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	<title>Comments on: FDA Criticizes Study On User Fees &#038; Approvals</title>
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	<description>News, Comment and Conversation</description>
	<pubDate>Fri, 10 Feb 2012 20:33:46 +0000</pubDate>
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		<title>By: Dr. Sal Giorgianni</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-255041</link>
		<dc:creator>Dr. Sal Giorgianni</dc:creator>
		<pubDate>Sat, 05 Apr 2008 22:05:17 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-255041</guid>
		<description>Lisa Van S

Back after a bit of a university related diversion - darn, still have to pay the bills.

First a bit of a personal note: Our #3 son is deployed USMC - hooorah!  Not in Middle East but deployed to Asia keeping an eye on things there.  Hope yours stays safe

Now back to that independent agency idea.  Yes, an independent agency for safety evals. (and or a presumably autonomous division within FDA) has indeed been around for a long time as Justice noted.  But I do think that every idea has its time.

Very interesting perspective on Hillary, could be she may be in the mood to break ranks with Teddy these days.  May be worth another try soon...dynamics there are going to change.

I am not sure what current PhARMA/BIO perspectives might be on this all but I do hope they change a bit (as they did regarding user fees) things as they are just do not add-up to anything helpful to their bottom-lines.</description>
		<content:encoded><![CDATA[<p>Lisa Van S</p>
<p>Back after a bit of a university related diversion - darn, still have to pay the bills.</p>
<p>First a bit of a personal note: Our #3 son is deployed USMC - hooorah!  Not in Middle East but deployed to Asia keeping an eye on things there.  Hope yours stays safe</p>
<p>Now back to that independent agency idea.  Yes, an independent agency for safety evals. (and or a presumably autonomous division within FDA) has indeed been around for a long time as Justice noted.  But I do think that every idea has its time.</p>
<p>Very interesting perspective on Hillary, could be she may be in the mood to break ranks with Teddy these days.  May be worth another try soon&#8230;dynamics there are going to change.</p>
<p>I am not sure what current PhARMA/BIO perspectives might be on this all but I do hope they change a bit (as they did regarding user fees) things as they are just do not add-up to anything helpful to their bottom-lines.</p>
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		<title>By: Lisa Van S</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-237865</link>
		<dc:creator>Lisa Van S</dc:creator>
		<pubDate>Mon, 31 Mar 2008 13:24:57 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-237865</guid>
		<description>Justice,

It is the Former,... as long as Hillary and Kennedy are on the HELP Committee,... rest assured IODS will never see the light of day. Industry has these folks in their back pocket.</description>
		<content:encoded><![CDATA[<p>Justice,</p>
<p>It is the Former,&#8230; as long as Hillary and Kennedy are on the HELP Committee,&#8230; rest assured IODS will never see the light of day. Industry has these folks in their back pocket.</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236656</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Mon, 31 Mar 2008 01:31:12 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236656</guid>
		<description>Lisa - Where is Grassley-Dodd now?  Did it become part of the FDAAA with the independent ODS deleted (like much else)?  Or is it still around?  My sense was the former, but I hope I'm wrong.</description>
		<content:encoded><![CDATA[<p>Lisa - Where is Grassley-Dodd now?  Did it become part of the FDAAA with the independent ODS deleted (like much else)?  Or is it still around?  My sense was the former, but I hope I&#8217;m wrong.</p>
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		<title>By: henry</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236535</link>
		<dc:creator>henry</dc:creator>
		<pubDate>Sun, 30 Mar 2008 23:49:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236535</guid>
		<description>of course industry funding the FDA creates bias. They are human and the pharmaceutical machine is not! Soreth alluded to that-Ketek transcripts where the FDA and the expert committee discuss the infamous fraudulent study  " that's what they pay us the big bucks for" she said. however a politically dependent 'independent body does not  work either. -Ketek again, Eschenbach refusedto cooperate with Stupack and Dingle-obviously the influence of Bush, whose friends are very close to big pharma. What;s the answer? I don't know, transparency, release of raw data to the public after all it's the public who participate in these clinical trials and the data belongs to them in a sense.</description>
		<content:encoded><![CDATA[<p>of course industry funding the FDA creates bias. They are human and the pharmaceutical machine is not! Soreth alluded to that-Ketek transcripts where the FDA and the expert committee discuss the infamous fraudulent study  &#8221; that&#8217;s what they pay us the big bucks for&#8221; she said. however a politically dependent &#8216;independent body does not  work either. -Ketek again, Eschenbach refusedto cooperate with Stupack and Dingle-obviously the influence of Bush, whose friends are very close to big pharma. What;s the answer? I don&#8217;t know, transparency, release of raw data to the public after all it&#8217;s the public who participate in these clinical trials and the data belongs to them in a sense.</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236422</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Sun, 30 Mar 2008 22:29:42 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236422</guid>
		<description>The idea of such an independent office has been around at least since the 1970s, in a couple of reviews of FDA by the National Academy of Sciences.  The usual model is the same division that we have between the FAA and the NTSB.  There are those who responsible for getting the planes in the air.  And those responsible for investigating what the heck happened when one comes down.

