{"id":12056,"date":"2011-08-15T09:01:16","date_gmt":"2011-08-15T13:01:16","guid":{"rendered":"http:\/\/1boringoldman.com\/?p=12056"},"modified":"2011-08-15T11:45:39","modified_gmt":"2011-08-15T15:45:39","slug":"the-corruption-rule","status":"publish","type":"post","link":"https:\/\/1boringoldman.com\/index.php\/2011\/08\/15\/the-corruption-rule\/","title":{"rendered":"the corruption rule&#8230;"},"content":{"rendered":"<div align=\"justify\">I suppose there&#8217;s something confirming in reading&nbsp; about the pharmaceutical industry&#8217;s invasion of psychiatry. Back in the 1980s when it all started, I smelled a rat, but didn&#8217;t know what was happening. It drove me a little crazy, and I ended up fleeing to private practice because I didn&#8217;t know what else to do, never really understanding quite what was going on. I was just too naive to even imagine where things were heading. Now, looking backwards, it&#8217;s clearer, but it&#8217;s also disillusioning. I find this piece particularly disheartening:          <\/div>\n<blockquote>\n<div align=\"center\"><a href=\"http:\/\/www.pharmalot.com\/2010\/08\/feds-probe-payments-in-overseas-drug-trials\/\" target=\"_blank\"><strong><font color=\"#200020\">Feds Probe Payments In Overseas Drug Trials<\/font><\/strong><\/a><br \/>                  <strong><font color=\"#200020\">Pharmalot<\/font><\/strong><br \/>                              By Ed Silverman<br \/>                  August 9th, 2010<\/div>\n<p align=\"justify\"><sup>As  promised, the US Justice Department &#8211; along with the US Securities and  Exchange Commission &#8211; is paying closer attention to interactions between  the pharmaceutical industry and foreign governments.  In recent months, at least five big drugmakers have received letters as  the federal government seeks to uncover any violations of the Foreign Corrupt Practices Act, which forbids US companies from bribing foreign government officials&#8230;<\/sup><\/p>\n<p align=\"justify\"><sup>Among the countries cited are Brazil, China, Germany, Greece, Italy, Poland, Russia and Saudi Arabia, according to Main Justice, which notes that the Arnold &amp; Porter law firm recently issued a client advisory  indicating the probe is also exploring whether drugmakers and clinical  trial organizations pay off third-party investigators to finesse  research data. Why? <strong><font color=\"#990000\">A recent report by the HHS Office of Inspector General noted  that eight percent of marketing applications to the FDA in 2008 relied  exclusively on foreign data, 80 percent of approved marketing  applications for drugs and biologics relied on at least one foreign  clinical study, and 78 percent of all human subjects were enrolled at  foreign sites.<\/font><\/strong><\/sup><\/p>\n<div align=\"justify\"><sup><strong><font color=\"#990000\">&ldquo;The number of third party contracts with CROs, academic and health  care facilities, and investigators provides a high-risk area for  potential violations. The US government is particularly interested in  any corrupt payments that may have wrongfully influenced the reliability  or integrity of data emerging from any trial, and companies may find  themselves facing critical legal issues if approval of products rested  on the results of studies that DOJ deems corrupt,&rdquo;<\/font><\/strong> Arnold &amp; Porter  attorneys wrote, adding the &ldquo;DOJ has recently taken the public position  that many investigators, foreign clinicians, and laboratory workers will  be deemed &lsquo;foreign officials&rsquo; for purposes of the FCPA&rdquo;&#8230;<\/sup><\/div>\n<\/blockquote>\n<div align=\"justify\">Back in March, when I was trying to get up to speed on the Clinical Research Industry and the Clinical Research Organizations [<u><strong><a target=\"_blank\" href=\"http:\/\/1boringoldman.com\/wp-admin\/..