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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
Expanding Access to Investigational Therapies for HIV Infection and AIDS
March 12–13, 1990 Conference Summary
Eve Nichols
Roundtable for the Development of Drugs and Vaccines Against AIDS
Institute of Medicine
NATIONAL ACADEMY PRESS
Washington, D.C. 1991
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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
National Academy Press
2101 Constitution Avenue, NW Washington, DC 20418
This conference summary was written by Eve Nichols for the Institute of Medicine's Roundtable for the Development of Drugs and Vaccines Against AIDS, chaired by Harold Ginsberg and Sheldon Wolff and directed by Robin Weiss. The document reports major themes of the conference discussions; these themes, however, do not represent policy statements by the Institute of Medicine.
The report has been reviewed by a group other than the authors according to procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine.
The Institute of Medicine was chartered in 1970 by the National Academy of Sciences to enlist distinguished members of appropriate professions in the examination of policy matters pertaining to the health of the public. In this, the Institute acts under both the Academy's 1863 congressional charter responsibility to be an advisor to the federal government, and its own initiative in identifying issues of medical care, research, and education.
The Roundtable is supported by the American Foundation for AIDS Research, the Merck Company Foundation, the Pharmaceutical Manufacturers Association, the U.S. Army, the U.S. Public Health Service, and the U.S. Department of Veterans Affairs.
Library of Congress Catalog Card No. 91-60585
International Standard Book Number 0-309-04490-1
Additional copies of this report are available from:
National Academy Press
2101 Constitution Avenue, NW Washington, DC 20418
S345
Printed in the United States of America
The serpent has been a symbol of long life, healing, and knowledge among almost all cultures and religions since the beginning of recorded history. The image adopted as a logotype by the Institute of Medicine is based on a relief carving from ancient Greece, now held by the Staatlichemuseen in Berlin.
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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
ROUNDTABLE FOR THE DEVELOPMENT OF DRUGS AND VACCINES AGAINST AIDS
HAROLD S. GINSBERG (Co-chair), Eugene Higgins Professor of Medicine and Microbiology,
Department of Medicine, College of Physicians & Surgeons, Columbia University, New York
SHELDON M. WOLFF (Co-chair), Physician-in-Chief,
New England Medical Center, and
Endicott Professor and Chairman,
Department of Medicine, Tufts University School of Medicine, Boston
DAVID W. BARRY, Vice President of Research,
The Wellcome Research Laboratories, Burroughs Wellcome Co., Research Triangle Park, North Carolina
JAMES S. BENSON, Acting Commissioner,
Food and Drug Administration, Rockville, Maryland
DONALD S. BURKE, Colonel,
Medical Corps, U.S. Army, and
Director,
Division of Retrovirology, Walter Reed Army Institute of Research, Rockville, Maryland
BRUCE A. CHABNER, Director,
Division of Cancer Treatment, National Cancer Institute, National Institutes of Health, Bethesda, Maryland
MAX D. COOPER, Investigator,
Howard Hughes Medical Institute, and
Professor of Medicine, Pediatrics, and Microbiology,
University of Alabama, Birmingham
MARTIN DELANEY, Co-Executive Director and President,
Project Inform, San Francisco
DANIEL DEYKIN, Chief,
Cooperative Studies Program. Veterans Administration Medical Center, Boston
R. GORDON DOUGLAS, Senior Vice President,
Medical and Scientific Affairs, Merck Sharp & Dohme International, Rahway, New Jersey
ANTHONY S. FAUCI, Associate Director for AIDS Research,
National Institutes of Health, and
Director,
National Institute of Allergy and Infectious Diseases, National Institutes of Health, Bethesda, Maryland
GERALD FRIEDLAND, Professor of Medicine,
Department of Medicine, Albert Einstein College of Medicine, Montefiore Medical Center, The Bronx, New York
L. PATRICK GAGE, Executive Vice President,
Genetics Institute, Inc., Cambridge, Massachusetts
PETER BARTON HUTT, Partner,
Covington & Burling, Washington, D.C.
JAY C. LIPNER, Partner,
Silverstein Langer Lipner & Newburgh, New York, New York
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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
DAVID W. MARTIN, JR., Vice President,
Research and Development, The Dupont Merck Pharmaceutical Company, Wilmington, Delaware
CATHERINE M. WILFERT, Professor of Pediatrics and Microbiology,
Department of Pediatrics, Division of Infectious Diseases, Duke University Medical Center, Durham, North Carolina
STAFF
ROBIN WEISS, Project Director and Director,
AIDS Activities
SHARON BARATZ, Research Associate
RICHARD BERZON, Staff Officer
GAIL SPEARS, Administrative Assistant
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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
PREFACE
The Roundtable for the Development of Drugs and Vaccines Against AIDS was established in 1988 by the Institute of Medicine. Composed of leaders from government, the pharmaceutical industry, academia, and the public, its mission is to identify and help resolve impediments to the speedy availability of safe and effective drugs and vaccines for human immunodeficiency virus (HIV) infection and acquired immune deficiency syndrome (AIDS). The Roundtable accomplishes its mission through regular meetings of its membership, during which urgent issues are identified and discussed, as well as through public conferences and workshops that explore scientific and policy matters central to the development of AIDS therapeutics. This publication is the report of a conference held March 12 and 13, 1990, in Washington, D.C.
