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Translational Research:
How Doctornauts Can Help
Stephen L. DeFelice,
M.D.
Awhile back I met with
Gordon Bernard, a physician clinical innovator in septic shock research and
currently the Associate Vice Chancellor for Clinical and Translational Research
at Vanderbilt University School of Medicine. He patiently listened as I pointed
out the urgent need for the Doctornaut Act in order to reduce
counter-productive barriers to clinical research. After I delivered my piece,
he educated me regarding the general Translational Scientific movement and the
establishment of Clinical and Translational Science Awards (CTSA) and its
patient-oriented goal to also reduce these barriers.
(For the record, Dr.
Bernard conducted a clinical study in septic shock patients on a discovery I
made in the past. Unfortunately, the results were not encouraging but, despite
it all, we remain friends)!
The National Center for
Research Resources (3/15/2011) describes the CTSA program as: "A national
consortium of medical research institutions, funded through Clinical and
Translational Science Awards (CTSA), is working together to improve the way
biomedical research is conducted nationwide. Consortium members share a common
vision to reduce the time it takes for laboratory discoveries to become
treatments for patients, to engage communities in clinical research efforts and
to train clinical and translational researchers. The
momentum behind the CTSA program continues to build as new connections are
emerging within, across and beyond the consortium. Launched in 2006, it now
includes 55 medical researchers in 28 states and the District of Columbia. When
the program is fully implemented, it will support approximately 60 CTSAs across
the nation."
The broader Translational
Science movement continues to gather steam. The prestigious American Society
for the Advancement of Science started the new journal, Science
Translational Medicine. The highly respected Francis Collins, the Director
of the NIH, is energetically pushing for ways to conduct more clinical trials
on potential promising new therapies and has recently proposed a separate NIH
unit for this purpose. It's good news, indeed, for patients that a highly
visible, distinguished physician and scientist has stepped forward and taken
the lead in this very sensitive arena.
NOW HERE'S THE BAD NEWS:
THE TRANSLATIONAL RESEARCH MOVEMENT NEEDS HELP: Unfortunately, our current
regulatory ground rules, coupled with our pervasive, obdurate cultural
suspicion of the risks in clinical research further coupled with our excessive
general, cultural preoccupation with risk, remain unbudgeable and will continue
to both retard and block clinical studies .If anything is impossible, it would
be to convince Congress, let alone the FDA, to significantly lower the barriers
for patient volunteers. There is little doubt that the CTSA will spur on
innovative clinical research and medical discovery, not the least by reducing
logistical logjams, but the principle barriers of the "system" will
remain. In addition, the CTSA effort is limited in scope.
Though Thomas Aquinas
believed that the argument from authority is the weakest of all, I remember
what my father used to periodically emphasize. "Son, there's an exception
to every rule." I'm speaking from extensive, personal experiences, which are
tough to quantify, in the world of clinical research and drug development of
new drugs starting from my initial clinical study with carnitine in 1965 up to
the present dealing with FDA, Clinical Research Organizations (CROs), IRBs, the
Orphan Drug Act, the CME, ethicists- moralists, corporations, academicians,
lawyers and international regulators. Whom have I left out? Yes, the powerless
patient!
There are huge barriers
to clinical research studies. A recent study conducted by Ken Getz at the Tufts
Center for the Study of Drug Development found that the median number of
procedures per clinical study increased by 49% between 2000-03 and 2004-07,
while the total effort required to complete those procedures grew by 54%. He
states that, "More complex and burdensome protocols are extending study
cycle times, increasing costs and challenging patient recruitment and
retention." He adds that enrollment criteria are discouraging patient
enrollments dissuading volunteers from staying in the study until completion.
(As a reminder, may I
interject here that the barriers to clinical studies were huge and growing and
increasingly stifling a long time before 2003! This pattern should make us all
very much disturbed about the inexorable continuum increasing of obstacles to
clinical studies).
