{"id":64299,"date":"2016-03-29T15:29:10","date_gmt":"2016-03-29T19:29:10","guid":{"rendered":"http:\/\/1boringoldman.com\/?p=64299"},"modified":"2016-03-29T15:39:49","modified_gmt":"2016-03-29T19:39:49","slug":"a-parable","status":"publish","type":"post","link":"https:\/\/1boringoldman.com\/index.php\/2016\/03\/29\/a-parable\/","title":{"rendered":"a parable&#8230;"},"content":{"rendered":"\n<p align=\"justify\" class=\"small\">A month ago I ran across a <a target=\"_blank\" href=\"http:\/\/www.medpagetoday.com\/Psychiatry\/Depression\/55999\"><strong><font color=\"#000001\">MEDPAGE<\/font> <font color=\"#0066ff\">TODAY<\/font><\/strong><\/a> article about <font color=\"#200020\">Vortioxetine<\/font> [<font color=\"#200020\">Brintellix<em>&reg;<\/em><\/font>] and a hearing at the FDA [see <a href=\"http:\/\/1boringoldman.com\/index.php\/2016\/02\/27\/indications\/\">indications&hellip;<\/a> and <a href=\"http:\/\/1boringoldman.com\/index.php\/2016\/02\/29\/more-vortioxetine-story\/\" target=\"_blank\">more vortioxetine story&hellip;<\/a>]. <font color=\"#200020\">Brintellix<em>&reg;<\/em><\/font> had been approved by the FDA for use in Major Depressive Disorder in September of 2014. I&nbsp; had previously run across it through a <a target=\"_blank\" href=\"http:\/\/www.psychiatrist.com\/JCP\/article\/Pages\/2014\/v75n12\/v75n1209.aspx\">review article<\/a> in the <font color=\"#200020\">Journal of Clinical Psychiatry<\/font> in December 2014 &#8211; a ghost-written garbled affair with multiple KOL guest authors [see <a href=\"http:\/\/1boringoldman.com\/index.php\/2014\/12\/29\/the-recommendation\/\" target=\"_blank\">the recommendation?&hellip;<\/a>]. It seems that the manufacturers [<font color=\"#200020\">Takeda and Lundbeck<\/font>] had been planning for years to try to get it approved for treating the <font color=\"#200020\">Cognitive Dysfuntion in Major Depressive Disorder<\/font>. That would be a new category for FDA Approval and would&#8217;ve become a strong selling point for this late-coming antidepressant. I found a recent article by Lisa Cosgrove et al who had done a case study of this particular drug and its approval process [<a target=\"_blank\" href=\"http:\/\/www.ncbi.nlm.nih.gov\/pubmed\/26890488\">Under the Influence: the Interplay among Industry, Publishing, and Drug Regulation<\/a>] that contained the results of both published and unpublished trials showing that in comparator studies, <font color=\"#200020\">Brintellix<em>&reg;<\/em><\/font> had uniformly come up short. And I later read a blog on George Dawson&#8217;s <font color=\"#990000\">Real Psychiatry<\/font> [<a href=\"http:\/\/real-psychiatry.blogspot.com\/2014\/05\/vortioxetine.html\" target=\"_blank\">Vortioxetine<\/a>] about it.<\/p>\n<div align=\"justify\" class=\"small\">The FDA originally looked unfavorably on approving <font color=\"#200020\">Brintellix<em>&reg;<\/em><\/font> for <font color=\"#200020\">Cognitive Dysfuntion in Major Depressive Disorder<\/font>, seeing it as an example of <em><font color=\"#200020\">pseudospecificity<\/font><\/em>. But the manufacturers kept coming. In February 2015, there was a Workshop at the Institute of Medicine entitled <a href=\"https:\/\/iom.nationalacademies.org\/%7E\/media\/Files\/Activity%20Files\/Research\/NeuroForum\/2015-FEB-24\/Cognitive%20Dysfunction%20in%20Depression%20agenda.pdf\" target=\"_blank\">Enabling Discovery, Development,  and Translation of Treatments for  Cognitive Dysfunction in Depression: A Workshop<\/a> moderated by Tom Insel [NIMH] and Thomas Laughren [formerly FDA&rsquo;s director of psychiatry products]. After the workshop, the FDA agreed to reconsider, but only in a public hearing with an independent advisory committee. That happened on Feb 3, 2016 [<a href=\"http:\/\/www.fda.gov\/AdvisoryCommittees\/CommitteesMeetingMaterials\/Drugs\/PsychopharmacologicDrugsAdvisoryCommittee\/ucm475314.htm\" target=\"_blank\">2016 Meeting Materials, Psychopharmacologic Drugs Advisory Committee<\/a>]. It was an elaborate all day affair with presenters from all parties concerned. At the end of the day, the FDA Advisory Committee voted 8:2 in favor of recommending Approval. When I looked at the papers and the presentations, I disagreed. My reasons are cataloged in my second blog [<a href=\"http:\/\/1boringoldman.com\/index.php\/2016\/02\/29\/more-vortioxetine-story\/\" target=\"_blank\">more vortioxetine story&hellip;<\/a>]:<\/div>\n<ul><sup>      <\/p>\n<li>\n<div align=\"justify\">The NIMH presentation was thoughtful and concluded that the psychometrics being used were not a valid sole proxy for a specific Cognitive Dysfuntion designation.