By Erica Verrillo
Day Two (April 26, 2013) of the FDA’s Drug development workshop for ME/CFS focused on clinical trial design, outcome measures, regulatory issues and possible pathways to expedite drug development for CFS and ME. The purpose was not to discuss individual products, but to discuss how to get effective drugs through the pipeline quickly.
Note: For additional coverage of the second day read Cort Johnson’s article on HealthRising.
You can read a summary of the presentations made on April 25, the first day of the workshop, HERE.
You can read a transcript of the April 26th sessions HERE.
Welcome by Dr. Michele: Objectives of Day 2: To examine common issues in drug development, and consider scientific and regulatory tools that might be brought to bear to move drug development forward in this area.(15:29) (VIDEO)
Panel 1: Drug Development, Innovation, Expedited Pathways, Regulatory Considerations (96:21) (VIDEO)
Panelists: Dr. Bernard Munos, founder of InnoThink Center for Research and Biomedical Innovation, Dr. Suzanne Vernon, scientific director of the CFIDS Association of America, Melissa Robb, associate director for Regulatory Affairs at the Office of Medical Policy.
First speaker: Dr. Bernard Munos [timestamp 4:59 – 31:26]
Dr. Bernard Munos spoke on “Drug Innovation and Derisking Drug Discovery.” [Note: “Derisking” in this context does not mean lowering the risk to patients taking drugs, but making drug discovery attractive to pharmaceutical companies.] The question Munos asked was, “How do we get innovation in CFS and why don’t we have innovation like we do in HIV and a number of other fields.”
Summary: The traditional model for drug innovation is not suited to a complex illness like CFS. Drug hunters generally look for established illness that new products can be developed for. There is a dearth of discoveries that could be turned into novel drugs for CFS. There is also lack of infrastructure, namely, data and tools. The disease shares symptoms with many other illnesses, therefore treatments address symptoms, not the underlying cause. The lack of a single etiology, and the shared symptoms makes for an ill-defined situation, which makes it hard for regulators to do their job. What is needed is an innovation supply chain. Patients have to make it worthwhile for scientists to investigate the illness.
How do we make it worthwhile?
1) We need data. There cannot be science without data. Data drives innovation. The data challenge in CFS/ME is magnified by its heterogeneity, which means we need more patient data. We also need international data to understand how CFS/ME affects people who come from different backgrounds. The natural history of the disease needs to be better documented, and genomic data must also be collected. Patients are the only ones who are qualified to speak on this.
2) We also need tools – tissue banks, animal models, biomarkers, and networking tools. The ability of scientists to “cross pollinate” across international boundaries is essential. Although patents are competitive, data are not, which means we should collaborate on the science. If you create the tools, the scientists will come.
3) Partners are essential for drug innovation. Partners include established scientific leaders, physicians, and young investigators. CFS/ME is a virgin field, which means it is important to attract young, enthusiastic researchers. Because they are on the front line, physicians should also be involved. Historically, physicians have been the most powerful source of innovation, because they know about the illness, and they customize and experiment with drugs that are used for other conditions.
4) Passion raises quality and success. Parents who have children who are ill, for example, agitate and become specialists in the disease. Scientists are moved by the passion of these parents, who are driven to find cures. Passion also lowers costs and raises the possibility of success. It’s hard to say “no” to people who are driven to a level of passion, and for whom failure is not an option.
5) Money is not as much of an issue as people think. You can run a very audacious program on a shoestring. Waste is prevalent in this industry – but it’s getting cheaper to gather data. The CFS/ME community is larger than other communities, so the ability to raise money is already there. Gathering data can be done cheaply, if it is taken up by the patient community.
When you have all five of those ingredients, you get to the point where you can generate intellectual property. At that point you can get companies interested in developing new drugs for CFS/ME. Munos’ message was: “Frankly, for industry, CFS hardly exists … but if you build it, they will come.”
Second speaker: Dr. Suzanne Vernon [timestamp 31:36 – 60:42]
Dr. Suzanne Vernon, scientific director of the CFIDS Association of America (CAA), gave a presentation entitled, “Knowledge and Intuition to Reposition Drugs for CFS.” The subject of the talk was drug repurposing, or the use of existing drugs to treat CFS/ME. Dr. Vernon also spoke about “derisking science” i.e. making the research on CFS/ME attractive for industry, and for pharma.
Summary: The CFIDS Association of America is currently finding ways to make information that comes from the bedside available, and attractive, to the pharmaceutical industry. The Association is gathering data through their Solve CFS BioBank, which includes a repository and registry. There is already a tremendous amount of information about CFS. There are over 6,000 abstracts and articles in PubMed about CFS/ME. Dr. Vernon stressed that we do, in fact, understand the pathophysiology of the illness. We simply lack validated markers for replication and we have no standardized guidelines or a regulatory framework. Because of that, our doctors are still treating CFS/ME symptomatically, which has both advantages and disadvantages. The advantage of symptomatic treatment is that because its symptoms are so numerous, CFS/ME is ideal for drug repurposing.
