long overdue…

Posted on Friday 27 June 2014


PsychiatricNews
by Paul Summergrad, M.D.
June 27, 2014

I recently covered on our inpatient psychiatry service at Tufts Medical Center. It is always valuable to see patients at the bedside and to spend time with wonderful psychiatric residents. As usual, the level of both medical psychiatric comorbidity and clinical complexity was challenging, as were the efforts to find the right clinical care and navigate a mental health system that is often fragmented and difficult at best. It was nevertheless greatly rewarding to see patients, to learn something about their life stories, and try to select care that was based on the best available science, and, when none was available, upon clinical experience and judgment…
To have an APA President acknowledge that the mental health system is "often fragmented and difficult at best;" to talk about learning "something about [patient’s] life stories;" and including "clinical experience and judgment" in the same sentence as "the best available science;" all feel like a cool breeze on a hot summer day after listening to years of dreams for some near-term biomedical future that never quite seems to materialize.
By this I meant that we must always remember, first and foremost, that we are physicians. It is thus incumbent upon us to be aware of the best scientific evidence available when we make clinical decisions, doing so in the context of the total needs — medical and otherwise — of our patients. It means to speak on their behalf even when it may bring us into conflict with others whose primary focus may be financial, legal, or ideological. It requires us to be deeply knowledgeable not only about the scientific literature and best practices, but also to have more than a passing familiarity with the limitations of that literature and to be prepared to speak when we must despite those limitations. And to do so on our patients’ behalf, not our own…
He adds speaking on behalf of our patients "even when it may bring us into conflict with others whose primary focus may be financial, legal, or ideological" and having "more than a passing familiarity with the limitations of [our] literature." Here he addresses the restraint on therapeutic zeal embodied in the ethical injunction, "first, do no harm" – too long neglected by organized psychiatry. And by mentioning the "financial, legal, or ideological" forces, he names those things that we all know have contaminated not only organized and academic psychiatry, but also many practitioners.
Even more importantly, we must always be mindful that as physicians we have a special responsibility to speak from our rich clinical experience, and most importantly, from the best science available, wherever that may take us and regardless of opposition. These values and clinical and scientific expertise must be the primary touchstones of our policies and public statements about psychiatry. People may not always like what we have to say, and they may often disagree with it. But if we speak as physicians from our best understanding of what the science of our field is, and our honest view of the best interests of our patients, then they do listen. Ultimately, they will often trust, respect, and rely on our opinion…
Obviously, the things Dr. Summergrad is saying in this piece are just what I’d want to hear, particularly when said from his position as president of the APA. But even more important, the intended audience are the psychiatrists he’s been elected to lead. The themes that touch on medical ethics, humility in the face of the limits of our knowledge, and the balance between science and clinical experience have been too long absent from  the rhetoric of the APA, and his repeated reminders that we must speak on our "patients’ behalf, not our own" is long overdue. High marks from this old man…
Mickey @ 1:11 PM

return to a madness in our method

Posted on Tuesday 24 June 2014

This is the sixth in a series:

  1. a madness to our method…
  2. are you listening?…
  3. another campaign?…
  4. read me him…
  5. a madness to our method – a new introduction…
First, my apologies for the length and number of posts about this BMJ article. It was so heavily pushed in the press and so confusing that I thought it was worth the monotony to chase down. In my original shot at this article [a madness to our method…], I just couldn’t follow what they were saying about how they came up with their method to identify suicide attempts in the database. I’ve highlighted the part I found confusing in red below in the abstract…
by 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
British Medical Journal. 2014 348:g3596.

Objective To investigate if the widely publicized warnings in 2003 from the US Food and Drug Administration about a possible increased risk of suicidality with antidepressant use in young people were associated with changes in antidepressant use, suicide attempts, and completed suicides among young people.
Design Quasi-experimental study assessing changes in outcomes after the warnings, controlling for pre-existing trends.
Setting Automated healthcare claims data [2000-2010] derived from the virtual data warehouse of 11 health plans in the US Mental Health Research Network.
Participants Study cohorts included adolescents [around 1.1 million], young adults [around 1.4 million], and adults [around 5 million].
Main outcome measures Rates of antidepressant dispensings, psychotropic drug poisonings [a validated proxy for suicide attempts], and completed suicides.
Results Trends in antidepressant use and poisonings changed abruptly after the warnings. In the second year after the warnings, relative changes in antidepressant use were −31.0% [95% confidence interval −33.0% to −29.0%] among adolescents, −24.3% [−25.4% to −23.2%] among young adults, and −14.5% [−16.0% to −12.9%] among adults. These reflected absolute reductions of 696, 1216, and 1621 dispensings per 100 000 people among adolescents, young adults, and adults, respectively. Simultaneously, there were significant, relative increases in psychotropic drug poisonings in adolescents [21.7%, 95% confidence interval 4.9% to 38.5%] and young adults [33.7%, 26.9% to 40.4%] but not among adults [5.2%, −6.5% to 16.9%]. These reflected absolute increases of 2 and 4 poisonings per 100 000 people among adolescents and young adults, respectively [approximately 77 additional poisonings in our cohort of 2.5 million young people]. Completed suicides did not change for any age group.
Conclusions Safety warnings about antidepressants and widespread media coverage decreased antidepressant use, and there were simultaneous increases in suicide attempts among young people. It is essential to monitor and reduce possible unintended consequences of FDA warnings and media reporting.
And in the text of the paper…
Study cohorts and outcome measures
Because previous studies showed that rates of depression diagnosis changed after the warnings and that outpatient claims are often incomplete for mental health conditions such as depression, to avoid introducing selection bias, we did not limit our cohorts to those with a coded diagnosis of depression.

…To examine changes in suicide attempts after the warnings, we used the same denominator population as defined previously. While encounters for suicide attempts can be identified in administrative databases using external cause of injury codes [E-codes], they are known to be incompletely captured in commercial plan databases. Our preliminary analysis found that E-code completeness varied across study sites, treatment settings, and years. Therefore, instead of deliberate self harm E-codes, we used poisoning by psychotropic agents [international classification of diseases, ninth revision, clinical modification [ICD-9] code 969], a more reliable proxy for population level suicide attempts. Poisoning by drugs or toxic substances is the most common method of suicide attempt leading to hospital admission and emergency room treatments. 35 36 Non-fatal poisoning by psychotropic drugs [predominantly tranquilizers] has a positive predictive value of 79.7% for suicide attempts [sensitivity was 38.3% and specificity was 99.3%], outperforming other types of injuries or poisonings..
So I was visiting a sick friend  out of town. And in the spaces when he was resting up, I started chasing the paper’s references backwards [as in the last post]. I thought their studying the inconsistency of the E-codes was solid. And I thought Patrick et al did a passable job of trying to locate a surrogate, though it felt forced. But when I got to the part where Lu et al rejected Patrick’s algorithm based on some of those old Pharma propaganda articles from back when they were trying to reverse the Black Box Warnings, I felt like I’d found the madness:

  1. Decline in treatment of pediatric depression after FDA advisory on risk of suicidality with SSRIs.
    by Libby AM, Brent DA, Morrato EH, Orton HD, Allen R, Valuck RJ.
    American Journal of Psychiatry. 2007 164[6]:884-891.
    [full text online]
  2. Persisting decline in depression treatment after FDA warnings.
    Libby AM, Orton HD, Valuck RJ.
    Archives of General Psychiatry. 2009 66[6]:633-639.
    [full text online]
They were assuming that the increasing rate of diagnosis of pediatric depression and prescribing antidepressants pre-Warning was correct and the Black Box Warning put a damper on things. Hallelujah for the damper is all I have to say about that. 