An eye-opening example
of the pervasive multiple obstacles to entering Phase III clinical studies is
given by, J. Evan Sadler, the President of the American Society of Hematology,
who writes:
"Recent studies in
basic and translational research have set the stage for tremendous progress in
clinical hematology, but trials to pursue these opportunities can run afoul of
many obstacles. For example, David Dilts, Director of Clinical Research of the
Knight Cancer Center Institute, reported last year that opening a phase III
cooperative group trial requires an average of 2.5 years to accommodate 118
decision points, complete more than 769 process steps, and receive approval up
to 36 separate groups and individuals. Whether many of these steps improve
trial quality or patient safety is doubtful. Many approved trials never enroll
a single patient and barely half are ever completed, which is a total waste of
human and financial capital. Small wonder that Garret Fitzgerald, M.D.,
Director of the Institute of Translational Medicine and Therapeutics at the
University of Pennsylvania, has described our current system as "Spreading
dysfunction that undermines progress for the sake of managing risks."
NOW HERE'S THE GOOD
NEWS: IT'S THE DOCTORNAUT ACT. The Doctornaut Act, which would permit
physicians to volunteer for clinical studies with substantially fewer
restraints than non- physicians, would quickly accelerate the number of
potential therapies tested in clinical trials and, pari passu, accelerate
medical discovery. It would, in my opinion, act synergistically with the
general Translational Science movement particularly in Phase I and Phase II
studies.
Frankly speaking, a
number of my colleagues most of whom, might I add, are highly competent
clinical research veterans, have their doubts whether doctornauts would make a
significant contribution to translational discovery research. Generally, their
initial reactions were those of apprehension rather than optimistic enthusiasm
which, in large part, understandably reflect our imbedded cultural fear of
risk. Senator Bill Frist, who had a Discussion Draft of the Doctornaut Act
circulated for comments, and I discussed this legitimate concern. We agreed
that guidelines for doctornauts participation in clinical studies should
balance this concern without unreasonably compromising the necessary risk
involved of doctornaut participation in clinical studies.
Let's now talk about the
role CTSAs and doctornauts could play: There are two types of clinical
research: pioneering and applied. A pioneering clinical study leads to an
important medical discovery such as the H. pylori study by the doctornaut, Dr.
Barry Marshall. This type of discovery occurs outside the "system"
and comes out of the blue. After the discovery phase then applied clinical
research follows in a larger population to better characterize the efficacy and
safety of the discovery. With respect to the clinical investigator, I do not
consider the first clinical study of a pharmaceutical company discovered
molecule, even if it is a medical breakthrough, as pioneering. It is applied. I
also do not consider a large clinical trial to determine whether statins or
beta- blockers reduce the incidence of myocardial infarction or stroke as
pioneering. It is applied. In fact, the vast majority of clinical studies are
not pioneering from the point of view of the clinical researcher. The idea
isn't his or hers but put on the clinical research plate by a third party. Our system
does not encourage clinical initiative; on the contrary, it powerfully
discourages clinical researchers from even daring to think about their own
innovative ideas. It's just too hard to get the job done. The mere existence of
the Translational Science movement confirms this reality. This state of affairs
must be remedied by our leaders who are concerned about "Cure" as
well as "Care".
What I'm not clear on is
the breadth of the mission statement of the CTSA endeavor. Is it primarily to
reduce the barriers to clinical studies for promising drugs or devices
discovered by third parties, which is a very welcomed step forward in applied
research in itself, or, does it also encourage clinical researchers to come up
with their own pioneering ideas or by brainstorming with their colleagues?
FIM's principal
objective is to reduce the barriers to Phase I-II studies, the medical
discovery step, for both pioneering and applied research and also to encourage
and expand the former's innovative potential which, given today's expanding
technology, is breathtaking. But there is little recognition of this marvelous
reservoir from any quarter including the medical research community.
Let's take some
theoretical case scenarios of pioneering clinical studies which hopefully will
get the Translational Science leaders thinking more toward how CTSAs can bring
into the research fold our potential medical innovators. What can they do to
pursue their creative ideas?
