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Facilitating Both Evidence and Access: Improving FDA's Accelerated Approval and Expanded Access Pathways

Lynch, Holly Fernandez; Bateman-House, Alison
PMID: 32631197
ISSN: 1748-720x
CID: 4545852

Oversight of Right-to-Try and Expanded Access Requests for Off-Trial Access to Investigational Drugs

Chapman, Carolyn Riley; Eckman, Jared; Bateman-House, Alison S
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.
PMID: 31967412
ISSN: 2578-2363
CID: 4273892

Academic Advocacy: Opportunities to Influence Health and Science Policy Under U.S. Lobbying Law

Lynch, Holly Fernandez; Bateman-House, Alison; Rivera, Suzanne M
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.
PMID: 31599758
ISSN: 1938-808x
CID: 4130702

Addressing the dichotomy between individual and societal approaches to personalised medicine in oncology

Salgado, Roberto; Solit, David B; Rimm, David L; Bogaerts, Jan; Canetta, Renzo; Lively, Tracy; Lyerly, Kim; Span, Paul N; Bateman-House, Alison; Makady, Amr; Bergmann, L; Nagai, Sumimasa; Smith, Chris; Robson, Mark; Savage, Mary; Voest, Emile; Sweeney, Christopher; Lambin, Philippe; Thomas, Marlene; Harris, Lyndsay; Lacombe, Denis; Massard, Chistophe
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.
PMID: 31060925
ISSN: 1879-0852
CID: 4271462

Preapproval Nontrial Access and Off-Label Use: Do They Meet Criteria for Dual-Deviation Review?

Chapman, Carolyn Riley; Folkers, Kelly McBride; McFadyen, Andrew; Shah, Lesha D; Bateman-House, Alison
PMID: 31135320
ISSN: 1536-0075
CID: 3898892

Putting Local All-Ages Bicycle Helmet Ordinances in Context

Bateman-House, Alison; Bachynski, Kathleen
PMID: 31298103
ISSN: 1748-720x
CID: 3976862

Single-Patient Expanded Access Requests: IRB Professionals' Experiences and Perspectives

Chapman, Carolyn Riley; Shearston, Jenni A; Folkers, Kelly McBride; Redman, Barbara K; Caplan, Arthur; Bateman-House, Alison
BACKGROUND:U.S. physicians may treat a patient with an investigational drug outside of a clinical trial by using the expanded access (EA) pathway or the recently created federal right to try (RTT) pathway. The EA pathway requires physicians to get prior permission from the U.S. Food and Drug Administration (FDA) and, except in emergency cases, institutional review board (IRB) approval. The perspectives of IRB professionals on the review of single-patient EA requests have not been empirically studied. METHODS:We used a cross-sectional online survey to ascertain IRB professionals' perspectives on IRB experiences with and preparedness for review of single-patient EA requests, as well as their attitudes about the importance of IRB review of such requests. Email invitations were sent to 234 IRB professionals connected to the SMART IRB platform. Approximately half of the survey questions used a Likert scale to assess respondents' agreement with specific statements. RESULTS:Eighty-three respondents completed the survey (36.4% response rate, with 228 deliverable e-mail invitations). Of the respondents, 73.5% were affiliated with an academic medical institution; 78.3% of respondents agreed that it is important for a designated member of an IRB to review single-patient EA requests before investigational drugs are used by patients. The majority indicated that local review of the EA request was important and that a single designated reviewer was sufficient (rather than full board). Further, 86.6% felt that their IRBs were prepared to review these requests, and 9.2% indicated that not all the single-patient EA requests reviewed by their IRBs in 2017 were approved. CONCLUSIONS:A large majority of IRB professionals affiliated with the SMART IRB platform who responded to this survey felt IRB review of single-patient EA requests is important and that their IRBs were prepared to handle such requests.
PMID: 30964737
ISSN: 2329-4523
CID: 3809202

What compassionate use means for gene therapies [Letter]

Chapman, Carolyn Riley; Moch, Kenneth I; McFadyen, Andrew; Kearns, Lisa; Watson, Tom; Furlong, Pat; Bateman-House, Alison
PMID: 30940936
ISSN: 1546-1696
CID: 3809852

Ethical Issues in Gender-Affirming Care for Youth

Kimberly, Laura L; Folkers, Kelly McBride; Friesen, Phoebe; Sultan, Darren; Quinn, Gwendolyn P; Bateman-House, Alison; Parent, Brendan; Konnoth, Craig; Janssen, Aron; Shah, Lesha D; Bluebond-Langner, Rachel; Salas-Humara, Caroline
Transgender and gender-nonconforming (TGNC) youth who suffer from gender dysphoria are at a substantially elevated risk of numerous adverse physical and psychosocial outcomes compared with their cisgender peers. Innovative treatment options used to support and affirm an individual's preferred gender identity can help resolve gender dysphoria and avoid many negative sequelae of nontreatment. Yet, despite advances in these relatively novel treatment options, which appear to be highly effective in addressing gender dysphoria and mitigating associated adverse outcomes, ethical challenges abound in ensuring that young patients receive appropriate, safe, affordable treatment and that access to this treatment is fair and equitable. Ethical considerations in gender-affirming care for TGNC youth span concerns about meeting the obligations to maximize treatment benefit to patients (beneficence), minimizing harm (nonmaleficence), supporting autonomy for pediatric patients during a time of rapid development, and addressing justice, including equitable access to care for TGNC youth. Moreover, although available data describing the use of gender-affirming treatment options are encouraging, and the risks of not treating TGNC youth with gender dysphoria are evident, little is known about the long-term effects of both hormonal and surgical interventions in this population. To support ethical decision-making about treatment options, we encourage the development of a comprehensive registry in the United States to track long-term patient outcomes. In the meantime, providers who work with TGNC youth and their families should endeavor to offer ethically sound, patient-centered, gender-affirming care based on the best currently available evidence.
PMID: 30401789
ISSN: 1098-4275
CID: 3520072

Fair, just and compassionate: A pilot for making allocation decisions for patients requesting experimental drugs outside of clinical trials

Caplan, Arthur L; Teagarden, J Russell; Kearns, Lisa; Bateman-House, Alison S; Mitchell, Edith; Arawi, Thalia; Upshur, Ross; Singh, Ilina; Rozynska, Joanna; Cwik, Valerie; Gardner, Sharon L
Patients have received experimental pharmaceuticals outside of clinical trials for decades. There are no industry-wide best practices, and many companies that have granted compassionate use, or 'preapproval', access to their investigational products have done so without fanfare and without divulging the process or grounds on which decisions were made. The number of compassionate use requests has increased over time. Driving the demand are new treatments for serious unmet medical needs; patient advocacy groups pressing for access to emerging treatments; internet platforms enabling broad awareness of compelling cases or novel drugs and a lack of trust among some that the pharmaceutical industry and/or the FDA have patients' best interests in mind. High-profile cases in the media have highlighted the gap between patient expectations for compassionate use and company utilisation of fair processes to adjudicate requests. With many pharmaceutical manufacturers, patient groups, healthcare providers and policy analysts unhappy with the inequities of the status quo, fairer and more ethical management of compassionate use requests was needed. This paper reports on a novel collaboration between a pharmaceutical company and an academic medical ethics department that led to the formation of the Compassionate Use Advisory Committee (CompAC). Comprising medical experts, bioethicists and patient representatives, CompAC established an ethical framework for the allocation of a scarce investigational oncology agent to single patients requesting non-trial access. This is the first account of how the committee was formed and how it built an ethical framework and put it into practice.
PMID: 29982174
ISSN: 1473-4257
CID: 3191732