The CFIDS Association has partnered with BioVista to mine information in PubMed and other databases through a search engine called a Clinical Outcomes Search Space (COSS). COSS searched through 20 million abstracts on PubMed, combined with a “whole bunch” of databases, which they then queried to extract information about CFS/ME. This technique can be used not only to identify drugs, but to identify biomarkers. The outcome is an extensive amount of data that people can then hone down to a plausible list that correlates symptoms and markers with medications.
[Dr. Vernon showed a number of slides which, unfortunately, were almost impossible to read.]
The most prominent association that COSS found was with serotonin, which was highly correlated with symptoms. From this data, Dr. Vernon drew the conclusion that some of the drugs [antidepressants] being used in this population may be contributing to symptoms. A second database measuring adverse events also indicated that the frequency of exhaustion was very high with antidepressants. These findings validated the central fatigue hypothesis of CFS, i.e. CFS fatigue is generated in the central nervous system.
Using the COSS, two drugs were identified which, in combination, might address sleep, pain and fatigue. [Regrettably, Dr. Vernon could not tell us which drugs those were, as they are currently under investigation.] Vitamin B12 injections were identified as effective in treating brain fog.
Dr. Vernon went on to talk about the results of the patient survey conducted by the CAA. Responses from the association’s survey showed symptoms clusters that could group patients into phenotypes. She noted that the pain subgroup was very distinct from the others. In terms of treatment, most patients used supplements and complementary strategies as well as anti-inflammatory drugs. The lesson learned from the survey is that patients have a lot of information that cannot not be discovered except by asking them directly.
Dr. Vernon finished her presentation with three proposed steps to help further research: taking the next steps in drug repurposing by expanding the Biobank, optimizing clinical information from physicians, and operationalizing data collection from patients.
Third speaker: Melissa Robb [timestamp 61:16 – 78:23]
Melissa Robb, Associate Director for Regulatory Affairs at the Office of Medical Policy at FDA gave a talk entitled “Drug Development and Review: FDA’s expedited Programs for Serious Conditions.”
Ms. Robb spoke about the history of the FDA’s expedited programs for serious conditions and explained the FDA’s rules and regulations that pertain to this area. She defined two common terms that are common in expedited programs:
- Serious conditions are associated with morbidity that has a substantial impact on day-to-day activity, including life-threatening conditions.
- Areas of unmet medical need are illnesses that have no approved therapies, but also those conditions in which new drugs may show an advantage over available therapy, if one exists.
There are four expedited drug approval programs:
1) Fast track designation – is determined by whether there is data (clinical and nonclinical) to address an unmet need. It allows sponsors to complete portions of applications, rather than submit a finished package. This is called a “rolling review.” The goal is to speed up the development process.
2) Breakthrough therapy designation – addresses the development of drugs for serious conditions. It covers all aspects of development, review and production. Like fast track, this helps developers.
3) Accelerated approval – uses an endpoint that is clinical, and can be measured earlier. Allows FDA to take into account a lack of availability of appropriate therapies. The endpoint is likely to show a benefit, but there is safety and efficacy to consider as well. These clinical endpoints shorten the approval process. The accelerated approval program has been used extensively with cancer and HIV. Post-market validation is required.
4) Priority Review – a program that is intended to shorten review time (by the FDA). Typically the review time is 10 months. For a priority review, the period is 6 months. The drugs that qualify must have the potential to provide a significant improvement in safety or effectiveness.
Go here for information about the four programs.
Question and Answer Period: [timestamp 81:35]
Question: From Dr. Vernon to Bernard Munos: As far as drug development in concerned, what kind of time frame would you put us on?
Answer: Under normal circumstances, it could take 10 to 15 years to get a new drug on the market. But this period can be shortened by half, if patients get involved. Dr. Munos stressed the point that with a million people with CFS, patient involvement is key, and could contribute significantly to getting new treatments developed and approved. We need more networking between physicians, scientists and patients to accomplish this goal. There must be a rich network of ideas and hypothesis for physicians to draw upon.
Question: Dr. Vernon, you searched only for fatigue and exhaustion in adverse event database, so it’s not surprising that you came up with neurotransmitters. Have you looked at multiple infections, orthostatic intolerance, and abnormal immune functions? It seems to me you are biasing your results by your choice of search terms.