At face value, the whole premise for the study is flawed. The SSRIs have only been shown to be effective in pediatric depression in Lilly’s earliest studies of Prozac, and in spite of their creative publications, the remainder have been ineffective. So, the idea that the SSRIs are even treatment for adolescent depression is in question, much less much a suicide attempt preventative. There is no direct linkage between the decrease in prescribing and their outcome parameter to validate the association implied. And the thing they actually measured is in itself a proxy for another proxy, based on the evidence from the most compromised of sources. My own takeaway from this article is that, once again, this was an attempt to answer a question using a huge dataset from a commercial administrative data, and it wasn’t up to the task. Having access to that much data is certainly tempting, but the absence of reliable E-coding doomed the study before it ever got off the ground. The errors intrinsic in any proxy, much less a second generation proxy, will probably never make them useful in answering subtle scientific questions.

There is a much larger question in this story, a question that has been present from the start – case studies versus population data. If you’ve seen Akathisia and suicidality in cases of adolescents put on SSRIs, and if you know of several completed suicides that you’re convinced were medication induced, how are you to look at a study like this even if you believe it?  This line of thinking presumes that the only thing one can do for a depressed teen is give them SSRIs, which has never been true. A blog is no place to launch into all the things one might do besides give a questionable symptomatic medication, how to actually approach a depressed teen. But even common sense tells us that there are a wide range of answers to that question that don’t only rely on medication. And if, after careful consideration, you decide to try an antidepressant, knowing that this kind of reaction can occur in some cases would certainly heavily inform how you would closely follow such a case.

There are many things one might say about this article, but this ending is certainly not one that would ever occur to me……
… it is disturbing that after the health advisories, warnings, and media reports about the relation between antidepressant use and suicidality in young people, we found substantial reductions in antidepressant treatment and simultaneous, small but meaningful increases in suicide attempts. It is essential to monitor and reduce possible unintended effects of FDA warnings and media reporting.
Mickey @ 11:15 PM

a madness to our method – a new introduction…

Posted on Tuesday 24 June 2014

The 1991 FDA hearing about SSRIs and suicidality was principally focused on Prozac and pitted case reports against the Clinical Trial data. My recollection is that the general thought was that this was seen as a campaign initiated by the Scientologists and it didn’t have a major impact at the time. But the second time around over a decade later was another matter. It was at what we might now call the apogee of the Age of Pharmacology [in that day still a rising star]. This time, the focus was on children and adolescents; there was a damning FDA meta-analysis; and many more cases. The Black Box Warning was born:

The war on the Black Box Warning began immediately, and has been unrelenting for the decade that followed – saying that the analyses showing increased suicidality were wrong or that the Black Box Warning and the publicity caused doctors and patients to withhold needed treatment leading suicide attempts to actually increase. If there is a single consistent point from all this flap, it was a consensus that the rate of prescribing antidepressants to children and adolescents has fallen as a result after the warning.

The many attempts to discredit or undo the Black Box Warnings have involved multiple tries at reanalysis of the Clinical Trials and some attempts to show an adverse effect using large databases from a variety of sources. This most recently published study from the Harvard Pilgrim Health Care Institute [Changes in antidepressant use by young people and suicidal behavior after FDA warnings and media coverage: quasi-experimental study] attempted to query the data from a number of commercial regional Health Care plans. There are a number of confounding factors in taking this approach, some having to do with the data itself. The most explicit coding in the ICD-9 for suicide attempts are in the E-codes [external events] – deliberate self harm. However in many of the Healthcare plans, E-coding is very spotty ["However, insurance claims databases such as Medicare have low rates of E-code completeness, presumably because the billing software used by many hospitals removes E-codes since they have no relevance for hospital payments"]. In 2010, Patrick et al studied several datasets trying to find a way around this problem:
by Amanda R. Patrick, Matthew Miller, Catherine W. Barber, Philip S. Wang, Claire F. Canning and Sebastian Schneeweiss
Pharmacoepidemiology and Drug Safety. 2010 19:1263–1275.

Context: Suicidal behavior has gained attention as an adverse outcome of prescription drug use. Hospitalizations for intentional self-harm, including suicide, can be identified in administrative claims databases using external cause of injury codes [E-codes]. However, rates of E-code completeness in US government and commercial claims databases are low due to issues with hospital billing software.
Objective: To develop an algorithm to identify intentional self-harm hospitalizations using recorded injury and psychiatric diagnosis codes in the absence of E-code reporting.
Methods: We sampled hospitalizations with an injury diagnosis [ICD-9 800–995] from two databases with high rates of E-coding completeness: 1999–2001 British Columbia, Canada data and the 2004 US Nationwide Inpatient Sample. Our gold standard for intentional self-harm was a diagnosis of E950-E958. We constructed algorithms to identify these hospitalizations using information on type of injury and presence of specific psychiatric diagnoses.
Results: The algorithm that identified intentional self-harm hospitalizations with high sensitivity and specificity was a diagnosis of poisoning, toxic effects, open wound to elbow, wrist, or forearm, or asphyxiation; plus a diagnosis of depression, mania, personality disorder, psychotic disorder, or adjustment reaction. This had a sensitivity of 63%, specificity of 99% and positive predictive value [PPV] of 86% in the Canadian database. Values in the US data were 74, 98, and 73%. PPV was highest [80%] in patients under 25 and lowest those over 65 [44%].
Conclusions: The proposed algorithm may be useful for researchers attempting to study intentional self-harm in claims databases with incomplete E-code reporting, especially among younger populations.
Using these two databases with high levels of E-code completion, they derived an algorithm that they felt was an adequate "proxy" that correlated well with the explicit E-codes for deliberate self harm: "a diagnosis of poisoning, toxic effects, open wound to elbow, wrist, or forearm, or asphyxiation; plus a diagnosis of depression, mania, personality disorder, psychotic disorder, or adjustment reaction."