The call for a "parallel track" for AIDS drug development—a proposal that would allow the early distribution of AIDS drugs to large numbers of patients in parallel with the conventional clinical trials that assess the drugs' safety and efficacy—has sparked controversy within the scientific community. Questions have arisen about the risks to patients of such a plan, about its potential effect on the successful completion of standard controlled trials, and about whether the parallel track will generate useful data. Larger questions have also been raised about whether the parallel track heralds fundamental changes in the philosophy underlying drug regulation in the United States, about the costs and financing of investigational therapies and associated medical costs, and about the role of expanded access mechanisms for drugs in reaching those whose health care generally is inadequate. The Roundtable sought to illuminate these issues by inviting knowledgeable speakers and the public to a two-day conference to examine proposals for expanded access to investigational drugs and possible repercussions of such an action.
Two months after the conference was held, in May 1990, the parallel track proposal was published in the Federal Register and comments were
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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
sought. A meeting was held in September 1990 by the Public Health Service (PHS) to discuss the comments. As this report goes to press, the PHS is finalizing the document, which, when completed, will constitute a written PHS policy. As the policy takes effect, many of the issues raised in this report will serve as valuable guideposts in evaluating the parallel track experiment.
A note on terminology: Although the word effectiveness rather than efficacy was used by Congress in the Drug Amendments of 1962, we have chosen in this report to conform to the definitions of the two terms as they are commonly understood in the field of medical technology assessment. Here, the term efficacy refers to what a method (e.g., a drug) can accomplish in expert hands when correctly applied to a patient; effectiveness refers to its performance in more general routine applications.1 Therefore, most randomized clinical trials assess efficacy; the Food and Drug Administration, in reviewing the results of these trials, is evaluating the efficacy of the drugs under investigation.
This report seeks to summarize the conference presentations. It contains no recommendations or conclusions, and the Roundtable has neither altered nor commented on the views and opinions expressed by the speakers, except for purposes of clarity. The Roundtable and staff wish to thank Eve Nichols, whose capable hands crafted the transcript of the meeting into a smooth narrative. We also thank, once again, the conference speakers for their thoughtful presentations, and all participants for the lively and challenging discussions throughout the conference.
1
Institute of Medicine, Assessing Medical Technologies (Washington, D.C.: National Academy Press, 1985).
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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
Contents
CONFERENCE PROGRAM
1
1
HISTORICAL PERSPECTIVE
5
Early Development of Expanded Access
6
Drug Amendments of 1962
7
Modern Clinical Trials (Non-AIDS Drugs)
9
The Advent of AIDS
11
Broadening Participation
11
Accelerating the Pace of Drug Development
12
Expanded Access
14
2
RIGHTS AND RESPONSIBILITIES
19
Freedom of Choice
19
Informed Consent
20
Information Resources
20
Access
22
Competing Rights
24
Institutional Review Boards
24
New Attitudes
25
3
EVALUATION OF EXPANDED ACCESS PROGRAMS
27
Treatment Investigational New Drugs
27
Potential Risks
28
Examples from the Past
28
The Target Population
29
Safety Data
30
Impact on Conventional Randomized Trials
31
The Parallel Track Experiment
32
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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
4
CREATIVITY IN CLINICAL TRIALS
35
The Changing Environment
35
Conventional Trials
36
Preference Trials
38
Large, Simple Randomized Trials
39
Physician Participation
40
Quality Control
41
Data from the Parallel Track
41
Efficacy Data
41
Safety Data and Related Information
42
Expectations
43
5
DRUG INNOVATION AND THE PHARMACEUTICAL INDUSTRY
45
Time to Commercialization
46
Direct Costs of Expanded Access
46
Manpower Needs
47
Drug Costs
48
The Small Manufacturer
48
Product Liability
49
Concerns Specific to the Parallel Track
50
Potential Solutions
50
6
THIRD-PARTY PAYERS
53
Blue Cross and Blue Shield
55
Health Insurance Association of America
56
Health Care Financing Administration
58
Medicaid
58
Medicare
60
Resources for Clinical Investigation
60
7
IMPROVING ACCESS TO CARE
63
People of Color
65
Resource Considerations
65
Suspicion
67
Informed Consent
67
Women
68
The Gender Perspective
68
A New Approach
70
The Pediatric Population
71
Scientific Issues
72
Social Issues
72
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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
EXPANDING ACCESS TO INVESTIGATIONAL THERAPIES FOR HIV INFECTION AND AIDS
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Expanding Access to Investigational Therapies for HIV Infection and AIDS: March 12-13, 1990 Conference Summary
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