|
|
|
@ -6,11 +6,11 @@
|
|
|
|
In 1938 President Franklin D Rosevelt signed the Food, Drug, and Cosmetic Act,
|
|
|
|
In 1938 President Franklin D Rosevelt signed the Food, Drug, and Cosmetic Act,
|
|
|
|
granting the Food and Drug Administration (FDA) authority to require
|
|
|
|
granting the Food and Drug Administration (FDA) authority to require
|
|
|
|
pre-market approval of pharmaceuticals.
|
|
|
|
pre-market approval of pharmaceuticals.
|
|
|
|
\cite{commissioner_MilestonesUS_2023}.
|
|
|
|
\cite{commissioner_milestonesusfood_2023}
|
|
|
|
As of Sept 2022 \todo{Check Date} they have approved 6,602 currently-marketed
|
|
|
|
As of Sept 2022 \todo{Check Date} they have approved 6,602 currently-marketed
|
|
|
|
compounds with Structured Product Labels (SPLs)
|
|
|
|
compounds with Structured Product Labels (SPLs)
|
|
|
|
and 10,983 previously-marketed SPLs
|
|
|
|
and 10,983 previously-marketed SPLs
|
|
|
|
\cite{commissioner_NSDE_2024}.
|
|
|
|
\cite{commissioner_nsde_2024},
|
|
|
|
%from nsde table. Get number of unique application_nubmers_or_citations with most recent end date as null.
|
|
|
|
%from nsde table. Get number of unique application_nubmers_or_citations with most recent end date as null.
|
|
|
|
In 1999, they began requiring that drug developers register and
|
|
|
|
In 1999, they began requiring that drug developers register and
|
|
|
|
publish clinical trials on \url{https://clinicaltrials.gov}.
|
|
|
|
publish clinical trials on \url{https://clinicaltrials.gov}.
|
|
|
|
@ -42,7 +42,8 @@ Hyrimoz, Idacio, Simlandi, Yuflyma, and Yusimry),
|
|
|
|
the biosimilars are required to prove they have similar efficacy and safety to the
|
|
|
|
the biosimilars are required to prove they have similar efficacy and safety to the
|
|
|
|
reference drug.
|
|
|
|
reference drug.
|
|
|
|
|
|
|
|
|
|
|
|
When registering these clinical trials
|
|
|
|
%TODO? Decide whether to include this or not
|
|
|
|
|
|
|
|
%When registering these clinical trials
|
|
|
|
% discuss how these are registered and what data is published.
|
|
|
|
% discuss how these are registered and what data is published.
|
|
|
|
% Include image and discuss stages
|
|
|
|
% Include image and discuss stages
|
|
|
|
% Discuss challenges faced
|
|
|
|
% Discuss challenges faced
|
|
|
|
@ -51,24 +52,25 @@ When registering these clinical trials
|
|
|
|
|
|
|
|
|
|
|
|
In the world of drug development, these trials are classified into different
|
|
|
|
In the world of drug development, these trials are classified into different
|
|
|
|
phases of development.
|
|
|
|
phases of development.
|
|
|
|
\cite{FDADrugApprovalProcess_2022}
|
|
|
|
\cite{anderson_fdadrugapproval_2022}
|
|
|
|
provide an overview of this process
|
|
|
|
provide an overview of this process
|
|
|
|
\cite{commissioner_DrugDevelopment_2020}
|
|
|
|
while
|
|
|
|
while describes the actual details.
|
|
|
|
\cite{commissioner_drugdevelopmentprocess_2020}
|
|
|
|
|
|
|
|
describes the actual details.
|
|
|
|
Pre-clinical studies primarily establish toxicity and potential dosing levels
|
|
|
|
Pre-clinical studies primarily establish toxicity and potential dosing levels
|
|
|
|
\cite{commissioner_DrugDevelopment_2020}.
|
|
|
|
\cite{commissioner_drugdevelopmentprocess_2020}.
|
|
|
|
Phase I trials are the first attempt to evaluate safety and efficacy in humans.
|
|
|
|
Phase I trials are the first attempt to evaluate safety and efficacy in humans.
|
|
|
|
Participants typically are heathy individuals, and they measure how the drug
|
|
|
|
Participants typically are heathy individuals, and they measure how the drug
|
|
|
|
affects healthy bodies, potential side effects, and adjust dosing levels.
|
|
|
|
affects healthy bodies, potential side effects, and adjust dosing levels.
|
|
|
|
Sample sizes are often less than 100 participants.
|
|
|
|
Sample sizes are often less than 100 participants.
|
|
|
|
\cite{commissioner_DrugDevelopment_2020}.
|
|
|
|
\cite{commissioner_drugdevelopmentprocess_2020}.
