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Selecting Risk Management Tools: FDA Considerations and Experience. Anne Trontell, M.D., M.P.H. Deputy Director, Office of Drug Safety Joint Advisory Committee of DSaRM and Dermatologic & Ophthalmic Drugs February 26, 2004 . Outline. Definitions General considerations
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Selecting Risk Management Tools: FDA Considerations and Experience Anne Trontell, M.D., M.P.H. Deputy Director, Office of Drug Safety Joint Advisory Committee of DSaRM and Dermatologic & Ophthalmic Drugs February 26, 2004
Outline • Definitions • General considerations • Concerns with current isotretinoin RMP • Candidate tools to address concerns • Related programs • Advantages, disadvantages of tool options
Risk Management Program (RMP) Definitions • Goals • ideal product use scenario/“vision” statement • tailored to product-specific risk concerns • may not be fully achievable in practical terms • example: No fetal exposures shall occur
RMP Definitions • Tools • processes or systems intended to enhance safe product use by reducing risk • Choice influenced by severity, reversibility and frequency of risk
Considerations in Selecting RMP Tools • Each tool should add value in attaining goals • Seek: proven effectiveness, acceptability, low burden • Avoid: unnecessary limitations on beneficial uses, multiple customized tools, unintended consequences
Broad Categories of Tools • Product labeling for health professionals • Education and outreach • educational materials for HCP and/or patients • Reminder/Prompting systems • stickers, informed consent, limited supply • Limited distribution • selected groups able to prescribe, dispense, use • often mandatory use of reminder-like systems
Experience with Tool Categories • Product labeling, education and outreach • extensive use; effectiveness limited/unknown • Reminder systems • infrequent use; effectiveness largely untested • Limited distribution • rarely used; typically small patient populations with limited therapeutic options; registration allows and has demonstrated effectiveness
Experience: Tool Categories • Reminder/prompting/limited supply • alosetron, isotretinoin, lindane • Limited distribution • bosentan*, clozapine*, dofetilide*, mifepristone, thalidomide*, xyrem * lab testing required
Areas of Concern with Current Isotretinoin RMP • Refills dispensed (2.4% of Rx) • Prescriptions filled without stickers (5-9%) • Stickers without pregnancy testing (9%) • Patients pregnant at initiation of therapy (6% of reported pregnancies) • 2 tests not done, timed incorrectly to menses, erroneous or misreported tests
Areas of Concern with Current Isotretinoin RMP Pregnancy exposures occurring during therapy (94% of total) • Poor/no use of adequate contraception • Abstinent patients having unanticipated sexual activity without contraceptive use Use without medical supervision (?%) • Internet, borrowed, leftover pills
Areas of Concern with Current Isotretinoin RMP • Extent of pregnancy exposures unknown • only voluntary reports and patient surveys • potential duplication of patients across surveys • Extent, duration of isotretinoin exposure among FCBP poorly estimated
Prescribing/Dispensing with Stickers Tool Options • Better education of pharmacists and physicians ( “good faith”) • Increase number or types of reminders (~ disease management models) • Limit prescribing, dispensing by HCPs • by training, certification, and/or registration • with systems that obligate compliance and/or allow monitoring
Pregnancy Testing Tool Options for HCP • More and better education • More or better reminders • Limit prescribing, dispensing to selected HCPs • Require documentation check of negative -HCG at time of dispensing (e.g. Kaiser)
Contraception: Challenges for Intervention • Complex and private behavior, sensitive to discuss • with adolescents when parents are present • assumptions, misinformation common among all ages • Behavior influenced but not necessarily controlled by knowledge • Attitudinal and behavioral components
Contraception Tool Options • Improved education and outreach to patients to increase knowledge • Need for 2 methods • Effective methods • Ineffective methods
Contraception Tool Options • Use reminders/prompts (such as counseling) • Reinforce knowledge • Address attitudes about contraceptive use, planned/unplanned sexual activity, partner cooperation/resistance to use • One time or periodic to reinforce behaviors • Methods could include technologies such as interactive voice response (IVR), moderated chat rooms, etc
