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THE ART OF ONCOLOGY: WHEN THE TUMOR IS NOT THE TARGET
From Access to Evidence: An Advocate’s Journey
By Musa Mayer
NINE YEARS ago this spring, I sat in a Long Island
courtroom with the rest of my breast cancer support
group. We had come in solidarity for our friend Pat, whose
insurance company had refused coverage for a second bone
marrow transplant, after the first had failed, on the basis that this
was an experimental treatment.
Experimental? Surely not, I thought. The insurance company
didn’t care about patients; its only concern was the bottom line.
When Pat’s doctor took the witness stand, he offered testimony
that seemed persuasive to me. At the time, I couldn’t have told
you the difference between a phase II study and a phase III
randomized clinical trial. All I knew was that many oncologists
were recommending this promising treatment to their high-risk
and metastatic breast cancer patients.
Pat felt that the transplant was her only hope. It would be cruel to
take away that hope, I thought. Members from the local advocacy
group turned out in force that day. The press was there, working on
yet another story of a young woman fighting for her life.
The judge, a cancer survivor himself, was clearly moved. Pat
got her transplant. Six months later, however, she was dead—not
from her metastatic breast cancer, but from treatment-induced
damage to her bone marrow.
Then, a second friend died following her transplant a few
months after that, and I began to read the research myself, and to
piece together what the studies actually showed—and what they
didn’t show.
Looking back now, I can trace my radicalization as a patient
advocate to the troubling discovery that in the case of high-dose
chemotherapy with bone-marrow or stem-cell transplant inhigh-risk and metastatic breast cancer, the tools of science had
been subverted by the rush to embrace the treatment.
Most
disturbing of all to me was the role that advocates had played in
guaranteeing broad access to an unproven and highly toxic
treatment, effectively sabotaging enrollment in the randomized
trials that would have provided a definitive answer years sooner.
This story may not seem relevant to a discussion of the U.S.
Food and Drug Administration (FDA) and drug development,
because it occurred outside FDA authority, with the use of
already-approved drugs. But I believe it offers a bitter lesson
about what can and does happen when advocacy and medical
practice allow emotion to supplant good science.
What Can Advocates Learn From This?
First, we should learn that new is not necessarily better. New
may be worse than standard treatment, or, as in this case,
equivalent, but more toxic.
We should learn that more is not necessarily better. Sometimes
more of a drug or combination of drugs is just more toxic,
not more effective. This can be the case even when the
theoretical model behind the treatment has both intuitive appeal
and a justifiable scientific rationale.
Hauling out the “big guns”
of bone-marrow transplant for high-risk and metastatic breast
cancer seemed to make sense. It seemed logical to propose that
because these high doses of chemotherapy made tumors shrink
more than moderate doses—the so-called dose-response curve—
patients would do better in the long run. But they did not.
Another lesson is that single-arm phase II studies, no matter
how compelling their results appear, contain potential sources of
bias, particularly what is called selection bias. The women inthese phase II transplant trials who seemed to do so well were
not typical of all women with high-risk or metastatic breast
cancer. Because of its toxicity, only younger, healthier women
who had responded well to chemotherapy were permitted this
treatment.
No wonder their outcomes looked better when compared
with historical controls from other studies of conventional
therapy. The intense diagnostic work-up associated with transplant
trials also led to “stage migration,” in which many patients
were upstaged from stage III to stage IV—creating more
favorable outcomes for both groups.
We should learn that it’s often impossible to enroll patients
onto randomized clinical trials of a popular treatment that is
widely available. Understandably, patients don’t want to take the
chance of not getting a treatment they believe to be better.
We should learn to be realistic, but not cynical, when
assessing motivations.
Doctors don’t always make treatment
recommendations based on conclusive evidence; they are human,
too, and also vulnerable to wishful thinking. So, too, are
researchers, who can also become convinced of the validity of
their findings in advance of proof.
Witnessing the media hype
and public relations that can surround drug development, we
should be looking critically at the financial and professional
interests of all parties involved.
Finally, we should learn that, as advocates, we must use our
influence wisely. We have the power to mobilize media and use
political pressure to ensure that the treatments we want are available.
During the 1990s, laws were passed in a number of states to
force insurance companies to pay for bone marrow transplants.
Without regulation and tight control of access, scenarios like
this might become common, as reports of new treatmentscirculate among desperate patients and their families and are
picked up by the media.
