day if they’re needed is no great burden. So my suspicions that the goals here are commercial rather than medical. But I don’t doubt that depressed adolescents feel better taking Zyprexa® or Symbiax®. I question whether it’s a good idea to prescribe it, particularly in the fixed dose COMBO pills. But the fact that it is a likely ghost-written, industry produced, COI-laden, commercially-driven RCT is not all that bothers me about this study.

Stay tuned…
Mickey @ 8:00 AM

did nothing medical…

Posted on Tuesday 30 December 2014

It would be hard not to know about the case of Dan Markingson, a young psychotic man who killed himself while in a clinical trial at the University of Minnesota in 2004 [see A referenced summary of the Dan Markingson case]. Bioethicist Carl Elliot at UM has kept us abreast of the ongoing attempts to block any thorough investigation of the case on his blog Fear and Loathing in Bioethics. In a recent post, Carl mentions a presentation at an ethics conference that defended the handling of the Markingson case by UM.
Fear and Loathing in Bioethics
by Carl Elliot
December 16, 2014

Well, no conflict of interest unless you count a $13,781 fee paid by the University of Minnesota to give expert testimony on this exact issue.  So yeah, if you want to get all technical and everything, then I guess that might count as a conflict. But can you really expect a research ethics expert to keep up with arcane issues like conflicts of interest? I mean, come on.
Well, Ernest Prentice had another problem besides his unacknowledged conflict of interest. He neglected to scope out his audience at the conference before he stepped into it, feet first…
Ernest Prentice, an associate vice-chancellor at the University of Nebraska, seems to have trouble with conflicts of interest, and not just his own.  According to Dr. Judy Stone, who attended Prentice’s talk on the Markingson case at this year’s PRIM&R meeting, Prentice also claimed to be unaware of the astonishing conflicts of interest on the IRB whose performance he defended…
He apparently didn’t notice that Dr. Judy Stone who has written extensively about the Markingson case in Scientific American was sitting in the audience…
Scientific American
Blog:  Molecules to Medicine
by Judy Stone
December 15, 2014
This Blog by Dr. Stone is a must-read, both because it adds to the facts about the Markingson case, but also because it is a classic take-down of Goliath proportions. An old mentor once told me, "Know your audience." And it is likely that Ernest Prentice has learned the wisdom of that advice first hand [in the Q&A that followed his talk]…

The higher-ups apparently think that they can get the Markingson case to go away. But that’s never going to happen. The ethical issues are too fundamental. As much as people love to debate about medical model[s] of disease and evidence-based medicine, medicine itself is much older that these scientific methods. It rests on two ancient intertwined principles:

  • Aesculapian authority: Authority is granted to the physician with the implicit contract that it will be used in the service of the patient, and for no other reason.
  • Primum Non Nocere: "First, do no harm." This injunction comes from antiquity and essentially says that there will be vigilance for anything that will hurt the patient, including therapeutic zeal.
In the case of Dan Markingson, it is obvious that there was betrayal of both of these principles. Dan was quite ill with a disorder that carried a guarded prognosis – Paranoid Schizophrenia with florid delusions of manifest lethal content. The physician recommendation [Aesculapian authority enforced by judicial authority] was not driven by his needs, but rather by the physician’s need to populate a clinical drug trial. And there is no question that the patient was harmed by being given only a maintenance dose of a blinded medication for six months with no apparent response to the treatment. So Dan was involuntarily committed to a treatment plan that would never have been suggested for him had it not been part of a clinical trial protocol to study maintenance medication. As he had never really responded, there was nothing to maintain. And one can hardly claim that his one doctor’s visit per month is anything like the necessary vigilance.

