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IMPACT OF PEDIATRIC EXCLUSIVITY ON SAFETY AND EFFECTIVENESS OF PEDIATRIC DRUGS: STAKEHOLDERS’ PERSPECTIVES by TIKA RAM RIZAL (Under the Direction of Paul J. Brooks) ABSTRACT Two-thirds of pediatric drugs currently prescribed have not been studied and labeled for pediatric use. The pediatric exclusivity provision established by the Food and Drug Administration (FDA) under Food and Drug Administration Modernization Act of 1997 (FDAMA) granted drug manufacturers six months of patent extension for conducting pediatric studies. This study seeks to identify by surveys and interviews of key stakeholders if the pediatric exclusivity provision has improved the safety and effectiveness of pediatric drugs vis-a- vis their improved labeling, dosing, and formulation information. In general, the pediatric exclusivity provision has been successful in stimulating pediatric studies by improving the labeling, dosing, and formulation of pediatric drugs. Respondents reported inadequate pediatric doses as the main problem and expensive pediatric trials as the main challenges in pediatric drug development. Well-designed pediatric studies conducted by highly trained investigators with active collaboration by parents are the key factors determining the success of studies for pediatric exclusivity. INDEX WORDS: Pediatric, Pediatric drugs, Pediatric Exclusivity, Safety, Effectiveness, FDA, Purposive sampling, Clinical trials, Pediatric labeling, Pediatric dosing

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Page 1: PEDIATRIC DRUGS: STAKEHOLDERS’ … of pediatric exclusivity on safety and effectiveness of pediatric drugs: stakeholders’ perspectives by tika ram rizal (under the direction of

IMPACT OF PEDIATRIC EXCLUSIVITY ON SAFETY AND EFFECTIVENESS OF

PEDIATRIC DRUGS: STAKEHOLDERS’ PERSPECTIVES

by

TIKA RAM RIZAL

(Under the Direction of Paul J. Brooks)

ABSTRACT

Two-thirds of pediatric drugs currently prescribed have not been studied and labeled for

pediatric use. The pediatric exclusivity provision established by the Food and Drug

Administration (FDA) under Food and Drug Administration Modernization Act of 1997

(FDAMA) granted drug manufacturers six months of patent extension for conducting pediatric

studies. This study seeks to identify by surveys and interviews of key stakeholders if the

pediatric exclusivity provision has improved the safety and effectiveness of pediatric drugs vis-a-

vis their improved labeling, dosing, and formulation information. In general, the pediatric

exclusivity provision has been successful in stimulating pediatric studies by improving the

labeling, dosing, and formulation of pediatric drugs. Respondents reported inadequate pediatric

doses as the main problem and expensive pediatric trials as the main challenges in pediatric drug

development. Well-designed pediatric studies conducted by highly trained investigators with

active collaboration by parents are the key factors determining the success of studies for pediatric

exclusivity.

INDEX WORDS: Pediatric, Pediatric drugs, Pediatric Exclusivity, Safety, Effectiveness, FDA,

Purposive sampling, Clinical trials, Pediatric labeling, Pediatric dosing

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IMPACT OF PEDIATRIC EXCLUSIVITY ON SAFETY AND EFFECTIVENESS OF

PEDIATRIC DRUGS: STAKEHOLDERS’ PERSPECTIVES

by

TIKA RAM RIZAL

FORB., Tribhuvan University, Nepal, 2003

A Thesis Submitted to the Graduate Faculty of The University of Georgia in Partial

Fulfillment of the Requirements for the Degree

MASTER OF SCIENCE

ATHENS, GEORGIA

2012

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© 2012

Tika Ram Rizal

All Rights Reserved

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IMPACT OF PEDIATRIC EXCLUSIVITY ON SAFETY AND EFFECTIVENESS OF

PEDIATRIC DRUGS: STAKEHOLDERS’ PERSPECTIVES

by

TIKA RAM RIZAL

Major Professor: Paul Brooks

Committee: Ronald Arkin

David Mullis

Randall Tackett

Electronic Version Approved:

Maureen Grasso

Dean of the Graduate School

The University of Georgia

May 2012

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iv

DEDICATION

This thesis is dedicated to my loving parents Laxmi and Kaushila Rizal. Thank you for being my

inspiration and support to better myself through higher education. Your sacrifices for me are

always appreciated. Where I am today is because of you. Mum, though you passed away, you are

always in my heart and truly missed.

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v

ACKNOWLEDGEMENTS

I would like to thank my thesis advisor Dr. Brooks for his advice and constructive criticism

during my research work. I want to thank my advisory committee-Dr. Mullis, Dr. Tackett, and

Ron Arkin, for their valuable expertise and guidance. I would like to thank Hye-Joo Kim,

Associate Director, Regulatory Affairs, at the Centers for Disease Control and Prevention (CDC)

Atlanta, for helping me realize my thesis topic. I would like to thank Johnna Hodges for her

continuous support and guidance throughout my studies at the Pharmaceutical and Biomedical

Regulatory Affairs program. I would like to thank my classmates for sharing their experiences

and knowledge throughout the program. Also, I would like to thank the pediatricians, clinicians,

pharmacists, regulatory affairs personnel, and the FDA staff for participating in the surveys and

interviews, in spite of their busy schedules, and providing me their valuable insights on pediatric

drugs and pediatric exclusivity. Finally, I would like to thank my wife for being so supportive of

my studies and for putting up with many days and nights of homework and projects. I could not

have done this without you all.

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vi

TABLE OF CONTENTS

Page

ACKNOWLEDGEMENTS ................................................................................................................ v

LIST OF FIGURES.......................................................................................................................... viii

CHAPTER

1 INTRODUCTION .......................................................................................................................... 1

1.1 Statement of the Research Problem ..................................................................................... 1

1.2 Purpose of Research ............................................................................................................ 2

1.3 Potential Outcomes of this Research ................................................................................... 3

2 LITERATURE REVIEW ............................................................................................................... 4

2.1 Pediatric Regulatory History ............................................................................................... 4

2.2 Challenges of Pediatric Drug Development ........................................................................ 6

2.3 Comments on Pediatric Studies conducted ......................................................................... 9

3 METHODOLOGY ....................................................................................................................... 11

3.1 Research Question ............................................................................................................. 11

3.2 Subsidiary Questions ......................................................................................................... 11

3.3 Study Design ..................................................................................................................... 12

3.4 Institutional Review Process ............................................................................................. 18

3.5 Data Analysis .................................................................................................................... 18

4 RESULTS .................................................................................................................................... 20

4.1 Survey and Interview Responses ....................................................................................... 20

4.2 Awareness of Pediatric Exclusivity ................................................................................... 21

4.3 Voluntary versus Mandatory Studies ................................................................................ 22

4.4 Studies conducted under Pediatric Exclusivity ................................................................. 24

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vii

4.5 Pediatric Conditions Requiring Studies ............................................................................. 28

4.6 Problems/Concerns with Pediatric Drugs .......................................................................... 31

4.7 Challenges of Pediatric Drug Development under Pediatric Exclusivity .......................... 35

4.8 Impact of Pediatric Exclusivity on Pediatric Age Category .............................................. 38

4.9 Advantages of Pediatric Exclusivity to Stakeholders ........................................................ 40

4.10 Disadvantages of Pediatric Exclusivity to Stakeholders ................................................. 41

4.11 Support for Pediatric Exclusivity Provisions .................................................................. 42

4.12 Pediatric Exclusivity and Drug Labeling ........................................................................ 43

4.13 Pediatric Exclusivity and Pediatric Dosing ..................................................................... 45

4.14 Pediatric Exclusivity and Pediatric Formulation ............................................................. 47

4.15 Duration of Pediatric Exclusivity .................................................................................... 48

4.16 Factors Affecting the Success of Studies for Pediatric Exclusivity ................................ 49

4.17 Adequateness of Incentive ............................................................................................... 50

4.18 Alternatives to Pediatric Exclusivity ............................................................................... 51

4.19 Comparison of Drugs Granted Pediatric Exclusivity and Drugs used by Children ........ 52

4.20 Criticisms for Pediatric Exclusivity ................................................................................. 54

5 CONCLUSION AND RECOMMENDATION ........................................................................... 56

5.1 Conclusion ......................................................................................................................... 56

5.2 Recommendation ............................................................................................................... 59

5.3 Study Limitations .............................................................................................................. 61

REFERENCES ................................................................................................................................ 64

APPENDICES……………………………………..…………………………………….………………..68

A SURVEY QUESTIONS .............................................................................................................. 68

B INTERVIEW QUESTIONS ......................................................................................................... 75

C INTERVIEW TRANSCRIPTS…………………………………………………….……………79

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LIST OF FIGURES

Page

Figure 4.1: The number of pediatric drugs granted pediatric exclusivity between

1998 and 2011 .......................................................................................................... 26

Figure 4.2: Pediatric conditions requiring studies ....................................................................... 29

Figure 4.3: Problems/concerns with pediatric drugs.................................................................... 32

Figure 4.4: Challenges of pediatric drug development under pediatric exclusivity .................... 35

Figure 4.5: Impact of pediatric exclusivity on pediatric age category ......................................... 39

Figure 4.6: Number of labeling changes for drug products granted pediatric exclusivity

falling within the scope of BPCA, PREA, and Pediatric Rule ................................. 43

Figure 4.7: Benefits of improved pediatric labeling as a result of pediatric exclusivity ............ 45

Figure 4.8: Factors affecting the success of studies for pediatric exclusivity ............................. 50

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CHAPTER 1

INTRODUCTION

1.1 Statement of the Research Problem

At a time when there is a need for safe, effective, and tested drugs, two thirds of pediatric

drugs currently prescribed have not been studied and labeled for pediatric use 1,2.

Up to 80% of

prescriptions for children in the hospital and in general practice are either unlicensed (without a

license for children) or used off-label (outside the indication or age for use approved by the

FDA) 3 as these drugs have not been subjected to clinical testing in pediatric patients. There are

significant deficits in our current knowledge of the quality and efficacy of many therapeutic

measures in children,4

and much pediatric therapeutic data is derived from studies in adults5.

Pediatric studies are needed for a number of reasons. Pediatric diseases are different from

adults. There is no analogy to neonatal diseases in adults, and illnesses affect children and adults

differently2. The effect of drugs can be different

2. Children may not tolerate some treatments

because of the taste or method of administration. The absence of adequate pediatric studies has

led to inadequate dosing information, drug safety issues, and ineffective treatment in children.2

Inadequate dosing information can create adverse reactions. The lack of pediatric safety

information can produce age-specific adverse reactions in children. The absence of pediatric

testing can lead to ineffective treatment through under dosing or prevent access to therapeutic

advances because physicians choose to prescribe existing, less effective medications in the face

of insufficient pediatric information about a new medicine.4

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Ideally, pediatric drugs should taste good, require reduced dosing frequency, have

minimal side effects, and employ improved delivery systems6. However, most pediatric

medications do not have adequate pediatric formulations and dosing guidelines for children

younger than 12 years of age6. In the absence of pediatric formulations, children are prescribed

adult formulations denying many important pediatric therapies with consistent bioavailability3.

Aimed at correcting this deficiency, Congress passed the Food and Drug Administration

Modernization Act (FDAMA) in 19972. Under Section 505A of the Act,

7 the Pediatric

Exclusivity Provision was established, which granted an additional 6 month patent extension, or

marketing exclusivity, to previously earned patent protection for certain drugs if the

manufacturers submitted requested information to the FDA regarding the use of the drug in

children.

1.2 Purpose of Research

The purpose of this study was to explore if the incentive scheme granted under the

pediatric provisions of FDAMA 1997 has stimulated pediatric studies in terms of number,

quality, and safety of pediatric drugs. Specifically, this study analyzed, by way of a questionnaire

survey and interviews based on stakeholders’ perspectives, if the pediatric exclusivity provisions

have improved the pediatric dosage forms, formulations, and labeling of drugs. Also, the

advantages and disadvantages of pediatric exclusivity provisions to pediatric patients and

consumers, medical practitioners, the FDA, and pediatric drug companies are discussed. Further,

the pediatric age categories where the impact of pediatric exclusivity was felt the most was

identified and suggestions are made as to which age categories need more studies. The major

problems and challenges of pediatric drug development, under the pediatric exclusivity

provisions are discussed and factors determining the success of the studies are outlined. A

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determination is made if the pediatric exclusivity provisions have helped to generate more useful

information to guide physicians in better prescribing drugs for children.

1.3 Potential Outcomes of this Research

The research has evaluated the impact of the pediatric exclusivity provisions in

improving the safety and effectiveness of pediatric drugs vis-à-vis improved dosage forms,

pediatric formulations and pediatric labeling, and increased number and improved quality of

drugs developed. Specifically, this study has provided information about the pediatric conditions

for which more studies are required, the kinds of studies required, the pediatric age categories

where more studies are required, the dosing type, labeling and formulation changes for an met

pediatric need. Suggestions are made as to what factors contribute the most to the success of

pediatric studies under the pediatric exclusivity provisions. Further, the adequacy of the

incentives and the appropriateness of its duration were analyzed. The results obtained from this

study should provide helpful information in formulation of any future regulations on pediatric

exclusivity. The study has provided suggestions for strengthening the quality and quantity of

pediatric clinical trials under the pediatric exclusivity to improve their efficacy and safety on

pediatric labeling and dosage. Overall, by identifying and analyzing the key factors affecting the

safety and effectiveness of pediatric drugs under the pediatric exclusivity provisions, the

pediatric drug development programs may be specialized to address the unmet pediatric medical

needs identified in this study.

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CHAPTER 2

LITERATURE REVIEW

2.1 Pediatric Regulatory History

Recognizing the need to have a determination of pediatric applicability and adequate

labeling instructions for children, Congress included incentives for conducting needed studies in

the Food and Drug Administration Modernization Act of 1997 (FDAMA). In 1998, Congress

passed the Pediatric Rule, which became effective in April 1999. The rule requires

manufacturers of new drugs to conduct studies to provide adequate labeling for the use of these

products in children if the drug is likely to be used in a substantial number of pediatric patients or

would provide a meaningful therapeutic benefit to pediatric patients over existing therapies 8,9

.

Due to slow progress, Congress added additional incentives in the Best Pharmaceuticals for

Children Act (BPCA) 10

in January 2002, which extended the economic incentives offered under

the Pediatric Exclusivity Provision by six months if adequate pediatric studies were performed

and allowed the FDA to formally request that such studies be performed 11

.

In 2003, the Pediatric Research Equity Act (PREA)12

which replaced the Pediatric Rule,

mandated pediatric studies for new active ingredients, new indications, new dosage forms, new

dosing regimens and new routes of administration, in support of New Drug Application (NDA)

and Biologics License Applications (BLA)13.

Additionally, the Act provided the FDA with the

authority to use bridging data from adult studies in approving pediatric medicines14

. These three

acts, together with continuing enabling legislation through the Prescription Drug User Fee Act

(PDUFA) renewals, encourage the development of pediatric drugs. In 2007, the Food and Drug

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Administration Amendment Act (FDAAA) reauthorized BPCA and PREA whereby a Pediatric

Review Committee (PeRC) was established 15

. The total number of studies completed under

BPCA and PREA pursuant to FDAAA16

between September 27, 2007 and December 31,

2011 was 360. Under these acts, the most studies were conducted within PREA (219), followed

by BPCA and PREA combined (72), and BPCA (69). The total number of patients in completed

FDAAA studies was 166,646. 16

The pediatric patient enrollment in studies conducted under

different Acts shows that the highest number of patients (114,731, 68.8%) were enrolled in

CBER PREA studies (vaccines and blood products), followed by CDER PREA studies (30,093,

18.1%). BPCA studies employed 21, 822 (13.1%) pediatric patients16

. Progress of pediatric

studies from September 27, 2007 (FDAAA) through December 31, 2011, based on the

information submitted by the applicants to the FDA, showed that in four years, 139 studies were

ongoing, 1104 studies were pending, 120 studies were submitted, 57 studies were fulfilled, 57

studies were released, 234 studies were delayed, and 13 studies were terminated.17

Studies were

delayed if their progression was behind the original study schedule. Delays have occurred in all

phases of the study, including patient enrollment, analysis of study results, or submission of the

final study report to the FDA. Pending studies are not delayed (i.e., the original projected date for

initiation of patient accrual or initiation of animal dosing has not passed) but they have not been

initiated (i.e., no subjects have been enrolled or animals dosed). More studies were delayed and

pending than were submitted and fulfilled, showing that the required studies are hard to come by

from pediatric clinical trials. The BPCA and PREA are set to expire on October 1, 2012 unless

Congress reauthorizes them. Many pediatric studies are expected to be conducted15

before these

key pieces of legislation expire.

