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	<title>Comments on: Pharma Lobbies DC For Off-Label Rights</title>
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	<pubDate>Sat, 05 Jul 2008 23:58:41 +0000</pubDate>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-313915</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Fri, 25 Apr 2008 12:22:25 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-313915</guid>
		<description>Got it.  Thanks for word.  Hope you feel better soon!  (Sounds like they took samples...)</description>
		<content:encoded><![CDATA[<p>Got it.  Thanks for word.  Hope you feel better soon!  (Sounds like they took samples&#8230;)</p>
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		<title>By: HorusCat</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-312919</link>
		<dc:creator>HorusCat</dc:creator>
		<pubDate>Fri, 25 Apr 2008 01:48:56 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-312919</guid>
		<description>Hi Justice,
I hope you find this. I was out-of-pocket for a couple of days:  I gave blood and it just wiped me out.  I could barely make it through the day for a couple of days.  I guess I am getting older--I used to give blood and then go run six miles the same day.

I wish I knew what was going on with the company.  I think you are right; there may be a "split" between power groups in the company.  I know one thing:  the attorneys are clear where they stand!  I don't know:  maybe they do a risk-benefit analysis...we stand to earn X dollars, while a penalty would be Y dollars.  I am clueless.  I just know that I am sticking to the label.  That's my story, and I'm sticking to it.  Fortunately, the products I have now don't lend themselves to off-label use at all.  One is a biologic, and you can't even get it without a confirmed diagnosis for the indicated disease state.  

Well, I'm still really tired.  I'm going to go take another iron supplement and go to bed.  I hate getting old.</description>
		<content:encoded><![CDATA[<p>Hi Justice,<br />
I hope you find this. I was out-of-pocket for a couple of days:  I gave blood and it just wiped me out.  I could barely make it through the day for a couple of days.  I guess I am getting older&#8211;I used to give blood and then go run six miles the same day.</p>
<p>I wish I knew what was going on with the company.  I think you are right; there may be a &#8220;split&#8221; between power groups in the company.  I know one thing:  the attorneys are clear where they stand!  I don&#8217;t know:  maybe they do a risk-benefit analysis&#8230;we stand to earn X dollars, while a penalty would be Y dollars.  I am clueless.  I just know that I am sticking to the label.  That&#8217;s my story, and I&#8217;m sticking to it.  Fortunately, the products I have now don&#8217;t lend themselves to off-label use at all.  One is a biologic, and you can&#8217;t even get it without a confirmed diagnosis for the indicated disease state.  </p>
<p>Well, I&#8217;m still really tired.  I&#8217;m going to go take another iron supplement and go to bed.  I hate getting old.</p>
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		<title>By: Doc</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-310227</link>
		<dc:creator>Doc</dc:creator>
		<pubDate>Wed, 23 Apr 2008 14:40:36 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-310227</guid>
		<description>The FDA is insane to loosen off label dissemination (promotion)of information by pharma. The vast majority of sales reps who would deliver this data are not medically trained and biased based on incentive compensation programs - both cash and award trips, annual performance reviews based to a large degree on product sales and forced rankings that can mean loosing your job. Once you open this door, you will reap a whirlwind of baised, unscientific, dollar driven activity by tens of thousands of sales reps with millions of budget dollars to spend. Is that really what the FDA or the public wants? And if you think that doctors can sift through the morass of biased data, think again. They are too busy and concerned with their survival to investigate every detail their reps bring them, besides a large part of the rep job is to develop those strong relationships that DO alter human behavior. Once you are the doctor's long term trusted 'friend', their guard drops - no matter what they think. Marketing departments know that with greater promotional latitude, they don't need to push off label use, the sales reps will naturally go that direction. It has already happened too many times under current guidance.</description>
		<content:encoded><![CDATA[<p>The FDA is insane to loosen off label dissemination (promotion)of information by pharma. The vast majority of sales reps who would deliver this data are not medically trained and biased based on incentive compensation programs - both cash and award trips, annual performance reviews based to a large degree on product sales and forced rankings that can mean loosing your job. Once you open this door, you will reap a whirlwind of baised, unscientific, dollar driven activity by tens of thousands of sales reps with millions of budget dollars to spend. Is that really what the FDA or the public wants? And if you think that doctors can sift through the morass of biased data, think again. They are too busy and concerned with their survival to investigate every detail their reps bring them, besides a large part of the rep job is to develop those strong relationships that DO alter human behavior. Once you are the doctor&#8217;s long term trusted &#8216;friend&#8217;, their guard drops - no matter what they think. Marketing departments know that with greater promotional latitude, they don&#8217;t need to push off label use, the sales reps will naturally go that direction. It has already happened too many times under current guidance.</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-301367</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Sun, 20 Apr 2008 16:06:24 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-301367</guid>
		<description>Thanks, HC.  This is interesting.

