Orphan Products Conference
Vienna, Virginia: September 16-17, 1999
The admirable progress of orphan
drug development since 1983 can be credited to a remarkable partnership between the
federal government, the pharmaceutical industry, academia, and consumer organizations
representing people with rare diseases. The public and private sectors have been firmly
committed to the success of the law, and voluntary health agencies are sensitive to the
Acts potential to ease the pain and suffering of the patients they represent. The
main goal of each patient organization is to cure its disease and put itself out of
business; this would not be possible if the pharmaceutical industry did not bring each
orphan drug to market.
In 1983 the pharmaceutical industry did not recognize that
we - the patients - are their customers. They thought that physicians were their
customers, and focused on enticing doctors to prescribe particular brands of drugs.
However, the Orphan Drug Act proved that the market for a drug could be driven by
consumers, and today the Internet and television advertising confirm that it is good
business to treat patients as your customers. In most cases, orphan medications are
breakthrough therapies for which there is little or no competition. Patients demand these
drugs from their doctors; if the doctor refuses to prescribe them, patients will go to
another doctor.
How do rare disease patients find out about new orphan
drugs? Patient organizations disseminate newsletters, they operate web sites, they
communicate with the general public, physicians, the research community, etc. Companies
hire expensive public relations firms to broadcast information about new drugs, but no one
can directly reach the patients -- your customers -- more efficiently than a voluntary
health agency. It is simply good business to work with patient organizations.
The problem is, voluntary health agencies and
pharmaceutical companies dont share a common goal. The role of the voluntary agency
is to encourage research and try to get as many treatment options as possible for the
patients they represent. The role of the pharmaceutical company is to market its drug and
prevail over competitors. Its important to enter relationships with patient
organizations with a clear understanding of this fundamental difference . . . and to find
ways to work to the mutual good in spite of it.
During the development stages of any orphan drug,
companies need to work closely with a consumer group. That groups Medical Advisory
Committee will likely be the most prestigious group of experts with the largest number of
patients with a particular diagnosis. The outreach of each voluntary health agency is more
pervasive than your company could possibly accomplish, both to the scientific community
and to the patients you need for clinical trials.
On the other hand, the relationship of any pharmaceutical
company with a patient organization can be difficult and complex. It is important for the
industry to understand this unique non-profit sector, and how you can maintain an ongoing
relationship with your most important link to the consumers who will buy your products.
Support groups for rare diseases are usually started by
families who are directly affected by the disorder. They may be parents of an affected
child, a spouse, a sibling, etc. Most begin on a kitchen table because you cannot create
programs and hire staff unless you succeed at fundraising. In general, the pioneer
founders of voluntary health agencies are people unwilling to accept the awful fate of
their loved ones, so they roll up their sleeves and do something about it.
As their organization grows, they attract doctors to their
cause, and the doctors refer more patients to them. It soon becomes obvious that
credibility is a major factor of success, and that any medical information distributed to
the public must be reviewed and edited by physicians.
When an organization succeeds at fundraising, its members
will undoubtedly develop a research grant program. They want to cure the disease and go
out of business -- thats their goal. But it sounds easier than it actually is. A lot
of good money can be wasted on bad research. Every organization eventually realizes that
laymen cannot judge the quality of research proposals, so they must institute a Medical
Advisory Committee to formalize the peer review process and recommend which grants should
be funded.
This process of building a Medical Advisory Committee
means they must reach out and make friends with the scientific experts for their disease
all over the country and the world. Moreover, they need to befriend basic scientists who
may know nothing about the disease and interest them in integrating the disease into their
research portfolios. For example, geneticists who may be studying related diseases might
be enticed into adding another disease if they are told that the consumer organization may
provide funding and encourage patients to submit blood samples.
So once a consumer organization experiences some success,
has a degree of stability and achieves credibility, it is well underway. Meanwhile it
continues to build its mailing list of patients -- lots of patients -- and when a disease
is genetic the whole extended family may want to receive the organizations
newsletter because theyre eager for news of medical progress. The consumer
organization is the repository for information about the diseases on which they focus.