\/index.php\/2011\/03\/08\/the-clinical-research-industry-cross-purposes\/\"><font color=\"#660033\">the clinical research industry: cross purposes&hellip;<\/font><\/a><\/strong><\/u>], I ran across their professional Organization, <strong><font color=\"#336600\">ACRO<\/font><\/strong>. Back then, I wrote:           <\/div>\n<blockquote>\n<div align=\"justify\">Looking over the <a href=\"http:\/\/www.acrohealth.org\/about-acro.html\" target=\"_blank\"><u><strong><font color=\"#003333\">ACRO<\/font><\/strong><\/u><\/a>  [Association of Clinical Research Organizations] web-site, it seems to  be standard industry-specific trade organization fare. Their central  thrust is <strong><font color=\"#200020\">Globalization<\/font><\/strong>. In fact the <u><a href=\"http:\/\/www.acrohealth.org\/policy-views.html\" target=\"_blank\"><strong>policy page<\/strong><\/a><\/u> seems organized around the topic:<\/div>\n<ul>\n<div><sup>ACRO&rsquo;s global advocacy program is focused around a set of core principles:<\/sup><\/div>\n<ol>\n<div align=\"justify\"><sup>&bull; Secure a consistent, stable regulatory environment to support the continued <strong><font color=\"#990000\">globalization<\/font><\/strong> of clinical research<\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Protect the safety of research participants <strong><font color=\"#990000\">globally<\/font><\/strong><\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Expand participation in clinical trials by physician investigators and volunteers; special emphasis on minority and special populations<\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Ensure ease of access to data necessary to conduct research while considering patient privacy<\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Promote industry participation in comparative effectiveness research<\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Encourage health information technology policies that include consideration of medical research needs<\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Advance policies that encourage innovation in pharmaceutical, biologic and regenerative medicine development<\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Support a strong FDA with expanded resources in the areas of regulatory science and <strong><font color=\"#990000\">international<\/font><\/strong> operations<\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Support the EMA and European Commission in their efforts to advance GCP compliance and enhance <strong><font color=\"#990000\">international<\/font><\/strong> inspection regimes<\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Oppose conflict of interest policies that unduly restrict research and innovation<\/sup><\/div>\n<div align=\"justify\"><sup>&bull; Further efforts to promote translational research through NIH and other government-funded bodies<\/sup><\/div>\n<\/ol>\n<\/ul>\n<div>In fact, they have a White Paper on Globalization [downloadable if you give them a name and email address]:<\/div>\n<ul>\n<div><sup><strong><u>Executive Summary<\/u><\/strong>:<\/sup><\/div>\n<div align=\"justify\"><sup> As clinical trials have become increasingly  globalized over the past ten to fifteen years, the possibility of  conducting studies that offer adequate subject&nbsp; protection and yield  reliable results in emerging countries has understandably attracted  considerable attention. In this analysis, we examine the facts regarding  the current state of clinical research and the role that  biopharmaceutical companies and their clinical research organization  (CRO) partners play in ensuring that&nbsp; the dual goals of trial safety and  quality are met. Although concerns have been raised about the  globalization of biomedical research, the reality is that emerging  countries play a vital role in the advancement of medical science.  Clinical trials in these countries, particularly those with industry  sponsorship, are conducted at the high standards necessary to obtain  regulatory approval in major markets. In addition, the investments made  by trial sponsors, which are frequently implemented by CROs, are a major  contributor to improving the health systems and economies of the  developing world&hellip;<\/sup><\/div>\n<\/ul>\n<\/blockquote>\n<div align=\"justify\">That all sounds like B.S. to me. When I read that back in March, what I read between the lines in the push for globalization was because it was cheaper to run clinical trials overseas. Then I read the piece in <strong><font color=\"#990000\">Vanity Fair<\/font><\/strong> [<a target=\"_blank\" href=\"http:\/\/www.vanityfair.com\/politics\/features\/2011\/01\/deadly-medicine-201101\"><u><strong><font color=\"#200020\">Deadly Medicine<\/font><\/strong><\/u><\/a>], which documents some real horror stories about overseas trials &#8211; a must read piece for anyone interested in this topic. I was left with a fairly dim view of the whole Clinical Research Organization scene [<u><strong><a href=\"http:\/\/1boringoldman.com\/wp-admin\/..