1. The blood brain barrier exists for a reason
but, because of unknown risks, one must be very careful in any attempt to
"open" it. Selective types of small molecules, fortunately, can pass
across the barrier, opening the door to expand the pool of potential therapies
for CNS diseases and disabilities. In certain instances, however, the oral
administration of small molecules may need help to achieve sufficient CNS
efficacious tissue levels. For quite a while it has been known that both
mannitol and cerebral ischemia do temporarily open the barrier, but clinical
studies to better define this phenomenon are lacking. Let's say that a young
curious clinical investigator believes that properly opening the barrier can
lead to major medical breakthroughs. He then collaborates with his scientific
colleague to design laboratory experiments with a medical device and come up
with a way of combining both experimental procedures to effectively open the
barriers for a brief, controlled period where small molecules can be
administered intravenously to increase tissue levels. Oral administration can
then follow maintaining such levels.
2. A cardiovascular physician, while reducing a
patient's body temperature to 91 degrees after cardiac arrest in order to
preserve his brain function during a clinical study, is reminded by his nurse
that the patient also has early stage pancreatic cancer. An idea spontaneously
jumps to mind. Can the patient's hypothermic state make his tumor or even other
tumors more sensitive to chemotherapeutic agents than at normal body
temperatures? He then wants to know what the next step should be to test his
hypothesis. He discusses the next step with his scientific oncologist colleague
experts, and they conduct several animal studies at the physician's own
expense. Creative minds despise barriers, and he didn't want to wait for the
long period of time it takes to obtain a grant, particularly when it is highly
probable, because of its out-of-the box approach, that the grant request would
be denied. DaVinci simply walked to his canvas with brush in hand with only air
as the barrier to create the Mona Lisa and, similarly, Einstein to the black
board with chalk in hand to divine his Theory of Relativity. And all Marshall
had to do was swig down his H. pylori soup.
3. A busy practicing rheumatologist makes the
diagnosis that his mother has crossed the Rubicon and is on her way to
crippling rheumatoid arthritis. He simply refuses to accept her rendezvous with
pain and loss of mobility which is not a recipe for happiness. He decides to
find an answer and surrenders his practice to another physician. He then
contacts two expert research scientists in the field, and they work together to
come up with a novel treatment approach with FDA approved drugs. They decide to
achieve greater efficacy reaching certain blood levels by periodic intravenous
infusion of two drugs followed by oral administration of three drugs between
the intervals hoping to temporarily halt the process. This regimen is to be
repeated when there are signs of the process acting up. (At this point I'd like
to raise the point of FDA's policy on combination drugs which IRBs tend to
honor for study approval. This issue is addressed on my Commentary entitled,
Medical Versus Scientific Clinical Research: Time for an Immediate Change!
4. A fellow in neurology, while on weekend call
and with some free time in his small quarters, reads in a lay journal that in
Mongolia there is a virtual absence of Alzheimer's disease. The author of the
article observed that Mongolians eat about a pound a day of the cruciferous
vegetable, turnips, usually divided into two meals. He visits the internet
searching for the ingredients of this type of turnip but, alas, the answer was
not to be found in cyberspace. He contacts his nutritionist friend who,
somehow, is able to come up with the list. He is excited about conducting a
nutraceutical clinical study. But the Mongolian turnips are not available in
the U.S. which presents a problem.
Some ways in which
doctornauts could increase the productivity of Translational Research clinical
investigators for early clinical discovery studies, which is the principle
objective of the Doctornaut Act, are as follows:
1. Broad expansion of IND exemptions which can
apply to multiple clinical situations: There already exist IND exemption
regulations but they are narrowly restrictive.
2. Significant increase in off- labeling
studies.
3. More testing of multiple combinations for
diseases and disabilities which FDA NDA policy, with few exceptions,
effectively discourages.
4. Third parties, such as pharmaceutical and
medical device companies, instead of sponsoring studies with one of their
potential discoveries, can sponsor two or more.
5. More studies on the combination of medical
devices and pharmaceuticals.
6. Create more entrepreneurial and charitable
organizations to clinically evaluate both low and high cost potential
therapies.