Research grants may make a good newsletter article when
they are awarded, but when they are completed it is not often very newsworthy. Progress is
so incremental; expectations that there will be a major breakthrough because of any one
research grant are unrealistic. This is why development of a treatment, whether in
academia or the corporate world, is newsworthy in our non-profit environment. But a
sophisticated organization knows that what they hope may be a breakthrough, may be a major
disappointment as clinical trials progress. They will check with their medical advisors
every step of the way before they print anything too positive in their newsletters because
they dont want to raise false hopes in their constituents. The only thing worse than
no hope is false hope.
Medical advisors will want information: Is it a controlled
trial or uncontrolled? What data do you have on preliminary clinical trials? Summarize the
toxicology, etc. They will want to speak with the clinicians who have some experience with
the drug, and they will report back to the consumer organization and carefully phrase any
newsletter articles regarding the product.
The medical advisors will recommend whether the
organization should cooperate in finding patients. If you are working on a rare disease
that doesnt have a patient organization, contact NORD and well find the
patients for you. But you must remember that consumer organizations will not
release the names and addresses of patients to any outside source. Rather, they will mail
a letter to patients, or print a newsletter article recommending that patients contact the
clinical sites. Since these organizations are usually overwhelmed with work and very
understaffed, you should make a donation to cover the costs of this project.
This is where the ethical line is drawn. Remember, a
strong organization is built on credibility. So while it needs your donations, it will not
take a donation with strings attached because its credibility might be threatened.
Moreover, it cannot endorse your product or make it sound like the best invention since
penicillin. Voluntary health agencies must maintain neutrality and any newsletter reports
about your product must be unbiased. They must tell people the good news along with the
bad, and your marketing people may not be happy about this. But this is their duty because
they must always keep the welfare of patients foremost in mind.
Voluntary health agencies can evolve into your best friend
or your worst nightmare, particularly if you are not open and honest with them. For
example, the recent trend toward limiting the inventory of investigational drugs, and the
need to create "lottery" systems when the demand outstrips the supply, does not
encourage the respect and trust of the patient community. Additionally, once a drug is
approved for marketing, patients will not be silent about extraordinarily high prices. To
counter this, you must prepare for an indigent care program long before the drug is
launched.
It is critically important that any medical assistance
program is fair and unbiased, and that income parameters are not set too low. Remember,
the rich can afford to buy your drug at any price, and the very poor will get it through
Medicaid. It is the middle class who need medication assistance programs -- not just the
uninsured, but also the underinsured. If you neglect to do this, you will find newspaper
articles popping up all over the country complaining about your pricing, asking why local
teachers and farmers have to hold a bake sale to raise money for their next dose of your
medicine.
Similarly, a Treatment IND for an orphan drug should
provide early access when no satisfactory alternative treatment exists, and particularly
when there has been any degree of publicity about your drug. One of the big mistakes of
the industry is failing to recognize that the information you release to Wall Street does
not stay on Wall Street. It reaches Main Street. So when pre-launch publicity talks about
the fabulous expectations you have for your drug, patients hopes are inflated,
sometimes artificially if the FDA does not get the data to back up any hype.
What happens after your drug is launched? After it becomes
apparent to your marketing people that the voluntary health agency can reach your
customers more easily than you can? How can you sustain a good relationship with the
patient organization? And how can a non-profit agency benefit from your support without
appearing like its been bribed by your company?
One way to ruin a relationship is to expect the
organization to praise your drug in response to a hefty donation. Dont get me wrong,
patient organizations need donations. They often exist from hand to mouth. However, it is
their responsibility to be unbiased and accurate, so they must talk about the
negative aspects of your drug, as well as the positives. It is much more rational for them
to praise your company in their newsletters than it is to praise your drug, because they
cannot be perceived as endorsing your product or demeaning the product of your
competitors.