In February 2014, Lu et al [authors of the recent article in the BMJ] wrote a letter to the editor about another article from Vanderbilt that had used E-codes and psychiatric diagnosis as an indicator of suicide attempts. They pointed out the unreliability of WE-code reporting in commercial databases and illustrated the point with some examples of their own:
Letter to the Editor
by Christine Y. Lu, Christine Stewart, Ameena T. Ahmed, Brian K. Ahmedani, Karen Coleman, Laurel A. Copeland. Enid M. Hunkeler, Matthew D. Lakoma, Jeanne M. Madden, Robert B. Penfold, Donna Rusinak, Fang Zhang, and Stephen B. Soumerai
Pharmacoepidemiology and Drug Safety. 2014 23[2]:218-220.

We advise caution in applying the claim-based algorithm developed by Callahan et alet al. method uses external cause of injury codes [E-codes] in combination with diagnosis codes for poisoning derived from the International Classification of Diseases, ninth revision, Clinical Modification [ICD-9-CM] coding scheme to identify hospitalizations for suicide attempts. In recent years, there has been considerable concern that suicidal behavior is a potential adverse outcome of prescription drug use such as antidepressant and anticonvulsant agents. Nonfatal, deliberate self-harms resulting in emergency department treatments and hospitalizations can be identified in administrative databases using E-codes. These codes are part of the ICD-9-CM and are used to provide information about the cause and intent of an injury or poisoning. E-coding is mandatory in about half of US states, and the completeness of E-codes in state hospital discharge databases typically exceeds 90%. As part of a study of effects of safety warnings on antidepressant use and suicidality in youth, we assessed the completeness of E-codes in commercial health plan databases.

METHODS: Our analysis included 10 geographically distinct healthcare organizations in the Mental Health Research Network [MHRN] within the Health Maintenance Organization Research Network [HMORN]. The health plans had a combined population of nine million enrollees in 2010. This analysis was part of a longitudinal study of effects of Food and Drug Administration warnings for antidepressants and suicidality in youth that was approved by the institutional review board of each participating organization…

We calculated the completeness of E-codes, defined as the proportion of encounters with an injury/poisoning ICD-9-CM code that had a valid E-code indicating the cause for the encounter. As in prior research, we identified hospitalizations and emergency department visits with a primary or secondary diagnosis of injury/poisoning. We focused on injuries that are likely methods of deliberate self-harm: open wound injuries, superficial injuries, and poisonings. Because E-code collection and reporting requirements vary temporally and by region, we assessed E-code completeness rates from 2000 to 2010 by MHRN site and care setting. A V-code [supplemental information about factors influencing health service use] was introduced in 2005 indicating suicidal ideation [ICD-9: V62.84]. In a sensitivity analysis, we calculated E-code completeness, while also including V62.84 that could be used in place of E-codes to identify a suicidal related encounter.

RESULTS: Figure 1 presents E-code completeness rates in emergency department and hospital settings over time. E-code completeness varied widely across study sites [e.g., ranging from 7% to 92% in the emergency department setting in 2010], across treatment settings [e.g., ranging from 7% to 56% at one study site in 2010], and across years [e.g., ranging from 36% in 2000 to 92% in 2010 at one study site]. Only two sites had consistent, reasonable levels of E-code recording over this period [ranging from 65% to 82%]. Our investigation indicates that the suicidal ideation code did not substitute or compensate for lack of E-codes with injury/poisoning diagnoses.


Proportion of injury and poisoning encounters that had a valid E-code in [A] emergency rooms and [B] hospitals by study site [2000–2010]

COMMENT: In our analysis of VDW data from 10 MHRN sites between 2000 and 2010, we found that E-code completeness varied across study sites, across treatment settings, and across years of observation. There are several possible reasons for the low rates of and/or variability in E-code completeness observed: E-codes have no relevance for payments; not all diagnosis codes are transformed into the VDW from source data; and recording practice for E-codes may vary across sites, possibly because of state regulations, health plan policies, or the clinical software used. The incompleteness we observed in this study limits the usefulness of the available E-coded data. Other studies also found high missingness of E-codes in hospital and emergency department settings.

Despite the high positive predictive value of 85% reported by Callahan et al. there are two issues relating to the use of the algorithm: [i] the completeness of E-codes in the dataset and [ii] the dependence on valid E-coded data.

We agree with Callahan et al. that it is important to develop and use alternative diagnosis codes that can identify suicide attempts. In the absence of complete E-codes, Patrick et al. developed and tested algorithms for identifying hospitalizations for deliberate self-harm in a population aged 10 years and over. This study used the US National Inpatient Sample data and data from British Columbia; both data sources had E-code completeness rates above 85 %. The gold standard for deliberate self-harm was defined as hospitalizations with a diagnosis of E950-958. Patrick et al. found that an algorithm combining diagnoses for psychiatric disorders [including depression] and injury/poisoning can produce a positive predictive value as high as 87.8% for identifying hospitalizations for deliberate self-harm [with specificity of 99.4% and sensitivity of 57.3%].
If you’ve been scanning along here sleepily, it’s time to sit up and take notice. After illustrating the E-code problem, they question Patrick et al’s solution [the algorithm above]…
In the context of our longitudinal study on the impact of Food and Drug Administration warnings on antidepressant use and subsequent suicidality in youth, using Patrick’s algorithm may introduce ascertainment bias because rates of depression diagnosis declined subsequent substantially after the warnings.
If you’re following this, they’re about to jettison Patrick’s algorithm because the rate of diagnosing pediatric depression was reported as being decreased [mostly in primary care]. Here are the references they cite for this comment:

  1. Decline in treatment of pediatric depression after FDA advisory on risk of suicidality with SSRIs.
    by Libby AM, Brent DA, Morrato EH, Orton HD, Allen R, Valuck RJ.
    American Journal of Psychiatry. 2007 164[6]:884-891.
    [full text online]
  2. Persisting decline in depression treatment after FDA warnings.
    Libby AM, Orton HD, Valuck RJ.
    Archives of General Psychiatry. 2009 66[6]:633-639.
    [full text online]
I call foul! These are Eli Lilly funded articles by Eli Lilly funded  authors from a period when there was an all out campaign against the warning. They proselytize calling for policy changes based on… I’ll stop rather than rant. The articles are there to read and are typical for the kind of PHARMA invasion of scientific literature that we’re all raving about. Take a look. The idea that they represent ascertainment bias is ludicrous. They represent something else – Bad Science by Bad Pharma. A rational interpretation is that the Black Box Warning put some badly needed brakes on a runaway overmedication epidemic. [see pretty loud coi…, tortured numbers…, etc]. Moving along…
A diagnosis of “poisoning by psychotropic agents” alone outperformed other injury/poisoning types; its positive predictive value was 79.7% with specificity of 99.3% and sensitivity of 38.3%.
So here they go back to Patrick’s article that compiled a bunch of algorithms to test and pick one with a much weaker sensitivity and predictive value and many other problems.
While psychotropic drug poisoning underestimates rates of suicide attempts because of its low sensitivity, it can be useful for detecting suicide attempts in study settings that have low or inconsistent E-code rates over time. Such consistency is required for longitudinal analyses of trends in deliberate self-harms.