Answer: [Dr. Vernon could not answer the question, facing the panel instead and asking, “Can you guys help me out on that?”] Yes, there probably is some bias. But the result was clear that fatigue was associated with the mechanism of these drugs.
Question: Dr. Vernon, are the results of the survey available online?
Answer: Yes. Well, not yet. We are still collecting data.
Question: Dr. Vernon, it is known that the “CFS” literature includes studies based on overall broad and non-specific definitions. As a result, these studies don’t have the disease that patients described yesterday. Did you eliminate those studies from the Biovista analysis, and, if not, how has that influenced your results?
Answer: The 20 million PubMed articles were not culled. The search was based on terms used to describe CFS. It’s an agnostic approach. We tried to be as inclusive as possible. Dr. Kweder: This is a heterogeneous group.
Question: Ms. Robb, is low-grade fever a surrogate marker?
Answer: [Ms. Robb was not comfortable answering the question.] Dr. Kweder interjected with, “That depends.” What is low-grade fever a surrogate marker for? In AIDS it predicts mortality. But the companies were required to show that low-grade fever actually led to mortality once they were further down the road. The key is that you have to show that the marker is predictive after approval.
II. Panel 2: Symptoms and Treatments: A View from Clinicians and Patients (71:37) (VIDEO)
Moderators: Nancy Klimas, M.D., FACP, FIDSA, Chair, Department of Clinical Immunology, Director, Institute for Neuro-Immune Medicine, Nova Southeastern University and Theresa Michele, M.D., Clinical Team Leader, Division of Pulmonary, Allergy, and Rheumatology Products (DPARP), Office of Drug Evaluation II (ODE II), Office of New Drugs, CDER, FDA
Panelists: Lucinda Bateman, M.D., Fatigue Consultation Clinic, Salt Lake City, Utah, Lisa W. Corbin, M.D., FACP, Associate Professor, Division of General Internal Medicine University of Colorado Denver School of Medicine, Lily Chu, M.D., MSPH, International Association for CFS/ME and Patient, Jose G. Montoya, M.D., FACP, FIDSA, Professor of Medicine, Division of Infectious Diseases and Geographic Medicine Stanford University School of Medicine. Jennifer Spotila, JD, Patient and Christine Williams, MEd, Patient.
Questions: What were your key take-away messages from the discussion yesterday on the most significant symptoms experienced by patients with CFS and ME? Please describe any significant differences in your experience as clinicians and patients compared to yesterday’s discussion. [timestamp 8:44 – 24:00]
Dr. Bateman said that she concurred with what she heard yesterday. She would add the psychological suffering that comes along with the illness. Top of the list are cognitive limitations and fear.
Dr. Lily Chu talked about the results of the survey she conducted. Fatigue, PEM (post-exertional malaise), pain, and cognitive impairments came first. Multiple chemical sensitivities, gastro-intestinal symptoms, and orthostatic intolerance appeared in over 50% of respondents. The impact of the illness was substantial: respondents were more than 95% impaired and 89% needed assistance for daily chores.
Dr. Montoya stated that the two most salient clinical features were cognitive dysfunction and unpredictable crashes. The ability to drive is significantly impaired in his patients. This makes sense, because driving is the perfect example of multi-tasking. When patients get better they start to come to their visits alone. Herpes simplex is a trigger in a cohort of patients. The third thing to consider is that there are several triggers for patients. We should keep in mind how the effect of a drug is undermined when there are several triggers.
Christine Williams, who became ill at the age of 56, brought up the “double whammy.” These are the effects of this illness on an aging population. For her, the flu-like symptoms are the worst, because they make her feel very sick.
Jennie Spotila: We need to remember that the working ill, who struggle to maintain jobs and raise families, are a significant part of the patient community. For her, the words “fatigue” and “tired” are placeholders to avoid the long description of a crash. She stressed the need to include multiple aspects of cognitive function in order to measure improvement in drug trials. Ms. Spotila noted that gut disturbances had not been addressed. She also pointed out that prevalent symptoms, like orthostatic intolerance, can be masked. In addition, many symptoms could be measured and identified, but people are not looking at them. There is a lot of suffering that is going under the radar.
Question 2: Based on your expertise as clinicians and your experience as patients, which symptoms of CFS and ME could be identified as valid, quantifiable and reliable outcome measures or endpoints in clinical trials to evaluate potential drugs to treat CFS and ME? [timestamp 24:01 – 39:10]
Dr. Lily Chu: Any symptom of ME could be used as a valid and quantifiable outcome measure, it depends on which scales you want to use and which drug you want to test. She also mentioned that because the disease is heterogeneous, studying subgroups would yield better results. Her second point is that it is very important to come up with a good outcome measure for post-exertional malaise. Post-exertional malaise (PEM) is not that same as post-exertional fatigue. Malaise can have a flu-like component, and involves collapse and confusion. There is not enough basic research on PEM. The difference between fatigue and fatigability is important, because it not only takes into account the subjective feeling of feeling tired, but puts it in relation to activities. The real test is whether a drug improves function, rather than measuring a subjective state.