Keep in mind that you may have one drug, but it is the
role of the patient organization to encourage other companies to develop additional
treatment options. Thus your company may be hoping to prevent competition, but the patient
organization will be working to promote competition because this is their mission. This
is usually the core of any conflict that may arise in your relationship with consumer
organizations. If you have realistic expectations when you start this relationship,
you can avoid conflicts.
The field of voluntary agencies is very sensitive to
scandal. Organizations accused by their members of being bribed by business interests
usually never recover. Even new leaderships will be tainted by past scandals, and
donations from the public will be greatly hampered. This is why your support must come
with no strings attached. Even if it appears to have strings, it could be
disastrous.
For example, one organization accepted a grant from a
company that manufactured drug to promote growth in children, to go to schools and measure
the height of children. If a child was below the 90th percentile of normal height for his
or her age, a note was sent to the parents suggesting that they talk to the childs
doctor about this drug. This grant does not pass the New York Times test; if the
story appears in the Times, would it look bad? Well, it did appear in the Times
as well as the Washington Post and virtually every other newspaper in the country.
The organization still hasnt recovered from the bad publicity, and the company paid
a hefty fine to the Federal Trade Commission. Its just not worth it.
Your goal should be to keep your good name in front of
your customers, the people who need your orphan drug. You can do this through unrestricted
educational grants to the patient organization. For example, they can print credit to your
company in their newsletters for supporting their educational programs; you can sponsor
their meetings or publications through which they will acknowledge your support, but you
cannot have editorial control over what they print or say; or you can give them a grant to
support outreach efforts that will get patients diagnosed earlier, as long as you
dont suggest these patients should take your drug. You need to build an image of a
compassionate and socially responsible corporation who wants to help patients and their
organization to ease pain and diminish the suffering of families.
To this end, it is critically important that you are
honest and open with the patient community so they will never lose faith in your
willingness to be truthful, even if the news is bad. Patients talk to each other, and a
rumor on the World Wide Web can have devastating consequences for your company,
particularly because the Internet is a technological wonder that never erases old messages
left on bulletin boards.
I was recently monitoring a bulletin board for a disease
that is treated with a drug that is experiencing manufacturing problems. A patient noticed
that his pharmacist would no longer give him a three-month supply of the drug and was
limiting refills to 30 days. After three or four months, he compared each bottle and
noticed they all had the same expiration date. He got on the Internet and spread a rumor
that the company was ceasing manufacture of the drug and was leaving the patients to die.
After a few days of this rumor scaring the daylights out
of patients all over the world, I picked up the phone and talked to the company. They
could have intervened earlier and eased the fright of these patients, but I learned that
their legal department had been undecided about what to do, and so had done nothing. By
that time, the messages on the web regarding the company were transitioning from
"R" rated to "X" rated words. This was a big multi-national company
that should not have risked any one of those patients going to 60 Minutes or Dateline
with their story. Accusing a respected multi-national company of being a murderer
makes for interesting television entertainment, and this should be avoided at all costs
with rapid and decisive crisis intervention.
In this case, the group of patients did not have a formal
non-profit organization to referee the argument, so NORD had to step in. But had a formal
patient organization existed, a spokesman from the company should have been selected to
create an alliance with the patient community and keep them informed of the temporary
manufacturing difficulties and how the company was trying to overcome them. The company
could have been a hero to the patients; instead it was a villain because of indecisiveness
and inaction.
What I am saying here is that this partnership between the
industry, the government, and patient organizations is a marriage that has to be worked on
every day. Marriage calls for compromise, and it is fraught with daily challenges, but we
each need to work at keeping the marriage intact. Divorce is not an option.
We patients need pharmaceutical companies to manufacture
our drugs. The companies need us to buy their products. We both need the government to
fund the research and ensure that the treatments are safe and effective. If the FDA
wasnt there, you would be in the nutritional supplement business and we would
probably be dead. Then there would be no market for your products.
So it is to your benefit to keep the voluntary health
sector strong, and to our benefit to make sure you are innovative and profitable. This is
why patient organizations are important in the development of orphan products.