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Until these acts (BPCA, PREA, and FDAAA) were passed, the approach in pediatric

drugs was first to develop a drug for adults and then adjust the dose for use in children15

. The

belief was if a drug was safe enough for adults, it would be safe enough for children. The three

acts (BPCA, PREA, and FDAAA) make the development of an "age-appropriate formulation" a

legal requirement if the drug under development is appropriate for children. Since the

implementation of FDAAA, the BPCA, the Pediatric Final Rule, and the PREA, hundreds of

drug trials have been conducted in children.

Many of these trials resulted in added FDA-approved indications for these drugs in

children. Similarly, many of these studies resulted in critical new warnings and safety data, new

pharmacokinetic data and dosing instructions, and even new designs for pediatric drug trials15

.

The present study will analyze the effectiveness of pediatric exclusivity provisions in stimulating

drug research in children, and should add valuable knowledge to this important regulatory arena.

2.2 Challenges of Pediatric Drug Development

Of the total global pediatric research conducted worldwide, only 6.5% is conducted in the

US compared to 47% in China, 33% in Russia, and 24.6% in the Czech Republic18

. More than

one-third of trials conducted under pediatric exclusivity provisions enrolled patients in sites

outside the US in developing/transition countries.19

This is mainly because of the reduced cost

and timeline of clinical trials conducted in less stringent regulatory environments overseas and

the ease of pediatric patient recruitment. 19

Some of these studies raise serious ethical and

scientific concerns. So, the need to conduct more pediatric trials is urgently felt in the US. Thus,

the US should increase its share of pediatric studies to obtain quality information rather than

depending excessively on pediatric studies outsourced to the emerging regions of the third world

countries.

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Pharmaceutical companies can earn pediatric exclusivity for an approved drug as well as one

in the approval process. To be eligible for pediatric exclusivity, an approved product must meet

the following three essential elements20

:

The applicant must receive a Written Request from the FDA asking for pediatric studies.

The request describes the studies needed to determine if the use of a drug could have

meaningful health benefits in the pediatric population. The FDA may issue a Written

Request for those studies at the request of an interested party or on its own initiative.

The studies must be submitted within the time-frame specified in the written request.

The studies performed must meet the terms specified in the written request.

The FDA has issued a Written Request (WR) For Pediatric Studies under the Best

Pharmaceuticals for Children Act (BPCA) to 19 approved active moieties with no marketing

protection (As of 11/24/2009). These moieties include: ampicillin, azithromycin, baclofen,

dactinomycin, daunomycin, griseofulvin, hydrochlorothiazide, hydrocortisone (hydrocortisone

valerate), isotretinoin, lindane, lithium, lorazepam, meropenem, methotrexate, metoclopramide,

morphine, rifampin, sodium nitroprusside, and vincristine 21

.

The development of pediatric drugs poses a number of challenges including ethical,

economical, logistical, and technical. There are ethical considerations when conducting studies in

diseases where a treatment is already available, where a placebo control is relevant,22

and in an

emergency setting. All of these affect the willingness of patients to participate in clinical

research. Even more challenging are the complex ethical issues presented by pediatric studies:

the unique requirements of recruiting minors and obtaining the appropriate level of informed

consent (or assent in the agreeing child's case), avoiding coercive or improper inducements, and

minimizing the distress and undue risk to the young patients who participate. Children, as a class,

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may be harmed due to lack of research into a disease and the effect of drugs. Further, the risks of

using drugs untested in children will always have greater potential for harm, given the high

figures for off-label and off-license use. Separate age-appropriate information sheets and consent

or assent forms should be developed for the parents or legal representatives and for the child.

Other ethical questions also constantly arise when sponsors consider pediatric trials. For

example, can healthy children participate in taste tests of pediatric liquid formulations? How

does one define “minimum risk” in terms of venipuncture and sample collection? Should

currently symptom-free children with cystic fibrosis participate in pharmacokinetic studies of

inhaled aerosolized antibiotics?22

How should investigators handle the need for contraceptives

for adolescents involved in therapeutic trials where teratogenesis may be of concern, such as

trials of new antiepileptics? What are the standards for off-license, off-label drug use in very low

birth weight infants (under 1 kg)? Do we need placebo-controlled trials when there is no existing

comparator, as in the case of antiviral agents?22

The ethical issues around compensation for

pediatric participants are also more challenging than in adult trials. Pediatric trials often find it

difficult to address several of these ethical challenges. The pediatric investigator and site staff

must be trained in the least-invasive and non-coercive methods for conducting pediatric studies,

and they must know how to budget their time and costs to prevent the patient or the practice from

unwittingly subsidizing the research. 22 A child’s response to illness varies with age. For

example, neonates and infants may be far more ill with a particular infection than an older child.

However, they may not be able to provide an assessment of pain due to an illness unlike an

adolescent. This can render statistical analysis difficult and perhaps inconclusive. Also, there is

lack of established relevance of surrogate markers for children. 22

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2.3 Comments on Pediatric Studies conducted

Inconsistent and confusing labels are present on pediatric drugs23

. There is dosing

information based on age, weight or both. Which is the best method is still unclear. Further, there

are pediatric labels of only a few medicines in children less than two years of age, but more

labels in drugs for children older than two years of age. Larger companies requiring additional

clinical studies were found to be better at filing exclusivity than smaller firms and the

competition level in each drug’s therapeutic class was positively associated with having

exclusivity. The drugs with exclusivities were more likely to treat chronic conditions that include

many blockbuster drugs.24

The European Union (EU) is of the opinion that pharmaceutical companies lack the

commercial interest to develop medicines for use in children.25

Studies in children are described

as being difficult to conduct, ethically challenging, and expensive26

. The development of specific

formulations adapted for use in children presents an additional expense. Furthermore, there is

little incentive to apply for the authorization of products for use in the pediatric population. To

stimulate the development of pediatric formulation, legislations were introduced in the EU

providing market incentives and regulatory requirements.27

The goals of these initiatives,

however, are difficult to reach if the challenges in pediatric formulation and taste optimization

are not well managed25

.

Mixed opinions have been reported on the adequacy of incentives provided under

FDAMA.28

The exclusivity provisions are not without criticisms. Some critics have described the

incentive provisions as a “carrot and stick” policy.28

The “carrot” is the voluntary pediatric

exclusivity provision of the Food and Drug Administration Modernization Act of 1997

(FDAMA), which was reauthorized in January 2002 and extended through 2007 as the Best

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Pharmaceuticals for Children Act (BPCA). The “stick” is the Pediatric Research Equity Act

(PREA), which allows the FDA to require pediatric studies. Some pediatric drug companies,

citing high costs, have tried to eliminate the pediatric rule for several years. Historically, many

pharmaceutical companies have opted not to conduct extensive pediatric clinical trials because of

the substantial fiscal, scientific, and ethical challenges they present. The comparative

effectiveness of medical interventions in adults versus children shows that treatment effects are

on average similar in adults and children,29

but available evidence leaves large uncertainty about

their relative efficacy. Clinically important discrepancies may occur29

. Extrapolation of adult

data to medicinal products for the child population is inappropriate. Many differences exist in

physiology, pathology, pharmacokinetics, and pharmacodynamics between children and adults

30. For example, in pharmacokinetics, there are differences in metabolic pathways, in organic

functions, and in metabolic rates. In pharmacodynamics, differences exist in receptor functions,

effector systems, and homeostatic mechanisms. Growth and development influence side effects,

and the dose of medications is dependent on body weight or surface area. Finally, age influences

severity of disease, pathological agents, and natural history. Children have become therapeutic

orphans due to the lack of adequate pediatric dosing information among drugs that are on the

market31

. Pediatric studies have reported improvements in dosage forms for children over the age

of six, but not much for younger children32

.

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CHAPTER 3

METHODOLOGY

3.1 Research Question

Has the incentive scheme granted under the pediatric exclusivity provisions of FDAMA

1997 stimulated pediatric studies in terms of number, quality, and safety of pediatric drugs? This

research has explored, by way of a questionnaire survey and interviews of key stakeholders, if

the pediatric exclusivity provisions have improved the safety and effectiveness of pediatric

drugs, vis-a vis their improved labeling, dosing, and formulation information.

3.2 Subsidiary Questions

1. Has the number of pediatric drugs developed changed before and after the passage of the

pediatric exclusivity provisions?

2. Were the development of pediatric drugs enhanced due to economic incentive provisions of

pediatric exclusivity?

3. Have the dosage forms, formulations, and labeling of drugs improved as a result of the market

incentive provision?

4. What are the advantages and disadvantages of pediatric exclusivity provisions to pediatric

patients and consumers, medical practitioners, and pediatric drug companies?

5. For what pediatric age categories are the impact of pediatric exclusivity felt the most and for

what age categories are more studies needed?

6. What factors could determine the success of studies for pediatric exclusivity?

7. What are the major problems with pediatric drugs?

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8. What are the challenges of pediatric drug development under the pediatric exclusivity

provisions?

The study determined whether the pediatric exclusivity provisions have improved the quality

of pediatric drugs making them more safe and efficacious, thus meeting the FDA’s intention of

passing the regulatory provision to a considerable extent. The information obtained from this

study should guide the formulation of any future regulations on pediatric exclusivity.

3.3 Study Design

A literature search was performed to identify prior studies conducted on pediatric drugs

and pediatric exclusivity. The search involved the following key words: children, pediatrics,

pediatric drugs, pediatric exclusivity, and pediatric clinical trials. Based on the titles and

abstracts, full copies of relevant studies were obtained. The FDA website was extensively used to

gather information to analyze data on the number and types of drugs granted pediatric

exclusivity. Based on the literature review conducted during the research proposal phase, a set of

interview questions was compiled and applied to the second level of research involving specific

human subject experts on the topic. The sample respondents for the survey and interview

included regulatory affairs personnel at pediatric drug manufacturing companies, pharmacists,

clinicians, pediatric consultants, and relevant FDA staff involved with regulating pediatric drugs.

The participants were identified through their company’s website, contact addresses, and

published articles. The pediatricians were identified through their hospital affiliations and contact

addresses available in the public domain, as well as through their contact information located

with their articles published in the peer-reviewed journals. All the respondents had demonstrated

experience and proven expertise with pediatric drugs.

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The inclusion criteria for the survey and interview were participants having essential

knowledge of pediatric drugs or having direct (manufacturing, research, clinical trials,

prescribing) or indirect (regulating) involvement with pediatric drugs for a minimum of two

years. Similarly, participants who willingly provided their informed consent were included in the

survey and interview to preserve the ethic of the study and to meet the IRB requirement.

Informed consent was obtained from each participant through an informational letter. The

exclusion criteria for the study were participants with less than two years of direct or indirect

experience with pediatric drugs. Also, participants not providing their informed consent to

participate were excluded from the study.

The author developed his own survey and interview instruments based on the literature

review. This was done because of unavailability of previously validated instruments. The survey

and interview questionnaires were the same except for one structural difference. A majority of

survey questionnaires were structured which asked for graded responses on a scale of 1-10

(where 1 denoted least or the lowest response and 10 denoted the most or the highest response)

to guide respondents to the best possible answers. However, most of the interview questions

were unstructured and did not ask for graded responses to allow respondents the flexibility to

state their perspectives. Moreover, the interview participants were asked additional questions if

necessary, based on their responses, for an in depth perspective on issues of central importance

to the research question. The draft questionnaire was preliminarily administered on a pilot scale

as a pre-test to three informed participants who met the inclusion criteria as the actual

participants. The participants’ responses were observed to determine the adequacy of the

questions for the research purpose. Responses were considered adequate if all the respondents

graded all structured questions on a scale of 1-10 as well as offered their perspectives on all

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open-ended questions. Accordingly, questions were improved, and modified to suit the purpose

of the research. Similarly, a follow-up post-test of the survey was conducted by way of phone

calls/email to participants to increase the validity of the data collected. In post-test, respondents

were asked to elaborate on certain points and illustrate others. A qualitative, non-random,

purposive sampling methodology was used for data collection. Using a purposive sampling,

which is a type of non-probability sampling, a specific predefined group of stakeholders with a

sound knowledge of pediatric drugs and pediatric exclusivity was sampled. Expert sampling,

which is a type of purposive sampling, was the best way to obtain information from stakeholders

with particular expertise in pediatric drugs. The expertise that was required during the

exploratory phase of qualitative research formed the basis of the study. Since there is lack of

empirical evidence and high levels of uncertainty of the impact of pediatric exclusivity on the

safety and effectiveness of pediatric drugs, expert sampling formed the cornerstone of the present

research design. The goal of the purposive sampling was to provide justification to make

generalizations from the sample that was studied. . Due to the complexity of the pediatric

exclusivity provisions, the respondents who were knowledgeable of the regulatory provisions

only participated in the survey and interviews while people who were not well informed of the

provision did not. Thus, responses obtained from well qualified and experienced participants

increased the validity of the study. A probability or random sampling method was not used for

the study. Probability or random sampling method if used would not have generated credible and

meaningful information on topics that required a highly specialized knowledge of pediatric drugs

and pediatric exclusivity. All survey and interview respondents were identified by using a

purposive sampling33

approach. Based on their knowledge and experience with pediatric drug

development, the author chose appropriate respondents for the study rather than random

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selection. This sampling method was used as there was a limited number of people with

sufficient expertise in pediatric drugs and pediatric exclusivity that could be accessed with ease.

Besides purposive sampling, a snowball-sampling method was also used. In this method,

regulatory affairs (RA) personnel who met the criteria for inclusion in the study were identified,

who in turn were asked to recommend another person in the similar field for the survey.

Similarly, pediatricians referred other pediatricians. The referred pediatricians generally had

authored several research articles related to the topic of interest that were published in peer-

reviewed journals. Many company-based RA personnel who were otherwise normally

inaccessible were reached by snowball-sampling method. Convenience sampling was used for

the research participation. The researchers whose articles on pediatric drugs were published in

peer-reviewed journals were contacted by email for the survey participation. These respondents

in addition to being knowledgeable in their respective fields were easy to access.

To minimize selection/sampling bias, respondents from across all stakeholders of

pediatric exclusivity were included. To avoid procedural bias in the response time, respondents

were given ample time (three weeks) to complete the survey. The respondents’ names have

remained anonymous and no individually identifiable information about them has been shared

with others. The results of the research study have been presented in summary form only and the

participants’ identity has not been associated with their responses in any published format. Since

all respondents were selected on meeting the set criteria, the sampling ensured strong quality

assurance and credible information.

For the survey, structured and open-ended questionnaires were administered via e-mail to

regulatory staff of pediatric drug manufacturing companies, pharmacists, and clinicians (n=10),

and pediatric consultants (n=10). Since the goal of the study was qualitative, sample size

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justification was also qualitative. Sampling of respondents was continued until saturation

occurred or upper bound was reached with the convergence of themes. Saturation occurred with

20 respondents when the same themes related to the research questions were repeated over and

over again and no new themes emerged. Though the sample sizes were small due to typically

busy and readily inaccessible respondents, the “information richness” of the cases and the

author’s analytical capabilities have made the qualitative inquiry in-depth, insightful, valid, and

meaningful.

The survey questionnaires were designed to obtain information about the number and

type of studies conducted for pediatric exclusivity, the motives behind the studies, and the

challenges faced in drug development. Also, questions pertained to challenges in developing

pediatric drugs, medical conditions for which pediatric exclusivity studies are required, kinds of

studies performed, pediatric age categories impacted, improvement in dosage form, formulations,

and labeling of drugs because of the incentive. Criticisms regarding pediatric exclusivity

provisions were questioned and suggestions for improvement sought along with factors affecting

the success of pediatric exclusivity provision. The survey questions are presented in Appendix A.

An inductive qualitative study34

was undertaken to identify and categorize perceptions

regarding the impact of pediatric exclusivity. The survey respondents were asked to rate their

responses to questions with multiple answers with varying degree of correctness on a scale of 1-

10. Responses below 5 were considered low in the descending order while responses above 5

were considered high in the ascending order. The average response from all participants for each

question was summed on a scale of 1-10 for analysis. The average score and percentage for each

response were calculated by a constant comparison process to determine the most common and

least common response from the sample. Constant comparison can be defined as a method to

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analyze word data by creating categories that are scored and used to develop conclusions,

themes, or hypotheses35

. Each item of datum was compared to the rest of the data to establish the

conclusion categories. This process was used to create numeric data from the qualitative word

data collected in the research interview process. The conceptual data were integrated to reveal

patterns and consensus among the group of stakeholders regarding the impact of pediatric

exclusivity. From the sampling observations and results, broader generalizations were theorized

and conclusions drawn from qualitative analysis of the data. As the study participants were

generally unknown to each other and to the author, they were expected to bring varied and

independent ideas to the research.