Ultimately, we all lose if we don’t advance well-designed
clinical trials. I believe that what happened with bone marrow
transplant in breast cancer is a prime example of what I call
“access advocacy,” and that this plays an important role in
how advocates interact with the FDA and the drug development
process.
What Do I Mean by “Access Advocacy”?
Access advocates believe that rapid approval of new drugs
is crucial, through fast-tracking, accelerated approvals, personal
influence, political and media pressure, legislation, and
other mechanisms.
A central focus of access advocacy is obtaining early access to
investigational drugs for patients with advanced cancer who
have run out of approved treatment options. This is ordinarily
accomplished either through single patient investigational new
drugs (INDs; often referred to as “compassionate use”) or
through expanded access programs, both of which must be FDA
approved, and made available through the pharmaceutical company.
Issues of inequity and special influence often associated
with single patient INDs are rarely, if ever, addressed.
Based on extremely limited evidence from responses in phase
I trials alone, some access advocates believe that new treatments
in the earliest phases of clinical development will save, or at least
extend, many lives. They appear to hold idealized views of these
drugs, emphasizing positive anecdotes and end-of-life miracles
and downplaying toxicities and drug failures.
These same access advocates believe that, ethically, individual
patient needs outweigh regulatory concerns with safety and
efficacy and that any experimental drug, following a phase I trial,
ought to be made available to cancer patients who have exhaustedother options and are ineligible for clinical trials.
One
recent initiative includes special approval and marketing for this
purpose, in the hope that being able to sell the drug at a profit to
desperate patients would offer an incentive to manufacturers.
This petition and subsequent lawsuit against the FDA have
garnered significant media attention.
Clinical trials are often perceived by access advocates as
representing an unnecessarily complex and drawn-out process,
resulting in the loss of many lives that otherwise could have been
saved or extended if only patients in need were granted access to
drugs under development. Concerns about the effects of early
access on enrollment in phase III trials are often minimized,
despite examples for which early access has clearly compromised
enrollment.
Access advocates may cast themselves in an adversarial role
with the FDA. They often perceive the regulatory process as
bureaucratic and obstructionist and believe strongly that it does
not represent patient interests.
In one memorable example, a Wall Street Journal editorial
about the drug Iressa (AstraZeneca, London, UK) last September
was titled, “FDA to Patients: Drop Dead.”
In Contrast, Let’s Look at What I Call
“Evidence-Based Advocacy.”
The primary goal of evidence-based advocates is to ensure
that good science gets done in the research and development of
new and innovative treatments. They see themselves as partners
with FDA, researchers, and the drug industry, representing
patient perspectives.
Evidence-based advocates believe that all new treatments
must be carefully tested for safety and efficacy before approval.They continually stress the need for patient input at every point
in the process.
Although the speed of drug development is important, evidence-
based advocates believe that evidence should not be
sacrificed for speed. They understand that cutting corners now
can have unforeseen negative consequences later on.
Evidence-based advocates make it their business to understand
enough of the science involved and its increasing complexity
to have a realistic view of both the potentials and the
drawbacks of new treatments.
They understand that economic pressures and realities play a
role in drug development, and they try to be ever-mindful of
influences and biases that may creep in, including their own.
Evidence-based advocates focus on what is likely to benefit all
patients with cancer equitably. Access to quality care for all
patients with cancer is the highest goal. While they applaud
innovations in treatment, they also realize that many lives could
be saved or extended if only all patients had access to the
treatments we already have.
They believe that old paradigms of clinical research must
yield to newer methods. For example, tumor shrinkage after
treatment may not be a meaningful way to measure the results of
a biologic therapy that works to stabilize tumor growth.
Evidence-based advocates are not heartless. They, too, stand
helplessly by as friends and family members exhaust their
treatment options and die of cancer. So they support expanded
access programs for promising drugs before approval, but only if
these programs guarantee fair access and do not interfere with
the completion of randomized clinical trials.
Because of the complexity of manufacturing a drug or the
financial constraints of small companies, however, the amount of
available drug may be quite limited early in development,
making large expanded access trials impossible.
In the Herceptin
(Genentech Inc, South San Francisco, CA) lottery, for example,
thousands of breast cancer patients with refractory metastatic
disease were forced to draw straws each month for a few
treatment slots. In such a case, an evidence-based advocate
might at least raise the question of whether the available drug
might not actually ultimately benefit more patients were it to be
used in a clinical trial—for example, in another cancer.