<\/div>\n<\/li>\n<li>\n<div align=\"justify\">They had one positive study [FOCUS]. But the second study [CONNECT] didn&#8217;t replicate those results. It was reported as statistically significant, but in my opinion, the statistical analysis was flawed.<\/div>\n<\/li>\n<li>\n<div align=\"justify\">There&#8217;s nothing in my clinical experience or reading that suggests that the affective and cognitive symptoms in depression can be cleanly parsed in this way. Frankly, this felt like a commercially driven ploy.<\/div>\n<\/li>\n<p>      <\/sup><\/ul>\n<div align=\"justify\" class=\"small\">So I bundled up my findings into a letter [essentially the two blog posts minus the 1boringoldman&middot;isms] and set out to figure out where to send a letter to the FDA that might get read [much thanks to Drs. Lisa Cosgrove, Bernard Carroll, and Erick Turner for their pointers]. I started with the <a href=\"http:\/\/www.fda.gov\/AboutFDA\/CentersOffices\/OC\/OfficeofScientificandMedicalPrograms\/ucm197508.htm\" target=\"_blank\">FDA Ombudsman<\/a> [who knew there was one?]. It didn&#8217;t fit their sphere of operations, but they forwarded it to someone at the generic <em><font color=\"#200020\">info@fda.gov<\/font><\/em> who was extremely helpful &#8211; sending it on to the reviewers herself and updating me with an email confirming it had gotten there. I was impressed. So I googled the topic last night, as I had often over the last month, and <em><font color=\"#200020\">Bingo!<\/font><\/em><\/div>\n<blockquote>\n<div align=\"center\" class=\"big\"><a href=\"http:\/\/www.prnewswire.com\/news-releases\/takeda-and-lundbeck-receive-complete-response-letter-for-brintellix-vortioxetine-snda-300242296.html\" target=\"_blank\">Takeda and Lundbeck Receive Complete Response Letter for Brintellix&reg; [vortioxetine] sNDA<\/a><\/div>\n<div align=\"center\" class=\"big\"><strong><font color=\"#200020\">PRNewswire <\/font><\/strong><\/div>\n<div align=\"center\" class=\"middle\">from <a href=\"http:\/\/www.prnewswire.com\/news\/takeda+pharmaceutical+company+limited%3B+h.+lundbeck+a%2Fs\" target=\"_blank\">Takeda Pharmaceutical Company Limited; H. Lundbeck A\/S<\/a> \t\t\t\t \t\t \t                                                     <\/div>\n<div align=\"center\" class=\"middle\">Mar 28, 2016, 20:02 ET<\/div>\n<p align=\"justify\">OSAKA, Japan and VALBY, Denmark, March 28, 2016 \/PRNewswire\/  &#8212;&nbsp;Takeda Pharmaceutical Company Limited [Takeda] and H. Lundbeck A\/S  [Lundbeck] today announced that the U.S. Food and Drug Administration  [FDA] issued a complete response letter [CRL] for the supplemental new  drug application [sNDA] to include new data in the clinical trials  section of the U.S. label of Brintellix<sup>&reg;<\/sup> [vortioxetine] for  treating certain aspects of cognitive dysfunction in adults with major  depressive disorder [MDD]. The FDA approved Brintellix on <span class=\"xn-chron\">September 30, 2013<\/span> for the treatment of MDD in adults. The CRL does not apply to the use of Brintellix in MDD.<\/p>\n<div align=\"justify\">Takeda and Lundbeck are disappointed  with the response given that the U.S. FDA Psychopharmacologic Drugs  Advisory Committee [PDAC] voted 8 to 2 that Takeda and Lundbeck  presented substantial evidence to support a claim of effectiveness for  Brintellix in treating certain aspects of cognitive dysfunction in  adults with MDD. However, the companies were pleased that  FDA recognized the importance of cognitive dysfunction in MDD and view  it as a legitimate target for drug development&#8230;<\/div>\n<\/blockquote>\n<div align=\"justify\" class=\"small\">In case you don&#8217;t speak FDA-ese, a <em><font color=\"#200020\">Complete Response Letter<\/font><\/em> essentially means &quot;<strong><font color=\"#200020\">No<\/font><\/strong>&quot; [see <a href=\"http:\/\/www.fda.gov\/Drugs\/GuidanceComplianceRegulatoryInformation\/LawsActsandRules\/ucm084138.htm\" target=\"_blank\">Complete Response Letter Final Rule<\/a>]. The proceedings are <a href=\"http:\/\/www.fda.gov\/AdvisoryCommittees\/CommitteesMeetingMaterials\/Drugs\/PsychopharmacologicDrugsAdvisoryCommittee\/ucm475314.htm\" target=\"_blank\">here<\/a>.