For the interview, a set of 10 participants were targeted. Over the phone interviews were

conducted with senior directors of regulatory affairs from two major pediatric drug

manufacturing companies (n=2) and FDA staff at the Office of Pediatric Therapeutics (OPT),

Center for Drug Evaluation and Research (CDER) (n=1), to obtain their experiences, thoughts,

and perceptions on the impact of pediatric exclusivity on the safety and effectiveness of pediatric

drugs. Although the interview target was not met, the responses collected were so consistent

from respondent to respondent for many questions that conclusions could still be drawn on the

pediatric population as a whole even with the smaller than desired sample size. Most of the

interview questions were unstructured and open-ended to allow maximum flexibility of

responses. The interview questions are presented in Appendix B. In designing the interview

questions, care was taken to ensure that when these questions were answered, they would

provide adequate data to develop conclusions that would answer the thesis question. The

questions intended for the industry respondents were same or very similar to questions intended

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for the FDA to facilitate comparison of responses. However, due to the different perspectives of

these two groups, this was not always feasible.

3.4 Institutional Review Process

This study proposal was submitted to The University of Georgia's (UGA) Institutional

Review Board (IRB) Office after completion of the IRB online training, for approval as required

by departmental policy, The University of Georgia policy,36

state law, 45 CFR part 46 37

, and 21

CFR part 5638

. For ethical considerations, the study was conducted only after the research

methods, study design, and survey/interview questionnaire obtained the UGA IRB approval

(Project Number: 2012-10182-0 Dated 9/27/2011).

3.5 Data Analysis

After the survey responses were received and interviews were conducted, inductive

qualitative studies were used to summarize and analyze the data39

. In inductive studies, broader

generalizations and theories are made from specific observations and patterns. Concepts are

usually associated with qualitative methods and often involve informal logic and critical

thinking. In inductive studies, related types of narratives are clustered together into a coherent

scheme based on the number of responses, their frequency, ratings, and commonality40

.

Qualitative data in the form of transcripts were analyzed by their content following Michael

Patton’s method as described in Qualitative Research & Evaluation Methods,34

In this method,

texts are explored to obtain reoccurring themes and patterns of thoughts between the

respondents. Phillip Burnard in his 16th volume of the 1996 Teaching the Analysis of Textual

Data: An Experimental Approach41

describes three steps to content analysis. First, the data, i.e.

transcripts, are read and categories are identified. Next, the data are divided into the identified

categories and finally, the data is presented in written form in which the identified categories

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from step one become the sub headings35

. Step 3 would also include "...verbatim sections of the

interviews..." which Burnard terms "...illustrations..." that show conclusions directly drawn from

the data and not personal opinion35

. Data from the study were analyzed utilizing Burnards's

method. The transcripts from each focus group were reviewed and categories identified. Then,

the participant's responses were separated into the appropriate category as identified previously.

As far as possible, research findings were “grounded” in the data that were received from the

survey and interview participants. Quotes from the interviews were transcribed on to the thesis

and key concepts were identified. These interview transcripts were used as evidence to

emphasize the primary interview findings. The interview transcripts are presented in Appendix

C. The interview responses served to supplement the survey responses for added clarity on issues

central to the research question. Numerical survey data were analyzed as a percentage for

comparison of impact to get the most common perspectives. Qualitative survey data were

analyzed from their narrative description. Finally, the numerical and qualitative survey data were

combined with the interview transcripts to identify themes to draw conclusions from them.

Conclusions were drawn to emphasize group responses of participants. Based on the research

findings, recommendations were made about the type of pediatric studies that should be explored

in greater depth in future studies on pediatric exclusivity.

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CHAPTER 4

RESULTS

4.1 Survey and Interview Responses

A total of 108 email requests for research participation, in the form of IRB approved

informational letter, were sent out to participants. Thirty-two (29.6%) informed participants

agreed to participate in the survey, to whom a questionnaire was sent out with their informed

consent. These participants included personnel from drug manufacturing companies,

pharmacists, clinicians, and pediatricians.

Among the pediatricians who participated in the surveys, 5 (50%) worked as instructors,

associate professors, or professors in pediatrics in various medical colleges, as well as practiced

medicines in their affiliated hospitals in the US. Four (40%) pediatricians were senior practicing

physicians, and one (10%) worked at the Child and Adolescent Treatment and Preventive

Intervention Research Branch at National Institutes of Health, Maryland. The industry

respondents were comprised of 2 associate directors of regulatory affairs, 2 directors of

regulatory affairs, 2 senior directors of regulatory affairs, 2 senior pharmacists, and 2 senior

clinicians. One of the two pharmacists worked for a pharmaceutical law group. Nine (45%)

respondents had one or more of their articles related to pediatric drugs published in peer-

reviewed journals. While 18 of the 20 survey respondents were US-based, two respondents were

non US-based-one a Canadian and the other a German. Both the international participants had

worked at the FDA and had expertise regulating pediatric drugs. The overall pool of respondents

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was knowledgeable and experienced in their respective positions to provide meaningful answers

to the survey questions.

Out of 32 respondents, 20 responses were received from pediatricians (n=10) and drug

companies, pharmacists, and clinicians (n=10), with a response rate of 62.5 % based on the

questionnaire sent. While the pediatricians answered 24.6% of the total questionnaires sent, the

respondents from companies, pharmacists, and clinicians answered 16.8%. The response rate

from pediatricians was 76.9% (10 out of 13) while the response rate from companies,

pharmacist, and clinicians was 52.6% (10 out of 19). The results indicate that while the

pediatricians involved in research and academia were more willing to respond to the survey, the

drug companies were more willing to talk about their own drugs than pediatric drugs in general.

Similarly, three over-the-phone interviews were conducted with two senior regulatory

affairs personnel in pediatric drug companies and one with the FDA staff at the Office of the

Pediatric Therapeutics (OPT). Although six FDA personnel were contacted for the purpose of

this research, only one agreed to participate. The primary reason given by other staff for not

participating was the inappropriateness for them to respond to many of the interview and survey

questions concerning the FDA’s positions on policy issues related to pediatric exclusivity,

BPCA, and PREA. While one respondent expressed his reluctance to give interviews without

permission from a supervisor or from the FDA’s Press Office, another respondent said that she

was advised by the FDA lawyers not to answer the survey.

4.2 Awareness of Pediatric Exclusivity

While 15 respondents (75%) were fully aware (awareness rating of 8.7 on a scale of 1-10)

of pediatric exclusivity provisions, 5 respondents (25%) were reasonably aware (awareness

rating of 5.5 on a scale of 1-10). Those respondents who were reasonably aware of pediatric

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exclusivity stated that the BPCA requires the FDA to issue summaries of data submitted under

the Pediatric Exclusivity Program but the agency policy requires the FDA to keep data secret.

Due to this “inconsistent policy,” respondents reported limited dissemination of the results of

the pediatric studies in the peer-reviewed literature, which was the reason for their reasonable

level of awareness of pediatric exclusivity. Comparison of the level of self reported awareness

of pediatric exclusivity provisions among stakeholders surveyed showed that the regulatory

affairs professionals (associate directors, directors, and senior directors) were fully aware

(awareness rating of 10 on a scale of 1-10) of pediatric exclusivity. The senior pharmacists and

senior clinicians were better aware (awareness rating of 8 on a scale of 1-10) than pediatricians

(awareness rating of 6 on a scale of 1-10). Since the regulatory affairs professionals most often

dealt with the FDA in their long pediatric product approval process, they had the highest level of

awareness of pediatric exclusivity. Similarly, the two senior RA professional and the FDA staff

interviewed said that they were “fully aware of pediatric exclusivity”. “For at least two studies

that I was involved, the FDA granted pediatric exclusivity,” said one RA personnel The

respondents who benefitted the most from the incentive provisions stated that they were “fully

aware of the regulatory requirements of pediatric exclusivity”. Overall results indicate a high

level of awareness of pediatric exclusivity provisions among stakeholders.

4.3 Voluntary versus Mandatory Studies

Fifteen (75%) survey respondents from industries and pediatricians said that they were

“fully satisfied with the flexibility and voluntary requirements” of pediatric exclusivity

provisions as opposed to a forced approach. These respondents stated that if these studies were

not voluntary, people would be “hesitant to conduct trials on children”, and hence there would be

no new trials and no novel medicines for pediatric conditions. Interview responses also offered

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support for voluntary and flexibility requirements of pediatric exclusivity. For example,

participants stated: “…it is up to the industry to decide if they want to take advantage of the

program”.., “…getting corporate buy-in by offering increased/prolonged profits on still useful

drugs seems more positive than a forced approach…” “…you don’t obtain exclusivity unless you

provide pediatric data…”, and “…the flexibility, sadly, is necessary…” The FDA staff

interviewed expressed his support for voluntary requirements stating “the economic incentive to

comply with the voluntary requirements balance the effort of compliance”.

To the question whether the FDA should make pediatric studies mandatory, 9 respondents (45%)

said that they supported “mandatory studies, in compliance with PREA” as long as they were

feasible, and assured that all pediatric age groups were appropriately treated. One RA staff

interviewed stated: “The FDA does make pediatric studies mandatory for applicable products in

accordance with PREA.” However, 18 respondents (90%) expressed concern that if these studies

were mandatory, it may “…cause fewer drugs to be available for children or delay drug

development…” while waiting on studies that were difficult to conduct. One RA staff

interviewed stated: “…I’d be concerned about the unintended consequences of mandated

pediatric research”, while one other RA staff said “…not sure it is feasible. The FDA cannot

make them [referring to pediatric studies] mandatory based on the current law. It is not a

regulatory issue but a legislative one.” Also, concerns were raised that making pediatric studies

mandatory could be problematic as there was very often a “force-fit”. Respondents cited, for

instance, that “children have different reasons to take antihypertensive than adults. So requiring

pediatric studies might be difficult, expensive, and not ultimately that beneficial”. However, all

respondents agreed that the need for pediatric studies should reflect “potential utility” and

expressed concern about unintended consequences of mandated pediatric research including high

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financial costs of drug development and risks of inadequate return on investment. Overall results

indicate that the regulatory affairs professionals, pharmacists, and clinicians more strongly

favored the mandatory studies in compliance with PREA than the pediatricians did.

4.4 Studies conducted under Pediatric Exclusivity

The FDA issues a written request (WR) to pharmaceutical companies before initiation of

pediatric exclusivity studies. The WR contains the required elements of the requested studies,

including indication, number of studies, sample sizes, trial design, and age ranges. Respondents

said that their company’s main motive behind conducting studies for pediatric exclusivity was

“improvement in pediatric dosages, labeling, and formulation”. For instance, an industry based

RA staff interviewed stated: “…primarily we had a pediatric indication. Exclusivity was granted

for work conducted to generate long-term safety and pharmacokinetic data to update the labeling

of the product”. One RA staff stated “…commitment of my industry to provide safe and effective

drugs to children”, “…compliance with PREA requirements”, as the main motives to conduct

studies for pediatric exclusivity followed by “financial rewards of pediatric exclusivity”.

The Best Pharmaceuticals for Children and Pediatric Research Equity Acts

(BPCA/PREA) have continued industry incentives and opportunities for pediatric drug trials

(PDTs). However, respondents opined that there was “…no current assessment of the capacity to

perform PDTs”. While 18 (90%) survey respondents noted an increase in PDTs since the initial

passage of BPCA/PREA, a dominant theme that emerged was that it was “insufficient” given the

high capacity of US PDTs. Respondents noted that this insufficient trials might hinder the

development of new drugs for children. Respondents stated the need for a more “transparent

pediatric testing process” where both positive as well as negative trial results are published or

otherwise publicly available post-trial. One pediatrician surveyed stated, “Future PDTs should

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provide additional information on “cardiovascular medicines, mental health medications, and

sedatives”. Eighteen (90%) survey respondents and all interview participants claimed that the 10

year period between the introduction of pediatric exclusivity (1997) and the reauthorization of

BPCA and PREA (September 2007) was a “great success, having generated some 800 studies

that have resulted in labeling changes for more than 100 drugs”. Respondents opined that, during

this period, more drugs were granted pediatric exclusivity than any other time due to the high

number of pediatric studies generated and much useful labeling changes resulted from them. One

RA staff interviewed stated “While the adult drug development is industry driven, pediatric drug

development is regulatory driven” [indicating the impact of pediatric exclusivity provision under

FDAMA in stimulating pediatric studies]. One other RA staff interviewed stated “Nothing has

worked better than incentives to get the pharmaceutical industry conduct pediatric clinical trials”.

The FDA staff interviewed stated that the exclusivity provision resulted in new studies and “has

been highly effective in generating pediatric studies on many drugs and in providing useful new

information regarding safety, efficacy, dosing, and unique risks of drugs in pediatric patients”.

The staff noted that the incentive “naturally tended to produce pediatric studies on those products

where the exclusivity has the greatest value” [referring to blockbuster drugs]. The FDA staff

further stated: The BPCA and PREA are “real success stories”; the pediatric exclusivity is “the

most successful pediatric initiative that the Agency has participated in to date” and the

regulations have been a “big advance” in developing pediatric medicines. Furthermore, the FDA

staff reported a “substantial increase in the number of pediatric clinical trial data” submitted to

the Agency under the BPCA and PREA. However, the FDA staff cautioned, “to what extent can

policy makers rely on incentives alone as a means of ensuring appropriate testing” remains

unclear. One survey respondent reported “numerous gaps” in current pediatric testing of both

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“off-and on-patent” drugs and said that pediatric exclusivity is “far from perfect”. One other

respondent stated, “Pediatric exclusivity has been undeniably successful but could have been

more successful”. Overall responses indicate that though pediatric exclusivity provision has been

successful in stimulating pediatric studies, the pharmaceutical industries need to conduct testing

of more pediatric drugs and make results publically available to ensure that they are safe and

effective.

The number of drugs granted pediatric exclusivity year wise from 1998 through 2011 was

counted from the FDA website and assembled into a chart. In 13 years, 185 drugs were granted

pediatric exclusivity* (Figure 4.1).

Figure 4.1: The number of pediatric drugs granted pediatric exclusivity* between 1998 and 2011

Note: *Figure based on the numbers and data that have been extracted from the FDA website from information

published in: Pediatric Exclusivity Granted. Available at:

http://www.fda.gov/downloads/Drugs/DevelopmentApprovalProcess/DevelopmentResources/UCM223058.pdf.

The most frequent drug groups that were granted pediatric exclusivity were reported to be

lipid-lowering preparations, antidepressants and mood stabilizers, ACE inhibitors, HIV

Year

No.

of

dru

gs

gra

nte

d p

edia

tric

excl

usi

vit

y

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antivirals, and non-steroidal anti-inflammatory and anti-rheumatic drugs, and drugs to treat

hypertension and elevated cholesterol. Respondents reported that numerous pharmaceutical

manufacturers initiated trials of their drugs in pediatric patients after the pediatric exclusivity

provisions were enacted to “take advantage of the incentive provisions”. Respondents reported

that nearly all drugs evaluated in exclusivity-inspired pediatric research had no serious adverse

events necessitating enhanced adverse event monitoring.

Analysis of the number of drugs granted pediatric exclusivity company-wise showed that

AstraZeneca had the most drugs granted pediatric exclusivity (14 or 7.6% of total pediatric

exclusivity granted until 2011), followed by GSK and Merck (13 or 7% of total pediatric

exclusivity granted until 2011) and Novartis had the third highest pediatric exclusivity granted (9

or 4.9% of total pediatric exclusivity granted till 2011). Though these multinational

pharmaceutical companies do not specialize in pediatric drugs, these firms with their high

volume of research and development have produced many drugs including several pediatric

drugs that were granted pediatric exclusivity. Big companies have availed incentive provisions of

pediatric exclusivity the most and developed many pediatric drugs.

The survey results from informed participants, on the kinds of studies conducted under the

pediatric exclusivity provisions showed 6.5 (65%) for efficacy and safety studies, 1.8 (18%) for

pharmacokinetics/safety studies, 1.0 (10%) for safety studies, and 0.7 (7%) for

pharmacokinetics/pharmacodynamics and pharmacokinetics/safety studies. Similarly, the

interview respondents reported that the most common studies conducted under pediatric

exclusivity were “efficacy/safety” followed by “pharmacokinetics/safety” studies.

