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Hospital Pharmacist
Vol 10 No 1 p8
January 2003

Hospital Pharmacist back issues

Letters (Controversy surrounding high-cost drug use in oncology)

From Mr de Lemos

Jones et al provided a timely review (PDF* 75K) on the dilemma faced by the oncology community in the era of more and more costly drugs (Hosp Pharm, October, 2002, pp275-77).

I would like to comment on two of their recommendations. First, the authors suggested that once a drug has been licensed, it should be freely accessible to prescribers. This probably stems from a misinterpretation of the distinctive roles of regulatory review and funding policy.

Regulatory approval to market a drug only requires demonstrated safety and efficacy, while funding policy generally needs to know if that treatment is medically reasonable or necessary.1.2

The relative therapeutic merit of new oncology drugs is not always easy to assess,3 but there are several scenarios when a drug may be safe and efficacious but still deemed not to be medically necessary. For example, the effectiveness of one drug compared with currently available therapies may be relatively small, or the drug's price may be much higher than the comparator drug, but only marginally more effective.4 The more difficult situation in oncology is that surrogate endpoints of potential, but unvalidated, clinical significance are used in lieu of survival data. This difficulty is compounded by the fact that many new oncology drug applications are based on phase II, non-comparator trials.5 It would be more helpful if the great urgency of introducing new drugs is matched by the same urgency to validate the commonly used surrogate endpoints.6

Secondly, the authors also suggested that when new drugs are licensed, national guidelines, like those from the National Institute for Clinical Excellence, should be issued concurrently. This is not possible for the simple reason that the timing of when a new drug would be approved is commercially confidential information, as any approval would lead to an increase in the value of the manufacturer's stock. A better way to solve this problem is to demand that all new drug applications include information needed for decision-making by both the regulatory and the funding review bodies.

Perhaps it is time that concerted efforts are made to ensure that drugs are not only tested for their efficacy, but also for their effectiveness in the real world.

References

1. Garber AM. Evidence-based coverage policy. Health Aff (Millwood) 2001;20:62-82.

2. Welch HG, Mogielnicki J. Presumed benefit: Lessons from the American experience with marrow transplantation for breast cancer. BMJ 2002;324:1088-92.

3. Sunstrum CA, Carruthers-Czyzewski P, Carruthers SG, Larochelle P, McLean W, Pollak PT et al. The difficulty in assessing the relative therapeutic merit of new antineoplastic drugs. Can J Clin Pharm 1997;4:118-25.

4. Laupacis A. Inclusion of drugs in provincial drug benefit programs: Who is making these decisions, and are they the right ones? Can Med Assoc J 2002;166:44-7.

5. Garattini S, Bertelé V. Efficacy, safety, and cost of new anticancer drugs. BMJ 2002;325:269-71.

6. Koopmans PP. Clinical endpoints in trials of drugs for cancer: time for a rethink? BMJ 2002;324:1389-91.

Mário de Lemos
Provincial Drug Information Co-ordinator
Systemic Therapy Program
British Columbia Cancer Agency
Vancouver
Canada

 

Ms Jones and Ms Strange reply:

The point that we were trying to emphasise was that, for a drug to obtain a product licence, the safety and efficacy have been established. It can be frustrating if the use of that drug is then not available/not funded (for example, with imatinib) when there is a clear clinical need for its use.

With respect to oncology clinical trials, we discussed in the text that trial data are not as simple to interpret compared with non-oncology trials. To the best of our knowledge, there is not any requirement for comparative efficacy to be proven for any drug in the application for a product licence.

We agree that the validation of surrogate endpoints, used in lieu of survival data, would be a major step forward. At the current time, it would take a number of years to obtain survival data, by which time, many more deaths could have been prevented. There is much more emphasis on improvements in quality of life — what is the point in increasing survival by a few months, when the quality of that extended life is reduced?

Finally, we agree that the way in which applications for product licences are made should be updated. The inclusion of information for both the regulatory and funding review bodies at the time of submission should be mandatory, especially for those drugs likely to have huge impacts on drug budgets.

Sarah Jones
Lead Cancer Services Pharmacist
The Cancer Centre
Queen Elizabeth Hospital
Birmingham

Sally Strange
MacMillan Oncology Pharmacist
Dorset Cancer Centre
Poole Hospital NHS Trust
Poole


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