The usual topic of this blog is the betrayal of these principles by an academic journal, its authors, a pharmaceutical company, or a regulatory body that provides misinformation to patients and physicians about a drug or treatment. The cause is invariably related to conflicts of interest involving money. This case has those same roots, but is at the other end – the process of generating the information. So not only was Dan betrayed as a sick person, but the clinical trial was betrayed by including a subject that didn’t belong. The UM administration, the involved doctors, even the presenter at the conference above, all make the same argument, "We did nothing wrong." While that’s not true, it’s not even the point. They accepted the medical responsibility for Dan Markingson, but they did nothing medical. And that’s why this case won’t go away…
Mickey @ 10:43 AM

the recommendation?…

Posted on Monday 29 December 2014

Rarely do you get to see an industry production that has all of these elements rolled into one article, but look no further. This article has all the right moves. It’s a review article in an industry friendly CME journal, Journal of Clinical Psychiatry. Its got some well known KOLs for guest authors: Alan Schatzberg former Chairman at Stanford, former Corcept principle, former APA President, former Sally Laden client, formerly included on Senator Grassley’s PHARMA income non-reporter list; Rakesh Jain, a principle in the CME conglomerate US Psychiatric and Mental Health Congress; and Michael Thase, just-about-everybody’s KOL.
by Alan F. Schatzberg, MD; Pierre Blier, MD, PhD; Larry Culpepper, MD, MPH; Rakesh Jain, MD, MPH; George I. Papakostas, MD; and Michael E. Thase, MD
Journal of Clinical Psychiatry 2014 75[12]:1411–1418.

Six clinicians provide an overview of the serotonergic antidepressant vortioxetine, which was recently approved for the treatment of major depressive disorder in adults. They discuss the pharmacologic profile and receptor-mediated effects of vortioxetine in relation to potential outcomes. Additionally, they summarize the clinical trials, which demonstrate vortioxetine’s efficacy, and discuss findings related to safety and tolerability that have high relevance to patient compliance.
In former times, this kind of industry-driven review article came from "roundtables" – KOL meetings that may or may not have occurred. But it’s different now – teleconferences among the various KOLs.
    … highlights from a series of teleconferences held in the spring of 2014. The series was chaired by Alan F. Schatzberg, MD… The faculty were Pierre Blier, MD, PhD…; Michael E. Thase, MD…; George I. Papakostas, MD…; Larry Culpepper, MD, MPH…; and Rakesh Jain, MD, MPH…
The article is obviously ghost-written by a professional medical communications company – apparently paid by the journal.
    This evidence-based peer-reviewed Academic Highlights was prepared and independently developed by Healthcare Global Village, Inc., with support from Physicians Postgraduate Press, Inc…
All of the guest authors have extensive industry connections. I’ve just included two from each, the two companies involved with marketing Vortioxetine – 100% onboard.
    Financial disclosure: Dr Schatzberg received grant funding and/or honoraria for lectures and/or participation in advisory boards for … Lundbeck/TakedaDr Blier received grant funding and/or honoraria for lectures and/or participation in advisory boards for … Lundbeck Takeda Dr Culpepper received grant funding and/or honoraria for lectures and/or participation in advisory boards for … H. Lundbeck A/STakeda. Dr Jain received grant funding and/or honoraria for lectures and/or participation in advisory boards for … LundbeckTakeda. Dr Papakostas received grand funding and/or honoraria for lectures and/or participation in advisory boards for Lundbeck Takeda. Dr Thase received grant funding and/or honoraria for lectures and/or participation in advisory boards for … H. Lundbeck, A/S Takeda.
The actual article is odd. For example, it has a discussion of the meanings of NNT and NNH, but neglects to say what Vortioxetine’s NNT actually is. It discusses the changing drug/placebo differences in clinical trials of antidepressants with a borrowed graph, but doesn’t show a graph of any Vortioxetine values. It mentions six positive clinical trials but not the four negative ones.