Not surprisingly, David Graham has supported it for years.  Senior management in FDA has been against.  The usual argument is that those who approved the drug "know most about it" and thus should not be excluded from deliberations of what happened if it fails.  The response is that they would not be excluded.  They just may not have final say.  Graham et. al. argue that having made a decision to approve a product, and then having to withdraw it, creates an inevitable COI.  On some level or other, one is saying (even if one couldn't have known) that one's initial decision was (in retrospect) the wrong one.

The major reviews of FDA have been split.  The IOM ended up not supporting a fully independent board.  As I recall, GAO went closer to doing so.  And, as above, as did several earlier reviews from the NAS.  

Everything depends on organization, funding, and power.  If/when FDA preemption happens and only the FDA as we know it is enforcing accountability - and the inevitable disaster happens (which will make Vioxx look like a picnic) - I believe industry will wish very much they had supported such an initiative.</description>
		<content:encoded><![CDATA[<p>The idea of such an independent office has been around at least since the 1970s, in a couple of reviews of FDA by the National Academy of Sciences.  The usual model is the same division that we have between the FAA and the NTSB.  There are those who responsible for getting the planes in the air.  And those responsible for investigating what the heck happened when one comes down.</p>
<p>Not surprisingly, David Graham has supported it for years.  Senior management in FDA has been against.  The usual argument is that those who approved the drug &#8220;know most about it&#8221; and thus should not be excluded from deliberations of what happened if it fails.  The response is that they would not be excluded.  They just may not have final say.  Graham et. al. argue that having made a decision to approve a product, and then having to withdraw it, creates an inevitable COI.  On some level or other, one is saying (even if one couldn&#8217;t have known) that one&#8217;s initial decision was (in retrospect) the wrong one.</p>
<p>The major reviews of FDA have been split.  The IOM ended up not supporting a fully independent board.  As I recall, GAO went closer to doing so.  And, as above, as did several earlier reviews from the NAS.  </p>
<p>Everything depends on organization, funding, and power.  If/when FDA preemption happens and only the FDA as we know it is enforcing accountability - and the inevitable disaster happens (which will make Vioxx look like a picnic) - I believe industry will wish very much they had supported such an initiative.</p>
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		<title>By: Lisa Van S</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236396</link>
		<dc:creator>Lisa Van S</dc:creator>
		<pubDate>Sun, 30 Mar 2008 22:19:27 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236396</guid>
		<description>Dr.Sal &#38; Justice,

I spent a lot of time in DC trying to convince legislators to support the Grassley/Dodd Bill. We were quite close in the Senate. Good old Hillary wouldnt go for it. She supported the industry written version. But yet she tells the public,.. she's not swayed by the Pharmaceutical Industry. Hmm reminds me of her Bosnia story. Maybe she should check out my nephews helmet, the one that was hit by an Iraqi Insurgents bullet.