Evidence-based advocates remain sensitive to the need to
make exceptions in cases wherein single patient INDs may be
warranted—for example, in cancers that are rare or have limited
treatment options and little active research. They support research
that shows the promise of individualizing cancer treatment,
sparing most patients with early cancer the toxicities of
systemic treatment, and targeting those whose cancer is most
likely to recur with more effective therapies.
Finally, evidence-based advocates try to carefully balance the
risks versus the benefits of treatment, realizing that many cancer
drugs carry short and long-term side-effects and that, sometimes,
important toxicities become apparent only after marketing approval.
I began this presentation with the story of high-dose
chemotherapy with bone-marrow or stem-cell transplant in
breast cancer, offered as a cautionary tale of what can happen
when new treatments are put into use without adequate
testing.
Some will recall how that story ended—in scandal,
malpractice, greed, misjudgment, and profound disappointment,
with the profession of medical oncology turning its
back on a treatment it had largely embraced, despite some
suggestions that, in an as yet undetermined subgroup of
patients, this treatment just might be effective.
It’s now
unlikely we’ll ever know the answer to that question.Good evidence of efficacy and safety is always a precious
commodity in drug development, and never more than right now.
In March 2003, I sat as a patient representative when the
Oncologic Drugs Advisory Committee of the FDA met to
consider eight indications for seven cancer drugs granted accelerated
approval, all of which had failed to meet their postmarketing
commitments to demonstrate evidence of clinical benefit
in randomized, controlled trials.
While we considered each
indication individually, some overarching explanations soon
emerged from the discussion. In some cases, medical practice
had changed; in others the pool of prospective trial participants
had become vanishingly small. But repeatedly during the twoday
meeting, it was clear that enrolling patients onto randomized
trials when a drug is available in the marketplace is next to
impossible.
In the case of Iressa, a recent recipient of accelerated approval,
the drug will be available in the US, but the postmarketing
randomized trials will be done abroad (where the drug is not
available) to address the problem of trial enrollment, a “solution”
that makes some advocates uneasy. From the March Oncologic
Drugs Advisory Committee meeting, it was unclear if any drug
granted accelerated approval would be withdrawn by the FDA in
the case of negative trials or unmet research commitments. That
makes us uneasy, too.
Advocates realize full well that we’re at the beginning of a
genomic revolution in cancer treatment. We’ve seen the first of
a new generation of targeted therapies that work, if not for cure,
then for the prolongation of life. Drugs like Herceptin and
Gleevec are leading the way, setting a standard of efficacy that
has so far proved elusive for other new therapies like Iressa, for
which a lack of targeting has resulted in low response rates.
Weknow there will be more effective targeted drugs and that we’ll
discover how to use them alone and in combination to transform
what is now relatively rapidly fatal illness into more chronic
illness and what is now life-threatening into curable. We can
almost taste what is to come.
Yet the explosion of molecular knowledge has inevitably led to
delays, disappointments, and further complexities. All the while, the
media weekly trumpet some new finding that will one day cure
cancer. For patients, families, and advocates, the tiny incremental
steps of drug development seem even more interminably slow when
we sense we are so close to real breakthroughs. It’s agonizing to
think these breakthroughs may not come soon enough for most of
those we love who are gravely ill today.
That sobering reality is painful enough to contemplate. It
will be more painful still if we, as advocates, do not learn
from the mistakes we have made in the past. We have all lost
people we love dearly. I believe we must see beyond our
personal grief and desperation to the greater good, to the
larger vision of compassion that emerges from scientific
clarity and rigor in drug development.
Submitted August 5, 2003; accepted August 18, 2003.
Adapted from a talk given at a plenary panel titled “The Role of the FDA
in the 21st Century: Safety, Science, and Speed” at the National Breast
Cancer Coalition’s Annual Advocacy Training Conference, May 4, 2003.
Author’s disclosures of conflicts of interest are found at the end of this
article.
Address reprint requests to Musa Mayer, 250 West 82nd St, Apt 42, New
York, NY 10024; e-mail: musa@echonyc.com.
3881 Journal of Clinical Oncology, Vol 21, No 20 (October 15), 2003: pp 3881-3884
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 Susan G. Komen Foundation
Exec Dir

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