[from the FDA Medical Review]

It even has a discussion of Irving Kirsch’s negative meta-analysis of antidepressant trials and a blurb about how the Affordable Care Act expands mental health benefits. There’s a pitch for Collaborative Care and encouragement for Primary Care Physicians to prescribe antidepressants. The review ends with:
    "Robinson et al in a 2005 study estimated that primary care providers are the sole contacts for more than half of patients with mental illness and that depressive symptoms are present in nearly 70% of patients visiting primary care providers. A patient in a primary care setting, particularly one who has recently acquired mental health coverage through the ACA or Mental Health Parity and Addiction Equity Act, may have one or more coexisting acute or chronic conditions, and to the extent possible, an antidepressant that will not aggravate and might be helpful for these conditions is preferable. A favorable tolerability profile also may improve patient adherence to treatment, leading in turn to not only a reduction in depressive symptoms but a reduced risk of behavioral or social actions that could adversely affect the patient’s overall health and well-being."
So now we have another SSRI on the market called Brintellix® [AKA Vortioxetine], with a review article in the style of so many professionally-written industry-driven articles that have been the flotsam and jetsam of the psychiatric literature for several decades.

At times, when I wear thin with all the anti-psychiatry criticism, the kind that assumes all psychiatrists think the same [stupid] [wrong] things, I’m tempted to get defensive or argue. Then I read an article like this, in a journal like this, by authors like these, and it helps me hold my tongue and turn the other cheek. There’s absolutely nothing here to defend. Fortunately, we don’t see articles like this so much any more, at least in any places that matter. But it’s bad enough that we ever had them in the first place [or that anybody is still writing them].


In the FDA Medical Report on Brintellix®, the reviewer conveniently included a list of all of the FDA approved treatments for Major Depressive Disorder:

It reminded me of my early days in psychiatry. The drugs available then were the ones in the top two boxes [pink]. In those days, the phrase Major Depressive Disorder would’ve referred to a group of severe conditions I think of as the Melancholic Depressions. I thought of them as diseases, nouns, entities [Depression with a capital "D"]. They aren’t common, but when you see a case, there’s nothing routine about it. The patients are quantitatively profoundly depressed. But there are qualitative features that are striking. It’s as if the affect-generator has been turned to a single frequency – self-hating gloom. Those were the patients we treated with the Tricyclic antidepressants. Sometimes they responded. Sometimes they didn’t. And sometimes they were treated with ECT. People like me who usually spend their days talking to depressed people [depression with a little "d"] are stopped in their tracks when Melancholic Depression is the problem. It’s something else.

When the DSM-III came along in 1980, the phrase Major Depressive Disorder took on a new meaning. If you saw a case of Depression with a capital "D", you could say Major Depressive Disorder with Melancholic features or some such as if there were a continuum between Depression [noun] and depression [symptom] [which isn’t true in my opinion]. Depression had lost its meaning. Any symptomatic depression became known as "MDD" and had graduated – had become a disease [and the most common DSM-III diagnosis at that]. But that’s not the end of the story. In the DSM, there are criteria required to make a diagnosis of "MDD." They’re soft compared to the Melancholic Depressions, but they are at least criteria. So I had a specific reason for posting about this review article, an article I would usually just let pass. But when I read that last paragraph, I started writing:
    "… primary care providers are the sole contacts for more than half of patients with mental illness and that depressive symptoms are present in nearly 70% of patients visiting primary care providers. A patient in a primary care setting, particularly one who has recently acquired mental health coverage through the ACA or Mental Health Parity and Addiction Equity Act, may have one or more coexisting acute or chronic conditions, and to the extent possible, an antidepressant that will not aggravate and might be helpful for these conditions is preferable."
According to this article, you don’t even have to meet the watered-down DSM-III criteria for "MDD" to get put on an antidepressant medication anymore. All you have to do is go to your GP for any reason and have some depressive symptoms ["particularly" if you have recently acquired mental health coverage]. Brintellix®, with…
    "A favorable tolerability profile also may improve patient adherence to treatment, leading in turn to not only a reduction in depressive symptoms but a reduced risk of behavioral or social actions that could adversely affect the patient’s overall health and well-being."
In an article from the former chairman of psychiatry at Stanford? From a former APA president? That’s the recommendation? Unbelievable!…
Mickey @ 8:00 AM

kudos…

Posted on Friday 26 December 2014


Inside Philanthropy
by Tate Williams
December 23, 2014

MacArthur just gave $400,000 to a popular blog about flawed and fraudulent science, so it can deepen its coverage and build a comprehensive database of journal retractions. We chatted with the program officer behind the grant about why got Mac into the science watchdog game, and the foundation’s adventurous side program for such grants. 

