Assessment of the FDA Risk Evaluation and Mitigation Strategy for Transmucosal Immediate-Release Fentanyl Products

Autor: G. Caleb Alexander, Peter Lurie, Lily Olson, Joshua M. Sharfstein, Jeffrey Eric Rollman, James Heyward
Rok vydání: 2019
Předmět:
medicine.medical_specialty
Health Knowledge
Attitudes
Practice

Prescription Drugs
media_common.quotation_subject
Risk Evaluation and Mitigation
MEDLINE
Off-label use
Pharmacists
01 natural sciences
Fentanyl
03 medical and health sciences
0302 clinical medicine
medicine
Product Surveillance
Postmarketing

Administration
Mucosal

Humans
030212 general & internal medicine
Immediate release
0101 mathematics
Practice Patterns
Physicians'

Prescription Drug Misuse
health care economics and organizations
Original Investigation
media_common
business.industry
United States Food and Drug Administration
Addiction
010102 general mathematics
Breakthrough Pain
Contraindications
Drug

General Medicine
Cancer Pain
Off-Label Use
medicine.disease
United States
Risk evaluation
Analgesics
Opioid

Family medicine
Health Care Surveys
Clinical Competence
business
Cancer pain
Addictive behavior
medicine.drug
Zdroj: JAMA. 321(7)
ISSN: 1538-3598
Popis: Importance Transmucosal immediate-release fentanyls (TIRFs), indicated solely for breakthrough cancer pain in opioid-tolerant patients, are subject to a US Food and Drug Administration (FDA) Risk Evaluation and Mitigation Strategy (REMS) to prevent them from being prescribed inappropriately. Objectives To evaluate knowledge assessments of pharmacists, prescribers, and patients regarding appropriate TIRF use; to describe sponsor assessments, based on claims data, of whether the REMS program was meeting its goals; and to characterize how the FDA responded to REMS assessments. Design, Setting, and Participants Qualitative analysis of 4877 pages of FDA documents obtained through a Freedom of Information Act request, including 6 annual REMS assessment reports (2012-2017), FDA evaluations of these reports, and FDA-sponsor correspondence about safety issues. Exposure A REMS program to reduce the risk of adverse outcomes, including misuse, abuse, addiction, and overdose, arising from use of TIRFs. Main Outcomes and Measures (1) Knowledge assessments of pharmacists, prescribers, and patients; (2) survey and claims-based prescribing assessments; (3) FDA and TIRF sponsor communications; (4) modifications to the REMS program; and (5) disenrollment of noncompliant prescribers. Results Twelve months after initiation of the program, 24 of 302 pharmacists (7.9%), 35 of 302 prescribers (11.6%), and 5 of 192 patients (2.6%) incorrectly reported that TIRFs can be prescribed to opioid-nontolerant patients, with similar levels of misunderstanding maintained in the subsequent reports. At 60 months, product-specific analyses of claims data indicated that between 34.6% and 55.4% of patients prescribed TIRFs were opioid-nontolerant. In the 48-month survey, 106 of 310 prescribers (34.2%) reported prescribing TIRFs for opioid-tolerant patients with chronic, noncancer pain; at 60 months, 54 of 302 prescribers (18.4%) and 148 of 310 patients (47.7%) erroneously reported that TIRFs were FDA-approved for such use. Over the 60-month period examined, there were few substantive changes made to the REMS to address evidence of high rates of off-label TIRF use, and, although the REMS program had a noncompliance plan, there was no report of prescribers being disenrolled for inappropriate prescribing. Conclusions and Relevance In this review of FDA documents pertaining to the TIRF REMS, surveys of pharmacists, prescribers, and patients reflected generally high levels of knowledge regarding proper TIRF prescribing, yet some survey items as well as claims-based analyses indicated substantial rates of inappropriate TIRF use. Despite these findings, the FDA did not require substantive changes to the program.
Databáze: OpenAIRE