F IRST, DO NO HARM,” IS a critical dictum in medica l prac t ice . Medical practitioners from ancient times to the present have used individual and shared scientific observations to determine the risks and benefits of individual therapies. However, the yield in this somewhat random process is certainly low. Since the development of the modern pharmaceutical industry as well as the Food and Drug Administration (FDA) as a regulatory agency, we as a medical and scientific community have been held to higher standards to provide proof of safety and efficacy of new treatments through randomized clinical trials. Phase 3 randomized clinical trials are the final phase of testing prior to FDA approval of a drug or technology for marketing. In general, this level of study compares the results of patients randomly assigned to a new treatment with those of a control group of patients randomly assigned to standard treatment or placebo to assess which group has better survival/ response rates or fewer adverse effects. However, the presence of a control reference group of patients from whom a potentially promising therapy is withheld has been deemed by many clinicians as lacking in compassion. Compassion, which is defined as intent to help, can be viewed altruistically as the objective of all new drug and procedure investigation activities. Although there is no FDA regulation or policy to define “compassionate use” of drugs, it is commonly understood as the use of drugs to treat diseases, usually serious lifethreatening conditions such as AIDS and cancer, without first going through the full process of randomized, controlled clinical trials through phase 3. However, without adequate controls in a pivotal phase 3 randomized clinical trial, the safety and benefit of new therapies cannot be adequately assessed until after approval and potentially not at all if the promised postapproval studies are not performed. As of 2005, there have been 91 drugs approved since 1992 with industry commitments to the FDA to perform postapproval studies: only 49 of those have been completed, and fully 21 have not even been started. While the few patients enrolled in a trial may potentially benefit from an as yet unapproved drug or procedure, the larger group of people suffering from the same condition will never see any benefit if the study is poorly controlled and therefore uninterpretable, resulting in either no approval or poor utilization of an approved drug. Although many new drugs and procedures show early promise, when they are subjected to a well-controlled randomized clinical trial, it is not unusual for the placebo group to show superior safety and the standard-of-care group to show better efficacy. Given the dilemma of balancing cold science and clinical compassion, one can invoke a differential approach in providing ethical and compassionate care, depending on whether the clinician is proposing the off-label use of an approved drug, a new surgical procedure, or a new drug. The last option can only be performed under the watchful eyes of the FDA, and significant benefit and safety of the drug have to be shown in the early phases before the drug can be subjected to a phase 3 trial. Once a trial has completed enrollment and the minimum follow-up mandated by the FDA in the required two phase 3 pivotal studies, many companies have created expanded access compassionateuse protocols to provide more patients with the opportunity to be treated with promising new therapies prior to approval. These compassionate-use protocols also provide the added benefit of being able to collect data from patients, principally for additional safety analyses. Regarding new surgical procedures and off-label use of existing drugs, there are several important examples of the role of randomized clinical trials. Randomized clinical trials such as the Diabetic Retinopathy Study, the Early Treatment Diabetic Retinopathy Study, and the Macular Photocoagulation Study, all sponsored by the National Eye Institute, clearly established the benefits and risks of laser photocoagulation in patients with diabetic retinopathy and choroidal neovascularization associated with agerelated macular degeneration and have served as the gold standards for subsequent clinical trials in ophthalmology. Regarding expanding offlabel use of approved drugs, physicians have been allowed more Author Affiliations: Department of Ophthalmology, University of California Irvine (Drs Narayanan and Kuppermann), and LV Prasad Eye Institute, Banjara Hills, Hyderabad, India (Dr Narayanan).
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