Research ethics. Rethinking research ethics: the case of postmarketing trials

Considering challenges for the new Alzheimer's drugs: Clinical, population, and health system perspectives

Recent approvals of amyloid immunotherapy drugs for early Alzheimer's disease (AD) have been highly controversial. In this piece, we consider challenges from the clinical, population health, and health systems perspectives to the role that the new AD drugs might be expected to play, now and in the future, in alleviating the morbidity caused by AD in the population. Clinically, short-term effects are small, adverse events are frequent, treatment regimens are burdensome, and, crucially, long-term effects are unknown. At a population level, there is always likely to be a trade-off between breadth of access and magnitude of benefit for any given individual. At a health system level, roll out of treatment even for only narrowly-defined patient groups will involve considerable resources to identify and treat eligible patients, with profound opportunity costs. Our considered view on current evidence is that there are challenges from each perspective to imagining a foreseeable future in which amyloid immunotherapy significantly alleviates AD morbidity at scale. HIGHLIGHTS: Recent approvals of Alzheimer's drugs have met with excitement but also controversy. Trial effects are small, adverse effects concerning, and long-term effects unknown. Results from trial cohorts may not generalize to broader, more complex patients. Significant resource requirements of eligibility assessment and drug administration. Use in "presymptomatic" populations is not supported by current evidence.

The Social Value Misconception in Clinical Research

Clinical researchers should help respect the autonomy and promote the well-being of prospective study participants by helping them make voluntary, informed decisions about enrollment. However, participants often exhibit poor understanding of important information about clinical research. Bioethicists have given special attention to "misconceptions" about clinical research that can compromise participants' decision-making, most notably the "therapeutic misconception." These misconceptions typically involve false beliefs about a study's purpose, or risks or potential benefits for participants. In this article, we describe a misconception involving false beliefs about a study's potential benefits for non-participants, or its expected social value. This social value misconception can compromise altruistically motivated participants' decision-making, potentially threatening their autonomy and well-being. We show how the social value misconception raises ethical concerns for inherently low-value research, hyped research, and even ordinary research, and advocate for empirical and normative work to help understand and counteract this misconception's potential negative impacts on participants.

Impact of physicians' participation in non-interventional post-marketing studies on their prescription habits: A retrospective 2-armed cohort study in Germany

BACKGROUND

Non-interventional post-marketing studies (NIPMSs) sponsored by pharmaceutical companies are controversial because, while they are theoretically useful instruments for pharmacovigilance, some authors have hypothesized that they are merely marketing instruments used to influence physicians' prescription behavior. So far, it has not been shown, to our knowledge, whether NIPMSs actually do have an influence on prescription behavior. The objective of this study was therefore to investigate whether physicians' participation in NIPMSs initiated by pharmaceutical companies has an impact on their prescription behavior. In addition, we wanted to analyze whether specific characteristics of NIPMSs have a differing impact on prescription behavior.

METHODS AND FINDINGS

In a retrospective 2-armed cohort study, the prescription behavior of 6,996 German physicians, of which 2,354 had participated in at least 1 of 24 NIPMSs and 4,642 were controls, was analyzed. Data were acquired between 6 October 2016 and 8 June 2018. Controls were matched by overall prescription volume and number of prescriptions of the drug studied in the NIPMS in the year prior to the NIPMS. Primary outcome was the relative rate of prescriptions of the drug studied in the NIPMS by participating physicians compared to controls during the NIPMS and the following year. Secondary outcomes were the proportion of prescriptions of the studied drug compared to alternative drugs used for the same indication, the revenue generated by these prescriptions, and the association between the marketing characteristics of the NIPMS and prescription habits. Of the 24 NIPMSs, the 2 largest drug groups studied were antineoplastic and immunomodulatory agents (7/24, 29.2%) and agents for the nervous system (4/24, 16.7%). Physicians participating in an NIPMS prescribed more of the studied drug during and in the year after the NIPMS, at a relative rate of 1.08 (95% CI 1.07-1.10; p < 0.001) and 1.07 (95% CI 1.05-1.09); p < 0.001), respectively. Participating physicians were more likely than controls to prescribe one of the studied drugs rather than alternative drugs used for the same indication (odds ratio 1.04; 95% CI 1.03-1.05). None of the marketing characteristics studied were significantly associated with prescription practices. The main limitation was the difficulty in controlling for confounders due to privacy laws, with a resulting lack of information regarding the included physicians, which was mainly addressed by the matching process.

CONCLUSIONS

Physicians participating in NIPMSs prescribe more of the investigated drug than matching controls. This result calls the alleged non-interventional character of NIPMSs into question and should lead to stricter regulation of NIPMSs.

