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FDA and the Voice of the Patients
The FDA approved the Pipeline Project’s proposal to expand the
agency’s Patient Consultant Program to include Parkinson’s disease.
Parkinson patient advocates now are incorporating the patient
perspective into the FDA drug review regulatory process. As patient
consultants in the pre-approval, clinical trial phase of Parkinson’s
drug development, they advise the FDA and drug sponsors on topics
such as clinical trial design, endpoint determination, expanded
access, protocol development, and clinical trial patient recruitment
strategies. The program is modeled after the successful Cancer Drug
Development Patient Consultant Program initiated in 2001, and a
similar one involving HIV/AIDS patient advocates.
“Parkinson’s is a good candidate to lead other neurological
conditions in this pilot effort because of the active community
advocating for enhanced scientific research and new therapy
development,” said Perry Cohen, Ph.D., who has served as an FDA
patient
representative since the Deep Brain Stimulation Advisory Panel in
March, 2000. (5)
The FDA has named the following Parkinson’s disease patient
advocates to serve as special consultants on the development of new
Parkinson's disease therapies:
- Katherine Decker, R.N., of Chesapeake, Virginia, a nurse and state
health occupations vocational education administrator, diagnosed 12
years ago.
- David Eger, Ph.D., a psychologist in private practice in White
Plains, New York, diagnosed five years ago.
- Marshall Loeb, a columnist for Market Watch from Dow Jones news
service, and an analyst for CBS radio with a focus on business and
the economy. He is the former managing editor of Fortune and Money
and senior editor of Time for Time, Inc. Loeb was diagnosed
two-and-a-half years ago.
Involving patients in the design of studies to evaluate new
therapies accelerates the process of bringing more effective
treatments to market, and ensures measurement of a broader range of
clinical outcomes in weighing the risk/benefit tradeoffs of an
investigational treatment. For example, non-motor Parkinson’s
symptoms were not given much attention until an October 2003 survey
by people with Parkinson’s (PWP). The survey, The Impact of
Parkinson's Disease on Quality of Life, revealed that loss of energy
and pain were two of the top three most disabling symptoms. (1) This
discovery prompted health care professionals to start asking
patients which PD symptoms were most troubling, resulting in a new
focus on autonomic functions (e.g. swallowing. digestion, and
cognitive and psychological factors, including memory and mood
changes).
Decisions about what to measure, how to administer treatment and
trial length are made during the design phase, with little opportunity
to adjust the protocol based on feedback from trial participants. Often
questions arise during study design concerning what patient participants
will or will not do, with assumptions made that can greatly affect
outcomes. Patient advisors bring the patient perspective to questions
such as, “Does the proposed clinical trial provide adequate disclosure
of risk information to patients in a manner that is understandable?”
Documenting the safety and efficacy of new treatments is a slow process.
The two to four years added to repeat a flawed study may mean the
difference in disability for those with chronic illnesses, and/or even
life and death.
Patient consultants have been hired as Special Government Employees
and are subject to the FDA's conflict of interest and
confidentiality regulations that govern each FDA employee,
consultant, and advisor. Parkinson’s disease patient advocates
chosen to serve as patient consultants have been receiving training
1) at FDA's Rockville, Maryland facilities, at FDA expense, 2) by
telephone lectures from FDA staff along with cancer patient
consultants and 3) in joint training sessions with PD industry
consultants. The FDA will arrange for patient consultants to
participate via telephone in FDA in-house meetings and meetings with
sponsors.
Pipeline Project Director Perry Cohen has consulted with FDA staff
in OSHI on the coordination of our company advisor
training-development with the FDA patient consultant efforts.
For further information regarding the application process, selection
criteria, and training of PD-FDA patient consultants visit the FDA
Office of Special Health Issues at
http://www.fda.gov/oashi/cancer/pconback.html,
or contact JoAnn Minor or David Banks at 301-827-4460
Patient Reps’ Unique Insights
Enhance FDA Decision-Making
The Patient Representative Program recruits and trains advocates to
serve on FDA advisory committees, providing “insight on issues,
problems, and/or questions pertinent to the viewpoint of patients
and family members living with a specific serious or
life-threatening disease.” (4) This input “contributes to the
quality of the FDA’s regulatory decision-making and lends
credibility to the product review process.” (1)
“When it comes to approving a drug’s use, you want to prolong
someone’s life, make it better, or both,” said Steven Hirschfeld,
M.D., Ph.D., a medical officer in the FDA's division of oncology
drug products. “The hard part is figuring out what and how you can
determine what 'better' means. No one else will have the experience
and perspective of a patient familiar with a disease to determine if
a benefit is meaningful or if the burden is severe.” (3)
Patient representatives and care-givers, and industry and consumer
advocates work alongside physician-scientists, statisticians,
epidemiologists, nutritionists, and toxicologists, discussing unique
aspects of safety, effectiveness, or clinical development of a
particular product. Advocates’ experience as patients enable them to
voice “real world” concerns of the potential recipient of new drugs,
biologics (e.g. vaccines), and medical devices under review. (1)
“Access to a growing range of products offers opportunities for
advancing public health and improving people's lives, but also
…creates greater potential risks for people who use the products.”
(1) To keep up with the challenges FDA experts face when evaluating
cutting edge scientific medical developments, the agency hires
outside advisers as "special government employees” to serve on
technical and scientific advisory committees, which have a prominent
role in the product approval stage. Committee recommendations are
non-binding. Final regulatory decision rests with the FDA.
Sources
- “Advisory Committees: Critical to the FDA's Product Review
Process” By Carol Rados; FDA Consumer Magazine January-February 2004
http://www.fda.gov/fdac/features/2004/104_adv.html
- “When a Patient Speaks...Patient Reps to FDA Advisory Committees”
http://www.fda.gov/oashi/patrep/patbroc.html
Last revised July 2, 1998, Office of Special Health Issues, HF-12
- Bringing Real Life to the Table: Patient Reps Help FDA Review
Products By Michelle Meadows FDA Consumer magazine; January-February
2002
- U.S. FDA Department of Health and Human Services October 2005
FDA Patient Representative Program
http://www.fda.gov/oashi/patrep/patientrep.html
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http://www.pdf.org/Publications/newsletters/fall05/News_in_Brief.cfm
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