So I have to ask a potentially loaded question, but it is again a genuine one.  A skeptic reading the account would ask - so why did the company keep sending you to those docs?  As you said, they were rx'ing a lot yet the situation was "begging for off-label promotion."

The skeptic would say - for four years, the company - or field directors - got what they wanted.  Then concern about liabiiity set in (was this post-Neurontin?).  So they create the scenes of reps coming in to be "sure" that no one was going off label.  Creates the appearance of propiety and concern ... four years later.

But, as you suggest, it sounds like there may have been splits within the company between different levels of management - or concerns about splits - between groups that were more and less comfortable with tacit or active off-label promoting.  Is that any closer to it?

When you say, "record" the conversation, I assume you mean your own notes, not electronic.</description>
		<content:encoded><![CDATA[<p>Thanks, HC.  This is interesting.</p>
<p>So I have to ask a potentially loaded question, but it is again a genuine one.  A skeptic reading the account would ask - so why did the company keep sending you to those docs?  As you said, they were rx&#8217;ing a lot yet the situation was &#8220;begging for off-label promotion.&#8221;</p>
<p>The skeptic would say - for four years, the company - or field directors - got what they wanted.  Then concern about liabiiity set in (was this post-Neurontin?).  So they create the scenes of reps coming in to be &#8220;sure&#8221; that no one was going off label.  Creates the appearance of propiety and concern &#8230; four years later.</p>
<p>But, as you suggest, it sounds like there may have been splits within the company between different levels of management - or concerns about splits - between groups that were more and less comfortable with tacit or active off-label promoting.  Is that any closer to it?</p>
<p>When you say, &#8220;record&#8221; the conversation, I assume you mean your own notes, not electronic.</p>
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		<title>By: HorusCat</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-300715</link>
		<dc:creator>HorusCat</dc:creator>
		<pubDate>Sun, 20 Apr 2008 11:57:02 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-300715</guid>
		<description>Justice,
Good questions. Thanks for your interest.  We once had a way of recording what went on in our offices, conversations with docs, nurses, etc.  I had a product that was not indicated for a certain group of people, but the doctors that served that group of people were in my quota and represented a substantial chunk of it, as a matter of fact.  So I, like every other rep, called on those doctors.  What I tended to do was the sort of detail companies hate, "Hi, what's happening?  Do you need anything."  But I would record what the doctor said back to me.  

At the same time, I and others were whining pretty hard about why those doctors were in our quota.  We kept pointing out that it was begging for off-label promotion.  Finally, 4 years later, they got taken out. In the meantime, any rep who had recorded notes from conversations with those doctors was interviewed.  It was non-adversarial--the company was actually trying to figure out what they had done to encourage off-label promotion.  The questions they asked me were about what managers and upper management had told us and had us do.  There were no repercussions for the reps involved.  I don't know what happened ultimately, because I left the company, but I was encouraged by that.

As for using my knowledge to expand the market, I don't know that I do that.  I understand how the drugs I sell work and I understand a little about the various parts of the brain, but I'm NOT a doctor.  What I can do is engage docs on a scientific level--I think it is more a gestalt they get from me than anything else.  My point to Former was that he was being patronizing in suggesting that I have nothing to offer a physician (because they are some sort of deities and I am a peon rep).  