|
|
|
|
Phase II trials typically involve a few hundred participants and is where
|
|
|
|
Phase II trials typically involve a few hundred participants and is where
|
|
|
|
investigators will dial in dosing, research methods, and safety.
|
|
|
|
investigators will dial in dosing, research methods, and safety.
|
|
|
|
\cite{commissioner_DrugDevelopment_2020}.
|
|
|
|
\cite{commissioner_drugdevelopmentprocess_2020}.
|
|
|
|
A Phase III trial is the final trial befor approval by the FDA, and is where
|
|
|
|
A Phase III trial is the final trial befor approval by the FDA, and is where
|
|
|
|
the investigator must demonstrate safety and efficacy with a large number of
|
|
|
|
the investigator must demonstrate safety and efficacy with a large number of
|
|
|
|
participants, usually on the order of hundreds or thousands.
|
|
|
|
participants, usually on the order of hundreds or thousands.
|
|
|
|
\cite{commissioner_DrugDevelopment_2020}.
|
|
|
|
\cite{commissioner_drugdevelopmentprocess_2020}.
|
|
|
|
Occassionally, a trial will be a multiphase trial, covering aspects of either
|
|
|
|
Occassionally, a trial will be a multiphase trial, covering aspects of either
|
|
|
|
Phases I and II or Phases II and III.
|
|
|
|
Phases I and II or Phases II and III.
|
|
|
|
|
|
|
|
|
|
|
|
@ -77,7 +79,7 @@ After a successful Phase III trial, the sponsor will decide whether or not
|
|
|
|
to submit an application for approval from the FDA.
|
|
|
|
to submit an application for approval from the FDA.
|
|
|
|
Before filing this application, the developer must have completed
|
|
|
|
Before filing this application, the developer must have completed
|
|
|
|
"two large, controlled clinical trials."
|
|
|
|
"two large, controlled clinical trials."
|
|
|
|
\cite{commissioner_DrugDevelopment_2020}.
|
|
|
|
\cite{commissioner_drugdevelopmentprocess_2020}.
|
|
|
|
Phase IV trials are used after the drug has recieved marketing approval to
|
|
|
|
Phase IV trials are used after the drug has recieved marketing approval to
|
|
|
|
validate safety and efficacy in the general populace.
|
|
|
|
validate safety and efficacy in the general populace.
|
|
|
|
Throughout this whole process, the FDA is available to assist in decisionmaking
|
|
|
|
Throughout this whole process, the FDA is available to assist in decisionmaking
|
|
|
|
@ -85,14 +87,14 @@ regarding topics such as study design, document review, and whether or not
|
|
|
|
they should terminate the trial.
|
|
|
|
they should terminate the trial.
|
|
|
|
The FDA also reserves the right to place a hold on the clinical trial for
|
|
|
|
The FDA also reserves the right to place a hold on the clinical trial for
|
|
|
|
safety or other operational concerns, although this is rare.
|
|
|
|
safety or other operational concerns, although this is rare.
|
|
|
|
\cite{commissioner_DrugDevelopment_2020}.
|
|
|
|
\cite{commissioner_drugdevelopmentprocess_2020}.
|
|
|
|
|
|
|
|
|
|
|
|
In the economics literature, most of the focus has been on evaluating how
|
|
|
|
In the economics literature, most of the focus has been on evaluating how
|
|
|
|
drug candidates transition between different phases and their probability
|
|
|
|
drug candidates transition between different phases and their probability
|
|
|
|
of final approval.
|
|
|
|
of final approval.
|
|
|
|
% Lead into lit review
|
|
|
|
% Lead into lit review
|
|
|
|
% Abrantes-Metz, Adams, Metz (2004)
|
|
|
|
% Abrantes-Metz, Adams, Metz (2004)
|
|
|
|
\cite{abrantes-metz_pharmaceutical_2004},
|
|
|
|
\authorcite{abrantes-metz_pharmaceuticaldevelopmentphases_2004}
|
|
|
|
described the relationship between
|
|
|
|
described the relationship between
|
|
|
|
various drug characteristics and how the drug progressed through clinical trials.
|
|
|
|
various drug characteristics and how the drug progressed through clinical trials.
|
|
|
|
% This descriptive estimate was notable for using a
|
|
|
|
% This descriptive estimate was notable for using a
|
|
|
|
@ -107,7 +109,8 @@ from the purpose of Phase III.