Former Pharma,
Not Political enough for me!! My Nephew is heading back to Iraq for his second tour.  Semper Fi !!!!!!</description>
		<content:encoded><![CDATA[<p>Dr.Sal &amp; Justice,</p>
<p>I spent a lot of time in DC trying to convince legislators to support the Grassley/Dodd Bill. We were quite close in the Senate. Good old Hillary wouldnt go for it. She supported the industry written version. But yet she tells the public,.. she&#8217;s not swayed by the Pharmaceutical Industry. Hmm reminds me of her Bosnia story. Maybe she should check out my nephews helmet, the one that was hit by an Iraqi Insurgents bullet.</p>
<p>Former Pharma,<br />
Not Political enough for me!! My Nephew is heading back to Iraq for his second tour.  Semper Fi !!!!!!</p>
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		<title>By: Former pharma Marketing Exec</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236323</link>
		<dc:creator>Former pharma Marketing Exec</dc:creator>
		<pubDate>Sun, 30 Mar 2008 21:21:49 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236323</guid>
		<description>JIM,

Independent Office of Drug Safety, Hmmm  This needs to be fleshed out more, but it certainly sounds appealing....</description>
		<content:encoded><![CDATA[<p>JIM,</p>
<p>Independent Office of Drug Safety, Hmmm  This needs to be fleshed out more, but it certainly sounds appealing&#8230;.</p>
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		<title>By: Dr. Sal Giorgianni</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236321</link>
		<dc:creator>Dr. Sal Giorgianni</dc:creator>
		<pubDate>Sun, 30 Mar 2008 21:20:55 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236321</guid>
		<description>A large number of FDA-Industry pundits have, to date, not been in favor of an office of drug safety review within the agency.  There are many reasons I have not favored this, not the least of which is that it could never be independent if structured within FDA and every decision or opinion they would render would be subject to the same second-guessing as now goes on within FDA.   

But, times and needs change.  In thinking through the whole notion a bit more I now do favor this as a potential solution.  With the continued issues that fly around drug approval, post-marketing surveillance and the need to maintain a reasonable time line for approvals of more and more sophisticated and potential problematic drugs and biologics something new needs to be tried.

My favorable view on this would be predicated on such an entity being fully funded, independent of FDA and with a chain of review and comment that insulates it from Congressional second guessing.  OK, the latter may be a pipe-dream but two outta three aint bad.  Maybe there is an area within CDC or NIH that could house such an agency.  Possibly such a review office could be staffed by some of the dedicated folks within the Public Health Service as a way to insulate them a bit from Congress.  Let’s all put on our thinking caps here.  If something is not done to mitigate the current climate of criticism very few truly novel drugs or biologics will ever make it out of the pipeline and survive the current market.  This is not an issue of helping the commercial interests of research companies but an issue of creating an environment that helps promotes the health of the public.</description>
		<content:encoded><![CDATA[<p>A large number of FDA-Industry pundits have, to date, not been in favor of an office of drug safety review within the agency.  There are many reasons I have not favored this, not the least of which is that it could never be independent if structured within FDA and every decision or opinion they would render would be subject to the same second-guessing as now goes on within FDA.   </p>
<p>But, times and needs change.  In thinking through the whole notion a bit more I now do favor this as a potential solution.  With the continued issues that fly around drug approval, post-marketing surveillance and the need to maintain a reasonable time line for approvals of more and more sophisticated and potential problematic drugs and biologics something new needs to be tried.</p>
<p>My favorable view on this would be predicated on such an entity being fully funded, independent of FDA and with a chain of review and comment that insulates it from Congressional second guessing.  OK, the latter may be a pipe-dream but two outta three aint bad.  Maybe there is an area within CDC or NIH that could house such an agency.  Possibly such a review office could be staffed by some of the dedicated folks within the Public Health Service as a way to insulate them a bit from Congress.  Let’s all put on our thinking caps here.  If something is not done to mitigate the current climate of criticism very few truly novel drugs or biologics will ever make it out of the pipeline and survive the current market.  This is not an issue of helping the commercial interests of research companies but an issue of creating an environment that helps promotes the health of the public.</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236178</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Sun, 30 Mar 2008 19:42:17 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-236178</guid>
		<description>Dr. Sal wrote:

"A user-fee would not be necessary if Congress simply and properly provided FDA with all of the funds to do its job. We could all go home and not engage in any of these debates. But, that is just goanna happen, folks."

I agree - something I've been making noise about for a while here.  And it is about funding.  An earlier study by Dan Carpenter showed pretty conclusively that more money leads to faster reviews (surprise, surprise), regardless of where it comes from.

Before I read FME's post, I was also going to make the same connection.  Industry's entire annual PFDUFA contribution is, yes, the equivalent of one day in Iraq. By federal standards, this is _not_ huge bucks.

