21st Century Cures Act

Hitting our goals: regulatory reform

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Way, way back in 2015 – seems like a lifetime ago doesn’t it – the team at CIRM sat down and planned out our Big 6 goals for the next five years. The end result was a Strategic Plan that was bold, ambitious and set us on course to do great things or kill ourselves trying. Well, looking back we can take some pride in saying we did a really fine job, hitting almost every goal and exceeding them in some cases. So, as we plan our next five-year Strategic Plan we thought it worthwhile to look back at where we started and what we achieved. We are going to start with Regulatory Reform.

The political landscape in 2015 was dramatically different than it is today. Compared to more conventional drugs and therapies stem cells were considered a new, and very different, approach to treating diseases and disorders. At the time the US Food and Drug Administration (FDA) was taking a very cautious approach to approving any stem cell therapies for a clinical trial.

A survey of CIRM stakeholders found that 70% said the FDA was “the biggest impediment for the development of stem cell treatments.” One therapy, touted by the FDA as a success story, had such a high clinical development hurdle placed on it that by the time it was finally approved, five years later, its market potential had significantly eroded and the product failed commercially. As one stakeholder said: “Is perfect becoming the enemy of better?”

So, we set ourselves a goal of establishing a new regulatory paradigm, working with Congress, academia, industry, and patients, to bring about real change at the FDA and to find ways to win faster approval for promising stem cell therapies, without in any way endangering patients.

It seemed rather ambitious at the time, but achieving that goal happened much faster than any of us anticipated. With a sustained campaign by CIRM and other industry leaders, working with the patient advocacy groups, the FDA, Congress, and President Obama, the 21st Century Cures Act was signed into law on December 13, 2016.

President Obama signs the 21st Century Cures Act.
Photo courtesy of NBC News

The law did something quite radical; it made the perspectives of patients an integral part of the FDA’s decision-making and approval process in the development of drugs, biological products and devices. And it sped up the review process by:

In a way the FDA took its foot off the brake but didn’t hit the accelerator, so the process moved faster, but in a safe, manageable way.

Fast forward to today and eight projects that CIRM funds have been granted RMAT designation. We have become allies with the FDA in helping advance the field. We have created a unique partnership with the National Heart, Lung and Blood Institute (NHLBI) to support the Cure Sickle Cell initiative and accelerate the development of cell and gene therapies for sickle cell disease.

The landscape has changed since we set a goal of regulatory reform. We still have work to do. But now we are all working together to achieve the change we all believe is both needed and possible.

How small talk led to a big break; a summer internship at CIRM

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At CIRM, California’s Stem Cell Agency, we are fortunate to work with some amazing people. This summer we added another name that list when Melissa Cairos joined us for an internship. Melissa is now on to the next part of her adventure, as a policy wonk in Washington DC., but before she left we asked her to write about her experiences, and thoughts after her time at the Stem Cell Agency.

Melissa

Melissa Cairos

In January of 2018, I had a casual conversation with a woman, whom I had never met before, at a high school basketball game. Through small talk about my studies in school and my career interests for the future, the woman suggested I may be interested in her work because it seemed to be aligned with what I wanted to do. Her work happened to be at CIRM and she happened to be Maria Millan, the President and CEO.

Interestingly, I had never heard of CIRM (the California Institute for Regenerative Medicine) and had limited knowledge of regenerative medicine. But, I had dedicated a semester in spring of 2015 to analyzing and lobbying for the 21st Century Cures Act. I engaged in that work because I believe in the importance of investing in, and expediting the regulatory process for, lifesaving medical innovations, so that they can be accessed faster by patients and at a lower cost. The 21st Century Cures Act has since become law and has created incredible opportunities for both CIRM and the entire field of regenerative medicine.

Since joining CIRM, I have been able to continue with similar work by analyzing legislation, policies and regulations that affect patients’ abilities to access regenerative medicine therapies and our grantees’ abilities to receive reimbursement for their therapies. Because the stem cell and gene therapies CIRM’s grantees are coming up with are so new and innovative, I quickly realized that the legislative, policy and regulatory solutions for them needed to reflect that innovative spirit.

Working alongside Geoff Lomax, (the Senior Officer for CIRM Strategic Infrastructures)  my manager and mentor, we identified a number of potential barriers to access and reimbursement and tried to come up with policy solutions to address them.