The admirable progress of orphan
drug development since 1983 can be credited to a remarkable partnership between the
federal government, the pharmaceutical industry, academia, and consumer organizations
representing people with rare diseases. The public and private sectors have been firmly
committed to the success of the law, and voluntary health agencies are sensitive to the
Acts potential to ease the pain and suffering of the patients they represent. The
main goal of each patient organization is to cure its disease and put itself out of
business; this would not be possible if the pharmaceutical industry did not bring each
orphan drug to market.
In 1983 the pharmaceutical industry did not recognize that
we - the patients - are their customers. They thought that physicians were their
customers, and focused on enticing doctors to prescribe particular brands of drugs.
However, the Orphan Drug Act proved that the market for a drug could be driven by
consumers, and today the Internet and television advertising confirm that it is good
business to treat patients as your customers. In most cases, orphan medications are
breakthrough therapies for which there is little or no competition. Patients demand these
drugs from their doctors; if the doctor refuses to prescribe them, patients will go to
another doctor.
How do rare disease patients find out about new orphan
drugs? Patient organizations disseminate newsletters, they operate web sites, they
communicate with the general public, physicians, the research community, etc. Companies
hire expensive public relations firms to broadcast information about new drugs, but no one
can directly reach the patients -- your customers -- more efficiently than a voluntary
health agency. It is simply good business to work with patient organizations.
The problem is, voluntary health agencies and
pharmaceutical companies dont share a common goal. The role of the voluntary agency
is to encourage research and try to get as many treatment options as possible for the
patients they represent. The role of the pharmaceutical company is to market its drug and
prevail over competitors. Its important to enter relationships with patient
organizations with a clear understanding of this fundamental difference . . . and to find
ways to work to the mutual good in spite of it.
During the development stages of any orphan drug,
companies need to work closely with a consumer group. That groups Medical Advisory
Committee will likely be the most prestigious group of experts with the largest number of
patients with a particular diagnosis. The outreach of each voluntary health agency is more
pervasive than your company could possibly accomplish, both to the scientific community
and to the patients you need for clinical trials.
On the other hand, the relationship of any pharmaceutical
company with a patient organization can be difficult and complex. It is important for the
industry to understand this unique non-profit sector, and how you can maintain an ongoing
relationship with your most important link to the consumers who will buy your products.
Support groups for rare diseases are usually started by
families who are directly affected by the disorder. They may be parents of an affected
child, a spouse, a sibling, etc. Most begin on a kitchen table because you cannot create
programs and hire staff unless you succeed at fundraising. In general, the pioneer
founders of voluntary health agencies are people unwilling to accept the awful fate of
their loved ones, so they roll up their sleeves and do something about it.
As their organization grows, they attract doctors to their
cause, and the doctors refer more patients to them. It soon becomes obvious that
credibility is a major factor of success, and that any medical information distributed to
the public must be reviewed and edited by physicians.
When an organization succeeds at fundraising, its members
will undoubtedly develop a research grant program. They want to cure the disease and go
out of business -- thats their goal. But it sounds easier than it actually is. A lot
of good money can be wasted on bad research. Every organization eventually realizes that
laymen cannot judge the quality of research proposals, so they must institute a Medical
Advisory Committee to formalize the peer review process and recommend which grants should
be funded.
This process of building a Medical Advisory Committee
means they must reach out and make friends with the scientific experts for their disease
all over the country and the world. Moreover, they need to befriend basic scientists who
may know nothing about the disease and interest them in integrating the disease into their
research portfolios. For example, geneticists who may be studying related diseases might
be enticed into adding another disease if they are told that the consumer organization may
provide funding and encourage patients to submit blood samples.
So once a consumer organization experiences some success,
has a degree of stability and achieves credibility, it is well underway. Meanwhile it
continues to build its mailing list of patients -- lots of patients -- and when a disease
is genetic the whole extended family may want to receive the organizations
newsletter because theyre eager for news of medical progress. The consumer
organization is the repository for information about the diseases on which they focus.