<\/div>\n<p align=\"justify\" class=\"small\">I don&#8217;t nor will I ever know if my letter had anything to do with the FDA&#8217;s decision. Other than the average expectable &quot;<em><font color=\"#200020\">tree<\/font><\/em>&quot; narcissism [&quot;<em><font color=\"#200020\">if a tree falls in the forest and no one hears it, does it make a sound?<\/font><\/em>], I&#8217;m not sure I care. I had already gotten my reward from hearing the echo. In another way, I&#8217;d actually feel even better if the decision came out this way totally based on the FDA&#8217;s own evaluation. Takeda and Lundbeck had gone all out and to a lot of expense trying for this indication [6 cognition-specific clinical trials, bringing a lot of big KOL guns to the IOM workshop and earlier hearing, etc]. I could only guess that the 8:2 vote for Approval was in response to their zeal and presentations. But it just wasn&#8217;t in the data, and that&#8217;s what the FDA is there to evaluate. So good on them. They did the right thing after all. As for my letter&#8230;<\/p>\n<div align=\"justify\" class=\"small\"><em><strong><font color=\"#200020\">A Parable<\/font><\/strong><\/em>: <font color=\"#400040\">Two years ago, my two closest friends died in the week after Easter, and so they are much in my mind. One was a photographer whose photographic chronicles of the poverty in the Mississippi Delta and in the Appalachian Mountains will never be forgotten. But as gifted as he was with his camera, he sure had his quirks. And he was never happier than when he was talking about the intrinsic evils of politics &#8211; any politics. He claimed to have never voted, and delighted in being asked why. &quot;It&#8217;s a trick to make you think you matter,&quot; he would begin [showing his own Appalachian roots]. This dialog was part tongue in cheek, but part deeply felt. One day, we were all floating in our little lake on a hot summer day, and he started up with his usual exposition on politics. My wife [a prime candidate for an fMRI study to locate the political regions of the cerebral cortex] announced, <\/font>&quot;<em><font color=\"#200020\">Al, you can&#8217;t talk about politics anymore. You&#8217;re on political restriction. If you&#8217;re not going to vote, you have no right to complain.<\/font><\/em>&quot;<font color=\"#400040\"> We were surprised at her little speech, as we were all used to Al&#8217;s diatribes and knew they would pass shortly. He didn&#8217;t say much and we went back to whatever old friends do when they&#8217;re cooling off in a lake on a hot summer day. But after that, he started voting &#8211; I think every time it came up until he died. I don&#8217;t know for sure that those things were 1:1 related, but I&#8217;d bet good money they were&#8230; <\/font><\/div>\n","protected":false},"excerpt":{"rendered":"<p>A month ago I ran across a MEDPAGE TODAY article about Vortioxetine [Brintellix&reg;] and a hearing at the FDA [see indications&hellip; and more vortioxetine story&hellip;]. Brintellix&reg; had been approved by the FDA for use in Major Depressive Disorder in September of 2014. I&nbsp; had previously run across it through a review article in the Journal [&hellip;]<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"open","ping_status":"closed","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":[5],"tags":[],"class_list":["post-64299","post","type-post","status-publish","format-standard","hentry","category-opinion"],"_links":{"self":[{"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/posts\/64299","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=64299"}],"version-history":[{"count":18,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/posts\/64299\/revisions"}],"predecessor-version":[{"id":64317,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/posts\/64299\/revisions\/64317"}],"wp:attachment":[{"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/media?parent=64299"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/categories?post=64299"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/1boringoldman.com\/index.php\/wp-json\/wp\/v2\/tags?post=64299"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}