The Social Value Requirement in Research: From the Transactional to the Basic Structure Model of Stakeholder Obligations

The history of research ethics includes ethical norms that do not neatly fit into a rubric of "human subjects protections" but that are nevertheless seen as fundamental ethical dictates. Among these norms is the so-called social value requirement for clinical research. Recently, however, the ethical foundation for the social value requirement has come under criticism. I seek to clarify the terms of this foundational debate. I contend that much of this discussion-both critiques of the social value requirement as well as recent defenses-is predicated on a framework of research ethics that I refer to as the "transactional model of stakeholder obligations." I argue that this model does not fully capture the ethical considerations that ought to inform the design and conduct of clinical research, and I introduce and defend an alternative framework that I call the "basic structure model of stakeholder obligations." The basic structure model is grounded in a claim that clinical research plays a direct role in establishing the justice or injustice of our social organization and should therefore be governed more explicitly by justice-based considerations. As such, the model explicitly accounts for the fundamentally social nature of the research enterprise itself. In addition to defending the basic structure model, I show how it provides a more stable foundation for the social value requirement, and I consider some worries about whether the model may be too demanding in practice.

Difficulties with Applying a Strong Social Value Requirement to Clinical Research

In an insightful article published in this issue of the Hastings Center Report, Danielle Wenner criticizes what she describes as transactional approaches to the social value requirement in clinical research and defends a "basic structure approach." Transactional approaches understand social value obligations as arising from transactions (or relationships) between research subjects, investigators, sponsors, and other parties. The basic structure approach, by contrast, understands social value obligations as stemming from the demands of Rawlsian social justice. According to Wenner, "The primary justification for the social value requirement lies not in the ethics of free and fair transactions but rather in the goals of the clinical research enterprise and the nature of its impacts on society. The requirement is justified because it ensures that biomedical progress occurs in a manner constrained by considerations of justice." In this commentary, I will not critique the basic structure approach per se but will raise some concerns that arise when oversight committees, such as institutional reviews boards, attempt to apply it to proposed studies involving human subjects.

Post-marketing studies of pharmaceutical opioid abuse-deterrent formulations: a framework for research design and reporting

BACKGROUND AND AIMS

Opioid formulations with properties to deter abuse (abuse-deterrent formulations; ADFs) have been developed as one response to the prescription opioid 'epidemic'. As for all medicines, ADFs undergo evaluation of safety and efficacy prior to registration for marketing. However, reduced extra-medical use (the primary intended outcome of ADFs and reason for their introduction) can only be established in post-marketing observational studies, comparing them to opioid formulations without abuse-deterrent properties. This has implications for various features of study design and analysis. We discuss proposals for the design, conduct, governance and reporting of post-marketing studies on the effectiveness of pharmaceutical and opioid ADFs.

METHODS

A review of current guidance documents, public work-shops and forums and our own experience with post-marketing studies of ADFs.

RESULTS AND CONCLUSIONS

Research questions for post-marketing studies on ADFs of opioids should reasonably be framed around detecting any probable intended or unintended clinical and/or meaningful changes in specific aspects of extra-medical use (e.g. injection use) and harms. Outcomes reported by prevalence and frequency of occurrence and disaggregated by specific product and route of administration can illustrate the magnitude of ADF impact. We argue that a multi-faceted approach is required, using data from both general population and sentinel high-risk cohorts and from primary and secondary data sources. The comparator (historical non-ADF formulation of that opioid, equivalent current generic or similar opioid product), duration of monitoring and analytical approach require justification and should be sufficient to add weight to conclusions of causality. To maximize transparency, we recommend explicit declarations of funding and conflict of interest, establishment of an advisory committee, publication of study protocol and access to study results.

Examining the Social Benefits Principle in Research with Human Participants

The idea that research with human participants should benefit society has become firmly entrenched in various regulations, policies, and guidelines, but there has been little in-depth analysis of this ethical principle in the bioethics literature. In this paper, I distinguish between strong and weak versions and the social benefits principle and examine six arguments for it. I argue that while it is always ethically desirable for research with human subjects to offer important benefits to society (or the public), the reasonable expectation of substantial public benefit should be a necessary condition for regarding research as ethical only when (a) it imposes more than minimal risks on non-consenting subjects; or (b) it is supported by public resources.

Postmarketing studies for novel drugs approved by both the FDA and EMA between 2005 and 2010: a cross-sectional study

OBJECTIVES

To characterise postmarketing studies for drugs that were newly approved by the US Food and Drug Administration and the European Medicines Agency.

DESIGN AND SETTING

Cross-sectional analysis of postmarketing studies registered in ClinicalTrials.gov until September 2014 for all novel drugs approved by both regulators between 2005 and 2010. Regulatory documents from both agencies were used.