In summary, our analysis confirmed that E-codes were substantially incomplete in commercial insurance claims databases. We observed that E-code completeness varied widely across MHRN sites, across treatment settings, and over time. Completeness improved at some sites and deteriorated at other sites. Psychotropic drug poisonings may be useful for identifying deliberate self-harm requiring hospitalization in commercial plan databases when E-codes are missing…
So now on to back to the article for another look…
Mickey @ 9:21 PM

read me him…

Posted on Saturday 21 June 2014

I’m about to hit the road to visit an old friend on the other end of the South for a few days and will be out of pocket, but I didn’t want to take off without linking to this article about the BMJ study at hand [Changes in antidepressant use by young people and suicidal behavior after FDA warnings and media coverage: quasi-experimental study].

I give it an A+!
PLoS Blogs
By Adrian Preda M.D.
June 21, 2014

A new study just published in the BMJ makes this very point [Changes in antidepressant use by young people and suicidal behavior after FDA warnings and media coverage: quasi-experimental study]

The title makes two claims:
  1. That the  2003 black box  US Food and Drug Administration warning about possible increased risk of suicidality with antidepressants lead to a change in antidepressant prescriptions.
  2. Further, that there were changes in suicidal behavior following the said US FDAwarning.
While the title does not indicate the direction of the changes, the study conclusions carry little ambiguity:
    Safety warnings about antidepressants and widespread media coverage decreased antidepressant use, and there were simultaneous increases in suicide attempts among young people.
This is obviously a big claim, with far reaching implications spreading from the level of primary care physicians who might consider changing their antidepressant prescription practices to the level of policy makers deciding on guidelines about antidepressants approvals and reimbursement. In this post we will discuss some of the study limitations that, for unclear reasons, seem to have been all but ignored by the over-excited welcome that study received in the mainstream media. Our goal here is to not discuss subtle academic limitations but rather obvious limitations which could have been picked even by a casual yet critical reader of the paper. We will then cursorily survey the media presentations of the paper and assess the quality of their review in terms of balance and fair criticism. Let’s start with some of the study most overt shortcomings:
  1. The title is not entirely informative. The study reviews US data however the title seems to indicate world-wide findings.
  2. The study uses a quasi-experimental design assessing changes in outcomes after the FDA  warnings, controlling for pre-existing trends. However the reliability of the controls is not entirely convincing.
  3. Not much is known about the relationship (if any) between the individuals entered in the study because they were prescribed antidepressants and the individuals who took psychotropic overdoses.
  4. The study uses psychotropic drug poising data as a proxy for suicide but is that a good proxi?
  5. The study does not address the possibility that suicide has been on the raise for reasons having nothing to do with antidepressant prescriptions (such as the recent years economic crisis).

Big media enthusiastic welcomes

First the Washington Post (Dennis) reports:
    As a result [of the FDA warnings] antidepressant prescriptions fell sharply for adolescents age 10 to 17 and for young adults age 18 to 29. At the same time, researchers found that the number of suicide attempts rose by more that 20 percent in adolescents and by more than a third in young adults.
Comment from a non-study affiliated expert? YES
How many limitations are discussed? NONE

According to NBC News (Raymond) :
    New research finds the warning backfired, causing an increase in suicide attempts by teens and young adults. After the FDA advisories and final black box warning that was issued in October 2004 and the media coverage surrounding this issue, the use of antidepressants in young people dropped by up to 31 percent.
Comment from a non-study affiliated expert? NO
How many limitations are discussed? NONE

Reuters (Seaman) reports that:
    Antidepressant use decreased by 31 percent among adolescents, about 24 percent among young adults and about 15 percent among adults after the warnings were issued. At the same time, there were increases in the number of adolescents and young adults receiving medical attention for overdosing on psychiatric medicines, which the authors say is an accurate way to measure suicide attempts. Those poisoning increased by about 22 percent among adolescents and about 34 percent among young adults after the warnings. That translates to two additional poisoning per 100,000 adolescents and four more poisoning per 1,000 young adults, the researchers write.
Comment from a non-study affiliated expert? YES
How many limitations are discussed? ONE (limitation #5)

According to USA TODAY (Painter):
    Warnings that antidepressant medications might prompt suicidal thinking in some young people may have backfired, resulting in more suicide attempts, new research suggests.
Comment from a non-study affiliated expert? YES
How many limitations are discussed? NONE

    Antidepressant use fell 31 percent among adolescents and 24 percent among young adults after the FDA warnings, according to the study. Suicide attempts increased by almost 22 percent among adolescents and 33 percent among young adults in the same time period. Suicide attempts tracked in the study were largely the result of drug overdoses.
Comment from a non-study affiliated expert? NO
How many limitations are discussed? NONE

NPR (Stein) also reports on the story:
    Antidepressant use nationally fell 31 percent among adolescents and 24 percent among young adults, the researchers reported. Suicide attempts increased by almost 22 percent among adolescents and 33 percent among young adults.
Comment from a non-study affiliated expert? YES
How many limitations are discussed? ONE (limitation #5)

Finally, the Boston Globe (Freyer) concludes that
    instead of declining as hoped, suicide attempts over the next six years showed a “small but meaningful” uptick among people ages 10 to 29, according to a study published Wednesday in the journal BMJ. That increase followed a substantial drop in the use of antidepressants.
Comment from a non-study affiliated expert? YES
How many limitations are discussed? NONE

Final conclusions

Somewhat paradoxically, a study that tongue-in-cheek points to the media’s uncritical coverage of medical news as a possible contributor to a public health issue receives an almost universal and equally uncritical acclaim from the same media that it rightfully criticizes. In a past analysis of medical news reporting I stated that
    In closing: my hope is that members of the media who cover [medical] debate[s] will realize that “first do no harm” is not only the duty of physicians; it is also the responsibility of anyone trusted with giving health information to the public at large.
More than 2 years later I found that this conclusion still stands…
Mickey @ 10:28 AM

another campaign?…

Posted on Friday 20 June 2014

First off, thanks to Suzanna for sending along a tutorial about QUASI-EXPERIMENTAL RESEARCH DESIGNS [I must’ve cut that lecture in psychoanalytic training]. Likewise, thanks to Dr. Carroll for his looking over Dr. Lu’s article [how does he see all that stuff?]. The tips are a big help in reading the article without my eyes crossing. One thing that Dr. Carroll noted was something I also wondered about along the way – a blip in adolescent males that didn’t pan out [see watchful waiting…] though it was earlier than Lu’s two year marker:

Early evidence on the effects of regulators’ suicidality warnings on SSRI prescriptions and suicide in children and adolescents. [see peaks and valleys…, watchful waiting…]
  by Gibbons RD, Brown CH, Hur K, Marcus SM, Bhaumik DK, Erkens JA, Herings RM, Mann JJ.
  American Journal of Psychiatry. 2007 Sep;164[9]:1356-63.