You ask very good questions, Justice, and I appreciate your insight.  I would say there is a difference between a clinical that addresses an off-label, but related, topic for a drug (i.e., panic for a drug with GAD indication) and a completely off-the-wall off-label indication (bipolar for Neurontin, although I still have a couple of docs who swear by it, go figure.).</description>
		<content:encoded><![CDATA[<p>Justice,<br />
Good questions. Thanks for your interest.  We once had a way of recording what went on in our offices, conversations with docs, nurses, etc.  I had a product that was not indicated for a certain group of people, but the doctors that served that group of people were in my quota and represented a substantial chunk of it, as a matter of fact.  So I, like every other rep, called on those doctors.  What I tended to do was the sort of detail companies hate, &#8220;Hi, what&#8217;s happening?  Do you need anything.&#8221;  But I would record what the doctor said back to me.  </p>
<p>At the same time, I and others were whining pretty hard about why those doctors were in our quota.  We kept pointing out that it was begging for off-label promotion.  Finally, 4 years later, they got taken out. In the meantime, any rep who had recorded notes from conversations with those doctors was interviewed.  It was non-adversarial&#8211;the company was actually trying to figure out what they had done to encourage off-label promotion.  The questions they asked me were about what managers and upper management had told us and had us do.  There were no repercussions for the reps involved.  I don&#8217;t know what happened ultimately, because I left the company, but I was encouraged by that.</p>
<p>As for using my knowledge to expand the market, I don&#8217;t know that I do that.  I understand how the drugs I sell work and I understand a little about the various parts of the brain, but I&#8217;m NOT a doctor.  What I can do is engage docs on a scientific level&#8211;I think it is more a gestalt they get from me than anything else.  My point to Former was that he was being patronizing in suggesting that I have nothing to offer a physician (because they are some sort of deities and I am a peon rep).  </p>
<p>You ask very good questions, Justice, and I appreciate your insight.  I would say there is a difference between a clinical that addresses an off-label, but related, topic for a drug (i.e., panic for a drug with GAD indication) and a completely off-the-wall off-label indication (bipolar for Neurontin, although I still have a couple of docs who swear by it, go figure.).</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-299738</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Sun, 20 Apr 2008 03:02:28 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-299738</guid>
		<description>HC - A different question, and one which is genuine and of interest.

I see on another thread that you have a Ph.D. in neuropharmacology (I think I have the field right).

And you are using your training to expand the market for your company (I have no problem with that).  But you have also suggested that the sales person and the science person are not always easy to balance.  You were once "called on carpet," you suggest, for pushing sales beyond FDA margins.  And you have also, along with others, pushed back from the field against expectations that could tempt at least some to push sales beyond science.

Every field has its high-wire acts so such challenges are not unique or concerning in themselves.  But I would be interested in your insights into how you see yourself managing them over the years, as well as other colleagues who you know.  What does it take to do it well?  What tend to be the reasons when things don't go so well?

As elsewhere, learning about things I don't know is, for me, the _best_ thing about Pharmalot.</description>
		<content:encoded><![CDATA[<p>HC - A different question, and one which is genuine and of interest.</p>
<p>I see on another thread that you have a Ph.D. in neuropharmacology (I think I have the field right).</p>
<p>And you are using your training to expand the market for your company (I have no problem with that).  But you have also suggested that the sales person and the science person are not always easy to balance.  You were once &#8220;called on carpet,&#8221; you suggest, for pushing sales beyond FDA margins.  And you have also, along with others, pushed back from the field against expectations that could tempt at least some to push sales beyond science.</p>
<p>Every field has its high-wire acts so such challenges are not unique or concerning in themselves.  But I would be interested in your insights into how you see yourself managing them over the years, as well as other colleagues who you know.  What does it take to do it well?  What tend to be the reasons when things don&#8217;t go so well?</p>
<p>As elsewhere, learning about things I don&#8217;t know is, for me, the _best_ thing about Pharmalot.</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-299678</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Sun, 20 Apr 2008 02:42:49 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-299678</guid>
		<description>Whoa!  "Congress creature Waxman"?  