Shifting issues slightly - anyone want to trade FDA preemption for an adequately funded, independent Office of Drug Safety? (Not totally disconnected from the OND; just not under their thumb.)  We all know post-marketing is where the most serious problems arise, and only a small bit of PDUFDA money has finally been wrangled out to cover a tad of it.</description>
		<content:encoded><![CDATA[<p>Dr. Sal wrote:</p>
<p>&#8220;A user-fee would not be necessary if Congress simply and properly provided FDA with all of the funds to do its job. We could all go home and not engage in any of these debates. But, that is just goanna happen, folks.&#8221;</p>
<p>I agree - something I&#8217;ve been making noise about for a while here.  And it is about funding.  An earlier study by Dan Carpenter showed pretty conclusively that more money leads to faster reviews (surprise, surprise), regardless of where it comes from.</p>
<p>Before I read FME&#8217;s post, I was also going to make the same connection.  Industry&#8217;s entire annual PFDUFA contribution is, yes, the equivalent of one day in Iraq. By federal standards, this is _not_ huge bucks.</p>
<p>Shifting issues slightly - anyone want to trade FDA preemption for an adequately funded, independent Office of Drug Safety? (Not totally disconnected from the OND; just not under their thumb.)  We all know post-marketing is where the most serious problems arise, and only a small bit of PDUFDA money has finally been wrangled out to cover a tad of it.</p>
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		<title>By: Former pharma Marketing Exec</title>
		<link>http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-235642</link>
		<dc:creator>Former pharma Marketing Exec</dc:creator>
		<pubDate>Sun, 30 Mar 2008 14:03:20 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/03/fda-criticizes-study-on-user-fees-approvals/#comment-235642</guid>
		<description>I think the crux of the problem is that the increase in knowledge about cancer and other diseases in general has allowed a number of drugs to be fast tracked through the system.  

The cancer drugs do show major life prolonging benefits but in some cases serious SE's are only realized after a few years on the market and depending on the patient size, data is harder to accrue.  

Understanding the human genome has given us the ability to develop more precisely targeted drugs. The benefits of these drugs are so critical that they must be brought to market as quickly as possible.  When you see patients who are near death, get up and walk out of the hospital after a few weeks on a pill, it is immoral to not provide that drug to every patient who could benefit from it.

This puts a serious strain on the entire system.  The fast tracked drugs are under obligation to continue to provide ongoing data to the FDA.

Clearly, as pointed out, the FDA is challenged with it's resources.

I do not think that user fees are entirely to blame in this case.  Not to get too political, how good would it be if we diverted some of the "war" funds over to the FDA?
 

The FDA system needs to be brought up to date to be able to allow us all to reap the benefits of our new drug technology.

I am not sure patent issues matter in this sense.  Since drugs will have a shorter life span, perhaps the patents could be shorter too.  But not before the approval process at te FDA is fixed.</description>
		<content:encoded><![CDATA[<p>I think the crux of the problem is that the increase in knowledge about cancer and other diseases in general has allowed a number of drugs to be fast tracked through the system.  </p>
<p>The cancer drugs do show major life prolonging benefits but in some cases serious SE&#8217;s are only realized after a few years on the market and depending on the patient size, data is harder to accrue.  </p>
<p>Understanding the human genome has given us the ability to develop more precisely targeted drugs. The benefits of these drugs are so critical that they must be brought to market as quickly as possible.  When you see patients who are near death, get up and walk out of the hospital after a few weeks on a pill, it is immoral to not provide that drug to every patient who could benefit from it.</p>
<p>This puts a serious strain on the entire system.  The fast tracked drugs are under obligation to continue to provide ongoing data to the FDA.</p>
<p>Clearly, as pointed out, the FDA is challenged with it&#8217;s resources.</p>
<p>I do not think that user fees are entirely to blame in this case.  Not to get too political, how good would it be if we diverted some of the &#8220;war&#8221; funds over to the FDA?</p>
<p>The FDA system needs to be brought up to date to be able to allow us all to reap the benefits of our new drug technology.</p>
<p>I am not sure patent issues matter in this sense.  Since drugs will have a shorter life span, perhaps the patents could be shorter too.  But not before the approval process at te FDA is fixed.</p>
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