In general, respondents stated that the type of study conducted depended on the “type of drug

developed and its risk benefit profile”. Although safety information was collected on all studies,

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only the safety and efficacy studies were generally designed and/or powered to detect safety

signals. One interview respondent stated, “If we understand how a drug works in adults, then

pharmacokinetic studies are sufficient for pediatric population…” Respondents reported that

pharmacokinetic studies. Interview respondents reported that the time to complete efficacy

studies was approximately 50% longer than pharmacokinetic studies (median 24 months vs 16

months). The median duration of bioequivalence studies was reported to be 6 months (range 5-7

months). Similarly, most respondents reported a higher cost of completing safety and efficacy

trials than pharmacokinetic trials. Interview respondents reported that many pediatric studies

were delayed and pending. The FDA staff interviewed stated: “…for timely development of

pediatric drugs, all pediatric studies that are delayed and pending need to be expedited”. One

pediatrician working with the NIH stated, “NIH has to conduct more studies of off-patent

pediatric drugs for which specific appropriation should be granted”.

While 17 (85%) respondents agreed that safety, pharmacokinetics, and

pharmacodynamics studies are a must, 2 (10%) respondents perceived that more short-term

efficacy and safety and pharmacokinetics and long term safety data are needed. One respondent

(5%) outlined that efficacy studies can be difficult or unethical depending on the product, and the

regulations have allowed for extrapolation of efficacy under certain circumstances. All 20

(100%) survey respondents and all 3 (100%) interview respondents agreed that studies conducted

under a written request (WR) with the FDA are adequate.

4.5 Pediatric Conditions Requiring Studies

When asked about their thoughts on which pediatric medicines currently available in the market

need non-clinical and clinical studies to establish their safety and efficacy, pediatric cancer

topped the list (7.5, 75%), followed by neonatal conditions (6.9, 69%), pediatric MRSA (6.4,

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64%), heart disease (6.3, 63%), HIV (6.2, 62%), and pediatric hypertension and asthma (5.3,

53%) (Figure 4.2).

Figure 4.2: Pediatric conditions requiring studies

Respondents outlined the need to generate information regarding the pharmacokinetics,

safety, and efficacy of pediatric cancer drugs specifically for neuroblastoma. Respondents stated

the urgent need of studies to better understand the biology and causes of childhood cancer to help

develop targeted therapeutics by integrating the latest molecular techniques. One RA personnel

interviewed stated, “Pediatric cancer studies are needed depending on the type of malignancy as

the pathogenesis may be similar in certain cancer”. Similarly, respondents outlined the need to

perform clinical studies on drugs for the treatment of pediatric pain, neonatal seizures, and

bronchopulmonary dysplasia among others. One interview respondent stated: “Neonatal studies

are very hard to conduct but the inherent safety concerns are a critical question especially for

long term development”. Also, a need to generate “safety and pharmacokinetics data in the use

of drugs like tetracycline, doxycycline, clindamycin, trimethoprim-sulfamethoxazole, in the

Sca

le (

1-1

0)

Pediatric conditions requiring studies

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treatment of pediatric MRSA was expressed”. Respondents stated, pediatric HIV studies are a

“major ongoing concern worldwide” but a minor concern in the US. The need of long-term

safety assessments of drugs in the treatment of pediatric asthma and their delivery systems was

also emphasized. Similarly, respondents outlined the need to conduct studies on pediatric

“antidepressants, ADHD medications, antiepileptics, and anti-infectives (especially antivirals

directed towards influenza”. Additionally, the respondents suggested “childhood obesity, fragile

X syndrome, sickle cell anemia, and Attention Deficit Hyperactivity Disorder (ADHD)” as

future areas of research consideration.

In general, responses indicated that for conditions that are common in children such as asthma,

bacterial/viral infections, dermatologic conditions (like eczema), medications targeting these

conditions should always be studied pre-approval in this important population. Also, for

conditions where there are safety concerns like developmental or neoplastic conditions due to

rapidly dividing cells, pediatric studies are required. Overall responses indicated that pediatric

conditions requiring studies was dependent upon the science of the medication, the safety &

pharmacokinetic profile, and the prevalence/incidence of the condition.

While 17 (85%) respondents outlined the unmet medical needs for pediatric conditions,

two (10%) respondents said that they did not have sufficient expertise to prioritize a list and one

(5%) respondent said that he did not use the pediatric medicines enough to answer all the

questions.

When queried about what pediatric medicines currently available in the market do not

require pediatric studies (non-clinical and clinical), 16 (80%) respondents said that ideally all

medications require pediatric studies as none of the medicines that they use are completely and

thoroughly studied. These respondents felt that out of hundreds of pediatric medications in the

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market, they had no clues, which have an adequate evidence base of safety and efficacy, and

which do not. The safety and efficacy range is much too broad. One pediatrician, specializing in

infectious diseases with 20 years of experience, opined that even in his own field, he did not

“know the full evidence base”. Twelve (60%) respondents said that medicines which are “rarely

used in the pediatric population, and medicines for diseases in which the affected physiological

systems are not altered” in pediatric patients, do not require pediatric studies. One interview

respondent said, “No further pediatric hypertension trials are needed in teenagers as there are at

least a dozen studies already conducted in them”. The respondent further stated, “if you want to

spend government dollars [referring to incentives of pediatric exclusivity] in pediatrics, I would

not recommend hypertension trials in obese teenagers, a disease caused by overeating. I am

ready to cure cancer as a tax payer”. In general, responses indicated that drugs that are already

labeled in pediatrics with published data and known to be fairly safe and effective do not require

pediatric studies.

4.6 Problems/Concerns with Pediatric Drugs

Eighteen (90%) out of 20 respondents expressed one or more problems/concerns with pediatric

drugs. On averaging the concerns, pediatric doses (8, 80%) ranked the number one, followed by

pediatric formulations (6.5, 65%) and pediatric labeling (6.4, 64%). Other concerns expressed

included indications for use (6.3, 63%), off- label use (6.2, 62%), unlicensed pediatric drugs (6.0,

60%), and routes of administration (5.6, 56%) (Figure 4.3). Respondents said that pediatric doses

are different from adult doses, which is not always taken into consideration seriously, resulting in

inadequate dosing information. For instance, pediatricians, pharmacist, and clinicians surveyed

stated that pediatric doses are “not standard” and there can be “errors in dose calculations”,

“suspensions often have to be compounded,” and “tablets may have to be cut”. Concerns were

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Figure 4.3: Problems/concerns with pediatric drugs

expressed that the “therapeutic and toxic dose” can be very close and there is no clear distinction

between the two. Concerns were raised that very little research exists to demonstrate what dose

would be appropriate for use in children to achieve a “therapeutic effect”. One survey respondent

stated that, within the pediatric population, the “appropriate dose for a 5-year old is different

from that for a 15-year old”. This may lead to “ineffective treatment through under dosing or

overdosing”. Participants recommended a flexible oral dosage form for children that can be taken

whole, dissolved in a variety of liquids, or sprinkled on foods, making it easier for children to

swallow.

The second major concern expressed was that drugs are given in formulations not

accepted in children, which may be poorly or inconsistently bioavailable. Participants outlined

that not all commercially available pediatric drugs meet the ideal pediatric dosage form

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requirements to be “orally dissolvable, tasteless, having minimal amounts of excipients, stable in

light, humidity, and heat, and having necessary release characteristics and dosage increments for

infants”. One interview participant suggested that formulation issues can be solved through

“research involving advanced knowledge in formulation (e,g reaction kinetics, taste–masking

technologies, physical chemistry of drug solubility and forms, taste assessment/optimization and

biopharmaceutics)”. Formulations for pediatrics, preferably a liquid, covering a broad age range

was recommended for children.

The third major concern expressed was that some drugs prescribed for children are not

labeled for them. The labeling of cough and cold medicines for children under 2 years of age

advising parents to “consult your physician” infers that pediatricians have access to dosing and

safety information unavailable to consumers. Participants expressed concerns that drugs are often

prescribed in children for different indications than in adults.

Participants outlined that many pediatric drugs are used “off-label and off-license” by

physicians, the scale of which is unknown. Participants reported that drugs were prescribed off-

label in relation to either “indication or age”. Many pediatricians, in their efforts to provide the

newest and best treatments, even adapt information developed in adult trials on children. The

acceptance of off label use provides companies less incentives to conduct pediatric trials.

Besides, the absence of strict statutory mandates and market demands often lead to a sponsor's

decision to not pursue pediatric studies. When questioned if the FDA does not control off-label

use, one RA personnel stated: “The FDA cannot deny treatment to kids when there are no better

medications for them”. One pediatrician who had published articles on off-label use of pediatric

drugs said that the majority of indication-related off-label use involved “gastrointestinal and

respiratory disorders”, while age-related off-label uses mainly involved “asthma medications and

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anti-convulsants”. Interviewed participants stated that the most frequently used “off-label drugs

are analgesics, bronchodilators, and antibiotics”. One pediatric respondent cited propofol, a

short-acting intravenous anesthetic, not licensed in children but used in intensive care units for

their sedation that caused metabolic acidosis and 15 deaths in children. The problem with off-

label and off-license use was that the drug manufacturing company has no product liability, thus

posing risks of adverse events associated with the drug.

When asked how the problems with pediatric drugs can be solved, all participants stressed the

need to conduct enhanced research on these issues by making “clear assessment of overall

benefits and risks”. Respondents overwhelmingly stated that one has to balance the degree to

which a certain medication is needed versus its potential side effects. Respondents recommended

that the drug should only be commercialized if its potential benefits outweigh its risks in specific

age pediatric population. One interview respondent stated, “if there is a significant benefit with a

minimal risk based on cumulative data, there should be minimal need for companies/physicians

to waste valuable resources on specific development studies”. The FDA staff interviewed stated,

“If there is uncertainty regarding either the benefits or the risks, the FDA under the authority

given by Congress mandates post-licensure studies to companies, and should also be able to have

significant sanctions in the event these post-marketing studies are not completed”.

When asked if the pediatric exclusivity provisions have helped to resolve the identified issues, all

respondents were affirmative. They stated that pediatric exclusivity has provided the economic

incentives to conduct pediatric studies to develop “pediatric specific dosing, formulations, and

labeling changes” in hundreds of therapeutics in children. Participants stated that pediatric

exclusivity has driven the need to determine the “risk benefit profile” of pediatric products prior

to being able to actively advertise for this patient population. This provides better confidence that

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the results will be pediatric patients beneficial. However, all participants suggested that much

more work still needs to be done to ensure the safety and efficacy of pediatric drugs.

4.7 Challenges of Pediatric Drug Development under Pediatric Exclusivity

When asked about the challenges of pediatric drug development under pediatric

exclusivity, (the average of responses of all 20 participants listed on a scale of 1-10) the main

challenges outlined were expensive trials (8.5, 85%), pediatric patient recruitment difficulties

(8.0, 80%), consent and assent process (6.1, 61%), scientific challenges (5.8, 58%), and cultural

bias against pediatric trials (5.8, 58%) (Figure 4.4).

Figure 4.4: Challenges of pediatric drug development under pediatric exclusivity

Participants explained that pediatric clinical trials performed under the pediatric

exclusivity program were “expensive and their economic returns were variable”. Participants

expressed their concerns that not all trials were profitable and remunerative. For new or

established drugs, the participants feared “possible lack of return on investment”, which may

deter drug firms from conducting any new clinical research. Participants opined that while the 6-

month patent extension granted under pediatric exclusivity is a huge incentive for blockbuster

drugs, the incentive is not enough to stimulate studies for rare pediatric indications or orphan

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drugs. However, overall responses show that economic incentives to comply with the voluntary

requirements generally balance the effort of compliance by way of increased/prolonged profits

and favorable return on investments.

Participants outlined that recruiting pediatric subjects was difficult since many diseases

are less common in children. Therefore, pediatric patients with the same conditions were more

scattered, difficult to find, and a few in number, leading to additional logistical and cost issues.

Further, participants stated that there was likely pressure being placed on children with chronic

diseases to enter a series of studies because their target population was small. The survey

participants, who were parents themselves, expressed their reluctance to enroll their children in

basic research with no perceivable immediate benefit. Further, the participants noted, “healthy

children were difficult to recruit” because research to them was perceived as “non-therapeutic”.

In addition, concerns were raised that many parents have reservation about enrolling their

children in placebo-controlled trials, as they do not understand these trials, which benefit

pediatric populations rather than the research participant directly. One interview participant,

however, noted “parents with children with life threatening diseases like leukemia and cystic

fibrosis for which standard therapies were unsatisfactory, were more willing to enroll their

children into research”.

Participants recommended that adequate and appropriate information about the potential

benefits and risks of clinical trials should be provided to parents and children in a child friendly

and unambiguous language. Also, appropriate transportation facilities to investigative sites,

research facilities, and communication in multilingual and multicultural populations will enhance

recruitment and retention and positively affect the quality and timeliness of a trial. Further,

participants unanimously agreed that for children to benefit from advances in pediatric research,

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both healthy children as well as children with chronic diseases should be enrolled as subjects in

potentially harmful research or research involving high risks.

Eighteen (90%) survey participants stated that pediatric research presents complex ethical

issues of “informed consent and assent” (in case of an agreeing child) processes to protect

vulnerable populations from undue risk. Participants stated that as children are unable to give

informed consent for their participation, they are particularly vulnerable to research-related

abuses. Also, they have greater potential for harm from the risks of using drugs untested in them

or being used as “guinea pigs”. “Can a 7 year old (the age arbitrarily recommended for including

children in the assent process) fully understand the complexities of clinical trials to which he/she

is assenting to?,” remarked one interview participant. However, 2 (10%) survey participants

stated that unless there is a risk of undesired effects there should be no major ethical concerns;

nonetheless the ethical controls surrounding the conduct of the study should be heightened.

“Whether pediatric participants are adequately compensated for their research participation is

another area of concern”, one respondent noted. Respondents also noted that researchers

sometimes underestimate “the stress of short-term pain (such as blood sampling)” in young

children. Because of small blood volume of children, not more than 5% of the circulating volume

can be taken for pharmacokinetic studies with frequent blood sampling, respondents stated.

Respondents suggested that researchers “conduct a proper informed consent and assent

process, avoid coercive or improper inducements, use less complex information sheets, and

minimize the distress of pediatric participants”. Researchers should make every effort to

anticipate safety issues and design pediatric studies that minimize patient risk while balancing

the potential benefit and harm of research, respondents noted.

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Respondents noted that there is only a “small pool of trained pediatric investigators” at a

time when there is increased demand for pediatric studies. They note that this has increased the

competition for resources and raised the cost of pediatric trials. Respondents noted that because

there are inherent “biological, psychological, and pharmacological differences between various

pediatric age groups”, trial designs are challenged to carefully weigh and balance these factors to

ensure valid results. The other issue that was pointed out by the participants was “the lack of

established relevance of surrogate markers for children”. Participants stated that “quality-of-life

questionnaire” to assess the impact of a disease or treatment on various aspects of a patient’s life

needs to be validated in children.

Respondents noted that since drug development programs were more geared towards

adults due to the high frequency of their illness and large market share of their drugs, pediatric

drug development programs get side tracked. Three survey respondents stated that some

pharmaceutical industries manifest a “corporate inertia” that favors the development and

marketing of new drugs for adult populations, thus delaying pediatric studies. However, this was

not true for all pharmaceutical companies. For instance, one interview participant stated,

“…really depends on your legal perspective; we have no bias against conducting pediatric

studies”.

4.8 Impact of Pediatric Exclusivity on Pediatric Age Category

When respondents were asked which pediatric age categories benefitted the most from

the incentive provisions of pediatric exclusivity (benefits rated on as scale of 1-10) they ranked

adolescents (12-16 years) at the top (9, 90%), followed by children (2-12 years) (7.4, 74%),

infants (1 month-2 years) (4, 40%), and neonates (0-1 month) (3.8, 38%) ranked at the bottom

(Figure 4.5).

