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Financial Conflicts of Interest: The Limits of Disclosure and Management Peter Lurie, MD, MPH Public Citizen’s Health Research Group Presented at: Conflicts of Interest, Privacy/Confidentiality, and Tissue Repositories: Protections, Policies, and Practical Strategies PRIM&R Conference Boston, Massachusetts, May 3, 2004 Conflicts of Interest Affect … • • • • • • Study design Research ethics Publication (or not) Data presentation Scientific debates Regulatory Review Placebo-controlled Trials of Acyclovir to Suppress Recurrent Herpes Genitalis Percent Recurrence-free 100 90 Average acyclovir response in 1st 2 studies 80 70 60 Placebo 50 Acyclovir 40 30 Average placebo response in 1st 2 studies 20 10 0 0 1 2 1984 3 4 5 1985 6 7 8 1986 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1988 89,91,92,94 Study Number and Year Published 1997 1998 A Drug Company-sponsored Unethical Clinical Trial in Developing Countries • • • • Discovery Laboratories, Doylestown, PA Synthetic surfactant (Surfaxin) 4 surfactants on the market (1st in 1990) Associated with 34% relative reduction in neonatal mortality (Cochrane metaanalysis) “Without doubt the most thoroughly studied new therapy in neonatal care” (NEJM review) A Drug Company-sponsored Unethical Clinical Trial in Developing Countries • Title of internal FDA meeting: “Use of placebo-controls in life threatening diseases: is the developing world the answer?” • Location: Mexico, Peru, Bolivia, Ecuador • Design: Surfaxin vs. placebo (vs. approved surfactant) 42 Randomized Trials of Natural and Synthetic Surfactant in the Treatment of Neonatal Respiratory Distress Syndrome 9 Number of trials 8 7 6 5 No Placebo Placebo 4 3 2 1 0 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 Year of Publication A Drug Company-sponsored Unethical Clinical Trial in Developing Countries • February 2001: Public Citizen writes to HHS Secretary Tommy Thompson • March 2001: Bolivian health ministry says the study is “totally prohibited” for legal, ethical and social reasons • April 2001: Discovery announces study changed to compare to known effective surfactant April 15, 1997 Content of Medical School-Industry Multicenter Trial Contracts Median Percentage of Contracts 12% 10% 10% 8% 6% 4% 2% 1% 0% 0% Data collection and monitoring Source: NEJM 2002;3471335-41 All authors have access to data Trial results must be published Depiction of Alosetron (Lotronex) Efficacy in Lancet Source: Lancet 2000;355:1035-40 Public Citizen Depiction of Alosetron (Lotronex) Efficacy 4.0 Mean Pain/Discomfort Score 3.5 3.0 2.5 1.97 Placebo Alosetron 2.0 1.85 1.40 1.5 1.24 1.24 1.33 1.0 1.07 1.00 0.5 0.0 0 1 2 Month of Treatment Source: Lancet 2000;356:2009 3 The Debate Over the Safety of Calcium Channel Blockers Financial Relationship with Sponsors 100% 90% 96% 80% 70% 60% 60% 50% 40% 37% 30% 20% 10% 0% Support Source: NEJM 1998;338:101-6 Neutral Critical FDA AC Member Recusals in Drug Procuct-Specific Meetings • 18 recusals (1.5%) in 81 meetings in study period • Through January 2002: 7 recusals; 0% reason given • After January 2002: 11 recusals; 36% reason given • Examples of recusals: Research and consulting on topic of scientific meeting Principal investigator of related clinical trial Research on competing products and consulting on product at issue Invention of competing product Disclosed Conflict Rates for AC Members and Consultants* Through January 2002 After January 2002 Total Per meeting COI rate** 92% 87% 89% Per person-meeting COI rate*** 24% 20% 22% *Includes recusals **Percentage of 81 meetings where at least 1 COI was disclosed ***Percentage of 1220 AC member or consultant person-meetings disclosing a COI Value of Particular Conflict Types for AC Members and Consultants, January 1, 2001-June 30, 2003* Consulting arrangements (n=114) 18% Investments (n=78) 10% 4% 22% No value given 33% $0-5,000 $5,001-25,000 $25,001-50,000 $50,001-100,000 $0-10,000 $10,001-50,000 73% 41% *Excludes 99 conflicts through January 2002 without any conflict-type details Conclusions • Conflict of interest permeates the entire research process • Financial conflict of interest, in particular, has an adverse impact upon the public face of science • Some conflicts are so worrisome that disclosure and “management” will not suffice