But I’m done with the science of this article and defer to people with more wisdom and talent on the methods of analysis. I want to talk about something else related – Big Data [see two points…]. It’s all the rage now and deserves our attention. Essentially, it comes from places like Google, Amazon, the NSA. It’s a way of thinking about the huge databases being amassed everywhere. The book is about how people are learning how to query and correlate these huge datasets without worrying so much about missing data and unequal sample sizes. We don’t think about it, but a lot of our science is based on looking at a small sample, then extrapolating to the general population – so we’re super precise and use our statistical tests and our rational brains. Big Data people don’t worry about that so much. They have huge data [like approximating all of it]. And they don’t care if the correlations don’t make sense [as in the most accurate index for following the spread of flu is an algorithm that queries Google searches]. It’s the fact that they correlate that matters. And this study [Changes in antidepressant use by young people and suicidal behavior after FDA warnings and media coverage: quasi-experimental study] is Big Data. They have an impressive dataset:
    Study cohorts included adolescents [around 1.1 million], young adults [around 1.4 million], and adults [around 5 million].
And they use an analytic technique that I’ve never encountered [Big Data people do that]. So in spite of the fact that I’m awed that Amazon can make recommendations for me that are big surprises but dead on the money [about a week after a friend sent me the Big Data book, Amazon popped it up based on my former buying habits!]. And I’m not upset that some computer somewhere is crunching big numbers to make adjustments in my retirement portfolio, but I’m pretty sure I don’t want some Big Data program making treatment recommendations on my family. I’ve seen suicidality including death in adolescents on SSRIs with my own eyes. And I’m underwhelmed that they are even clinically effective in adolescent depression with Clinical Trials that look like this:

If I decide that an SSRI might be useful in an adolescent [OCD, GAD, maybe big depression], I want to find out a lot of stuff. Will the kid come back and let me look for myself? How stable is the family? Are the parents well informed and looking? Do I have an alliance with these people? Or is the kid an impulsive latchkey kid with an alcoholic single parent who collects guns? [a real example]. This Big Data study says nothing to me about that kind of decision either way. But If I worked for Managed Care as a population statistician and I saw all that data [and I got raises or kudos based on any cost cutting], I might find myself really impressed with these small differences.

The Clinical Trial era has already confronted us and our patients with the problem of small differences in medication effect and reams of treatment guidelines that may or may not be meaningful. We’d best anticipate that studies like this one are just harbingers of what’s going to happen when these vast datasets gathered by electronic medical records, HMOs, prescriptions, pharmacies, scanners, screenings, etc multiply exponentially in the coming years. I expect some good things will emerge, but the possibilities for confusion, error, and deceit will likely grow in parallel. In psychiatry, we already have studies ongoing like iSpot and EMBARC that hope to pick your antidepressant based on some collection of other measurable parameters [don’t hold your breath]. Add to that the dream of adjusting your medication dose based on your weekly iPhone CAT-D App via a brief chat on the cloud with your tele-psychiatrist. Maybe your Google searches can get in the mix as well [I wish I were exaggerating].

The approach in this article moves us away from case centered medicine to a much more population centered focus, away from pathophysiological understanding to empiricism, and leaves both doctor and patient prey to misinformation that can not be tested by either. In these posts, I’ve only listed a few of the many articles that purport to tell us about the Black Box Warning. It’s a study in case reports versus epidemiological data – and I expect it will keep coming. Meanwhile, this article is on the opening page of the Harvard Medical School website, it’s a Psychiatric News Alert, and it’s tweeted by the new APA President. Feels almost like another campaign [see smell a campaign…, the campaign…]
I guess I can’t complain. It’s on this blog three times too…

UPDATE: OK. You win. It’s a campaign…
New England Public Radio
by Rob Stein
June 18, 2014

… “I think there were a lot of mistakes made in terms of how this risk was communicated to the public, which led a lot of parents to be terrified to have their children on these medications — and they took them off and there was a lot of untreated, serious depression,” says Robert Gibbons, a University of Chicago biostatistician who advised the FDA on the issue…
and…
etc. etc…
Mickey @ 1:06 PM

are you listening?…

Posted on Thursday 19 June 2014

If you go to the Department of Population Medicine website, the home of Christine Lu, MSc, PhD, first author of the article in my last post [a madness to our method…], you’ll notice two logos. One is the familiar Harvard Medical School logo [currently featuring Unintended Danger from Antidepressant Warnings], the other is something called the Harvard Pilgrim Health Care Institute. Go ahead and click them [here if you like]:
Notice that the Harvard Pilgrim Health Care Institute icon takes you to the Harvard Pilgrim Health Care Plan – "Harvard Pilgrim Health Care is the #1 health plan in the nation for the 10th year in a row!" And you might check out some of Dr. Lu’s other publications. Now go back and take a look at the Department of Population Medicine website and nose around for a bit. It’s a Managed Care Think Tank. Now, go back to the article and look at the Competing Interests, it says:

    Competing interests: All authors have completed the ICMJE uniform disclosure form at www.icmje.org/coi_disclosure.pdf [available on request from the corresponding author] and declare that all authors have support from the National Institute of Mental Health for the submitted work… Other authors [including Christine Lu] declared no financial relationships with any organizations that might have an interest in the submitted work in the previous three years, no other relationships or activities that could appear to have influenced the submitted work.

We have lived with thirty long years of enduring a medical literature literally infested with pharmaceutical industry generated articles which weren’t originally even identified as coming from industry. This particular topic was a regular target for the pharmaceutical industry, but there was a hint of Managed Care along the way. A few examples:

  • The relationship between antidepressant medication use and rate of suicide.
    by Gibbons RD, Hur K, Bhaumik DK, Mann JJ.
    Arch Gen Psychiatry. 2005 Feb;62(2):165-72.
  • The relationship between antidepressant prescription rates and rate of early adolescent suicide.
    by Gibbons RD, Hur K, Bhaumik DK, Mann JJ.
    Am J Psychiatry. 2006 Nov;163(11):1898-904.
  • Association of suicide and antidepressant prescription rates in Japan, 1999-2003.
    by Nakagawa A, Grunebaum MF, Ellis SP, Oquendo MA, Kashima H, Gibbons RD, Mann JJ.
    J Clin Psychiatry. 2007 Jun;68(6):908-16.
  • Relationship between antidepressants and suicide attempts: an analysis of the Veterans Health Administration data sets.
    by Gibbons RD, Brown CH, Hur K, Marcus SM, Bhaumik DK, Mann JJ.
    Am J Psychiatry. 2007 Jul;164(7):1044-9.
  • Impact of Publicity Concerning Pediatric Suicidality Data on Physician Practice Patterns in the United States
    by Charles B. Nemeroff, Amir Kalali, Martin B. Keller, Dennis S. Charney, Susan E. Lenderts, Elisa F. Cascade, Hugo Stephenson, and Alan F. Schatzberg
    Archives of General Psychiatry. 2007 64(4):466-472.
  • Early evidence on the effects of regulators’ suicidality warnings on SSRI prescriptions and suicide in children and adolescents.
    by 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.
  • The role of randomized trials in testing interventions for the prevention of youth suicide.
    by Brown CH, Wyman PA, Brinales JM, Gibbons RD.
    Int Rev Psychiatry. 2007 Dec;19(6):617-31.
  • Mixed-effects Poisson regression analysis of adverse event reports: the relationship between antidepressants and suicide.
    by 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.
  • News coverage of FDA warnings on pediatric antidepressant use and suicidality
    by Barry CL and Busch SH.
    Pediatrics. 2010 125[1]:88-95.
  • Strategies for quantifying the relationship between medications and suicidal behaviour: what has been learned?
    by Gibbons RD, Mann JJ.
    Drug Saf. 2011 May 1;34(5):375-95.
  • Suicidal Thoughts and Behavior With Antidepressant Treatment: Reanalysis of the Randomized Placebo-Controlled Studies of Fluoxetine and Venlafaxine
    by Robert D. Gibbons, PhD; C. Hendricks Brown, PhD; Kwan Hur, PhD; John M. Davis, MD; J. John Mann, MD
    Arch Gen Psychiatry. 2012;69(6):580-587.
Now we have a new assault. This time, it’s from Harvard’s Health Insurance Company’s Think Tank. And I don’t think "no financial relationships with any organizations that might have an interest in the submitted work" is a truthful declaration. I would argue that Managed Care plans are heavily invested in using antidepressants in depressed youth as opposed to the alternatives. Call me paranoid, but I smell a large rat here and would suggest that the medical literature faces the potential threat of yet another invasion as destructive as the last one. Managed Care has a literature of its own, and I’d appreciate their publishing in it rather than in mine eg the British Medical Journal [Editor Fiona Goddlee, are you listening?]…
Mickey @ 11:47 PM

a madness to our method…

Posted on Thursday 19 June 2014

by Christine Y Lu, Fang Zhang, Matthew D Lakoma, 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, and Stephen B Soumerai
British Medical Journal. 2014 348:g3596.

Objective To investigate if the widely publicized warnings in 2003 from the US Food and Drug Administration about a possible increased risk of suicidality with antidepressant use in young people were associated with changes in antidepressant use, suicide attempts, and completed suicides among young people.
Design Quasi-experimental study assessing changes in outcomes after the warnings, controlling for pre-existing trends.
Setting Automated healthcare claims data [2000-10] derived from the virtual data warehouse of 11 health plans in the US Mental Health Research Network.
Participants Study cohorts included adolescents [around 1.1 million], young adults [around 1.4 million], and adults [around 5 million].
Main outcome measures Rates of antidepressant dispensings, psychotropic drug poisonings [a validated proxy for suicide attempts], and completed suicides.
Results Trends in antidepressant use and poisonings changed abruptly after the warnings. In the second year after the warnings, relative changes in antidepressant use were −31.0% [95% confidence interval −33.0% to −29.0%] among adolescents, −24.3% [−25.4% to −23.2%] among young adults, and −14.5% [−16.0% to −12.9%] among adults. These reflected absolute reductions of 696, 1216, and 1621 dispensings per 100 000 people among adolescents, young adults, and adults, respectively. Simultaneously, there were significant, relative increases in psychotropic drug poisonings in adolescents [21.7%, 95% confidence interval 4.9% to 38.5%] and young adults [33.7%, 26.9% to 40.4%] but not among adults [5.2%, −6.5% to 16.9%]. These reflected absolute increases of 2 and 4 poisonings per 100 000 people among adolescents and young adults, respectively [approximately 77 additional poisonings in our cohort of 2.5 million young people]. Completed suicides did not change for any age group.
Conclusions Safety warnings about antidepressants and widespread media coverage decreased antidepressant use, and there were simultaneous increases in suicide attempts among young people. It is essential to monitor and reduce possible unintended consequences of FDA warnings and media reporting.
I sippose that I would be predicted to react negatively to this article, described by some today as the most famous article on the planet several hours after it went online. But to be honest, I spent the afternoon reading and rereading the Methods section to no avail. It actually reminded me of those opaque Gibbons articles [an anatomy of a deceit 1… etc] two years ago. Even if it said what I would expect it to say, I wouldn’t believe it either without a major methodological explanation. For one thing, the suicide data from these HMOs is radically different in shape and magnitude from that in the CDC Compressed Mortality which goes back to 1979 [see peaks and valleys…]:
 
Whatever the case, I expect there will be re-analyses all over the Internet by month’s end. So if you’re going to read this article, read the Methods section first and if you understand what they actually did, please enlighten the rest of us…
Mickey @ 8:00 PM

first order solution…

Posted on Thursday 19 June 2014

There are things one misses by going to medical school and having a medical career. People like me know next to nothing about business or legal matters. Pre-Med was all science. Medical School was all science, A couple of residencies and psychoanalytic training didn’t fill in any legal blank spaces. And frankly, most doctors are too busy to have time to do much sin or have brushes with the law. I’ve never even been picked for a jury. So when it comes to the legal stuff, many of us are dumb as posts [take me for example], and it takes us a while to get up to speed with matters legal. I finally figured out what Dr. Poses of Healthcare Renewal has been talking about for years, the anechoic effect – why stories of great fraud in medicine just die out. I finally got it that by settling a suit, a drug company seals the evidence, walks away saying "we admit no wrongdoing," and puts a damper on any publicity for the incriminating evidence [see with no echo…]. And they go to any lengths to keep it that way, as in this story…
Pharmalot
By Ed Silverman
Jun 16, 2014

A federal judge may sanction a physician who served as an expert witness in the ongoing litigation over the Vioxx painkiller for describing confidential documents to The Wall Street Journal. Earlier this month, U.S. District Court Judge Eldon Fallon issued a restraining order saying David Egilman, who is a Brown University clinical professor of family medicine, “may have acted in derogation of his responsibilities.” Egilman was an expert witness with access to documents in litigation over the Merck pill that took place in various courts around the country. Vioxx was withdrawn a decade ago over links to heart attacks and strokes. Fallon, who presides over Vioxx litigation that was consolidated in federal court in New Orleans, had issued an order in 2005 that marked swaths of documents as confidential. Much of the documentation was filed as evidence in litigation in both state and federal courts.

Three months ago, though, a Kentucky state judge permitted Egilman to challenge the confidentiality of the documents, since he had standing as an expert witness which gave him previous access to the materials. As we noted at the time, the judge wrote that “important public policy questions regarding consumer protection and public health have been raised. The public has an interest in evaluating Dr. Egilman’s opinions and the documents on which they were based.” Egilman was a paid expert witness for plaintiffs in a lawsuit that had been filed by the Kentucky Attorney General, who alleged Merck violated consumer protection laws by failing to disclose to doctors and patients that taking Vioxx significantly raised the risk of a heart attack. The lawsuit was settled last November for $23 million, although the drug maker did not admit to any wrongdoing.