PRIMARY AND SECONDARY OUTCOME MEASURES

All identified postmarketing studies were classified according to planned enrolment, funding, status and geographical location, and we determined whether studies studied the originally approved indication.

RESULTS

Overall, 69 novel drugs approved between 2005 and 2010 were eligible for inclusion. A total of 6679 relevant postmarketing studies were identified; 5972 were interventional (89.4%). The median number of studies per drug was 55 (IQR 33-119) and median number of patients to be enrolled per study was 60 (IQR 28-183). Industry was the primary sponsor of 2713 studies (40.6%) and was a primary or secondary sponsor in 4176 studies (62.5%). In all, 2901 studies (43.4%) were completed, 487 (7.3%) terminated, 1013 (15.2%) active yet not recruiting, 1895 (28.4%) recruiting and 319 (4.8%) not yet recruiting. A total of 80% of studies were conducted in only one country and 84.4% took place in Europe and/or North America; 2441 (36.5%) studied another indication than the originally approved indication. Studies designed in the originally approved indication were found to be more industry-sponsored than others 68.7%vs53.7%; P<0.0001.

CONCLUSIONS

Postmarketing pharmaceutical research was highly variable and predominantly located in North America and Europe. Postmarketing studies were frequently designed to study indications other than the originally approved one. Although some findings were reassuring, others question the lack of coordination of postmarketing research.

Post-marketing research and its outcome for novel anticancer agents approved by both the FDA and EMA between 2005 and 2010: A cross-sectional study

Post-marketing research in oncology has rarely been described. We aimed to characterize post-marketing trials for a consistent set of anticancer agents over a long period. We performed a cross-sectional analysis of post-marketing trials registered at ClinicalTrials.gov through September 2014 for novel anticancer agents approved by both the US Food and Drug Administration and the European Medicines Agency between 2005 and 2010. All relevant post-marketing trials were classified according to indication, primary outcome, starting date, sponsors, and planned enrollment. Supplemental indications were retrieved from regulatory documents and publication rate was assessed by two different methods. Ten novel anticancer agents were eligible: five were indicated for hematologic malignancies and the remaining five for solid cancers (three for kidney cancer). We identified 2,345 post-marketing trials; 1,362 (58.1%) targeted an indication other than the originally approved one. We observed extreme variations among drugs in both number of post-marketing trials (range 8-530) and overall population to be enrolled per trial (1-8,381). Post-marketing trials assessed almost all types of cancers, the three most frequently studied cancers being leukemia, kidney cancer and myeloma. In all, 6.6% of post-marketing trials had a clinical endpoint as a primary outcome, and 35.9% and 54.1% had a safety or surrogate endpoint, respectively, as a primary outcome. Nine drugs obtained approval for supplemental indications. The publication rate at 10 years was 12.3 to 26.1% depending on the analysis method. In conclusion, we found that post-marketing research in oncology is highly heterogeneous and the publication rate of launched trials is low.

Contribution of industry funded post-marketing studies to drug safety: survey of notifications submitted to regulatory agencies

OBJECTIVES

 To investigate the practice of post-marketing studies in Germany during a three year period and to evaluate whether these trials meet the aims specified in the German Medicinal Products Act.

DESIGN

 Survey of notifications submitted to German regulatory agencies before post-marketing studies were carried out, 2008-10.

SETTING

 Notifications obtained through freedom of information requests to the three authorities responsible for registering post-marketing studies in Germany.

MAIN OUTCOME MEASURES

 Descriptive statistics of post-marketing studies, including the products under study, intended number of patients, intended number of participating physicians, proposed remunerations, study plan and protocol, and availability of associated scientific publications and reports on adverse drug reactions.

RESULTS

 Information was obtained from 558 studies, with a median of 600 (mean 2331, range 2-75 000) patients and 63 (270, 0-7000) participating physicians per study. The median remuneration to physicians per patient was €200 (€441, €0-€7280) (£170, £0-£6200; $215, $0-$7820), with a total remuneration cost of more than €217m for 558 studies registered over the three year period. The median remuneration per participating physician per study was €2000 (mean €19 424), ranging from €0 to €2 080 000. There was a broad range of drugs and non-drug products, of which only a third represented recently approved drugs. In many notifications, data, information, and results were, by contract, strictly confidential and the sole property of the respective sponsor. No single adverse drug reaction report could be identified from any of the 558 post-marketing studies. Less than 1% of studies could be verified as published in scientific journals.

CONCLUSIONS

 Post-marketing studies are not improving drug safety surveillance. Sample sizes are generally too small to allow the detection of rare adverse drug reactions, and many participating physicians are strictly obliged to maintain confidentiality towards the sponsor. High remuneration and strict confidentiality clauses in these studies could influence the physicians' reporting behaviours of adverse drug reactions.