Anyway, I think you make my point which I first stated above.  Getting an article in a referreed journal (like JAMA) is a much lower bar than getting an FDA approved indication.  The CLASS example shows that one can get an article in JAMA which is total baloney (or bologna, for the continentals).

You write: "The question of the quality of the research published in journals is a different one than whether pharma should be allowed to distribute them."

If research published in journals is pretty easy to spin, I think that is absolutely material to whether reps should be allowed to distribute "peer-reviewed" studies related to unapproved uses.  So, once again, the distinction you make has logical but not practical relevance. 

So the actual question: Should reps be able to hand out potential baloney that appears to support unapproved indications and/or unreal benefits and/or lesser-than-actual risks?  

Me and the Wax Creature would vote "No."  Dan Troy and his Ad Company votes "Yes."  I assume that you are with Troy and the Ad Company.</description>
		<content:encoded><![CDATA[<p>Whoa!  &#8220;Congress creature Waxman&#8221;?  </p>
<p>Anyway, I think you make my point which I first stated above.  Getting an article in a referreed journal (like JAMA) is a much lower bar than getting an FDA approved indication.  The CLASS example shows that one can get an article in JAMA which is total baloney (or bologna, for the continentals).</p>
<p>You write: &#8220;The question of the quality of the research published in journals is a different one than whether pharma should be allowed to distribute them.&#8221;</p>
<p>If research published in journals is pretty easy to spin, I think that is absolutely material to whether reps should be allowed to distribute &#8220;peer-reviewed&#8221; studies related to unapproved uses.  So, once again, the distinction you make has logical but not practical relevance. </p>
<p>So the actual question: Should reps be able to hand out potential baloney that appears to support unapproved indications and/or unreal benefits and/or lesser-than-actual risks?  </p>
<p>Me and the Wax Creature would vote &#8220;No.&#8221;  Dan Troy and his Ad Company votes &#8220;Yes.&#8221;  I assume that you are with Troy and the Ad Company.</p>
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		<title>By: HorusCat</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-298888</link>
		<dc:creator>HorusCat</dc:creator>
		<pubDate>Sat, 19 Apr 2008 21:58:08 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-298888</guid>
		<description>Justice,
I think the guidelines disallow use of editorials, letters to the editor, etc.?  

The question of the quality of the research published in journals is a different one than whether pharma should be allowed to distribute them. 

Everyone points out that the authors of the articles have pharma connections.  Of course they do!!!  Who else is going to fund these studies?  Don't say the government--it is NOT the job of the government to do medical research.  It may be appropriate to demand more transparency around the research, but let's stop with the self-righteous outrage about who writes the articles and does the trials.  Of course trials have a commercial purpose; drug companies have an interest in expanding the market for their product.  This is a case of different constituencies having interests that merge (scientists are curious, doctors want advances in medicine, patients want better drugs, and drug companies want to make money), while also having some interests that conflict.  That is an argument for oversight and regulation--in an environment that is conducive to innovation and risk-taking--not for the sanctimonious outrage expressed by the likes of the Congress creature Waxman.</description>
		<content:encoded><![CDATA[<p>Justice,<br />
I think the guidelines disallow use of editorials, letters to the editor, etc.?  </p>
<p>The question of the quality of the research published in journals is a different one than whether pharma should be allowed to distribute them. </p>
<p>Everyone points out that the authors of the articles have pharma connections.  Of course they do!!!  Who else is going to fund these studies?  Don&#8217;t say the government&#8211;it is NOT the job of the government to do medical research.  It may be appropriate to demand more transparency around the research, but let&#8217;s stop with the self-righteous outrage about who writes the articles and does the trials.  Of course trials have a commercial purpose; drug companies have an interest in expanding the market for their product.  This is a case of different constituencies having interests that merge (scientists are curious, doctors want advances in medicine, patients want better drugs, and drug companies want to make money), while also having some interests that conflict.  That is an argument for oversight and regulation&#8211;in an environment that is conducive to innovation and risk-taking&#8211;not for the sanctimonious outrage expressed by the likes of the Congress creature Waxman.</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-297957</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Sat, 19 Apr 2008 16:52:30 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-297957</guid>
		<description>Should have included the fact that most of the articles authors were Pharmacia employees and/or consultants.</description>
		<content:encoded><![CDATA[<p>Should have included the fact that most of the articles authors were Pharmacia employees and/or consultants.</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-297940</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Sat, 19 Apr 2008 16:50:19 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/pharma-lobbies-dc-for-off-label-rights/#comment-297940</guid>
		<description>HC - Glad to hear re: the field.  If you haven't seen it, a post for you over on the aging "F You" thread still hanging on over on the margins.

