Faculty Bibliography

Convalescent plasma is an investigational product, not approved by the Food and Drug Administration for any use, that has been administered for the prevention and treatment of epidemic infections, including Ebola and most recently COVID-19. On 3 April 2020, Food and Drug Administration authorized an Expanded Access Program for treatment use of convalescent plasma in hospitalized COVID-19 patients, with Mayo Clinic as the coordinating site for this nationwide effort. Expanded Access, historically referred to as ''compassionate use,'' is a regulatory pathway that allows patients to use an investigational product outside of a clinical trial when four conditions are met: the patient has a life-threatening or serious disease, no comparable or satisfactory alternative treatment options are available, clinical trial enrollment is not possible, and non-trial use does not pose a threat to timely clinical development. Food and Drug Administration can authorize Expanded Access through requests for single patients, intermediate-size patient populations, and widespread treatment programs. The convalescent plasma Expanded Access Program was the largest in US history, leading to infusion of more than 94,000 patients. In comparison, the largest prior Expanded Access Programs-for lamivudine (HIV) and gefitinib (cancer)-each provided unapproved drugs to approximately 30,000 patients outside of clinical trials. Expanded Access Programs of this size are unusual and dwarf most clinical trials. However, Expanded Access Programs are intended for treatment, not research. Therefore, even when they involve sizable patient populations, they lack features of rigorous trial design, including control groups and randomization. Nevertheless, Expanded Access Program data have been considered pivotal by both the Food and Drug Administration and European Medicines Agency, often in the context of rare disease and the collection of safety data, and it was primarily the convalescent plasma Expanded Access Program data that led Food and Drug Administration to issue an emergency use authorization for that product. Although Expanded Access Programs are by regulation not supposed to hinder clinical trials, large Expanded Access Programs can create circular challenges, as when a lack of trial opportunities makes an Expanded Access Program an important pathway for initial access to an investigational product, but then the Expanded Access Program becomes a barrier to launching new trials. In this session, we will discuss the statistical, ethical, and regulatory issues that arise in the context of Expanded Access Programs, using the convalescent plasma Expanded Access Program as a case study in contrast to clinical trials, with a focus on issues arising in the context of a global pandemic. We will first discuss biostatistical considerations for extracting realworld evidence from Expanded Access Program data, as well as the role of these data in supplementing results from clinical trials. We will also consider the perspective of the patient in deciding whether to enroll in an Expanded Access Program versus clinical trial, including the opportunity for personal benefit or harm, potential for participation to impact the greater good, and the patient understanding of an unproven investigational treatment. Then, we will address the gatekeeping role of clinicians, institutions, and regulators, to ensure that Expanded Access Programs do not interfere with clinical trials. Finally, we will address patient pathways for accessing investigational drugs, especially in the context of a global pandemic, and the capacity for collecting rigorous data via these mechanisms, while prioritizing rigorous trials

This article examines the origins and context of mandatory bicycle helmet laws in the United States. Localities began to enact such laws in the early 1990s, having experimented with helmet laws for motorcycles previously. As cycling became increasingly popular in the 1970s and 1980s because of a variety of historical trends, from improved cycle technology to growing environmental consciousness, cycling-related injuries also increased. Bicycle safety advocates and researchers alike were particularly troubled by head injuries. National injury surveillance systems and a growing body of medical literature on bicycle-related injuries motivated a number of physicians, cyclists, children, and other community members to advocate helmet laws, which they argued would save lives. Controversy over these laws, particularly over whether they should apply universally or only to children, raised public health ethics concerns that persist in contemporary debates over bicycle helmet policies. (Am J Public Health. 2020;110:1198-1204. doi: 10.2105/AJPH.2020.305718).

Aim: The US FDA has two nontrial pre-approval access pathways: expanded access (EA) and right to try (RTT). Reports of successful RTT use are scarce, and the FDA has not yet published RTT usage data, yet proponents tout its utility. In the face of this discrepancy and a lack of transparency of usage statistics, our aim is to add to the limited understanding of RTT usage. Materials & methods: We searched crowdfunding campaigns referencing 'expanded access', 'right to try' or 'compassionate use' since 2018. Results: We identified 26 EA campaigns, 29 RTT campaigns and two referencing both. Twenty one EA campaigns described being approved to receive access to the requested experimental medical product versus one RTT campaign. Conclusion: RTT is associated with poor understanding of nontrial pre-approval access. These campaigns suggest RTT is not offering a practical alternative to EA. Cost remains a significant barrier to these patients.

For decades, the U.S. Food and Drug Administration (FDA) has provided an "expanded access" pathway that allows patients who meet qualifying conditions to gain access outside a clinical trial to an investigational medical product being tested to see if it is safe and effective for a specific use. The Right to Try (RTT) Act, enacted in 2018, created a second mechanism for off-trial, or non-trial, access to investigational drugs. In contrast to the expanded access pathway, the federal RTT pathway does not require the involvement of the FDA or an institutional review board (IRB). Given that physicians, drug manufacturers, and medical institutions now have a choice whether to assist individual patients through the expanded access or the federal RTT pathway, we review the differences between these options and discuss the benefits and burdens of IRB involvement in requests to access interventions through the pathways. We also suggest ways in which IRB oversight may be further improved.

Medical school faculty and their colleagues in schools of nursing, public health, social work, and elsewhere often research issues of critical importance to health and science policy. When academics engage with government policymakers to advocate for change based on their research, however, they may find themselves engaged in "lobbying," thereby entering a complex environment of legal requirements and institutional policies that they may not fully understand. To promote academic advocacy, this article explains what is and is not legally permitted when it comes to engaging with policymakers and encourages academic institutions to facilitate permissible advocacy activities.U.S. law permits academic researchers to conduct certain types of policy-focused advocacy without running afoul of legal restrictions on lobbying. Academics acting in their personal capacities and with their own resources may freely engage with policymakers in any branch of government to provide their expertise and advocate for desired outcomes. When acting in their professional capacities, academics are free to engage in most advocacy activities directed to the executive and judicial branches, and they also may advocate to influence legislation and legislators within certain limits that are particularly relevant to academic work. In all cases, academics must take care to not use restricted funds for lobbying.Academic researchers have an important role to play in advancing evidence-based health and science policy. They should familiarize themselves with legal restrictions and opportunities to influence policy based on their research, and their institutions should actively support them in doing so.

Academic, industry, regulatory leaders and patient advocates in cancer clinical research met in November 2018 at the Innovation and Biomarkers in Cancer Drug Development meeting in Brussels to address the existing dichotomy between increasing calls for personalised oncology approaches based on individual molecular profiles and the need to make resource and regulatory decisions at the societal level in differing health-care delivery systems around the globe. Novel clinical trial designs, the utility and limitations of real-world evidence (RWE) and emerging technologies for profiling patient tumours and tumour-derived DNA in plasma were discussed. While randomised clinical trials remain the gold standard approach to defining clinical utility of local and systemic therapeutic interventions, the broader adoption of comprehensive tumour profiling and novel trial designs coupled with RWE may allow patient and physician autonomy to be appropriately balanced with broader assessments of safety and overall societal benefit.