For one project, we looked at the high cost of regenerative medicine therapies. Because high cost affects both patient access and potential reimbursement problems for the companies that develop those therapies we felt it was essential to try and come up with policy solutions to address these issues. To do this, we studied the traditional payment structure for drugs and medical devices and found it inappropriate for regenerative medicine in most cases.

This is because regenerative medicine requires a one-time high cost payment, but the regenerative medicine treatments/cures would eliminate long term costs including: previous treatment cost, complications from that treatment, progression of disease cost, hospitalizations, disability, quality of life, co-morbidities, disease effect on longevity etc. Thus, we proposed that payment models for regenerative medicine should consider their unique value benefits, such as the number of additional years of life the treatment added, and the overall cost-effectiveness of a one-time treatment compared to years of  treatment. With this in mind, we suggested innovative payment models that accounted for these factors and further proposed changes that need to be made so that different manufacturers and payors can engage in innovative financing agreements.

Through my work at CIRM, I found that what makes regenerative medicine unique is that it not only offers new ways of treating previously untreatable diseases, but it has additional benefits or value. Not only the economic value, but also the human value, as regenerative medicine offers patients with life threatening or painful chronic diseases a solution that will change their lives and the lives of their families for the better. Through this understanding, I grew an incredible appreciation for CIRM, for not only being a great place to work with incredibly talented and kind people, but also an incredibly unique government agency that reflected the value and innovative spirit of the research it supports.

I am so grateful that I met Maria at that basketball game and got the opportunity to support CIRM in adding value to California in my role this summer as a Policy Fellow. I plan to return to California in the future and work in the health policy field to further support programs, policies, and/or agencies, like CIRM, that bring so much value to this state.

 

 

Turning the corner with the FDA and NIH; CIRM creates new collaborations to advance stem cell research

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FDAThis blog is part of the Month of CIRM series on the Stem Cellar

A lot can change in a couple of years. Just take our relationship with the US Food and Drug Administration (FDA).

When we were putting together our Strategic Plan in 2015 we did a survey of key players and stakeholders at CIRM – Board members, researchers, patient advocates etc. – and a whopping 70 percent of them listed the FDA as the biggest impediment for the development of stem cell treatments.

As one stakeholder told us at the time:

“Is perfect becoming the enemy of better? One recent treatment touted by the FDA as a regulatory success had such a high clinical development hurdle placed on it that by the time it was finally approved the standard of care had evolved. When it was finally approved, five years later, its market potential had significantly eroded and the product failed commercially.”

Changing the conversation

To overcome these hurdles we set a goal of changing the regulatory landscape, finding a way to make the system faster and more efficient, but without reducing the emphasis on the safety of patients. One of the ways we did this was by launching our “Stem Cell Champions” campaign to engage patients, patient advocates, the public and everyone else who supports stem cell research to press for change at the FDA. We also worked with other organizations to help get the 21st Century Cures Act passed.

21 century cures

Today the regulatory landscape looks quite different than it did just a few years ago. Thanks to the 21st Century Cures Act the FDA has created expedited pathways for stem cell therapies that show promise. One of those is called the Regenerative Medicine Advanced Therapy (RMAT) designation, which gives projects that show they are both safe and effective in early-stage clinical trials the possibility of an accelerated review by the FDA. Of the first projects given RMAT designation, three were CIRM-funded projects (Humacyte, jCyte and Asterias)

Partnering with the NIH

Our work has also paved the way for a closer relationship with the National Institutes of Health (NIH), which is looking at CIRM as a model for advancing the field of regenerative medicine.

In recent years we have created a number of innovations including introducing CIRM 2.0, which dramatically improved our ability to fund the most promising research, making it faster, easier and more predictable for researchers to apply. We also created the Stem Cell Center  to make it easier to move the most promising research out of the lab and into clinical trials, and to give researchers the support they need to help make those trials successful. To address the need for high-quality stem cell clinical trials we created the CIRM Alpha Stem Cell Clinic Network. This is a network of leading medical centers around the state that specialize in delivering stem cell therapies, sharing best practices and creating new ways of making it as easy as possible for patients to get the care they need.

The NIH looked at these innovations and liked them. So much so they invited CIRM to come to Washington DC and talk about them. It was a great opportunity so, of course, we said yes. We expected them to carve out a few hours for us to chat. Instead they blocked out a day and a half and brought in the heads of their different divisions to hear what we had to say.