Re: the guidelines that Jack2 first excerpted and I posted above, they are drafts that the FDA is circulating (hat tip to Gooz News, as Ed would say).  

Let's be specific: the famous JAMA CLASS study publication in which study Pharmacia was seeking FDA approved GI benefit for Celebrex.  As published, CLASS appeared to show that.  JAMA wrote editorial in praise of cox-2s and Celebrex in particular.  And even Bob Temple noted that this probably had an enormous impact on rx'ing Celebrex.

Turns out, of course, it was baloney.  CLASS, as it appeared in JAMA, left out the second six months of the data.  Once those back in, the GI benefit disappeared.

That is why FDA (which had all the data) did not allow Pharmacia/Pfizer to claim GI benefit for Celebrex.  And thus why you won't find it on the label.

Now let's say (hypothesis) that Celebrex turns out to have significantly increased CV risks at higher doses.  In the new regime as proposed, docs would have been flooded by reps giving them the JAMA editorial and talking up the GI benefit till cows come home.  This was, after all, "medical information," canonized (so it appeared) in JAMA.

So docs would and did start rx'ing Celebrex in much greater numbers.  For a benefit that turned out to be bogus.  And, in the process, _could_ have ended up killing some number of people because of Pharmacia's duplicity.

All enshrined in what seems to be the most reliable peer-reviewed journal there is, and even with an editorial.

Bob Temple ended up saying that the "hype" of the article probably "has more impact than our labeling does."

Undoubtedly, it did.

Is that the future folks want?</description>
		<content:encoded><![CDATA[<p>HC - Glad to hear re: the field.  If you haven&#8217;t seen it, a post for you over on the aging &#8220;F You&#8221; thread still hanging on over on the margins.</p>
<p>Re: the guidelines that Jack2 first excerpted and I posted above, they are drafts that the FDA is circulating (hat tip to Gooz News, as Ed would say).  </p>
<p>Let&#8217;s be specific: the famous JAMA CLASS study publication in which study Pharmacia was seeking FDA approved GI benefit for Celebrex.  As published, CLASS appeared to show that.  JAMA wrote editorial in praise of cox-2s and Celebrex in particular.  And even Bob Temple noted that this probably had an enormous impact on rx&#8217;ing Celebrex.</p>
<p>Turns out, of course, it was baloney.  CLASS, as it appeared in JAMA, left out the second six months of the data.  Once those back in, the GI benefit disappeared.</p>
<p>That is why FDA (which had all the data) did not allow Pharmacia/Pfizer to claim GI benefit for Celebrex.  And thus why you won&#8217;t find it on the label.</p>
<p>Now let&#8217;s say (hypothesis) that Celebrex turns out to have significantly increased CV risks at higher doses.  In the new regime as proposed, docs would have been flooded by reps giving them the JAMA editorial and talking up the GI benefit till cows come home.  This was, after all, &#8220;medical information,&#8221; canonized (so it appeared) in JAMA.</p>
<p>So docs would and did start rx&#8217;ing Celebrex in much greater numbers.  For a benefit that turned out to be bogus.  And, in the process, _could_ have ended up killing some number of people because of Pharmacia&#8217;s duplicity.</p>
<p>All enshrined in what seems to be the most reliable peer-reviewed journal there is, and even with an editorial.</p>
<p>Bob Temple ended up saying that the &#8220;hype&#8221; of the article probably &#8220;has more impact than our labeling does.&#8221;</p>
<p>Undoubtedly, it did.</p>
<p>Is that the future folks want?</p>
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