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Figure 4.5: Impact of pediatric exclusivity on pediatric age category

The respondents cited “ease of recruitment of older pediatric patients” as the main reason

why the majority of studies were conducted in adolescents under pediatric exclusivity. Besides,

they stated, “… the size of the patient population and the economic incentive expected with each

of these age groups is directly correlated with the increase in pediatric age”. Participants cited

less challenges with recruitment and study procedures with older children who are also able to

give meaningful feedback on the effect of drug. Also, respondents stated that due to “ethical and

logistical issues”, older children are easier to recruit than neonates and infants. Most respondents

stated in general terms that younger children have benefitted more from the exclusivity

provisions than neonates and infants. They stated, “Adolescents due to their closer relevance to

adults in physiological maturity and overlap of broad indications”, have benefitted the most, but

not to the same degree as adults. In contrast, respondents felt that the youngest age children,

which are the most difficult to study, make it the hardest to demonstrate overlap with adult-use

drugs. Thus, respondents opined that in general, improvements in licensing of medicines have

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occurred for “children over the age of six, but not much for younger children”, subsequent to the

pediatric exclusivity provision.

4.9 Advantages of Pediatric Exclusivity to Stakeholders

The main advantage of pediatric exclusivity as reported by the stakeholders is improved

global health care of children because of “better dosage, labeling, and drug safety information”

provided based on clinical studies. Respondents from pediatric drug companies (8, 80%)

reported that the main advantage of pediatric exclusivity to them was the “high profit earning”

due to increased drug sales and bigger market share of their drugs because of the 6 month patent

extension. Respondents stated that the high profit/ high return on investment was also due to

“slow generic intrusion” as a result of exclusivity, which led to “optimization of pediatric

product marketing”. Six (60%) pediatric drug company respondents stated that since the FDA

lists applications submitted as a result of pediatric study under the BPCA as a “priority

application”, they are granted a faster review and 6 month patent exclusivity to all forms of a

drug product line containing the active moiety. This “additional marketing control”, the

respondents reported, is the “financial incentive” of pediatric exclusivity. One interview

respondent stated that the primary beneficiaries of pediatric exclusivity are the pharmaceutical

companies rather than study participants or pediatric population. Pediatricians (9, 90%) reported

easier “prescription justification” and avoidance of possible lawsuits because of better dosing

and labeling information for pediatric drugs. Four (40%) pediatricians reported “increased

practitioner loyalty and trust by patients” as a result of better prescription and safety information

provided to them, based on studies conducted under pediatric exclusivity. One RA personnel

interviewed stated, “I would say these [referring to the benefits of pediatric exclusivity to

stakeholders] are equally aligned. Companies receive the economic benefit for conducting the

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studies while pediatric patients and pediatricians receive the assurance that the products will

have a positive benefit risk profile”.

4.10 Disadvantages of Pediatric Exclusivity to Stakeholders

A majority of survey respondents (18, 90%) reported that the main disadvantage of

pediatric exclusivity provisions was that it “raised consumer expenditure on brand name or

patent drugs” by delaying the time for generics to appear by 6 months. Two (10%) respondents

reported that pediatric exclusivity “raised the economic costs of government” due to higher

expenditures by Medicaid during the sales of brand name drugs during 6 month exclusivity

periods. Three (30%) pediatricians felt that they were challenged to “keep abreast with” all the

recent drugs granted pediatric exclusivity, amidst their busy schedules, which added “confusion

in prescribing” to pediatric patients. While 4 (40%) respondents from pediatric drug companies

voiced concern over the loss of revenue by the generic drug industry and retail pharmacies

during the exclusivity period, 6 (60%) respondents voiced concern over the problems with

meeting the high costs of clinical studies for pediatric drug development. One RA staff

interviewed stated that pediatric exclusivity puts a “financial burden on consumers” [indicating

the high cost the consumers are forced to pay on brand name drugs during the exclusivity period

when less expensive generics are delayed by 6 months] while delivering a “windfall” [indicating

the high profit earnings from sales of brand name drugs which are expensive] to the prescription

drug industry. In general, findings indicated that for drug companies, the main disadvantage of

pediatric exclusivity was the burden of conducting pediatric studies with the return on

investment not always apparent. For patients, taxpayers, and prescribers, the main disadvantage

of pediatric exclusivity was the economic impact of longer term for branded medicines before

generics can enter as well as the burden of study involvement.

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4.11 Support for Pediatric Exclusivity Provisions

When queried if they support pediatric exclusivity, 18 (90%) respondents said that they

overwhelmingly support the provision because it grants companies the “incentive to conduct

clinical studies” to provide useful information on dosing, labeling, and safety of pediatric drugs.

Additionally, the respondents stated that the exclusivity provision provides the consumer with

the much needed confidence that the drug product has been adequately “tested in the intended

patient population”. However, 2 (10%) respondents expressed their concerns regarding

exclusivity. They stated that since pediatric studies are “costly to taxpayers” in the form of

Medicaid payments for brand name drugs, NIH should fund research for those drugs that

industries decline to take on. When asked for the level of support for pediatric exclusivity (on a

scale of 1-10) the average responses of all participants earned a score of 9.2 (92%), which is

overwhelming.

Eight (40%) respondents stated that the results of pediatric studies need to be more

“transparent” (i.e. published in the peer-reviewed literature). They expressed ethical concern

about the appropriateness of financial incentives to participants, since the majority of the studies

are performed in the developing world, not in the US. They questioned, “Will children in the

third world reap possible benefits of research?” Three (15%) participants, citing a heavy tax

burden on consumers, stated that Congress should “reduce exclusivity or scrap” the program all-

together. They felt that NIH should study off patent pediatric drugs but continue to require

industries to conduct pediatric studies for new drugs. However, most participants (15, 75%)

stated that a reduction or cancellation of the exclusivity will “curb industry enthusiasm” for

undertaking new and costly pediatric trials, especially on drugs with small market sizes.

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4.12 Pediatric Exclusivity and Drug Labeling

Eighteen (90%) respondents reported that pediatric exclusivity has resulted in improved

pediatric drug labeling. A study of pediatric labeling changes information in the FDA web site

through January 4, 2012, showed that a total of 426 labeling changes were made for pediatric

drugs*. This included 388 (91%) labeling changes for drugs with new pediatric studies and 38

(9%) labeling changes for drugs with no new pediatric studies (NNPS).

One hundred forty seven (35%) of the labeling changes in the drugs granted pediatric

exclusivity fell within the scope of BPCA only, 50 (12%) with BPCA and PREA, 181 (42%)

PREA only, and 48 (11%) Pediatric Rule. All these labeling changes were based on information

obtained from clinical trials in pediatric patients (Figure 4.6). Respondents reported that under

Figure 4.6: Number of labeling changes for drug products granted pediatric exclusivity

falling within the scope of BPCA, PREA, and Pediatric Rule.*

Note: *The number of labeling changes under different pediatric regulations have been extracted from the FDA

website and assembled into a chart from New Pediatric Labeling Information Database. Available at:

http://www.fda.gov/downloads/ScienceResearch/SpecialTopics/PediatricTherapeuticsResearch/UCM163159.pdf

PREA, when the FDA mandated pediatric studies, companies conducted a substantial number of

pediatric studies resulting in the largest labeling changes ever in the history of pediatric drug

Pediatric Regulations

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regulation. Respondents stated that the pediatric exclusivity provisions have provided new and

useful information about whether and how drugs work in children. Respondents stated that

labeling changes have included “new child-safety information, new or altered pediatric dosing

information, additional warnings about adverse events in children, recommended dosage

modifications, and findings of lack of efficacy for some drugs”. Improved drug labeling resulted

in “improvement in compliance” by prescribing physicians and pediatric patients, reported the

surveyed pediatricians. One pediatrician stated, “We have an improved understanding of the

pharmacokinetics of drugs we prescribe in pediatric population. Thanks to the exclusivity-

inspired pediatric clinical studies”. However, one RA staff questioned “Can it [referring to

pediatric exclusivity provision] guarantee that companies receiving exclusivity make the results

of their studies known through the labeling changes necessary for safe and effective use of

drugs?” All pediatricians surveyed said, that the clinically important pediatric drug labeling

information updates from pediatric dosage book influenced their prescribing behavior. Thus,

pediatric exclusivity was effective in stimulating pediatric testing and the resulting

improvements in labeling for the development of safer and more effective pediatric drugs.

When participants were asked about the benefits of added pediatric labeling (average

responses rated on a scale of 1-10), they reported reduced medical errors (6.5, 65%) as the top

benefit, followed by decreased hospitalizations (4.8, 48 %), and fewer physician visits (4.5,

45%). Other benefits reported were less days missed from school and work by children (4.1.

41%), lower treatment costs (3.7, 37%), and lower health insurance premiums (3.0, 30%) (Figure

4.7).

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Pediatricians, pharmacists, and clinicians noted the increasing implementation of various

risk reduction strategies to reduce pediatric medication errors. Reported strategies include

“development and maintenance of pediatric formulary, limiting concentrations and dosage

strengths, and using oral syringes to administer oral medications”. Two (10%) respondents,

however, said, “they did not think that there were sufficient data available to justify that pediatric

exclusivity had resulted in improved drug labeling”. The overall response indicated most of the

pediatric exclusivity awards led to “labeling changes for drugs” that treated a wide range of

diseases, including some life-threatening conditions for children.

Figure 4.7: Benefits of improved pediatric labeling as a result of pediatric exclusivity

4.13 Pediatric Exclusivity and Pediatric Dosing

Seventeen (85%) of the survey respondents stated that pediatric drugs did not provide

health care professionals with adequate dosing information for children less than 2 years of age

but provided better dosing information for children over 2 years of age. For instance, one

pediatrician surveyed stated, “…neonates have decreased activity of many enzymes than older

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children. That is why drug dosages should be decreased for neonates compared to older

children”. This pharmacokinetic information is not always provided in pediatric drug label.

When asked to compare the dosing improvements across pediatric age categories, the

respondents felt that, in general, more dosing improvement was seen in “adolescents (12-16

years) than in neonates (0-1 month) and infants (1 month-2 years)”. The dosing improvement in

adolescents is mainly because of their resemblance to adult dosing where abundant studies have

been conducted. One RA staff interviewed stated, “Pediatric exclusivity has resulted in providing

dosing recommendations for high b.p. and fungal medicines that I am aware of.” In general, most

participants stated that the incentive provisions of pediatric exclusivity have led to the

availability of meaningful information to allow for dosing pediatric patients safely and

effectively.

Respondents preferred a combination of weight and age-based dosing (9.7, 97%)

followed by weight-based dosing (6.6, 66%) in pediatric Drug Facts Labels. Respondents said

that while age-based dosing is “more typical”, dosing by weight in some cases (i.e. in infants and

young children) may achieve “better efficacy results and may be safer”. These respondents stated

that the weight-based dosing schedule provides more consistent dosing in the targeted 10-15

mg/kg dosing range for most children when compared with age-based dosing. One pharmacist

and five pediatricians stated that in weight-based dosing, “doses for patients are customized”

requiring accurate calculations of child weight. Pediatric medication errors have occurred

because of “variation in children’s weight”. Respondents stated that caregivers expressed their

preference for weight-based dosing to select a correct dose, to prevent any dosing error,

compared to age-related dosing only. One respondent stated that in some situations, dosing

should be based on “body surface area such as in cancer drugs”. One participant stated that an

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ideal pediatric medicine should suit the “age, physiological condition and body weight” of the

child taking it. In general, respondents stated that exclusivity-inspired studies have resulted in the

correction of several dosing errors that may have prevented potential overdoses and under-doses

and possible detrimental health-related consequences. The participants outlined an unmet need

for pediatric dosing information for biologics as the key issue for future research.

4.14 Pediatric Exclusivity and Pediatric Formulation

Two pharmacists and five pediatricians surveyed stated that “adult capsules/tablets are

often manipulated into solutions for pediatric use”, solution concentrations can differ, leading to

prescribing errors when volume doses are written”. “Since pediatric drug prescription is often

off-label, finding dosing information can be challenging,” noted one pharmacist. Surveyed

participants and the FDA staff interviewed said that the FDA in a written request (WR) to the

drug companies, “requests pediatric formulation” in most cases, and studies are being conducted

towards that end. Participants noted that solid doses that are scored or different doses are usually

followed for drugs that require weight-based dosing or dosing based on endocrine status (e.g.

puberty). However, participants were concerned that it is not easy for children under 12 years of

age to swallow or chew tablets. Therefore, for dose flexibility and ease of swallowing, a “liquid

formulation” is often chosen for pediatric administration. Participants stated that to ensure ease

of dose titration and dose administration, liquid formulations are chosen, which are tasty as well

as stable in bottles. Participants expressed the need to develop more commercially available “oral

pediatric formulations” under the pediatric exclusivity program. Also, participants recommended

a more coherent approach to the development of pediatric formulations from all stakeholders.

This included an interdisciplinary input from formulation and sensory scientists to address

excipient compatibility, physical and chemical stability, taste, preservative, bioavailability,

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regulatory, and packaging issues as early as possible in the drug development process. For this,

respondents recommended a good understanding of the “technical, clinical, regulatory and

market requirements” using a multidisciplinary development approach, to develop pediatric

formulations.

4.15 Duration of Pediatric Exclusivity

When asked about their views on the duration of pediatric exclusivity, respondents had

mixed opinions. While 15 (75%) respondents were satisfied with the current 6 months of

exclusivity program, 12 (60%) participants wanted it to be extended to 12 months. In contrast, 4

(20%) participants wanted it to be reduced to 3 months. Three (15%) respondents wanted the

provision to be extended to 18, 24, or 36 months. The duration preference for pediatric

exclusivity earned a score of 8.8 (88%) for 6 months, 6.6 (66%) for 12 months, and 5.8 (58%)

for 3 months. Scores indicated a preference for the existing 6 months of pediatric exclusivity

compared to the hypothetical 12 months and 3 months. The permanent extension of duration of

pediatric exclusivity earned no point, which indicates that it is impractical.

Participants who were fine with the current 6 months of pediatric exclusivity stated that it

has been “effective in encouraging studies in pediatric drugs without crippling the generic drug

manufacturers for long”. However, participants opined that moving forward, “the exclusivity

provision will need to be adjusted to provide incentives for manufacturers who are not taking

advantage of market exclusivity” due to a small market size or lack of existing patent/market

exclusivity. The FDA staff interviewed declined to speak his views on the duration of exclusivity

citing the Agency’s rule not to comment on its policy issues.

Participants who viewed the extension of pediatric exclusivity program to one year felt

that it would be “enough incentive given the length of time and investment required to conduct

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pediatric studies”. They felt that the current duration of 6 months of exclusivity is often

inadequate to permit companies to take advantage of the incentive program. “Why stop at six

months?” questioned one survey respondent indicating the need for longer patent extension. For

certain pediatric drugs with small market sizes, respondents felt that the extension of exclusivity

provision to one year would “boost industry enthusiasm” for undertaking pediatric studies that

would potentially yield “modest return on investment”.

The respondents who opined for a reduction of pediatric exclusivity provision to 3

months were mainly for blockbuster drugs with sales over $1 billion. These respondents felt that

the current 6 month exclusivity program provides a big “windfall” to blockbuster drugs, at the

cost of high consumer expenditure on innovator drugs and high taxpayer burden. These

respondents who mainly comprised the patient advocates and generic drug makers, favored for

less costly and quicker availability of generic drugs. The respondents stated that the generic drug

makers generally favored the early expiry of patents for brand name drugs so that they could

make some extra income from the sale of generics. One respondent, however, was unsure about

the specifics of the balance between the pros and cons of extension and reduction of exclusivity.

4.16 Factors Affecting the Success of Studies for Pediatric Exclusivity

When respondents were asked to list the factors determining the success of studies for

pediatric exclusivity (the average of responses rated on a scale of 1-10), they listed well-

organized study as the most important requirement (8.5, 85%), followed by well-trained

investigators (8.2, 82%), and parents collaboration in research (6.8, 68%). The other important

factors reported were no other available therapeutic options (6.4, 64%), and high quality facilities

(5.1, 51%). The investigators’ financial compensation was of the lowest importance for the

feasibility of the trials (4.2, 42%) (Figure 4.8). By well-organized trials, participants referred to

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studies that were “well designed, properly analyzed, and based on good science”. Also, the study

procedures should be properly undertaken and documented to ensure the well-being and

protection of research subjects, respondents stated. Respondents stated that parental collaboration

is critical in successful recruitment of pediatric patients for maintaining an adequate sample size

and in the consent and assent processes of on-going studies. The respondents unanimously

agreed that “prior results suggesting benefit (and minimal risk)” are critical for any study to have

a good chance to recruit and follow-up pediatric patients.

