3 ms·
On gaming: it's very interesting that, even within all of the byzantine rules and regulations and guidances how much gray area and leeway there can be. From a d
by doctoring 6y ago
On gaming: it's very interesting that, even within all of the byzantine rules and regulations and guidances how much gray area and leeway there can be. From a drug/device company perspective, which people in the FDA assigned as reviewers / contact points for you and how well you are able to articulate & convince them of your goals can play a huge role in whether you have to do X type of trial or adhere to Y rules. This is especially true at the boundaries (new types of testing, devices, technologies) that don't quite exactly fit the more well-trod paths. Not saying this in a judgmental way -- it's just the nature of dealing with extremely complex problems while also making sure people aren't harmed unnecessarily and that at the end when you say drug/device/tech A improves condition B we actually are sure it is true.
And then there's the more malicious "gaming", fraud! Clinical research is obviously heavily incentivized toward positive trial outcomes, but for each site the act of just enrolling patients is incentivized, so you need to be damn sure the patient data (and the patients themselves!) in your study are real. And being sure is not easy or cheap.
For fun, here's the FDA's list of people who have been blacklisted from performing clinical research: https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/compliance-actions-and-activities/fda-debarment-list-drug-product-applications https://www.fda.gov/inspections-compliance-enforcement-and-c...
Their associated "Volume Page" lists (in excruciating bureaucratese) their "crimes", which may be unrelated illegal narcotics peddling (oops) or falsifying patient data.
- gumby 6y agoThe gaming has really made it harder to work with the Agency because you can't just call up or stop by and ask a question any more -- your interactions are more structured and formal. I agree that the shift to biomarker endpoints has made the process a bit more aggressive (in probably a good way) but has also lead to all sorts of opportunities for gaming you way to pointless success...but then you have something in the market with something you can talk about!
- refurb 6y agoI wouldn't really consider "articulate & convince them of your goals" as really gaming. There are areas that are new for everyone, and you are correct, if you don't come up with your approach, the FDA will come up with one for you. What I've appreciated about the FDA is their scientific focus. The FDA might say "You need to do X", but if you can come back and convince them with a scientific argument that you don't have to, they will listen to you!