Contraception Tool Options • Limit product to patients demonstrating appropriate knowledge, skills, and behaviors • Counselor certification of patient commitment, skills with chosen contraceptives • Periodic IVR or counselor screening for high risk behaviors • DOT for OCP or patches, pill counts, other models to track adherence
Contraceptive ‘Failures’ • Contraceptive effectiveness in actual practice << efficacy • Options to limit exposure of FCBP to only with the most severe cases of acne • require documentation, prior authorization, 2nd opinion, or other check mechanism for use by FCBP
Medically Unsupervised UseTool Options • Educate patients about risks • Alter product packaging • note risks of unsupervised use, Internet purchase, sharing • limit supply dispensed << 30 days to decrease sharing • Constrain Internet sales
Relevant RMPs for Comparison • Clozapine • multiple manufacturers • interrelated data systems • evaluation data used to relax requirements • Thalidomide • teratogen with extensive and effective system • experience with FCBP limited (~5%)
Clozapine Goal: No agranulocytosis • Weekly to biweekly blood testing assures adequate WBC and prevents agran • Pharmacist must see documented WBC to dispense • Only registered patients, pharmacists, physicians can access drug
Clozapine Processes • Central, shared non-rechallenge registry of those with history of low WBC • Independent sponsor programs for weekly, biweekly testing • No patient survey, education
Thalidomide Goal: No fetal exposures • Only registered patients, pharmacists, physicians can access drug • Pregnancy testing done according to pregnancy risk category (gender, age, fertility) • Physician reports negative pregnancy status to central authorization database
Thalidomide • Patients must report via IVR module on risk factors for pregnancy exposure: high-risk routed directly to person for action • Pharmacist dispenses product only if check of central database assures appropriate physician and patient responses • System tracks pregnancy exposures not lost to f/u • Extensive education, including medication guide, informed consent, video
Comparison of Programs: Isotretinoin, Thalidomide, Clozapine • Warnings in labeling: All • Patient education materials: I, T • Medication guide: I, T • Patient informed consent: I, T
Comparison of Programs: Isotretinoin, Thalidomide, Clozapine • Lab testing • Documentation of results required: C • Physician report of results required: T • Physician uses sticker to attest to pregnancy test done and negative: I
Comparison of Programs: Isotretinoin, Thalidomide, Clozapine • Patient Registration • All patients: T • Nonrechallenge only: C • None: I • Physician registration • Required to prescribe: T, C • Voluntary to get stickers: I
Comparison of Programs: Isotretinoin, Thalidomide, Clozapine • Pharmacist Registration • Required to dispense product: T, C • None: I
Comparison of Programs: Isotretinoin, Thalidomide, Clozapine • Tracking performance • patient behaviors: T (I) • patient exposures: T (C) • Direct tracking of outcomes: T, C • Voluntary outcomes, AEs: I
Advantages Acceptable to most Feasible No change in access More time to see if performance improves Disadvantages Effectiveness limited/unknown, particularly for changing behaviors such as contraception Increasing Education and Outreach Tools Advantages/Disadvantages
Advantages Physician, pharmacist, patient autonomy Ongoing education, reminders re risks and safe use Less intrusive than limited distribution Disadvantages Limited experience Unknown effectiveness Time and $ costs for counseling, disease mgt Increasing Reminder/Prompting Systems Advantages/Disadvantages
Advantages Limits access to those adhering to critical risk minimization tools Mandatory participation registration, better data for evaluation Likely to limit exposure by FCBP Disadvantages Unknown effectiveness in young, fertile women Time and $ burdens Limits access to drug benefits May increase illicit access without any safety measures Limited Distribution Advantages/Disadvantages
Considerations in Modifying or Selecting New RMP Tools • Seek evidence for effectiveness and high likelihood of added value • Stay close to familiar tools that work and are acceptable • Avoid unnecessary limitations • Anticipate time, cost, access impacts of constraints, including unintended consequences