A model for the future

We hope the meeting is, to paraphrase Humphrey Bogart at the end of Casablanca, “the start of a beautiful friendship.” We are already seeing signs that it’s not just a passing whim. In July the NIH held a workshop that focused on what will it take to make genome editing technologies, like CRISPR, a clinical reality. Francis Collins, NIH Director, invited CIRM to be part of the workshop that included thought leaders from academia, industry and patients advocates. The workshop ended with a recommendation that the NIH should consider building a center of excellence in gene editing and transplantation, based on the CIRM model (my emphasis).  This would bring together a multidisciplinary disease team including, process development, cGMP manufacturing, regulatory and clinical development for Investigational New Drug (IND) filing and conducting clinical trials, all under one roof.

dr_collins

Dr. Francis Collins, Director of the NIH

In preparation, the NIH visited the CIRM-funded Stem Cell Center at the City of Hope to explore ways to develop this collaboration. And the NIH has already begun implementing these suggestions starting with a treatment targeting sickle cell disease.

There are no guarantees in science. But we know that if you spend all your time banging your head against a door all you get is a headache. Today it feels like the FDA has opened the door and that, together with the NIH, they are more open to collaborating with organizations like CIRM. We have removed the headache, and created the possibility that by working together we truly can accelerate stem cell research and deliver the therapies that so many patients desperately need.

 

 

 

 

 

 

CIRM & NIH: a dynamic duo to advance stem cell therapies

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NIH

National Institutes of Health

There’s nothing more flattering than to get an invitation, out of the blue, from someone you respect, and be told that they are interested in learning about the way you work, to see if it can help them improve the way they work.

That’s what happened to CIRM recently. I will let Randy Mills, who was our President & CEO at the time, pick up the story:

“Several weeks ago I got a call from the head of the National Heart. Lung and Blood Institute (NHLBI) asking would we be willing to come out to the National Institutes of Health (NIH) and talk about what we have been doing, the changes we have made and the impact they are having.”

Apparently people at the NIH had been reading our Strategic Plan and our Annual Report and had been hearing good things about us from many different individuals and organizations. We also heard that they had been motivated to engage more fully with the regenerative medicine community following the passage of the 21st Century Cures Act.

We were expecting a sit down chat with them but we got a lot more than that. They blocked out one and a half days for us so that we had the time to engage in some in-depth, thoughtful conversations about how to advance the field.

collins-portrait_1

Dr. Francis Collins, NIH Director

The meeting was kicked off by both Francis Collins, the NIH Director, and Gary Gibbons, the NHLBI Director. Then the CIRM team – Dr. Mills, Dr. Maria Millan, Gabe Thompson and James Harrison – gave a series of presentations providing an overview of how CIRM operates, including our vision and strategic priorities, our current portfolio, the lessons learned so far, our plans for the future and the challenges we face.

The audience included the various heads and representatives from the various NIH Institutes who posed a series of questions for us to answer, such as:

  • What criteria do we use to determine if a project is ready for a clinical trial?
  • How do we measure success?
  • How have our strategies and priorities changed under CIRM 2.0?
  • How well are those strategies working?

The conversation went so well that the one day of planned meetings were expanded to two. Maria Millan, now our interim President & CEO, gave an enthusiastic summary of the talks

“The meetings were extremely productive!  After meeting with Dr. Collins’ group and the broader institute, we had additional sit down meetings.   The NIH representatives reported that they received such enthusiastic responses from Institute heads that they extended the meeting into a second day. We met with with the National Institutes of Dental and Craniofacial Research, Heart, Lung and Blood, Eye Institute, Institute on Aging, Biomedical Imaging and Bioengineering, Diabetes, and Digestive and Kidney Diseases, and the National Center for Advancing Translational Sciences.  We covered strategic and operational considerations for funding the best science in the stem cell and regenerative medicine space.  We explored potential avenues to join forces and leverage the assets and programs of both organizations, to accelerate the development of regenerative medicine and stem cell treatments.”

This was just a first meeting but it laid the groundwork for what we hope will be a truly productive partnership. In fact, shortly after returning from Washington, D.C., CIRM was immediately invited to follow-up NIH workgroups and meetings.

As this budding partnership progresses we’ll let you know how it’s working out.

A ‘Call to Action’ for change at the FDA

/ Kevin McCormack / 2 Comments

hd

It’s bad enough to have to battle a debilitating and ultimately deadly disease like Huntington’s disease (HD). But it becomes doubly difficult and frustrating when you feel that the best efforts to develop a therapy for HD are running into a brick wall.

