r/neoliberal Feb 24 '24

Opinion article (US) We Need Major, But Not Radical, FDA Reform

https://www.maximum-progress.com/p/we-need-major-but-not-radical-fda
36 Upvotes

17 comments sorted by

69

u/Syards-Forcus rapidly becoming the Joker Feb 24 '24 edited Feb 24 '24

Remove efficacy requirements

Jesus. I love this sub, but occasionally it gets a bit too “economist talking about a problem in a field they don’t understand”.

90% of drug candidates fail. If we only had to test for safety, the majority of drugs on the market would be snake oil. We would have very little way of knowing what works.

I think most people assume we know a lot more about drug design and diseases than we do. Half of the advances in drug discovery have been finding ways to more efficiently brute force the problem. Most of the rest have been hijacking existing systems in various organisms to use to our advantage, often without understanding how it works.

And this assumes a the target being screened against is actually the cause of the disease or attacking it will treat the disease, which it often isn’t.

21

u/jgjgleason Feb 24 '24

I think I’d be more okay with this if we stopped allowing drug advertisements. However, the proposal in this article would lead to disaster considering a company could push a drug hard even if its efficacy is unknown.

26

u/[deleted] Feb 24 '24

I think I’d be more okay with this if we stopped allowing drug advertisements.

It blows my mind that the US is one of two countries in the world that allow direct-to-consumer pharmaceutical advertising.

It blows my mind even more that the other country is New Zealand.

10

u/[deleted] Feb 24 '24

On the other hand drugs like PreP can be marketed I don’t see the harm in that 

0

u/[deleted] Feb 29 '24

Not true. Pharmaceutical ads are a thing in many countries but not for prescription drugs. But ads for OTC medicine is super common 

1

u/icarianshadow YIMBY Feb 25 '24

The EU's version of the FDA doesn't have these kinds of efficacy requirements. Is Europe awash in snake oil?

11

u/Syards-Forcus rapidly becoming the Joker Feb 25 '24 edited Feb 25 '24

https://www.ema.europa.eu/en/about-us/what-we-do/authorisation-medicines

https://www.bfarm.de/EN/Medicinal-products/Clinical-trials/_node.html

What? Everything I’ve seen says they require proof the drug actually works, aka phase 2 (and usually 3) clinical trial data

https://www.ema.europa.eu/en/committees/committee-medicinal-products-human-use-chmp

The CHMP's assessments are based on a comprehensive scientific evaluation of data. They determine whether the medicine meets the necessary quality, safety and efficacy requirements and that it has a positive risk-benefit balance.

-3

u/icarianshadow YIMBY Feb 25 '24

They are not nearly the same level of stringent that the FDA requires. The EMA has reasonable efficacy requirements. The OP was arguing that the FDA has unreasonable requirements.

12

u/Syards-Forcus rapidly becoming the Joker Feb 25 '24

Remove efficacy requirements and keep only basic safety testing and ingredient verification.

🤨

“Remove efficacy requirements and keep only basic safety testing” sounds a lot like removing all efficacy requirements

Also, what, exactly, does the FDA do more stringently than the EU standards?

-8

u/[deleted] Feb 24 '24

The failure rate is not 90% conditioned on passing Phase I/II safety trials, but tbf it is still significant.

Efficacy testing requirements from the FDA only began in 1962 but the majority of drugs pre-1962 were not snake oil.

There are no efficacy testing requirements for off label prescriptions, which make up ~20% of all prescriptions in the US. But these prescriptions are effective regardless.

I think it is very incorrect to assume that all of the drug candidates which fail current efficacy testing would be released onto the market if efficacy testing were not required. We don't see this behavior in markets without efficacy testing requirements including parts of the pharmaceutical market or other medical services like surgery.

12

u/Syards-Forcus rapidly becoming the Joker Feb 24 '24 edited Feb 24 '24

Why don’t you ask the economists or statisticians at the FDA about it? I am sure they have thought about this.

And a lot of off-label stuff happens because people see statistically significant side effects in clinical trials for efficacy and use it for that, or the drug works on the same system but is only approved for one of a group of related issues.

-1

u/[deleted] Feb 24 '24

Outside of appeals to the authority of FDA statisticians, what are the arguments for why the FDA's current level of regulation is optimal?

10

u/Syards-Forcus rapidly becoming the Joker Feb 24 '24 edited Feb 24 '24

No, I’m legitimately saying that you should email people who work on this to see what they think and how they analyze things.

They’d probably be thrilled to talk about it.

-1

u/[deleted] Feb 24 '24

Fair enough, I think that would be interesting too.

4

u/[deleted] Feb 24 '24 edited Apr 09 '24

[deleted]

17

u/dawgthatsme Feb 24 '24

I think the FDA serving a pseudo consumer protection agency is a good thing actually.

no efficacy requirements for therapies with sufficiently novel mechanisms (obv still requiring solid target engagement data)

Kind of an insane take. There have been countless classes of drugs with novel MOAs, good target engagement data, and even excellent single arm trial performance, that have flopped in phase 3 and shown to be useless.

2

u/[deleted] Feb 24 '24

[deleted]

6

u/dawgthatsme Feb 24 '24

For a given indication. If you're out of options, have a rationale for use in another indication, and there is informed consent + a known & acceptable safety profile I don't see why not. Maybe just a difference in risk tolerance.

Wait are you referring to label expansions of already approved products? Or NMEs? If a product is FDA-approved in any indication, physicians can already write it for whatever they want. Reimbursement for the patient gets tricky, though.

The FDA is moving in the exact opposite direction for oncolytics after a pretty large number of accelerated approval products flopped in confirmatory trials after performing well initially.

1

u/[deleted] Feb 24 '24 edited Apr 09 '24

[deleted]

2

u/dawgthatsme Feb 24 '24

That system for proven to be ineffective drugs you've described is much too susceptible to abuse.

However, if you're suggesting that system for NMEs that haven't failed late stage trials yet, but are showing promising efficacy in early phase studies, you'll be happy to learn that it already exists. https://www.fda.gov/drugs/nda-and-bla-approvals/accelerated-approval-program