Research grants may make a good newsletter article when
they are awarded, but when they are completed it is not often very newsworthy. Progress is
so incremental; expectations that there will be a major breakthrough because of any one
research grant are unrealistic. This is why development of a treatment, whether in
academia or the corporate world, is newsworthy in our non-profit environment. But a
sophisticated organization knows that what they hope may be a breakthrough, may be a major
disappointment as clinical trials progress. They will check with their medical advisors
every step of the way before they print anything too positive in their newsletters because
they dont want to raise false hopes in their constituents. The only thing worse than
no hope is false hope.
Medical advisors will want information: Is it a controlled
trial or uncontrolled? What data do you have on preliminary clinical trials? Summarize the
toxicology, etc. They will want to speak with the clinicians who have some experience with
the drug, and they will report back to the consumer organization and carefully phrase any
newsletter articles regarding the product.
The medical advisors will recommend whether the
organization should cooperate in finding patients. If you are working on a rare disease
that doesnt have a patient organization, contact NORD and well find the
patients for you. But you must remember that consumer organizations will not
release the names and addresses of patients to any outside source. Rather, they will mail
a letter to patients, or print a newsletter article recommending that patients contact the
clinical sites. Since these organizations are usually overwhelmed with work and very
understaffed, you should make a donation to cover the costs of this project.
This is where the ethical line is drawn. Remember, a
strong organization is built on credibility. So while it needs your donations, it will not
take a donation with strings attached because its credibility might be threatened.
Moreover, it cannot endorse your product or make it sound like the best invention since
penicillin. Voluntary health agencies must maintain neutrality and any newsletter reports
about your product must be unbiased. They must tell people the good news along with the
bad, and your marketing people may not be happy about this. But this is their duty because
they must always keep the welfare of patients foremost in mind.
Voluntary health agencies can evolve into your best friend
or your worst nightmare, particularly if you are not open and honest with them. For
example, the recent trend toward limiting the inventory of investigational drugs, and the
need to create "lottery" systems when the demand outstrips the supply, does not
encourage the respect and trust of the patient community. Additionally, once a drug is
approved for marketing, patients will not be silent about extraordinarily high prices. To
counter this, you must prepare for an indigent care program long before the drug is
launched.
It is critically important that any medical assistance
program is fair and unbiased, and that income parameters are not set too low. Remember,
the rich can afford to buy your drug at any price, and the very poor will get it through
Medicaid. It is the middle class who need medication assistance programs -- not just the
uninsured, but also the underinsured. If you neglect to do this, you will find newspaper
articles popping up all over the country complaining about your pricing, asking why local
teachers and farmers have to hold a bake sale to raise money for their next dose of your
medicine.
Similarly, a Treatment IND for an orphan drug should
provide early access when no satisfactory alternative treatment exists, and particularly
when there has been any degree of publicity about your drug. One of the big mistakes of
the industry is failing to recognize that the information you release to Wall Street does
not stay on Wall Street. It reaches Main Street. So when pre-launch publicity talks about
the fabulous expectations you have for your drug, patients hopes are inflated,
sometimes artificially if the FDA does not get the data to back up any hype.
What happens after your drug is launched? After it becomes
apparent to your marketing people that the voluntary health agency can reach your
customers more easily than you can? How can you sustain a good relationship with the
patient organization? And how can a non-profit agency benefit from your support without
appearing like its been bribed by your company?
One way to ruin a relationship is to expect the
organization to praise your drug in response to a hefty donation. Dont get me wrong,
patient organizations need donations. They often exist from hand to mouth. However, it is
their responsibility to be unbiased and accurate, so they must talk about the
negative aspects of your drug, as well as the positives. It is much more rational for them
to praise your company in their newsletters than it is to praise your drug, because they
cannot be perceived as endorsing your product or demeaning the product of your
competitors.