Dr. Montoya talked about the importance of separating out symptoms. He mentioned a double-blind study he did in which a smallgroup of patients were given antivirals. Their cognitive symptoms improved before their physical symptoms, but this improvement was only discovered when they compared a subscore on their initial questionnaire. Otherwise, it may have been missed. Separating cognitive fatigue from physical fatigue could be helpful for clinical trials. Because of the fluctuating nature of the disease he recommended using linear regression statistical models in order to measure various points, rather than simply comparing a beginning and endpoint. Type of onset is also extremely important. Do patients have viral onset, abrupt onset? What is the duration of the illness? “It’s very hard to believe that a patient with CFS of two years’ duration would have the same pathogenesis as a patient with 20 years’ duration”.
Dr. Lisa Corbin brought up the point that while it is important to look at function as an endpoint, there may be different parameters for function in the CFS/ME population. For example, being able to read a book for two hours (or at all) will not appear on any functional scale. The way we measure function needs to be more specific for this population. It’s important to follow the symptoms that are most distressing for patients.
Dr. Bateman mentioned that there are already objective measures in place to measure orthostatic intolerance, sleep disorder, as well as other symptoms. One problem in clinical testing is that as a patient’s ability to function increases they do more, which produces symptoms. So, unless patients maintain the same level of activity throughout the trial, measuring symptoms is unreliable.
III. Question 3: What are the key factors you take into account when making decisions to prescribe (as clinicians) or use (as patients) therapies to treat symptoms associated with CFS and ME? [timestamp 40:00 – 56:15]
Dr. Lisa Corbin: The first factor is patient input. I treat the most disabling symptom first. I do treatments one at a time. Start low and go slow.
Dr. Bateman talked about individualizing treatments as well as managing and coping strategies.
Dr. Montoya talked about preventing the wild fluctuations of the illness. He also addressed treating infectious triggers. He does PCR tests for HHV6 and measures viral loads. Those patients are treated separately. Other patients undergo testing to identify other viral triggers, risk factors for Q fever, and other pathogens. But, Dr. Montoya stressed, the pathogens must be correctly identified.
Question 4: If you had a drug to explore what would be your top one or two choices? [56:26 – 58:56]
Dr. Bateman: On top would be antiviral and immune-modulating drugs. Next would be symptom management drugs for pain, stimulants for cognition, and sleep meds and meds for OI (orthostatic intolerance).
Dr. Lily Chu: Same plus Rifaxamin
Dr. Montoya: Antivirals, immune modulators. He believes that the immune response to the infectious agent is what drives CFS/ME symptoms, but for some patients it may be too late.
Jennie Spotila added Rituximab, as well as drugs that can increase VO2 max. These could potentially make a huge difference in the functionality of patients.
Question and Answer Period [timestamp 58: 56]
Question: How do we deal with the fact that so many patients are not located close to clinical trials?
Answer: Dr. Klimas mentioned that there is a spouse CBT protocol that involves long-distance CBT via a video group session. (Dr. Klimas noted that CBT is not a treatment.) Dr. Klimas added that there is a disconnect between 20-year-old guidelines and how doctors actually treat their patients.
Questions about viral makers and immune markers were referred to, but the questions were not read.
Question for Dr. Montoya: “Do you subgroup out to foreign diseases, and what is the prevalence of HSV and CMV in your practice, and do you use cidofovir (Vistide) for HSV positive patients?
Answer: Dr. Montoya: We have a small group of patients with positive test results, but it is hard to come up with treatments for tick-borne illnesses. For herpes simplex we use acyclovir. We reserve cidofovir for patients who are severely ill, because it is very toxic. Doctors need to remember to “do no harm.”
Question: How can we better break down the barriers of data sharing?
Answer: Lily Chu: There are problems with privacy when it comes to freely disseminating medical data from individual patients. Dr. Montoya: Something similar needs to be done as was done for AIDS. Within 15 years they had highly effective treatments. We need a “bailout” for CFS/ME, a huge infusion of money and infrastructure. Dr. Vernon mentioned that CAA requires that anyone they give a grant to must share their data. Dr. Klimas stated that NOVA shares its data with other CFS/ME institutions, and there are other multi-institutional initiatives underway. Dr. Montoya mentioned that Stanford also has a biobank of several hundred CFS/ME patients. There is, in fact, a large amount of data already gathered and accessible for pharmaceutical companies.