That’s how patients and patient advocates working on HD feel as they see the Food and Drug Administration (FDA) throw up what they feel are unnecessary obstacles in the way of promising research.

So the group Help 4HD International has decided to push back, launching an online campaign to get its supporters to pressure the FDA into taking action. Any action.

Posing the question “Does the FDA understand that time is something we simply don’t have?” Help 4HD is urging people to write to the FDA:

“We have heard the FDA say they feel like our loved ones have quality of life at the end stages of HD. We have heard them say people with HD get to live for 20 years after diagnosis. It seems like the FDA doesn’t understand what we are having to live with generation after generation. We have seen HD research die because the researcher couldn’t get an IND (Investigational New Drug, or approval to put a new drug into clinical trials) from the FDA. We have seen trials that should be happening here in the USA move to other countries because of this. We have seen the FDA continue to put up delays and roadblocks. We are lucky to have amazing research going on for HD/JHD (juvenile HD) right now, but what is that research worth if the FDA doesn’t let it go into clinical trials? Drug development is a business and costs millions of dollars. If the FDA continues to refuse INDs, the fear is that companies will stop investing in HD research. This is a fate that we can’t let happen! We need to write to the FDA and let them know our frustrations and also help them understand our disease better.”

The group has drafted a sample letter for people to use or adapt as they see fit. They’ve even provided them with the address to mail the letter to. In short, they are making it as easy as possible to get as many people as possible to write to the FDA and ask for help.

The HD community is certainly not the only one frustrated at the FDA’s  glacial pace of approval of for clinical trials. That frustration is one of many reasons why Congress passed the 21st Century Cures Act late last year. That’s also the reason why we started our Stem Cell Champions campaign, to get the FDA to create a more efficient, but no less safe, approval process.

Several of our most active Stem Cell Champions – like Frances Saldana, Judy Roberson and Katie Jackson – are members of the HD Community. Last May several members of the CIRM Team attended the HD-Care Conference, held to raise awareness about the unmet medical needs of this community. We blogged about it here.

While this call to action comes from the HD community it may serve as a template for other organizations and communities. Many have the same frustrations at the slow pace of approval of therapies for clinical trials.

We are hoping the 21st Century Cures Act will lead to the desired changes at the FDA. But until we see proof that’s the case we understand and support the sense of urgency that the HD community has. They don’t have the luxury of time.

 

 

‘Right To Try’ laws called ‘Right To Beg’ by Stem Cell Advocates

/ Kevin McCormack / 1 Comment

In recent years, ‘Right to Try’ laws have spread rapidly across the US, getting approved in 32 states, with at least three more states trying to pass their own versions.

The organization behind the laws says they serve a simple purpose:

‘Right To Try’ allows terminally ill Americans to try medicines that have passed Phase 1 of the FDA approval process and remain in clinical trials but are not yet on pharmacy shelves. ‘Right To Try’ expands access to potentially life-saving treatments years before patients would normally be able to access them.”

That certainly sounds like a worthy goal; one most people could get behind. And that’s what is happening. Most ‘Right To Try’ laws are passed with almost unanimous bi-partisan support at the state level.

Beth Roxland

Beth Roxland

But that’s not the view of Beth Roxland, an attorney and health policy advisor with an extensive history in both regenerative medicine and bioethics. At the recent World Stem Cell Summit Roxland said ‘Right To Try’ laws are deceptive:

“These are not patient friendly but are actually patient unfriendly and could do harm to patients. The problem is that they are pretending to do something that isn’t being done. It gives patients a sense that they can get access to a treatment, but they don’t have the rights they think they do. This is a right to ask, not a right to get.”

Roxland says the bills in all 32 states are almost all identical, and use the same cookie-cutter language from the Goldwater Institute – the libertarian organization that is promoting these laws. And she says these laws have one major flaw:

“There is no actual right provided in the bill. The only right is the right to try and save your life, “by requesting” from a manufacturer a chance to try the therapy. The manufacturer doesn’t have to do anything; they aren’t obliged to comply. The bills don’t help; they give people false hopes.”

Roxland says there isn’t one substantiated case where a pharmaceutical company has provided access to a therapy solely because of a ‘Right To Try’ law.

However, Starlee Coleman, the Vice President for Communications at the Goldwater Institute, says that’s not true. She says Dr. Ebrahim Delpassand, a cancer specialist in Texas, has testified before Congress that he has treated dozens of patients under his state’s ‘Right To Try’ law. You can see a video of Dr. Delpassand here.