Keep in mind that you may have one drug, but it is the
role of the patient organization to encourage other companies to develop additional
treatment options. Thus your company may be hoping to prevent competition, but the patient
organization will be working to promote competition because this is their mission. This
is usually the core of any conflict that may arise in your relationship with consumer
organizations. If you have realistic expectations when you start this relationship,
you can avoid conflicts.
The field of voluntary agencies is very sensitive to
scandal. Organizations accused by their members of being bribed by business interests
usually never recover. Even new leaderships will be tainted by past scandals, and
donations from the public will be greatly hampered. This is why your support must come
with no strings attached. Even if it appears to have strings, it could be
disastrous.
For example, one organization accepted a grant from a
company that manufactured drug to promote growth in children, to go to schools and measure
the height of children. If a child was below the 90th percentile of normal height for his
or her age, a note was sent to the parents suggesting that they talk to the childs
doctor about this drug. This grant does not pass the New York Times test; if the
story appears in the Times, would it look bad? Well, it did appear in the Times
as well as the Washington Post and virtually every other newspaper in the country.
The organization still hasnt recovered from the bad publicity, and the company paid
a hefty fine to the Federal Trade Commission. Its just not worth it.
Your goal should be to keep your good name in front of
your customers, the people who need your orphan drug. You can do this through unrestricted
educational grants to the patient organization. For example, they can print credit to your
company in their newsletters for supporting their educational programs; you can sponsor
their meetings or publications through which they will acknowledge your support, but you
cannot have editorial control over what they print or say; or you can give them a grant to
support outreach efforts that will get patients diagnosed earlier, as long as you
dont suggest these patients should take your drug. You need to build an image of a
compassionate and socially responsible corporation who wants to help patients and their
organization to ease pain and diminish the suffering of families.
To this end, it is critically important that you are
honest and open with the patient community so they will never lose faith in your
willingness to be truthful, even if the news is bad. Patients talk to each other, and a
rumor on the World Wide Web can have devastating consequences for your company,
particularly because the Internet is a technological wonder that never erases old messages
left on bulletin boards.
I was recently monitoring a bulletin board for a disease
that is treated with a drug that is experiencing manufacturing problems. A patient noticed
that his pharmacist would no longer give him a three-month supply of the drug and was
limiting refills to 30 days. After three or four months, he compared each bottle and
noticed they all had the same expiration date. He got on the Internet and spread a rumor
that the company was ceasing manufacture of the drug and was leaving the patients to die.
After a few days of this rumor scaring the daylights out
of patients all over the world, I picked up the phone and talked to the company. They
could have intervened earlier and eased the fright of these patients, but I learned that
their legal department had been undecided about what to do, and so had done nothing. By
that time, the messages on the web regarding the company were transitioning from
"R" rated to "X" rated words. This was a big multi-national company
that should not have risked any one of those patients going to 60 Minutes or Dateline
with their story. Accusing a respected multi-national company of being a murderer
makes for interesting television entertainment, and this should be avoided at all costs
with rapid and decisive crisis intervention.
In this case, the group of patients did not have a formal
non-profit organization to referee the argument, so NORD had to step in. But had a formal
patient organization existed, a spokesman from the company should have been selected to
create an alliance with the patient community and keep them informed of the temporary
manufacturing difficulties and how the company was trying to overcome them. The company
could have been a hero to the patients; instead it was a villain because of indecisiveness
and inaction.
What I am saying here is that this partnership between the
industry, the government, and patient organizations is a marriage that has to be worked on
every day. Marriage calls for compromise, and it is fraught with daily challenges, but we
each need to work at keeping the marriage intact. Divorce is not an option.
We patients need pharmaceutical companies to manufacture
our drugs. The companies need us to buy their products. We both need the government to
fund the research and ensure that the treatments are safe and effective. If the FDA
wasnt there, you would be in the nutritional supplement business and we would
probably be dead. Then there would be no market for your products.
So it is to your benefit to keep the voluntary health
sector strong, and to our benefit to make sure you are innovative and profitable. This is
why patient organizations are important in the development of orphan products.
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