Egilman maintains that some documents demonstrated a failure to properly inform research subjects of side effects and risks, and thus he believes the information should be publicly available. “In general, there’s information on the toxicity of the drug that’s not been previously published by Merck and there is information that Merck published that misrepresents the health effects of the drug,” he told us three months ago, which prompted the drug maker to complain to the federal judge. At the time, he added that, in his role as an expert witness, he reviewed raw study data, company emails and internal analyses that “provide new information on the health hazards of the drug and evidence of fraud in the conduct of the studies. I’ve been able to see documents few others have”…
Healthcare Renewal
by Roy Poses
June 17, 2014

We have written often, and most recently this week, about the limp posture taken by US law enforcement and regulatory agencies in the face of misbehavior by large health care organizations.  At best, official action often results in legal settlements which let companies pay fines, sometimes large, while the individuals who profited most from the alleged wrongdoing do not suffer any negative consequences.  Worse, the legal settlements often allow the companies to continue to deny any culpability, and the legal evidence underlying the settlement, which might let the public at least estimate culpability, is often kept sealed, or confidential.  As Judge Rakoff wrote in turning down such a settlement involving a financial, not health care company, sealing evidence hides "any proven or admitted facts upon which to exercise even a modest degree of independent judgment,"  and prevents courts and presumably anyone else from trying to determine whether the government endorsement of such a settlement serves any public purpose [look here]…

We have long talked about what we have called the anechoic effect, how inconvenient truths that might reflect badly on the current health care status quo and especially those insiders who are making so much money from it are treated as recent unpleasantness that one just should not talk about. The anechoic effect does not arise merely from politeness, or desire not to discomfit the powerful, but from active measures the powerful take to keep dissent down. Here we have an example of a huge drug company, apparently helped by US law enforcement and US courts trying to keep truths about how it marketed a drug out of the public eye, even after so much information suggesting that its marketing was deceptive and unethical, and lead to patients dying has come out.

As we have said endlessly, until health care professionals, policy makers, and the public can obtain and openly discuss information about health care dysfunction, even if that information and its discussion may threaten those who lead health care and make so much money doing so, health care dysfunction will continue. True health care reform would improve transparency and put an end to the anechoic effect.
In with no echo…, I suggested several reasons that the plaintiffs settles…
Lots of reasons. A lot of these are whistle blower suits and the whistle blowers want their money [there’s no appeal to a settlement]. The same holds for the lawyers who take such cases on contingency. Whether it’s civil or criminal, settling avoids the lengthy appeal process and gets the case off the books. They all go out and celebrate, ignoring the fact that they’ve played into the hands of the companies.
But I came up short with ways to solve this problem that badly needs solving. Another outrageous example came from GSK after settling a record breaking $3+ B suit. They went out of their way to "admit no wrongdoing" [after signing a settlement saying they admitted to all charges – charges of many wrongdoings including those related to Paxil Study 329][see the only enduring contract…]. This settling thing is a mammoth loophole – maybe more like one of those huge sinkholes that eats houses.


People are harmed when these suits settle and there’s no definite verdict. They’re harmed when the transcript and the testimony doesn’t get to see the light of day, doesn’t get a full hearing in the press. A quick mention on Pharmalot or in Reuters doesn’t alert them to the danger specific to the suit or the general problem of how the pharmaceurical industry works – the echo doesn’t reverberate. Patients are as vulnerable two weeks later as they were before the trial started. Usually, when there’s something that happens that causes harm repetitiously, we do something. We add speed humps to high wreck-prone streets. We put up stop-lights. We pass laws. We do something to keep the harm from happening over and over again, even if it means infringing on someone’s privacy. We list pedophiles on the Internet. My medical or psychiatric patient has the right of privacy, confidentiality, but if she says she’s going to kill someone, or herself, or is being abused, I am mandated by law to pass that on to someone who can act preventively:
    Tarasoff v. Regents of the University of California, 17 Cal. 3d 425, 551 P.2d 334, 131 Cal. Rptr. 14 [Cal. 1976], was a case in which the Supreme Court of California held that mental health professionals have a duty to protect individuals who are being threatened with bodily harm by a patient. The original 1974 decision mandated warning the threatened individual, but a 1976 rehearing of the case by the California Supreme Court called for a "duty to protect" the intended victim. The professional may discharge the duty in several ways, including notifying police, warning the intended victim, and/or taking other reasonable steps to protect the threatened individual.
Withholding the raw data from Clinical Trials has caused enormous harm to patients because the published articles have frequently been jury-rigged. In the suggested amendments to the Canadian Food and Drug Act, it has been proposed that the new law be very explicit that the raw information needed to check the work of the authors and sponsors is not proprietary. It should be in the public domain. That suggestion is being made to prevent secrecy and an inability to verify the results, in order to protect patients from being harmed by distorted studies.
    Regulating prescription drugs for patient safety: Does Bill C-17 go far enough?

    International treaties simply require Canada to protect trade secrets and confidential business information without specifying the scope of those types of information. No Canadian court decision indicates that information about the safety or efficacy of a drug is proprietary, and current case law casts doubt on any such assertion. In principle. Health Canada can at present disclose greater amounts of safety and efficacy information. However, to clarify and to overcome manufacturers efforts to resist disclosure. Bill C-17 should explicitly state that the results of clinical trials, including de-identified patient-level data, postmarket studies, and adverse drug reactions reported by drug manufacturers and health care institutions, are not proprietary and therefore should be publicly disclosed…
And even in the World Trade Organization TRIPS Trade agreement, it says that data should be kept from disclosure except where necessary to protect the public. Contingencies to keep people out of harms way are the rule.
PART II — Standards concerning the availability, scope and use of Intellectual Property Rights
SECTION 7: PROTECTION OF UNDISCLOSED INFORMATION
Article 39

3. Members, when requiring, as a condition of approving the marketing of pharmaceutical or of agricultural chemical products which utilize new chemical entities, the submission of undisclosed test or other data, the origination of which involves a considerable effort, shall protect such data against unfair commercial use. In addition, Members shall protect such data against disclosure, except where necessary to protect the public, or unless steps are taken to ensure that the data are protected against unfair commercial use.
Protection from harm trumps privacy in every venue I can think of. We have the right to life, liberty, and the pursuit of happiness – but not to privacy, confidentiality, and secrets if it hurts or kills other people. It’s part of the Social Contract that inspires most of our laws.