Coleman says ;

“We think the promise of ‘Right To Try’ is self-evident. If one doctor alone can treat 80 patients in one fell swoop, but the FDA can only manage to get 1200 people through its expanded access program each year, we think the potential to help patients is significant.”

Other speakers at the panel presentation at the World Stem Cell Summit said these laws can at the very least play an important role in at least raising the issue of the need for people battling terminal illnesses to have access to experimental therapies. Roxland agreed it was important to have that conversation but she pointed out that what often gets lost in the conversation is that these laws can have hidden costs.

  • 13 states may withdraw hospice eligibility to people who gain access to an early or experimental intervention
  • 4 states may withdraw home care
  • 6 states say patients taking part in these therapies may lose their insurance
  • Several states allow insurers to deny coverage for conditions that may arise from patients getting access to these therapies
  • 30 states say the companies can charge the patients for access to these therapies

Roxland says the motives behind the ‘Right To Try’ laws may be worthy but the effect is misleading, and diverts attention from efforts to create the kind of reforms that would have real benefits for patients.

Here is a blog we wrote on the same topic last year.

Why Goldilocks could provide the answer to changing the way FDA regulates stem cells

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img_1077

Panel on FDA regulation at World Stem Cell Summit

One of the hottest topics of the past year in regenerative medicine has been the discussion about the need for regulatory reform at the Food and Drug Administration (FDA) so it’s no surprise that topic was the subject of the first main panel discussion at the 2016 World Stem Cell Summit in West Palm Beach, Florida.

The panel, titled ‘FDA Oversight in Regenerative Medicine: What are the Options to Accelerating Translation’, kicked off with Celia Witten, Deputy Director of the Center for Biologics Evaluation and Research at the FDA. She laid out all the new steps that the agency is implementing to try and be more responsive to the needs of researchers and patients.

Perils facing pioneers

Martin McGlynn, the former CEO of StemCells Inc. was up next and he wasted little time listing the companies that had once been considered pioneers in the field only to fail for a variety of reasons. He said one of the big problems is that translational efforts, moving from a good idea to a clinical trial, take too long, saying 15 – 20 years is not unusual and that Big Pharma and strategic investors won’t invest until they see strong Phase 2 study results.

“We need to do great science and design and conduct great clinical trials to advance this field but we also have to come up with a sustainable business model to make this happen.”

A good start

He called the 21st Century Cures Act, which the US Senate approved yesterday, a good start but says many of the challenges won’t be helped by some of the new provisions:

“Many sponsors and companies don’t make it out of open label early studies, so the existence of an accelerated pathway or some of the other enabling tools included in the act will come too late for these groups.”

McGlynn warned that if we don’t take further steps, we risk falling behind the rest of the world where companies are buying up struggling US ventures:

“Many non-USA companies in Japan and China and Australia are quicker to recognize the value of many of the products and approaches that struggle here in the US.”

Too much, too little, just right

Marc Scheineson was the final speaker. He heads the food and drug law practice at Washington, DC law firm Alston & Bird and is a former Associate Commissioner for Legislative Affairs at the FDA. He began his presentation with what he said are the scariest words in the English language: “I‘m a lawyer from Washington D.C. and I’m here to help you.”

Scheineson says part of the problem is that the FDA was created long before cell therapy was possible and so it is struggling to fit its more traditional drug approval framework around stem cell therapies. As a result, this has led to completely separate regulatory processes for the transplantation of human organs and blood vessels, or for the use of whole blood or blood components.

He says it’s like the fable of Goldilocks and the Three Bears. Some of the regulation is too hard- resulting in a lengthy regulatory process that takes years to complete and costs billions of dollars – and some of the regulation is too soft allowing clinics to open up around the US offering unproven therapies. He says we need a Goldilocks approach that blends the two into regulations that are just right.

Time to take a second step

Scheineson agreed with McGlynn that the 21st Century Cures Act is a good start but it’s not enough.  He says it still relies heavily on the use of traditional criteria to regulate stem cells, and also leaves much of the interpretation of the Act to the discretion of the FDA.

“It’s a first step, an experiment to see if we can break the logjam and see if we can move things to an affordable BLA (The Biologics License Application is needed to be able to market a product once it’s approved by the FDA). But make no mistake, a cell therapy revolution is underway and I believe the FDA should seize the opportunity to promote innovation and not defensively protect the “status quo”.