|
|
|
|
|
|
|
|
|
|
|
|
Continuing on this theme,
|
|
|
|
Continuing on this theme,
|
|
|
|
%DiMasi FeldmanSeckler Wilson 2009
|
|
|
|
%DiMasi FeldmanSeckler Wilson 2009
|
|
|
|
\cite{dimasi_TrendsRisks_2010} examine the completion rate of clinical drug
|
|
|
|
\authorcite{dimasi_trendsrisksassociated_2010}
|
|
|
|
|
|
|
|
examine the completion rate of clinical drug
|
|
|
|
develompent and find that for the 50 largest drug producers,
|
|
|
|
develompent and find that for the 50 largest drug producers,
|
|
|
|
approximately 19\% of their drugs under development between 1993 and 2004
|
|
|
|
approximately 19\% of their drugs under development between 1993 and 2004
|
|
|
|
successfully moved from Phase I to recieving an New Drug Application (NDA)
|
|
|
|
successfully moved from Phase I to recieving an New Drug Application (NDA)
|
|
|
|
@ -120,7 +123,7 @@ They note that this may reduce the cost of new drugs by eliminating late
|
|
|
|
and costly failures in the development pipeline.
|
|
|
|
and costly failures in the development pipeline.
|
|
|
|
|
|
|
|
|
|
|
|
Earlier work by
|
|
|
|
Earlier work by
|
|
|
|
\authorcite{dimasi_ValueImproving_2002}
|
|
|
|
\authorcite{dimasi_valueimprovingproductivity_2002}
|
|
|
|
used data on 68 investigational drugs from 10 firms to simulate how reducing
|
|
|
|
used data on 68 investigational drugs from 10 firms to simulate how reducing
|
|
|
|
time in development reduces the costs of developing drugs.
|
|
|
|
time in development reduces the costs of developing drugs.
|
|
|
|
He estimates that reducing Phase III of clinical trials by one year would
|
|
|
|
He estimates that reducing Phase III of clinical trials by one year would
|
|
|
|
@ -128,13 +131,13 @@ reduce total costs by about 8.9\% and that moving 5\% of clinical trial failures
|
|
|
|
from phase III to Phase II would reduce out of pocket costs by 5.6\%.
|
|
|
|
from phase III to Phase II would reduce out of pocket costs by 5.6\%.
|
|
|
|
|
|
|
|
|
|
|
|
Like much of the work in this field, the focus of the the work by
|
|
|
|
Like much of the work in this field, the focus of the the work by
|
|
|
|
\citeauthor{dimasi_ValueImproving_2002}
|
|
|
|
\authorcite{dimasi_valueimprovingproductivity_2002}
|
|
|
|
and
|
|
|
|
and
|
|
|
|
\citeauthor{dimasi_TrendsRisks_2010}
|
|
|
|
\authorcite{dimasi_trendsrisksassociated_2010}
|
|
|
|
tends to be on the drug development pipeline, i.e. the progression between
|
|
|
|
tends to be on the drug development pipeline, i.e. the progression between
|
|
|
|
phases and towards marketing approval.
|
|
|
|
phases and towards marketing approval.
|
|
|
|
A key contribution to this drug development literature is the work by
|
|
|
|
A key contribution to this drug development literature is the work by
|
|
|
|
\authorcite{khmelnitskaya_CompetitionAttrition_2021}
|
|
|
|
\authorcite{khmelnitskaya_competitionattritiondrug_2021}
|
|
|
|
on a causal identification strategy
|
|
|
|
on a causal identification strategy
|
|
|
|
to disentangle strategic exits from exits due to clinical failures
|
|
|
|
to disentangle strategic exits from exits due to clinical failures
|
|
|
|
in the drug development pipeline.
|
|
|
|
in the drug development pipeline.
|
|
|
|
@ -143,7 +146,7 @@ terminations and that the rate of new drug production would be about 23\%
|
|
|
|
higher if those strategic terminatations were elimintated.
|
|
|
|
higher if those strategic terminatations were elimintated.
|
|
|
|
|
|
|
|
|
|
|
|
The work that is closest to mine is the work by
|
|
|
|
The work that is closest to mine is the work by
|
|
|
|
\authorcite{hwang_FailureInvestigational_2016}
|
|
|
|
\authorcite{hwang_failureinvestigationaldrugs_2016}
|
|
|
|
who investigated causes for which late stage (Phase III)
|
|
|
|
who investigated causes for which late stage (Phase III)
|
|
|
|
clinical trials fail -- with a focus on trials in the USA,
|
|
|
|
clinical trials fail -- with a focus on trials in the USA,
|
|
|
|
Europe, Japan, Canada, and Australia.
|
|
|
|
Europe, Japan, Canada, and Australia.
|
|
|
|
@ -157,14 +160,14 @@ on commercial or other grounds.
|
|
|
|
Unlike the majority of the literature, I focus on the progress of
|
|
|
|
Unlike the majority of the literature, I focus on the progress of
|
|
|
|
individual clinical trials, not on the drug development pipeline.