Since editor and physician Ivan Oransky and science writer Adam Marcus launched Retraction Watch in 2010, the blog cataloging retracted articles in science journals has drawn a lot of attention, and had more fodder than it can keep up with.

Now, thanks to a two-year grant from the MacArthur Foundation, Retraction Watch is going to expand from a scrappy watchdog to a full-fledged monitoring program that will catalog nearly all retractions issued by major journals in a database, and do deeper analysis of the root causes. 

As Ivan Oransky told the program BioCentury This Week, “It’s easy and fun — and useful — to write about the fraud in particular cases, but looking at the big picture is always much more interesting and important. And so we’re going to be able to do that and to look at the scale of these things and see what’s actually happening”…
[see also Retraction Watch is growing, thanks to a $400,000 grant from the MacArthur Foundation] Good for the MacAurthur Foundation! Adam and Ivan’s blog is top notch already, promoting a level of transparency in science reporting long needed. Adding in-depth reports on the details and reasons for the retraction will just put icing on the cake. In the psychiatric literature I follow, there are a number of articles, particularly articles on clinical drug trials funded by industry, that should have never been published, have not been retracted, and still show up as references. While it would be an extremely tricky undertaking, I can coneive of some group that might undertake investigation of articles so identified by multiple observers. I’m not aware of that being done, but there’s a need. The journal editors themselves seem reticent to undertake such a task, and that’s understandable. But it does science nor medicine no real service to let this kind of article stand in perpetuity. But that’s not for Retraction Watch to worry with right now – just a wish list item for the universe. Their proposed expansion into investigative work and cataloging sounds ambitious enough, and a real solid addition to the science watchdog world…
Mickey @ 9:00 AM

not hardly…

Posted on Thursday 25 December 2014

Ben Goldacre tweeted a document, a letter to UK doctors from Pfizer. I don’t know the specifics of the UK regulatory agencies and how they differ from the FDA. I don’t know what a CCG is. But I don’t think we need to  know those things to get what Pfizer is trying to get said in their letter – their unimaginable letter. He posted a jpeg that was too small to read, so I transcribed it for all to experience first hand.

ben goldacre @bengoldacre
This @pfizer threat at UK doctors is especially amusing given they were done for off-patent promotion of pregabalin. https://twitter.com/bengoldacre/status/547492475544559616?s=03
ben goldacre ‏@bengoldacre
This threatening letter to UK drs from @pfizer is farcical copyright fearmongering. Always use scientific drug names.

Pfizer             Worldwide Biopharmaceutical Businesses

[Date]

[CCG Address]

Dear [NAME]

Re: Lyrica® (pregabalin) pain patient

I am writing to ensure thay  you are informed about the relatively unususl issues surrounding the loss of exclusivity situation for the Pfizer product Lyrica® (pregabalin) so you can take necessary action to prevent patent infringement by your organization.

An appendix is attached describing the factual aspects of the situation in detail to ensure that you have the full information available. You will see that, whilst tyhe basic patent for pregabalin has expired and regulatory data for pregabalin has expired in July 2014, Pfizer has a second medical use patent protecting pregabalin’s use in pain which extends to July 2017. Pfizer conducted further research and development on pregabalin leading to its use in pain and hence was granted a second medical use patent for this indication. This patent does not extend to pregabalin’s other indications for generalized anxiety disorder (GAD) or epilepsy.

As a result of the pain patent, we expect that generic manufacturers will only seek authorization of their pregabalin products for use in epilepsy and generalized anxiety disorder and not for pain, whilst Pfizer’s pain patent is in place. Generic pregabalin products therefore are expected not to have the relevant information regarding the use of the product in the PIL (Patient Information Leaflet) and SmPC (Summary of Product Characteristics). In other words, the generic pregabalin products are expected tro carry so-called "skinny labels" and will not be licensed for use in pain.