7. Internationally approved therapies not yet
approved in the U.S. will be tested either alone or in combination with FDA
approved ones.
8. Increase clinical studies on potential orphan
drugs and "orphaned" phases of general disease such as late stage,
drug resistant ovarian cancer.
9. Expand nutraceutical-pharmaceutical
combinations.
10. Bring into the medical discovery potential
the huge creative potential thinking of scientists-physicians to test their
ideas. This is a critical element to maximize discovery productivity and must
be effectively encouraged.
11. Other unforeseen situations that will
eventually unfold as the system evolves.
Who will sponsor these
clinical studies? A healthy Translational Science movement together with an
approved Doctornaut Act will bring about a rapid and substantial increase as
well a transformation of research and development players ranging from
start-ups, charitable institutions such as foundations, traditional
pharmaceutical and device companies and the government. The discovery field
will be highly competitive with substantial funding for clinical studies. As
previously mentioned, a broad variety of unique types of emerging therapies
will not fit into regulatory categories. It is important to note that in our
country, once breakthrough therapies are discovered, it is difficult to
suppress them, and the regulations will necessarily bend. As Santayana noted about
a century ago, America is unique by its preponderance of good will. This
coupled with the forces of the marketplace will form a formidable anti-Luddite
duo.
A justifiable concern is
whether present day physicians, influenced by modern values, would volunteer as
doctornauts. FIM's top priority is an interest in the medical potential of
natural substances that are not clinically exploited largely because of patent
problems.
Some years ago, FIM
funded a physician survey regarding their willingness to be doctornauts for
natural substances. The following is a summary:
"A total of 3,100
inquiries were mailed to a cross section of 2,100 male M.D.'s, 500 female
M.D.'s and 500 Doctors of Osteopathy. Age was considered. In addition, a
telephone survey of seven academic institutions was conducted. A total of 10.3
percent of physicians responded. A simple "Yes" or "No" was
required to the following question. 'Would you as a physician patient want the
privilege to volunteer for clinical research of natural substances under the
supervision of a physician- clinical researcher without FDA, institutional or
other restraints?'
PHYSICIAN RESPONSE
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Yes %
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No %
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Male M.D.'s Total
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52.5
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47.5
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Male M.D.'s Under Age
50
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56.6
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4.4
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Male M.D.'s Over Age
50
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50.0
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50.0
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Male D.O.'s
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60.0
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40.0
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Female M.D.'s
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56.3
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43.7
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Academic Institutions
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57.7
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42.3
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But what is surprising
today is that, with few exceptions, almost all of my current physician
colleagues doubt whether modern physicians would volunteer to be doctornauts,
even for non-risky clinical studies, without FDA supervision. They may be right
but if a survey were conducted asking questions such as, "If you are still
rational on your way to inevitable mind -destroying Alzheimer's, or in the late
stages of cardiomyopathy with a few years to live, or your cancer is out of
control resistant to chemotherapy and you have a certain rendezvous with death
within in a year, or two or if your arthritis is becoming so crippling that you
can't even embrace your beloved wife, would you volunteer to be a
doctornaut?" Speaking to a number of physicians who have or may in the
future have serious diseases I have found that, with few exceptions, they
agreed to have the "right" to be a doctornaut. But this is only an
impression and not solid survey data so let's look at it another way: There are
about 700,000 physicians in our country. If only 10%, an extremely conservative
figure, of our current physician population agrees to be doctornauts, then
there will be 70,000 doctornauts, an impressive healthy number, to test many
applied and pioneering early clinical discovery studies.
In conclusion, my hat is
off to those who conceived of and got the ball rolling on the essential
importance of clinical research but let there be no doubt that the obstinate
barrier "system" is still intact and even growing which will
effectively frustrate the potential of the Translational Research movement.
And, as is frequently the case, the patient pays the price.
The Doctornaut Act is a natural partner to the
movement. To those of you in doubt consider Pascal's Wager regarding the need
to believe in the existence of God. "There is little to lose and much to
gain."
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