Figure 4.8: Factors affecting the success of studies for pediatric exclusivity

4.17 Adequateness of Incentive

To the question, “is the incentive provided by the pediatric exclusivity regulation potentially

sufficient to offset the cost of pediatric drug development?” respondents had mixed opinions.

They said that the adequacy of the incentive depends on the “drug, its market share, and its

Factors Affecting the Success of Studies for Pediatric Exclusivity

Sca

le (

1-1

0)

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indications”. Fifteen (75%) respondents stated that for drugs with a large size of the market and

reasonable ease of recruitment of pediatric patients, the additional 6 month of exclusivity is

“generally sufficient” to recuperate the investment in clinical studies as well as an economic

“windfall” in some instances. One respondent stated that the incentives are “absurdly generous”

for some drugs with large market share. One RA personnel interviewed stated, “this [referring to

adequateness of incentive] really depends on the medication, the condition, and the competitive

situation for this medication. For example, a condition with no known treatments can easily

result in a positive return on investment as the manufacturer will be able to set a very high price;

however, if there are multiple products available, recruitment will be difficult and sales

diminished due to the competition”. Similarly, one other RA personnel interviewed stated, “in all

instances they [referring to pharmaceutical companies] make money and in most instances they

make a whole lot of money”.

Participants stated that the only studies that are pursued under the voluntary program (the

only program that provides exclusivity) are those that are “cost-effective”. However, six (30%)

participants stated that the 6 month exclusivity is not an enough of an incentive to recuperate

investment generally for drugs with a “small market share, rare pediatric conditions, and

difficulty in patient recruitment”. The two regulatory staff interviewed stated that the incentive

was not adequate for “old antibiotics and other drugs lacking patent protections or drugs for

certain younger age groups, especially neonates”.

4.18 Alternatives to Pediatric Exclusivity

When respondents were asked if there is any better/practical alternative to pediatric

exclusivity to encourage drug manufacturers to conduct pediatric clinical studies, 16 (75%)

survey respondents said that there is “none” that is practically viable at this time. Participants

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stated: “None that are politically viable”, “none that I can think of”, “not really”, “ok with what

we have”, and “unsure” as their responses. However, one respondent said that something has to

be done to incentivize or require generic and over the counter (OTC) product companies to

conduct pediatric studies, like PREA requirements which has mandated pediatric studies for

applicable branded products. With PREA requirements, there will not be a need to give

companies an additional six months of market protection to encourage them to “test their drugs

in children”, the respondent opined. Further, one RA personnel interviewed stated, “companies

need an incentive to evaluate special populations because of the cost involved”. One RA

personnel interviewed stated: “To address outstanding pediatric data needs, Congress should

grant a program allowing the FDA to fund pediatric clinical research directly”. However,

concerns were raised that due to shortage of funding and the limited infrastructure at the FDA,

such an ambitious program is not a practical alternative to pediatric exclusivity. One RA

personnel interviewed stated, “the only other incentive that could be granted to pediatric drug

companies is to provide them tax breaks or grants similar to what is done for orphan conditions,

the viability of which is unknown”. The FDA staff interviewed declined to comment on the topic

stating it is a “policy issue which the Agency staff cannot comment on”.

4.19 Comparison of Drugs Granted Pediatric Exclusivity and Drugs used by Children

Eleven (55%) respondents stated that the drugs granted pediatric exclusivity are not the

drugs most used by children. They stated, while the most frequent drug groups granted pediatric

exclusivity were “central nervous system drugs such as antidepressants and psychotropics,

cardiovascular drugs mainly ACE inhibitors and lipid-lowering preparations, systemic anti-

infectives among which largely HIV antivirals, and cytostatics, and alimentary tract medication

among which proton pump inhibitors and oral antihyperglycemic medication”. The respondents

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cited “anti-infectives, respiratory drugs, and dermatologicals” as the drugs most frequently used

by children. Further, the participants stated that the drugs studied under pediatric exclusivity are

likely to be blockbuster adult drugs. Participants cited examples of anti hypertensives and lipid

lowering agents that are granted exclusivity, though frequently only used in overweight

teenagers. One RA respondent stated, “The distribution of these drugs [referring to drugs granted

pediatric exclusivity] closely matched the distribution of these drugs over the adult market, and

not the drug utilization by children”. One RA staff interviewed questioned, “Can it [referring to

pediatric exclusivity provision] assure that drugs likely to be used in children are tested in

children before they are prescribed for their use?” One pediatrician criticizing the incentive

provision stated that pediatric exclusivity creates a system in which big rewards are received for

“testing drugs that sell the most” but not the drugs that are “used by children the most”.

Similarly, respondents felt that the drugs most commonly used by children are OTC drugs, which

as a whole, have inadequate data for pediatric administration. Since OTC drugs are ineligible to

receive the benefits of pediatric exclusivity, there are no incentives for companies that

manufacture these products to conduct pediatric studies, respondents stated.

Nine (45%) respondents said that they are not familiar enough with the specific drugs that

have been granted pediatric exclusivity to make a general statement about the relationship

between drugs granted pediatric exclusivity and drugs actually used by children. Overall survey

findings indicate that children have infrequently used the drugs granted pediatric exclusivity. In

light of this finding, participants recommended that the priorities for pediatric drug research

should be set by the “need of the patients, not by the market considerations”.

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4.20 Criticisms for Pediatric Exclusivity

Respondents stated that although pediatric exclusivity was successful in stimulating

pediatric studies, the provision was not without criticism. Respondents felt that pediatric

exclusivity provided excessive incentives to some manufacturers, while not enough to others.

Respondents had the following criticisms for pediatric exclusivity:

1. Respondents reported that pediatric exclusivity has been “inefficient” to study drugs citing that

the government could fund several studies with the same amount of money than allowing

pharmaceutical companies to conduct studies on one drug and make several billion dollars. For

instance, one RA personnel interviewed stated, “suppose if we extend the patent of a drug

making 5 billion dollars a year by 6 months, then the drug company is going to make an excess

of a billion dollars out of the patent extension. People are paying a billion dollar extra for that

drug. How many drugs could you study for that 1 billion dollar? Probably the government pays

50% of that billion dollar and 50% is paid by insurance companies, which still comes out of

taxpayers’ pockets. The government gives a billion dollar to companies to treat fat teenagers

with hypertension or high blood pressure. The government can take that billion dollars and give

it to NIH to study 20 therapeutic agents. How can you let drug companies walk away with

hundreds of millions of dollars in profit studying drugs when you can just pay for it to do it?”

One RA professional interviewed questioned, “Why drug makers should be rewarded for

something they are required to do under PREA?”

2. Because the program offers manufacturers a fixed incentive, respondents stated that products

with a larger sales volume might yield “excessive returns” that exceed the cost of performing

pediatric studies-regardless of the actual uses of these products in children. For example,

respondents cited drugs like atorvastatin (Lipitor), pravastatin (Pravachol), celecoxib (Celebrex),

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and a variety of anticancer agents, which are mainly used in adults, but have still received

exclusivity. Respondents stated that since the purpose of the exclusivity program is to “generate

data rather than increase drug use”, a product could gain the full six months of exclusivity even if

pediatric studies demonstrate that the drug should never be used by children. Respondents have

opined that the rewards of pediatric exclusivity are “too large for companies manufacturing

blockbuster drugs”. Respondents have criticized the pediatric exclusivity program for over

compensating the pediatric drug companies with sales greater than $1 billion. They have stated

that while the financial incentives for most products are modest, they are negative for some

products with small market share.

3. Respondents noted that BPCA has no provisions encouraging “testing of off-patent pediatric

drugs”. Due to this, respondents stated that pediatric exclusivity leaves many medications needed

by children “unstudied”. Respondents stated that the regulations like pediatric exclusivity and

BPCA are “voluntary, complex, and difficult to enforce”. Respondents opined that even for the

drugs still on patent, some industries might not believe that pediatric exclusivity is an adequate

incentive to compensate them for the modest cost of studying and labeling these drugs for use in

children.

4. Respondents noted that while a number of drug labels have been changed to incorporate

findings from research conducted under the pediatric exclusivity provisions, some label changes

typically occur long after the FDA has granted the extension of market exclusivity. One RA staff

interviewed suggested that by granting exclusivity only after companies have made labeling

changes, the FDA would retain a “powerful carrot” to assure that labeling changes are made.

Besides, respondents expressed concerns that not all studies lead to label changes under the

pediatric exclusivity program.

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CHAPTER 5

CONCLUSION AND RECOMMENDATION

5.1 Conclusion

The study demonstrated that stakeholders who were surveyed and interviewed were

generally aware of the pediatric exclusivity provisions and were satisfied with its flexibility and

voluntary requirements. However, the respondents expressed concerns that if the FDA made

these studies mandatory especially for drugs on which studies are difficult to conduct; industries

would have to invest huge sums of money to develop these products. The return on investment

on these drugs may be potentially low.

Respondents reported that the pediatric exclusivity provision has been effective in

generating pediatric studies to provide useful dosage and labeling information. The drugs granted

pediatric exclusivity were generally safe as they had no serious adverse events. Large drug

companies with their high volume of research and development were better at filing pediatric

exclusivity than small companies. The studies conducted by companies under a written request

(WR) with the FDA were adequate to ensure the safety and effectiveness of pediatric drugs. The

study findings were similar to a study by Li et al., which reported that pediatric exclusivity has

created a strong incentive to conduct FDA requested safety studies.26

The type of drug developed

and its risk benefit profile generally determined the type of studies conducted under pediatric

exclusivity. Most studies conducted under pediatric exclusivity, as reported by participants were

efficacy and safety studies, followed by pharmacokinetics (pk) /safety studies, safety studies,

and pharmacokinetics/pharmacodynamics and pharmacokinetics/safety (pk/pd pk/safety) studies.

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The study findings are similar to FDA’s breakdown of FDAAA completed pediatric studies16

.

All pediatric medicines without an adequate evidence base require pediatric studies under

pediatric exclusivity while drugs that were well studied and known to be fairly safe and effective

do not require pediatric studies.

The study results on pediatric conditions requiring studies are similar to the ‘‘priority list

of drugs for which pediatric studies are needed’’42

developed by the NIH in consultation with the

FDA and pediatric experts in 2007. The NIH list has included, similar to the survey findings,

infectious diseases, with a focus on Methicillin-resistant Staphylococcus aureus (MRSA)

infections, pediatric cancer, specifically neuroblastoma, neonatal pain, and asthma, as the

conditions for which research priorities are required. This priority list was developed based on

the gaps in scientific knowledge of pediatric drugs and their labeling, and their potential for

providing health benefit in the general pediatric population. However, the survey findings

pointed out three additional pediatric conditions-heart diseases, HIV, and epilepsy-that require

further research. These conditions did not fall in the NIH ‘‘priority list of drugs for which

pediatric studies are needed.’’

Respondents ranked inadequate pediatric doses as the main problem with pediatric drugs, which

can be solved by conducting enhanced research making clear assessment of overall benefits and

risks. Participants stated expensive pediatric trials with uncertain return on investment as the

biggest challenge that held them back from conducting studies under pediatric exclusivity. The

impact of pediatric exclusivity has been felt the most in adolescents where more studies are

conducted while felt least in neonates and infants where more studies are required.

While pediatric drug companies have benefitted from high profits from sales of pediatric

drugs, all stakeholders have benefitted from improved health care of children as result of better

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dosage, labeling, and drug safety information provided. In contrast, the main disadvantage of

pediatric exclusivity provisions was the high consumer cost on brand name drugs because of

delayed market entry of generics due to the added duration of exclusivity. Respondents

overwhelmingly supported the pediatric exclusivity for its incentive program on pediatric drug

development but feared the consequences of its reduction or cancellation. The pediatric

exclusivity has facilitated pediatric testing that generated a substantial number of labeling

changes resulting in reduced medical errors. The comparison of dosing improvement across

pediatric age categories showed better results in adolescents than in neonates and infants because

of their resemblance to adult dosing where abundant studies have been conducted. Similarly, the

pediatric exclusivity has provided better pediatric dosing based on children’s weight as well as

age. Respondents generally preferred a combination of weight and age-based dosing in pediatric

Drug Facts Labels. Respondents stated that caregivers preferred weight-based dosing for better

efficacy and safety compared to the typical age-based dosing. Respondents have reported

development of adequate pediatric formulation in solid and liquid doses, covering a broad age

range, in children over 2 years of age but not in children less than 2 years old. Respondents felt

that though pediatric exclusivity has resulted in many labeling changes for pediatric drugs, the

need for pediatric labels in all pediatric drugs was still strong. The pediatric labels, in addition to

providing better pediatric dosage information and reduced medical errors minimize off-label use

of drugs. Nearly all drugs evaluated in exclusivity-inspired pediatric research had no serious

adverse events necessitating enhanced adverse event monitoring. Absence of serious adverse

events indicated improved safety of pediatric drugs.

While the majority of respondents were satisfied with 6 months of exclusivity, some wanted it

extended to 12 months to boost industry enthusiasm to make a high investment in pediatric

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studies. Well-designed pediatric studies conducted by highly trained investigators with active

collaboration by parents were the key factors determining the success of studies for pediatric

exclusivity. For the success of exclusivity studies, prior results suggesting benefits and minimal

risks were critical for any study to have a good chance to recruit and follow-up pediatric patients.

Further, the incentive provisions of pediatric exclusivity were adequate for drugs with large

market share but not enough for drugs with small market share and rare pediatric conditions. Li

and colleagues at Duke University examined the likely cost of clinical studies under the pediatric

exclusivity program26

, and reported similar findings of variable returns. They found that the net

return-to-cost ratios varied widely, from negative returns for products with relatively small sales

volumes to a 73-fold return for a blockbuster drug. The returns ranged from -$8.9 million to $

507.9 million.26

The pediatric exclusivity provision has been criticized as too costly and

inefficient to study pediatric drugs. Respondents said that there was no practical alternative to

pediatric exclusivity at this time to encourage pediatric studies. Respondents felt that the FDA

should grant exclusivity to drugs that are mostly used by children and not adults.

5.2 Recommendation

This research, through surveys and interviews, has explicated the beliefs of key

stakeholders regarding the pediatric exclusivity provision established by the FDAMA, 1997. In

general, the research participants believe that the pediatric exclusivity provision has been

successful in stimulating pediatric studies. These studies under the guidance of the FDA have

been successful in providing significant changes in labeling, dosing, and formulation of pediatric

drugs, to make them more safe and effective for pediatric use. Despite the successes, there is

more work to be done. A large number of drug products need to be adequately labeled for

children. Long-term safety and effects on drugs on growth, learning, and behavior of children

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need further studies. Due to technical challenges and the need for sequential studies, neonates

remain mostly unstudied and little is known about the safety and efficacy of the therapies being

used to treat them. The study proposes the following recommendations:

1. Cost reduction of pediatric exclusivity

To reduce the high costs of the pediatric exclusivity program to the consumers and the

government, the US Congress could consider a few options. These alternatives could include

prioritizing data collection for pediatric drugs by making a better assessment of its need and the

potential benefits on children’s health. The incentive could be adjusted to encourage timely data

collection on pediatric drugs post marketing. Additional alternatives include reducing the size of

the financial incentive to pediatric drug manufacturers without cancelling it all together.

However, this approach to reduce the incentive must be sensitive to the needs of drug companies

with small market shares and low return on investment. Similarly, drugs with a primary pediatric

indication can only be allowed to have access to the incentive program.

2. Reauthorization of BPCA and PREA

Though stakeholders have raised concerns over the cost of pediatric exclusivity to the

federal government and consumers, evidence suggests value in reauthorizing the BPCA and

PREA. Congress could renew these key pieces of legislation that are set to expire in October 1

2012, to continue to incentivize pediatric drug manufacturers to develop safe and effective

medications for children. Additionally, the reauthorization of these legislations would provide

pharmaceutical industries more predictable regulatory path and certainty that would help spur

increased pediatric research.

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3. Pediatric drug trial assessment and information dissemination

Although there is no current assessment of the US capacity to perform pediatric drug

trials (PDTs), stakeholders feel that there is insufficient US PDTs. Future studies should focus

on assessing the capacity of US drug trials. Based on this assessment, recommendation should

be made to aid the development of new pediatric drugs. Additionally, pediatric labeling claims

should be supported by adequate pediatric test data derived from clinical trials. The BPCA

requirement of the FDA to issue summaries of data submitted under the pediatric exclusivity

program does not align with the FDA’s policy to keep the pediatric data secret. A consistent

policy should be developed by the FDA in line with the BPCA to disseminate information to

the public about pediatric drug trials. Mechanisms should be developed to more widely

disseminate this information through publication and broadcast media like radio and

television programs, which are more effective in information dissemination than peer-

reviewed literature. This recommendation is similar to a finding by Benjamin et al. of Duke

University43

.