\/index.php\/2011\/03\/11\/the-clinical-research-industry-something-to-change\/\" target=\"_blank\"><font color=\"#660033\">the clinical research industry: an invisible empire&hellip;<\/font><\/a><\/strong><\/u>].<\/div>\n<p align=\"center\"><img decoding=\"async\" width=\"250\" border=\"1\" src=\"http:\/\/www.vanityfair.com\/politics\/features\/2011\/01\/deadly-medicine-201101\/_jcr_content\/par\/cn_contentwell\/par-main\/cn_pagination_contai\/cn_image.size.deadly-medicine.jpg\" \/><br \/>   <sup>from <u><strong><font><a target=\"_blank\" href=\"http:\/\/www.vanityfair.com\/politics\/features\/2011\/01\/deadly-medicine-201101\"><u><strong><font color=\"#200020\">Deadly Medicine<\/font><\/strong><\/u><\/a><\/font><\/strong><\/u><\/sup><\/p>\n<div align=\"justify\">I recall thinking when I was looking into the CROs and their push for Globalization that it would be easier to fudge the results doing a trial in some third world country, but I let the thought pass. I was disillusioned enough already. I see that I should&#8217;ve let that thought linger. It must have been rolling around in my head, because I went to the trouble to compile this graph [from clinicaltrials.gov]:<\/div>\n<p align=\"center\"><img loading=\"lazy\" decoding=\"async\" width=\"293\" height=\"249\" border=\"0\" src=\"http:\/\/1boringoldman.com\/images\/cro-15.gif\" \/><\/p>\n<p align=\"justify\">I put it together to show that sending trials overseas allowed them to shorten the time it took to complete a study, but it shows something else &#8211; that globalization is a reality. Given the inflated efficacy and questionable safety of Seroquel, it wouldn&#8217;t be hard to convince me that AstraZeneca paid for their questionable results.<\/p>\n<div align=\"justify\">I guess the rule in looking at the pharmaceutical industry is that if you suspect an area that could possibly be corrupted, it is corrupt [until proven otherwise]&#8230;      <\/div>\n<hr size=\"1\" \/>\n<div>see also <u><strong><a href=\"http:\/\/www.pharmalot.com\/2011\/08\/pfizer-confesses-about-potential-overseas-bribes\/\" target=\"_blank\"><font color=\"#200020\">Pfizer Confesses About &lsquo;Potential&rsquo; Overseas Bribes<\/font><\/a><\/strong><\/u><font color=\"#200020\">&#8230;<\/font><\/div>\n","protected":false},"excerpt":{"rendered":"<p>I suppose there&#8217;s something confirming in reading&nbsp; about the pharmaceutical industry&#8217;s invasion of psychiatry. Back in the 1980s when it all started, I smelled a rat, but didn&#8217;t know what was happening. It drove me a little crazy, and I ended up fleeing to private practice because I didn&#8217;t know what else to do, never [&hellip;]<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_bbp_topic_count":0,"_bbp_reply_count":0,"_bbp_total_topic_count":0,"_bbp_total_reply_count":0,"_bbp_voice_count":0,"_bbp_anonymous_reply_count":0,"_bbp_forum_subforum_count":0,"footnotes":""},"categories":[2],"tags":[],"class_list":["post-12056","post","type-post","status-publish","format-standard","hentry","category-politics"],"_links":{"self":[{"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/posts\/12056","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/comments?post=12056"}],"version-history":[{"count":13,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/posts\/12056\/revisions"}],"predecessor-version":[{"id":45322,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/posts\/12056\/revisions\/45322"}],"wp:attachment":[{"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/media?parent=12056"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/categories?post=12056"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/tags?post=12056"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}