|
|
|
|
individual clinical trials, not on the drug development pipeline.
|
|
|
|
In both
|
|
|
|
In both
|
|
|
|
\authorcite{khmelnitskaya_CompetitionAttrition_2021}
|
|
|
|
\authorcite{khmelnitskaya_competitionattritiondrug_2021}
|
|
|
|
and
|
|
|
|
and
|
|
|
|
\authorcite{hwang_FailureInvestigational_2016}
|
|
|
|
\authorcite{hwang_failureinvestigationaldrugs_2016}
|
|
|
|
the authors describe failures due to safety, efficacy, or strategic concerns.
|
|
|
|
the authors describe failures due to safety, efficacy, or strategic concerns.
|
|
|
|
There is another category of concerns that arise for individual clinical trials,
|
|
|
|
There is another category of concerns that arise for individual clinical trials,
|
|
|
|
that of operational failures.
|
|
|
|
that of operational failures.
|
|
|
|
Operational failures can arise when a trial struggles to recruit participants,
|
|
|
|
Operational failures can arise when a trial struggles to recruit participants,
|
|
|
|
the principle investigator or other key member leaves for another opportunity,
|
|
|
|
the principal investigator or other key member leaves for another opportunity,
|
|
|
|
or other studies prove that the trial requires a protocol change.
|
|
|
|
or other studies prove that the trial requires a protocol change.
|
|
|
|
|
|
|
|
|
|
|
|
% In a personal review of 199 randomly selected clinical trials from the AACT
|
|
|
|
% In a personal review of 199 randomly selected clinical trials from the AACT
|
|
|
|
@ -189,23 +192,27 @@ or other studies prove that the trial requires a protocol change.
|
|
|
|
This paper proposes the first model to separate the causal effects of
|
|
|
|
This paper proposes the first model to separate the causal effects of
|
|
|
|
market conditions (a strategic concern) from the effects of
|
|
|
|
market conditions (a strategic concern) from the effects of
|
|
|
|
participant enrollment (an operational concern) on Phase III Clinical trials.
|
|
|
|
participant enrollment (an operational concern) on Phase III Clinical trials.
|
|
|
|
This will allow me to answer the questions:
|
|
|
|
This allows me to answer the question
|
|
|
|
\begin{itemize}
|
|
|
|
\textit{
|
|
|
|
\item What is the marginal effect on trial completion of an additional
|
|
|
|
``How does the probability of trial termination change
|
|
|
|
generic drug on the market?
|
|
|
|
when the enrollment period is extended?''
|
|
|
|
\item What is the marginal effect on trial completion of a delay in
|
|
|
|
}
|
|
|
|
closing enrollment?
|
|
|
|
using administrative data.
|
|
|
|
\end{itemize}
|
|
|
|
To understand how I do this, we'll cover some background information on
|
|
|
|
To undderstand how I do this, we'll cover some background information on
|
|
|
|
clinical trials and the administrative data I collected in section
|
|
|
|
clinical trials in section \ref{SEC:ClinicalTrials},
|
|
|
|
\ref{SEC:ClinicalTrials},
|
|
|
|
explain the data in section \ref{SEC:DataSources},
|
|
|
|
explain the approach to causal identification strategy and the required data in section
|
|
|
|
and then examine causal identification and econometric model in sections
|
|
|
|
\ref{SEC:Data},
|
|
|
|
\ref{SEC:CausalIdentificationAndModel}.
|
|
|
|
and describe how the data used matches these requirements in section
|
|
|
|
Finally I'll review the results and conclusion in sections
|
|
|
|
\ref{SEC:}.
|
|
|
|
\ref{SEC:Results}
|
|
|
|
Then we'll cover the econometric model
|
|
|
|
and
|
|
|
|
(section \ref{SEC:EconometricModel})
|
|
|
|
\ref{SEC:Conclusion}
|
|
|
|
and results (section
|
|
|
|
respectively.
|
|
|
|
\ref{SEC:Results}).
|
|
|
|
|
|
|
|
Finally, we acknowledge deficiencies in the analysis and potential improvements
|
|
|
|
|
|
|
|
in section
|
|
|
|
|
|
|
|
\ref{SEC:Improvements},
|
|
|
|
|
|
|
|
then summarize everything in the conclusion \ref{SEC:Conclusion}
|
|
|
|
|
|
|
|
|
|
|
|
% \subsection{Market incentives and drug development}
|
|
|
|
% \subsection{Market incentives and drug development}
|
|
|
|
% %%%%%%%%% What do we know about drug development incentives?
|
|
|
|
% %%%%%%%%% What do we know about drug development incentives?
|
|
|
|
|