5.3 Study Limitations

Since the respondents for the survey on pediatric exclusivity including regulatory affairs

professionals, pharmacists, clinicians, pediatricians, and FDA staff at the division of Pediatric

Drug Development, were a small number of people selected by purposive sampling, the study

findings may not cover all stakeholders’ perceptions and is limited in scope. If future researchers

choose to repeat this study, taking larger sample sizes of survey and interview respondents would

allow extrapolation of the results of the studies to larger pediatric populations. Since the survey

and interview instruments were not validated, bias may have occurred in the question design and

consequently the responses obtained. For instance, some respondents stated that questions were

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hard to interpret in terms of what was expected as answers especially when there were many

possible answers that were to be graded on a scale. Since a purposive, non-random, and non-

probability sampling method was used for the survey, selection bias may have affected the

results which cannot be generalized to broader population. In spite of the limited scope of the

study, the expert sampling has provided a lot of empirical evidence to justify the generalizations

made. The perspectives of key stakeholders of pediatric exclusivity are documented which have

contributed to our knowledge of pediatric drug development under pediatric exclusivity. The

research has provided new insights into the prevalent knowledge of pediatric conditions

requiring studies, challenges of pediatric drug development under pediatric exclusivity, and

pediatric age categories impacted. Further, advantages and disadvantages of pediatric exclusivity

to stakeholders are outlined and factors contributing to the success of of studies under pediatric

exclusivity are explained. Researchers need to update themselves with the safety and

effectiveness of prevailing pediatric medicines and the regulatory guidance as well. Additionally,

this research covers pediatric drugs only and not medical devices and biologics. Thus, the study

represents only the safety and efficacy of pediatric drugs but in no case the whole spectrum of

pediatric treatment.

Future studies to investigate the effectiveness of pediatric exclusivity should analyze

relevant summaries of medical and clinical pharmacology reviews and labeling information of

drugs granted pediatric exclusivity. Further, studies on pediatric exclusivity should explore the

settings of published studies, the therapeutic area of drug studied, and the types of studies

conducted. Studies should also explore a greater understanding of the capacity for US pediatric

drug trials (PDTs) by assessing PDT infrastructure, barriers to PDTs, and potential approaches

and solutions to identified issues. Research needs to be conducted to explore the frequency and

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type of adverse events and new safety information arising from studies conducted under pediatric

exclusivity program.

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31. Food and Drug Administration. Pediatric Drug Development and the Orphan Drug Act

Incentives. Available at:

http://www.fda.gov/ForIndustry/DevelopingProductsforRareDiseasesConditions/Howtoapply

forOrphanProductDesignation/ucm135125.htm. Accessed August 14, 2011.

32. Tordoff GJ, Reith D, Norris P. Effect of the Pediatric Exclusivity Provision on Children’s

Access to Medicines. Brit J Clin Pharmacol. June 2005; 59 (6):730-735.

33. Nastasi BK, Schensul SL.Contributions of Qualitative Research to the Validity of

Intervention Research. J School Psychol. 2005; 43(3):177-195.

34. Patton, Michael Q. Qualitative Research & Evaluation Methods. Sage Publications. 3rd. Ed.

2002.

35. Glaser BG. The Constant Comparative Method of Qualitative Analysis. Social Problems.

University of California Press. 1965; 12 (4): 436-445.

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36. The University of Georgia. “General FAQ, Question 3.” Office of the Vice President of

Research at the University of Georgia website. Available:

http://www.ovpr.uga.edu/hso/faqs/general.

37. Code of Federal Regulations. Part 46 Protection of Human Subjects. United States

Department of Health & Human Services: Office for Human Research Protections. Title 45.

Available at: http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm. Accessed June

18, 2011.

38. Code of Federal Regulations. Part 56 Institutional Review Boards. United States Department

of Health & Human Services: Available at:

http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=56&utm_

campaign=Google2&utm_source=fdaSearch&utm_medium=website&utm_term=21 CFR

part 56&utm_content=1. Accessed March 11, 2012.

39. Polit D, Beck C. Essentials of Nursing Research: Methods, Appraisal and Utilization (sixth

ed.), Lippincott Williams and Wilkins, Philadelphia; 2006.

40. Clissett P. Evaluating Qualitative Research. J Orthopaed Nursing. 2008; 12(2): 99-105.

41. Burnard, Phillip. “Teaching the Analysis of Textual Data: An Experimental Approach.”

Nurse Educ Today. 1996; 16: 279 - 281.

42. Federal Register / Vol. 72, No. 59 / Wednesday, March 28, 2007 / Notices. Available at:

http://www.fda.gov/downloads/Drugs/DevelopmentApprovalProcess/DevelopmentResources

/UCM077702.pdf. Accessed November 15, 2011.

43. Benjamin DK et al. Peer- Reviewed Publication of Clinical Trials Completed for Pediatric

Exclusivity. JAMA. 2006; 296 (10): 1266-1273.

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APPENDIX A - SURVEY QUESTIONS

Questions to Pediatric Drug Manufacturing Companies, Pharmacists, Clinicians,

Pediatricians, the FDA, and people having knowledge of pediatric drugs

Name of Respondent ………………………………………

Job Title:…… ……………………………………………...

Name of the Company: … ………………………………..

Work Address:……………………………………………...

1. Are you aware of pediatric exclusivity provision?

No

Yes

If yes, rate your awareness on a scale of 1-10, where 1 being minimally aware and 10 being

fully aware.

2. Under the pediatric exclusivity provision, conducting studies on pediatric drugs are voluntary

and encouraged.

Are you satisfied with the voluntary requirements?

Yes (Give reasons)

No (Give reasons)

If yes, rate the level of satisfaction on a scale of 1-10, where 1 being least satisfied and 10 being

most satisfied.

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If not, do you think the FDA should make these studies mandatory? What are its pros and cons?

3. In your opinion, which pediatric medicines currently available in the market need studies

(non-clinical and clinical) to establish their safety and efficacy? List on a scale of 1-10,

where 1 being the condition for which least studies are required and 10 being the conditions

for which most studies are required.

a. __Pediatric cancer

b. __Pediatric MRSA

c. __Pediatric hypertension

d. __ Asthma

e. __Neonatal conditions

f. __Heart diseases

g. __ HIV

h. __Others (specify)

4. In your opinion, which pediatric medicines currently available in the market do not require

pediatric studies (non-clinical and clinical)? Give reasons

5. The following are some problems/concerns with pediatric drugs. Which one do you think is

the major problem? List on a scale of 1-10, where 1 being the minor problem and 10 the

major problem.

a. __Some drugs prescribed for children are not labeled for children

b. __Different doses in children than in adults

c. __Different indications for use

d. __Different routes of administration than those recommended

e. __Unlicensed drugs for pediatric use

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f. __Drugs are given in formulations not accepted in children

g. __Off-label use of drugs

h. Others (specify)

Explain how individual problems can be resolved.

Has the pediatric exclusivity provisions helped to resolve the above-mentioned problems?

Yes

If yes, how has the pediatric exclusivity provision helped the manufacturers to make pediatric

drugs more safe and efficacious?

No If no, give reasons

6. What are the challenges of pediatric drug development under pediatric exclusivity? List the

individual challenges on a scale of 1-10, where 1 being the smallest and 10 being the biggest

challenge.

a. Ethical challenges

__Informed consent and assent process

b. Economic challenges

__Expensive trials, low profit potential, and less remunerative

c. Logistical challenges

__Recruitment of pediatric subjects

d. Technical challenges

__Scientific challenges, complexity of trials, and small pool of pediatric investigators

e. Corporate cultural bias against pediatric trials

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7. Which of the following kinds of studies is most commonly conducted in children under the

pediatric exclusivity provisions? Give reasons. List on a scale of 1-10, where 1 being the

least common studies and 10 being the most common studies.

a. __Efficacy/Safety

b. __Pharmacokinetics/Safety

c. __Pharmacodynamics/Safety

d. __Safety

e. __ All of the above

f. __ Others (Specify)

Are the studies conducted adequate? Give reasons.

Impact of Pediatric Exclusivity

8. Under pediatric exclusivity provisions, in what pediatric age categories has the impact of

pediatric studies conducted been felt the most? Rate the impact on a scale of 1-10, where 1

being of minimal impact and 10 being of maximal impact.

(Age categories are set as: neonates (0-1 month), infants (1 month to 2 years); children (2

years to 12 years); adolescents (12 years to 16 years).

a. __Neonates (0-1 month)

b. __Infants (1 month to 2 years)

c. __Children (2–12 years)

d. __Adolescents (12–16 years)

Give reasons why the impact is felt maximum at the selected age group?

Give reasons why the impact is felt minimum at the selected age group?

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9. What are the gains/ advantages of FDA’s pediatric exclusivity provision to the following

assuming that companies conduct pediatric studies to avail the incentives?

a. Pediatric patients and consumers

b. Medical practitioners

c. Pediatric drug companies

10. What are the disadvantages of pediatric exclusivity program to:

a. Pediatric patients and consumers

b. Medical practitioners

c. Pediatric drug companies

11. Do you support pediatric exclusivity provisions?

Yes (Give reasons) No (Give reasons)

If yes, list your level of support on a scale of 1-10, where 1 being minimal support and 10 being

the strongest support.

12. Do you have any concerns regarding FDA’s grant of pediatric exclusivity?

Yes (Explain) No

If yes, rate the concern on a scale of 1-10; where 1 being lowest level of concern and 10 being

the highest level of concern.

13. Do you have any suggestions on improving the FDA’s pediatric exclusivity provisions?

Explain.

Drug Labeling

14. It is said that pediatric exclusivity has resulted in improved pediatric drug labeling. List the

main benefits of added pediatric labeling to consumers and the health-care system. Rate the

benefits on a scale of 1-10, where 1 being the least benefit and 10 being the highest benefit.

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15. Which one of the following dosing types do you prefer for pediatric drug labeling? Give

reasons for your choice of dosing.

Rate your dosing preference on a scale of 1-10, where 1 being the least preferred and 10 being

the most preferred.

a. __ Weight–based dosing

b. __ Age-based dosing

c. __ Both

d. __ Others (specify)

Views on the duration of pediatric exclusivity

16. What is your view on the duration of pediatric exclusivity? How long do you think should it

be? Give reasons

Rate your duration preference on a scale of 1-10, where 1 being the least preferred and 10 being

the most preferred duration.

a. __3 months

b. __ 6 months

c. __12 months

d. __18 months

e. __24 months

f. __36 months

g. __permanent

17. What factors could determine the success of studies for pediatric exclusivity. Rate the factors

based on their importance on a scale of 1-10, where 1 being the least important factor and 10

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being the most important factor contributing to the success of studies for pediatric

exclusivity.

18. Is the incentive provided by the Pediatric Exclusivity Regulation potentially sufficient to

offset the cost of developing drugs for use in children? Give reasons.

19. In your opinion, is there any better/practical alternative to pediatric exclusivity to encourage

drug manufacturers to conduct clinical studies on pediatric drugs? Explain.

Criticisms

20. Some critics say the drugs granted pediatric exclusivity are not the drugs most used by the

children. Do you agree? Give reasons. How do you compare the drugs granted pediatric

exclusivity and drugs used by children?

21. What are your criticisms for pediatric exclusivity provisions? Explain.

22. Any questions/comments

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APPENDIX B - INTERVIEW QUESTIONS

Name of Respondent:……………………………………..

Position:…………………………………………………….

Name of the Company: …………………………………..

Work Address:……………………………………………..

1. How aware are you of the Food and Drug Administration’s (FDA’s) pediatric exclusivity

provision? Please rate your awareness on a scale of 1-10, where 1 being minimally aware and

10 being fully aware.

2. Under the pediatric exclusivity provisions, conducting studies on pediatric drugs are

voluntary and encouraged. Are you getting the expected number and quality of studies from

pediatric drug companies, with the voluntary requirements? Explain.

If not, do you think the FDA should make these studies mandatory? What are its pros and

cons?

3. What is your company’s main motive behind conducting studies for pediatric exclusivity?

4. Could you comment on the pediatric studies conducted under pediatric exclusivity?

5. Which of the following kinds of studies is most commonly conducted in children under the

pediatric exclusivity provisions? Give reasons.

a. __Efficacy/Safety

b. __Pharmacokinetics/Safety

c. __Pharmacodynamics/Safety

d. __Safety

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e. __ All of the above

f. __ Others (Specify)

Are the studies conducted adequate? Give reasons.

6. In your opinion, which pediatric medicines currently available in the market need studies

(non-clinical and clinical) to establish their safety and efficacy?

7. In your opinion, which pediatric medicines currently available in the market do not require

pediatric studies (non-clinical and clinical)? Give reasons

8. What do you think are some major problems/concerns with pediatric drugs? Explain how

individual problems can be resolved to make pediatric drugs more safe and efficacious.

Has the pediatric exclusivity provisions helped to resolve the above-mentioned problems?

Yes

No

If no, give reasons

9. What major challenges do pharmaceutical companies encounter in the development of

pediatric drugs? How have the companies been handling these challenges?

10. Under pediatric exclusivity provisions, in what pediatric age categories has the impact of

pediatric studies conducted been felt the most?

(Age categories are set as neonates (0-1 month), infants (1 month to 2 years); children (2

years to 12 years); adolescents (12 years to 16 years).

a. __Neonates (0-1 month)

b. __Infants (1 month to 2 years)

c. __Children (2–12 years)

d. __Adolescents (12–16 years)

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Give reasons why the impact is felt maximum at the selected age group?

Give reasons why the impact is felt minimum at the selected age group?

11. What are the gains/ advantages of FDA’s pediatric exclusivity provision to the following

assuming that companies conduct pediatric studies to avail the incentives?

a. Pediatric patients and consumers

b. Medical practitioners

c. Pediatric drug companies

12. What are the disadvantages of pediatric exclusivity program to:

a. Pediatric patients and consumers

b. Medical practitioners

c. Pediatric drug companies

13. Do you support pediatric exclusivity provisions? Give reasons.

14. How has pediatric exclusivity influenced pediatric drug labeling? Explain the changes.

15. How has pediatric exclusivity influenced pediatric drug dosing? Explain the changes.

16. Which of the dosing types- age-based, weight-based, or both do you prefer for pediatric drug

labeling? Give reasons for your choice of dosing.

17. How has pediatric exclusivity influenced pediatric formulation? Explain the changes.

18. What is your view on the current 6 months duration of pediatric exclusivity? Does it serve its

intended purpose? If not, should the duration of pediatric exclusivity be reduced or extended?

Give reasons.

19. What are the factors that determine the success of studies for pediatric exclusivity? List the

factors.

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20. Is the incentive provided by the pediatric exclusivity regulation potentially sufficient to offset

the cost of pediatric drug development? Explain.

21. In your opinion, is there any better/practical alternative to pediatric exclusivity to encourage

drug manufacturers to conduct clinical studies on pediatric drugs? Explain.

22. Some critics say the drugs granted pediatric exclusivity are not the drugs most used by the

children. Do you agree? Give reasons. How do you compare the number of drugs granted

pediatric exclusivity and the number of drugs used by children?

23. Do you have any criticism on FDA’s pediatric exclusivity program? Explain.

24. Do you have any comments and suggestions?

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APPENDIX C-INTERVIEW TRANSCRIPTS

1. How aware are you of the Food and Drug Administration’s (FDA’s) pediatric exclusivity

provision? Please rate your awareness on a scale of 1-10, where 1 being minimally aware

and 10 being fully aware.

Participant 1: 10- “…fully aware of pediatric exclusivity. For at least two studies that I was

involved, the FDA granted pediatric exclusivity to generate safety and pharmacokinetic data for

labeling update…”

Participant 2: 10- “…“fully aware of the regulatory requirements of pediatric exclusivity.We

have utilized the incentive provisions of pediatric exclusivity on three of our pediatric drugs”.

Participant 3: 10- “… fully aware of the incentive provisions of pediatric exclusivity”.

2. Under the pediatric exclusivity provisions, conducting studies on pediatric drugs are

voluntary and encouraged. Are you getting the expected number and quality of studies

from pediatric drug companies, with the voluntary requirements? Explain.