An Argument for Fewer Clinical Trials

The volume of clinical research is increasing exponentially-far beyond our ability to process and absorb the results. Given this situation, it may be beneficial to consider reducing the flow at its source. In what follows, I will motivate and critically evaluate the following proposal: researchers should conduct fewer clinical trials. More specifically, I c onsider whether researchers should be permitted to conduct only clinical research of very high quality and, in turn, whether research ethics committees (RECs) should prohibit all other, lower-quality research, even when it might appear to meet some minimal ethical standard. Following a close analysis of the social-value requirement of ethical clinical research, I argue that this proposal is defensible. The problem identified in this paper has two parts, quantity and quality, and some clarification is needed about the latter because "quality" is a highly contested term in the medical literature. When some scholars advocate for high-quality trials, they mean large-scale, simple, explanatory randomized controlled trials. Others, including myself, have defended a different characterization of high-quality research that tends more toward pragmatic trial design and the use of methods other than RCTs. Pragmatic trials aim to provide evidence that directly supports clinical decision-making in "usual" care settings. Unlike explanatory trials, which aim to abstract away from particular settings and patients, in the hopes of creating ideal conditions for the success of an intervention, pragmatic trials deliberately pursue knowledge of high applicability, through the use of representative subjects, clinically important questions, flexible treatment protocols, patient-oriented outcome measures, and so on. I see applicability as a marker of high-quality research. The context in which research is meant to be applied should be the context in which new interventions are evaluated.

Assessing risk/benefit for trials using preclinical evidence: a proposal

Moral evaluation of risk/benefit in early phase studies requires assessing the clinical promise of a candidate intervention using preclinical evidence. Yet, there is little to guide ethics committees, investigators, sponsors or other stakeholders morally charged with making these assessments ('evaluators'). In what follows, we draw on published guidelines for preclinical study design to develop a structured process for assessing the clinical promise of new interventions. In the first step, evaluators gather all relevant preclinical studies, assess the magnitude of treatment effects and determine clinical promise in light of various threats to valid clinical inference. In the second step, evaluators adjust the assessments of clinical promise from preclinical studies by examining how other agents in the same reference class-and supported by similar evidence-have fared in clinical development. Assessments of clinical promise can then be fed into the moral evaluation of risk and benefit in early phase trials. Though our approach has limitations, it offers a systematic and transparent method for assessing risk/benefit in early phase trials of novel interventions.

Ethics, error, and initial trials of efficacy

Clinical trial reforms aimed at boosting phase 2 positive predictivity may involve ethical and social trade-offs.

Legal Requirements, Definitions, and Standards for Non-interventional Drug Studies: A Global Picture of Variability-Results and Conclusions From a Single-Institution Survey

Non-interventional studies (NIS) have become increasingly important in the continuous benefit-risk assessment of medicines. However, the diversity in study designs and in requirements necessitates a careful planning of NIS. In view of a changing regulatory environment, a company-internal online survey was initiated to gather information on existing standards, definitions, and requirements for NIS and to draw advice for the future conduct of multinational NIS. Answers from 45 countries worldwide depicted a global picture of variability in terms of legal and regulatory requirements for NIS. Definitions and terminology are lacking harmonization, and different good practice standards are concurrently in use. Variations in terms of applicable standards and requirements were observed within most geographic regions. The methodological variety in terms of study designs and the divergent perspectives on NIS constitute communicative barriers. Because of the absence of one worldwide applicable good practice standard, differences in semantics and regulatory systems contribute to system disparities.

Studying Cyborgs: Re-Examining Internet Studies as Human Subjects Research

Virtual communities and social networks assume and consume more aspects of people's lives. In these evolving social spaces, the boundaries between actual and virtual reality, between living individuals and their virtual bodies, and between private and public domains are becoming ever more blurred. As a result, users and their presentations of self, as expressed through virtual bodies, are increasingly entangled. Consequently, more and more Internet users are cyborgs. For this reason, the ethical guidelines necessary for Internet research need to be revisited. We contend that the IS community has paid insufficient attention to the ethics of Internet research. To this end, we develop an understanding of issues related to online human subjects research by distinguishing between a disembodied and an entangled view of the Internet. We outline a framework to guide investigators and research ethics committees in answering a key question in the age of cyborgism: When does a proposed Internet study deal with human subjects as opposed to digital material?

Research ethics. Aligning regulations and ethics in human research

New U.S. rules should ensure assessment of subjects' understanding, compensation for injury, and standards of study quality.

A non-paternalistic model of research ethics and oversight: assessing the benefits of prospective review

This paper offers a non-paternalistic justification for prospective research review as providing a credible social assurance that the institutions of scientific advancement respect and affirm the moral equality of all community members and as creating a "market" in which stakeholders working to advance diverse ends also advance the common good.