In the circumstances dwscribed above, Pfizer believes the supply of generic pregabalin for use in the treatment of pain whilst the pain patent remains in force in the UK would infringe Pfizer’s patent rights.This would not be the case with supply or dispensing of generic pregabalin for the non-pain indications, but we believe it is inccumbant on those involved to ensure that slinny labeled generic products are not dispensed and used for pain.

In this regard, we believe the patent may be infringed, even potentially unwittingly, by pharmacists and others in the supply chain, if they supply generic pregabalin for the pain indications. Without information, guidance, and practical solutions from the authorities. Pfizer believes that multiple stakeholders, possibly without realizing, may contribute to patent infringement which would be an unlawful act. This runs contrary to the government’s established policy of rewarding additional research by granting a second medical use patent.

We also note that, by issuing guidance, your CCG is able to influence patterns of prescribing ans dispensing in your area. We believe these powers must be exercised responsibly and with a view to avoiding the infringement  of Pfizer’s pain patent.

In view of the above, Pfizer requests that you use appropriate guidance to prescribing clinicians withing your CCG to help ensure that our pain patent is respected and that all prescribing clinicians are aware of the pain patent situation. There are a number of ways in which this might be achieved, but the simplest solution, we believe, is for clinicians to be advised to prescribe Lyrica® by brand when prescribing pregabalin to treat neuropathic pain. Pharmacists will then be able to dispense Lyrica® against such prescriptions and this will ensure that they do not infringe the pain patent. In addition this will mean that patients with pain will be provided with a PIL that describes the use of pregabalin in pain.

Your CCG may also consider reviewing patient records retrospectively (in advance of the availability of generic drugs) and use prescribing decisions support mechanisms such as Scriptwatch to support appropriate ongoing prescribing. We are willing to discuss, or assist CCG’s with, the development of other solutions.

We should also note that, in our view,(i) CCG guidance instructing or encouraging the usage of generic pregabalin in pain would amount to procurement of patent infringement (an unlawful act); and (ii) your CCG is under an obligation to address the risk of wide scale infringement of Pfizer’s patent rights. Pfizer therefore formally reserves all of its legal rights in this regard.

If you have any questions in relation to the above please contact Pfizer LTD on 01304 616161.

Yours Sincerely,

Ruth Coles
Legal Director

UPDATE

ben goldacre @bengoldacre
So @Pfizer UK press office are being very coy about whether this threatening letter to GPs is genuine. Embarrassed? http://boingboing.net/2014/12/24/pfizer-threatens-pharmacists.html
    hu·bris ‘hyu br?s
    noun.
    Overbearing pride or presumption; arrogance:

After being fined $2.3B for off-brand promotion with their non-product Neurontin®, Pfizer brought out Lyrica®, a molecular clone, ran it for its patent life, and now want to extend the exclusivity for a secondary patent for the same use they got fined for in the first place. And the way they propose to do that is threaten GPs and Pharmacists.

I’ve never prescribed Lyrica®, and only refilled Neurontin®. The thing I’ve noticed is that patients are reticent to stop Neurontin®, and I suspect it is because it has a mild Benzo-like antianxiety effect. The problem with this system is contained in this letter. "This runs contrary to the government’s established policy of rewarding additional research by granting a second medical use patent". That’s built on the notion that pharmaceutical companies should be rewarded in return for developing new drugs for the betterment of our patient’s lives. They’ve turned that into a mechanism to make gajillions off of medications that have a minimal effect [if that] and then sell that effect to the public that clamors for the drug so they can be like the pretty lady on the television dancing her way through an exotic vacation.

Do we really want to reward companies for developing life-style drugs?  What is the point of trying to rein in escalating healthcare costs if what we’re doing is making it easier to go to the doctor and get the made for t.v. "ask your doctor if Lyrica® is right for you" drug with a prescription plan? And when they come up with something that may be a life-saver for some, like the new Hepatitis-C drugs, do we really want to let them use their patent exclusivity to sell the 90 day treatment at $1000/day? And with this silly ploy, do we really want to let Pfizer intimidate doctors and pharmacists by using patent laws to insist on their writing Brand prescriptions? or the NHS? or anybody? Not hardly…
Mickey @ 8:52 AM