Participant 1: “…it is up to the industry to decide if they want to take advantage of the

program”.., “…getting corporate buy-in by offering increased/prolonged profits on still

useful drugs seems more positive than a forced approach…” “…you don’t obtain exclusivity

unless you provide pediatric data…”, and “…the flexibility, sadly, is necessary…”

Participant 2: “…a number of quality pediatric studies have been done…”, “… much more

needs to be done…”

Participant 3: “…“the economic incentive to comply with the voluntary requirements balance the

effort of compliance”.

If not, do you think the FDA should make these studies mandatory? What are its pros and

cons?

Participant 1: “…“The FDA does make pediatric studies mandatory for applicable products in

accordance with PREA.”

Participant 2: “…if these studies were mandatory, it may cause fewer drugs to be available for

children or delay drug development… while waiting on studies that were difficult to

conduct. “…I’d be concerned about the unintended consequences of mandated pediatric

research”, “…not sure it is feasible”, “…force fit…”

Participant 3: “…The FDA cannot make them mandatory based on the current law. It is not a

regulatory issue but a legislative one.” “I support mandatory studies, in compliance with

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PREA as long as they are feasible and assure that all pediatric age groups are appropriately

treated”.

3. What is your company’s main motive behind conducting studies for pediatric

exclusivity?

Participant 1: “…improvement in pediatric dosages, labeling, and formulation…”,

“…commitment to produce safe and effective drugs…”, “…patient safety first…”

Participant 2: “…primarily we had a pediatric indication. Exclusivity was granted for work

conducted to generate long-term safety and pharmacokinetic data to update the labeling of

the product”.

“…commitment of my industry to provide safe and effective drugs to children”, “…compliance

with PREA requirements”, “…financial rewards of pediatric exclusivity…”

4. Could you comment on the pediatric studies conducted under pediatric exclusivity?

Participant 1: “…no current assessment of the capacity to perform PDTs”. Need for a more

“transparent pediatric testing process”, “…PDTs should provide additional information on

“cardiovascular medicines, mental health medications, and sedatives”.

Participant 2: “While the adult drug development is industry driven, pediatric drug development

is regulatory driven”, “Nothing has worked better than incentives to get the pharmaceutical

industry conduct pediatric clinical trials”, “…great success…”

Participant 3: “…has been highly effective in generating pediatric studies on many drugs and in

providing useful new information regarding safety, efficacy, dosing, and unique risks of

drugs in pediatric patients”, “…naturally tended to produce pediatric studies on those

products where the exclusivity has the greatest value”, “…real success stories”, “…the most

successful pediatric initiative that the Agency has participated in to date”, “…big

advance…” in developing pediatric medicines, “…substantial increase in the number of

pediatric clinical trial data…”, “…to what extent can policy makers rely on incentives alone

as a means of ensuring appropriate testing” remains unclear.

5. Which of the following kinds of studies is most commonly conducted in children under

the pediatric exclusivity provisions? Give reasons.

a. __Efficacy/Safety

b. __Pharmacokinetics/Safety

c. __Pharmacodynamics/Safety

d. __Safety

e. __ All of the above

f. __ Others (Specify)

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Participant 1: The type of study conducted depends on the “type of drug developed and its risk

benefit profile”.

Most common studies “efficacy/safety” followed by “pharmacokinetics/safety”, “… if we

understand how a drug works in adults, then pharmacokinetic studies are sufficient for

pediatric population…”

Participant 2: Most common studies “efficacy/safety” followed by “pharmacokinetics/safety”

“…the time to complete efficacy studies is approximately 50% longer than pharmacokinetic

studies (median 24 months vs 16 months). The median duration of bioequivalence studies is

6 months (range 5-7 months)”.

Participant 3: Most common studies “efficacy/safety” followed by “pharmacokinetics/safety,”

“…efficacy studies takes approximately 50% longer than pharmacokinetic studies”.

“…for timely development of pediatric drugs, all pediatric studies that are delayed and pending

need to be expedited”.

Are the studies conducted adequate? Give reasons.

Participant 1: Studies conducted under a “written request (WR) with the FDA” are adequate.

Participant 2: Studies conducted under a “written request (WR) with the FDA” are adequate.

Participant 3: Studies conducted under a “written request (WR) with the FDA” are adequate.

6. In your opinion, which pediatric medicines currently available in the market need

studies (non-clinical and clinical) to establish their safety and efficacy?

Participant 1: “…Pediatric cancer studies are needed depending on the type of malignancy as the

pathogenesis may be similar in certain cancer”.

Participant 2: Pediatric HIV studies are a “major ongoing concern worldwide”.

“…neonatal studies are very hard to conduct but the inherent safety concerns are a critical

question especially for long term development”.

Participant 3: “safety and pharmacokinetics data in the use of drugs like tetracycline,

doxycycline, clindamycin, trimethoprim-sulfamethoxazole, in the treatment of pediatric

MRSA”.

“antidepressants, ADHD medications, antiepileptics, and anti-infectives (especially antivirals

directed towards influenza”.

7. In your opinion, which pediatric medicines currently available in the market do not

require pediatric studies (non-clinical and clinical)? Give reasons

Participant 1: “…none are completely and thoroughly studied”.

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Participant 2: “…pediatric hypertension…”, “…medicines which are rarely used in the pediatric

population…”,

Participant 3: “…drugs that are already labeled in pediatrics with published data and known to be

fairly safe and effective…”

8. What do you think are some major problems/concerns with pediatric drugs? Explain

how individual problems can be resolved to make pediatric drugs more safe and

efficacious.

Participant 1: “…not standard doses…” “… dose calculation error…”, develop “…pediatric

specific dosing, formulations, and labeling changes…”

“…pediatric formulation”- solved through “…research involving advanced knowledge in

formulation…”

Participant 2: “…labeling…”, “consult your physician” “…“off-label and off-license use-

“…analgesics, bronchodilators, and antibiotics”.

Resolved through study of- “…risk benefit profile…”.

Participant 3: “…off-label and off-license use…”,

Resolved through study of- “ …risk benefit assessment…”

“…“If there is uncertainty regarding either the benefits or the risks, the FDA under the authority

given by Congress mandates post-licensure studies to companies, and should also be able to

have significant sanctions in the event these post-marketing studies are not completed”.

Has the pediatric exclusivity provisions helped to resolve the above-mentioned problems?

Yes

Participant 1: “Yes”

Participant 1: “Yes”

Participant 1: “Yes”

No

If no, give reasons

9. What major challenges do pharmaceutical companies encounter in the development of

pediatric drugs? How have the companies been handling these challenges?

Participant 1: “…expensive trials and their economic returns are variable…”, “…possible lack of

return on investment…”, “…small pool of trained pediatric investigators…”, “…“corporate

inertia” to develop and market drugs for adults over pediatric drugs

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Participant 2: “…costly trials…”, “…pediatric patient recruitment difficulties…”, “the stress of

short-term pain (such as blood sampling)”, “…trial designs challenging …”, difficulty in

validating “…quality-of-life questionnaire…”

Participant 3: “…expensive trials…” “…healthy children were difficult to recruit…”, “…“non-

therapeutic” research, ethical issues of “informed consent and assent”

“Can a 7 year old (the age arbitrarily recommended for including children in the assent process)

fully understand the complexities of clinical trials to which he/she is assenting to?”,

“the lack of established relevance of surrogate markers for children”.

Impact of Pediatric Exclusivity

10. Under pediatric exclusivity provisions, in what pediatric age categories has the impact

of pediatric studies conducted been felt the most?

(Age categories are set as: neonates (0-1 month), infants (1 month to 2 years); children (2

years to 12 years); adolescents (12 years to 16 years).

a. __Neonates (0-1 month)

b. __Infants (1 month to 2 years)

c. __Children (2–12 years)

d. __Adolescents (12–16 years)

Participant 1: “Adolescents >Children> Infants> Neonates”

Participant 2: “Adolescents >Children> Infants> Neonates”

Participant 3: “Adolescents >Children> Infants> Neonates”

Give reasons why the impact is felt maximum at the selected age group?

Participant 1: “…ease of recruitment of older pediatric patients…” “…younger children have

benefitted more…”

Participant 2: “…easier to recruit and study older children…”, “…ethical and logistical issues…”

Participant 3: “… Adolescents due to their closer relevance to adults in physiological maturity

and overlap of broad indications…”, Impact felt more in “…children over the age of six, but not

much for younger children…”,

Give reasons why the impact is felt minimum at the selected age group?

11. What are the gains/ advantages of FDA’s pediatric exclusivity provision to the following

assuming that companies conduct pediatric studies to avail the incentives?

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a. Pediatric patients and consumers

b. Medical practitioners

c. Pediatric drug companies

Participant 1: “…better dosage, labeling, and drug safety information…”, “…the biggest benefit

of pediatric exclusivity is the right dosage information for the pediatric medicine studied…”,

“…high profit earning…”, “…priority application…”, “…all stakeholders benefit…”

“…I would say these are equally aligned. Companies receive the economic benefit for

conducting the studies while pediatric patients and pediatricians receive the assurance that the

products will have a positive benefit risk profile”.

Participant 2: “…high return on investment, “…slow generic intrusion…” “…better dosage,

labeling, and drug safety information…”, “…high profit earning…”, “…additional marketing

control …”, “…profit optimization…”

Participant 3: “…better dosage, labeling, and drug safety information…”, “…prescription

justification…”, “…high return on investment…”

12. What are the disadvantages of pediatric exclusivity program to:

a. Pediatric patients and consumers

b. Medical practitioners

c. Pediatric drug companies

Participant 1: “… “raised consumer expenditure on brand name or patent drugs”, “…financial

burden on consumers…” “…burden of conducting studies with uncertain return on

investment…”

Participant 2: “…expensive to taxpayers…”, “…raised the economic costs of government”,

“…pediatricians challenged to “keep abreast with” all the recent drugs granted pediatric

exclusivity…”, “…burden of study involvement...”.

Participant 3: “…economic impact of longer term for branded medicines…”

13. Do you support pediatric exclusivity provisions? Give reasons.

Participant 1: “yes”, it grants companies the “incentive to conduct clinical studies” though a

“…heavy burden on tax payers…”

Participant 2: “yes”, it provides confidence that the drug product has been adequately “tested in

the intended patient population”, “…boosts industry enthusiasm” for conducting pediatric studies

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Participant 3: “yes”, “…incentive to conduct pediatric studies…” to develop “…safe and

effective pediatric drugs…”

14. How has pediatric exclusivity influenced pediatric drug labeling? Explain the changes.

Participant 1: “…improved pediatric drug labeling…”, “…provided new and useful information

on drug labels…”

Participant 2: “…improved pediatric drug labeling…” “…but can it guarantee that companies

receiving exclusivity make the results of their studies known through the labeling changes

necessary for safe and effective use of drugs…?”

Participant 3: “…improved pediatric drug labeling…”, provided “…new child-safety

information, new or altered pediatric dosing information, additional warnings about adverse

events in children, recommended dosage modifications, and findings of lack of efficacy for some

drugs”.

15. How has pediatric exclusivity influenced pediatric drug dosing? Explain the changes.

Participant 1: “…generally provided better dosing information for children over 2 years of

age...”, “…corrected dosing errors…”

Participant 2: “…more dosing improvement is seen in “adolescents (12-16 years) than in

neonates (0-1 month) and infants (1 month-2 years)”.

“Pediatric exclusivity has resulted in providing dosing recommendations for high b.p. and fungal

medicines that I am aware of.”

Participant 3: “…provided information for safely and effectively dosing pediatric population but

much needs to be done mainly in neonate dosing…”

16. Which of the dosing types- age-based, weight-based, or both do you prefer for pediatric

drug labeling? Give reasons for your choice of dosing.

Participant 1: “…combination of weight and age…”, age-based dosing “more typical”,

“…widespread but probably not the best…”, dosing by weight in some cases (i.e. in infants and

young children) may achieve “better efficacy results and may be safer”, “…male vs female

dosing difference in some cases…”

Participant 1: “…both…”, “…weight-based dosing to select a correct dose, to prevent any

dosing error, compared to age-related dosing only…”

Participant 1: “…combination of weight and age…”, “…weight-based dosing for dosing

consistency…”

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17. How has pediatric exclusivity influenced pediatric formulation? Explain the changes.

Participant 1: “…liquid formulation” is often chosen for pediatric administration, “…solid doses

that are scored…” for weight-based dosing

Participant 2: “…need to develop more commercially available “oral pediatric formulations”

under the pediatric exclusivity program, “…flexible dose liquid formulation…”

Participant 3: FDA in a written request (WR) to the drug companies, “requests pediatric

formulation” in most cases,

18. What is your view on the current 6 months duration of pediatric exclusivity? Does it

serve its intended purpose? If not, should the duration of pediatric exclusivity be reduced

or extended? Give reasons.

Participant 1: “…6 months is fine…”, “…satisfied with 6 months of pediatric exclusivity …”,

“…effective in encouraging studies in pediatric drugs without crippling the generic drug

manufacturers for long”, “…12 months for some drugs to be able to recover and recoup pediatric

development cost, given the investment and time required…”

“…current 6 month exclusivity program provides a big windfall to blockbuster drugs…”

Participant 2: “…6 months of pediatric exclusivity has been serving its purpose adequately…”,

“…“the exclusivity provision will need to be adjusted to provide incentives for manufacturers

who are not taking advantage of market exclusivity…”

Participant 3: “…has been serving its intended purpose…” “…no comments…”

19. What are the factors that determine the success of studies for pediatric exclusivity? List

the factors.

Participant 1: “… “prior results suggesting benefit (and minimal risk)”, “…well designed studies,

expert investigators, properly analyzed data based on good science…”

Participant 2: “…well-organized study, well-trained investigators. parents collaboration in

research, no other available therapeutic options, and high quality facilities…”

Participant 3: “…well-organized study conducted in high quality facilities by well-trained

investigators with parental collaboration…”

20. Is the incentive provided by the pediatric exclusivity regulation potentially sufficient to

offset the cost of pediatric drug development? Explain.

Participant 1: depends on the “drug, its market share, and its indications…”, “…this

really depends on the medication, the condition, and the competitive situation for this

medication...”, incentive was not adequate for “old antibiotics and other drugs lacking patent

protections or drugs for certain younger age groups, especially neonates”, “… incentive is never

too much…”

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Participant 2: “…“generally sufficient”, “economic windfall in some cases…”, “in all

instances they make money and in most instances they make a whole lot of money”, incentive

not adequate for “old antibiotics and other drugs lacking patent protections or drugs for certain

younger age groups, especially neonates”.

Participant 3: “…“generally sufficient for most drugs…”

21. In your opinion, is there any better/practical alternative to pediatric exclusivity to

encourage drug manufacturers to conduct clinical studies on pediatric drugs? Explain.

Participant 1: “…none…” that is practically viable at this time, “…PREA requirements to test

their drugs in children…”, “…Providing tax breaks or grants…”, “…ok with what we have,

need no more regs…”, “…rare pediatric indications need more studies…”

Participant 2: “…not really…”, “…“companies need an incentive to evaluate special populations

because of the cost involved…”, “…To address outstanding pediatric data needs, Congress

should grant a program allowing the FDA to fund pediatric clinical research directly…”.

Participant 3: “…none that is practical…”, “…policy issue which the Agency staff cannot

comment on…”.

22. Some critics say the drugs granted pediatric exclusivity are not the drugs most used by

the children. Do you agree? Give reasons. How do you compare the number of drugs

granted pediatric exclusivity and the number of drugs used by children?

Participant 1: “…yes…”, “…the distribution of these drugs closely matched the distribution of

these drugs over the adult market, and not the drug utilization by children…”, “…“Can it

[referring to pediatric exclusivity provision] assure that drugs likely to be used in children are

tested in children before they are prescribed for their use?”

Participant 2: “…yes…”, “…big rewards for testing drugs that sell the most” but not the drugs

that are “used by children the most”.

Participant 3: “…generally yes…”, “…priorities for pediatric drug research should be set by the

need of the patients, not by the market considerations…”.

23. Do you have any criticism on FDA’s pediatric exclusivity program? Explain.

Participant 1: “…“inefficient to study pediatric drugs…”, “… returns variable and uncertain…”,

“…no testing of off-patent pediatric drugs…”, “… by granting exclusivity only after companies

have made labeling changes, the FDA would retain a powerful carrot to assure that labeling

changes are made…”.

Participant 2: “…Why drug makers should be rewarded for something they are required to do

under PREA…?”, Purpose- “…to generate data rather than increase drug use”, “…BPCA

voluntary, complex, and difficult to enforce…”

Participant 3: “…No comment…”

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24. Do you have any comments and suggestions?