I frankly doubt that there’s any way to completely interrupt the cycle of settling out of these suits and silencing the echo. As they say, the barn door has been left open and the cows are long gone by the time these suits get to court. Many are Civil suits and the tradition of settling is a time-honored resolution. Even the criminal suits are the stuff of corporate fines rather than direct punishment of the individuals involved. The one obvious thing that occurs to me has to do with, "issued an order in 2005 that marked swaths of documents as confidential." Apparently, that’s in the realm of judicial discretion. It’s the Achilles heel in this story. I can see sequestering evidence or silencing experts if the defendant wins the litigation. That’s the best we can do to determine innocence. But settling is neither winning nor a declaration of innocence. It implies the opposite. If they want to continue on with any rights of privacy, let them win that right by being exonerated in a court of law. If they are found guilty or settle out of the suit, squashing the evidence shouldn’t be on the table. That bit of judicial discretion is abetting harm and needs some serious rethinking, because it has given them a way to win by choosing how to lose – over and over.

Each of my three examples represents a legal solution that places limits on secrecy based on the risk of future harm. In this case, secrecy is actually the conduit to future harms by blocking independent confirmation of trial results. There’s nothing about the results of Clinical Trials of a medication that reveals Trade Secrets or anything about the manufacturing process. The studies are only about efficacy and risk – nothing more. Given the stakes and the loud lessons of history, the obvious first order solution is data transparency in Clinical Trials. The only viable alternative is the Godlee solution:
    "… we have to recognize that the pharmaceutical industry has an irreducible conflict of interest in relation to the way it represents its drugs, in science and in marketing. And unless we can resolve this in a way that is more in the public interest and in patients’ interest, I would argue that drug companies should not be allowed to evaluate their own products."
We can’t continue to wait for the echo that never comes…
Mickey @ 11:48 AM

interlude…

Posted on Wednesday 18 June 2014

Mickey @ 12:00 AM

a missing link…

Posted on Tuesday 17 June 2014

In the last post [doing the right thing…], I was praising Canadian Bill C-17 to amend their Food and Drug Act to give the government needed powers to deal with Clinical Trial reporting and drug approval, but I was worried that I couldn’t find the details [that place where the devil lives]. I was helpfully pointed to some articles in the Toronto Star [Mar 10, 2014 Canadian Medical Association Journal says proposed drug recall bill has too many loopholes, May 30, 2014 Federal drug reform law approved for further review]. They, in turn, lead to an article in the Canadian Medical Association Journal published online in March and in print in May called Regulating prescription drugs for patient safety: Does Bill C-17 go far enough? [It is neither abstracted nor available on-line past page 1, so we’re going to have to go with my pulling out key quotes].


They began with the problems of the past [readable on page 1]. Then they have a section about what they think is right with the bill:

  • Power to recall drugs: "Bill C-17 empowers the Health Minister to issue a recall, without first entertaining representations from the manufacturer, provided he or she ‘believes that a therapeutic product presents a serious or imminent risk of injury to health.’"
  • Power to overcome information asymmetries: Bill C-17 enables Ihe Health Minister to compel manufacturers to provide information about drugs. eg information "about a serious adverse drug reaction that involves a therapeutic product or a medical device incident." "These information-sharing requirements are a major improvement on the status quo."
  • Power to enforce conditions on market authorizations and compel changes to product labels: "In 2007, Ihe US Food and Drug Administration (FDA) was granted powers to enforce conditions and to compel changes to a product’s label in light of safety concerns that emerge after market approval. It is imperative that Health Canada be vested with these powers."
  • Serious enforcement measures: "Finally, Bill C-17 creates much stronger penal- ties for failure to comply with some of the provi- sions of the Food and Drugs Act and accompa- nying regulations.These include lines of up to $5 million per day during which the offence is committed, and/or imprisonment for the most egregious oflences. "
Then they moved on to elements that should be added to the proposed legislation:

  • Enhance the power of recall and alter the ability to suspend:
  • Exempt the Health Minister from liability for drug suspensions and recalls:
  • Ensure transparency in clinical trials: "… requiring registration by law, and creating a robust mechanism to enforce that requirement, is an important step toward improving the transparency of the evidence base behind drugs and other therapies, and avoiding potential harm to patients." In addition, making sure that clinical trial data, whether collected before market approval or in postmarket studies, are available for scrutiny by independent researchers is critical to ensuring that treatment and use decisions are evidence-based."
  • Enhance transparency in Health Canada’s decision-making: "Bill C-17 should empower Health Canada to publish both positive and negative regulatory decisions. At minimum. Health Canada should publish the rationales lor decisions concerning all drugs approved for sale, drugs refused for reasons of safety or efficacy, and drugs that are suspended or recalled."
  • Outline clear limits to the scope of proprietary information: "Meaningful transparency is hard to achieve in practice, in part because manufacturers often claim that the government is obliged to protect information about the safety and efficacy of a drug as "proprietary," either as a "trade secret" or as "confidential business information."" These assertions overstate what the law actually requires and prevent important information about safety and effectiveness from being released." International treaties simply require Canada to protect trade secrets and confidential business information without specifying the scope of those types of information. No Canadian court decision indicates that information about the safety or efficacy of a drug is proprietary, and current case law casts doubt on any such assertion. In principle. Health Canada can at present disclose greater amounts of safety and efficacy information. However, to clarify and to overcome manufacturers’ efforts to resist disclosure, Bill C-17 should explicitly state that the results of clinical trials, including de-identilied patient-level data, poslmarket studies, and adverse drug reactions reported by drug manufacturers and health care institutions, are not proprietary and therefore should be publicly disclosed."
  • Do not allow trade to trump patient safety: "Bill C-17 gives the Governor in Council scope to impose stringent rules favouring data protection to the detriment of other powers in the Food and Drugs Act This proposal is fundamentally problematic and must not be enacted."
Conclusion: "Bill C-17 is an important step toward the safe regulation of drugs because it enhances the ability of Health Canada to act in the face of threats to public health. It also introduces meaningful enforcement mechanisms, including substantial penalties, for noncompliance. However, it requires amend- ment to incorporate several additional key compo- nents of prescription drug safety. Bill C-17 has the potential to make an important and positive difference to public safety in Canada We urge that Bill C-17 be revised and enhanced before it becomes law so that this potential can he realized."

This is the most comprehensive proposal that I’ve seen to date – one that directly addresses the Trade Agreements and PHARMA’s claims about proprietary ownership of Clinical Trial Data. And what’s totally amazing, it’s in a medical journal! a big medical journal! instead of just lolling on some blog at the rim of the galaxy. And from the blurb I’ve quoted already [House of Commons adopts government strengthened patient safety legislation], these suggestions look to have become the amendments that have passed the House of Commons and are headed to the Canadian Senate:

    The amendments to Bill C-17 were introduced by Member of Parliament, Terrence Young and adopted by the House of Commons Standing Committee on Health on June 12. The Bill has now passed Third Reading in the House of Commons and moves to the Senate for consideration. The amendments include the requirement that both positive and negative decisions about drug authorizations be disclosed on a public website; and that clinical trial information be disclosed on a public registry. The amendments also better define the scope of confidential business information [CBI] and allow the Minister to disclose CBI about a product if the Minister believes the product may pose a serious risk to Canadians.

Like I said, Canada seems "poised to be quietly just doing the right thing." May the force be with them…
Mickey @ 4:16 PM