To: DaveAu who wrote (11298 ) 10/26/2002 7:38:14 PM From: axial Respond to of 14101 Hi, Dave - "She was also clear that these were for marketing and haven't been shown to the regulator because that would just slow down the process as they were reviewed." Thanks for that: it makes sense, and it establishes that the process is apart and separate from the approval process (Director Review), which goes on, unimpeded. I append some comments by CaptainKlutz on the question of the possible purpose of these studies:"I think it is more likely that any head-to-head comparisons that DMX is presently conducting are largely for the purposes of reimbursement -- convincing third party payors to list Pennsaid on their respective formularies -- and to some extent, pricing,. It is highly unlikely that the FDA would permit a superior safety claim for a new drug on the basis of short term (12 wk.) trial data. I expect you would need several years experience with the drug and a number of long term pivotal trials before it would be allowed. On the other hand, the drug payors are quite willing to rely on short term comparative data in deciding whether or not to list a particular product. In fact most of them will insist on it and it will be to the company's advantage to have some economic outcomes data before they seek a listing with the various payors. The current studies are likely aimed at the provinces and the HMO's. (And possibly the regulatory agencies in Germany and France where, if I am not mistaken, the approval of the drug depends on the willingness to pay for it in the first place.)" stockhouse.ca ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ I think the question of whether or not these studies would be acceptable to the FDA in terms of changes to labelling/marketing is unresolved, and is worthy of further research. He may be correct, I don't know. However, Klutz rightly brings up the importance of pricing in different jurisdictions, and trying to address the issue of cost-effectiveness. It is known that the price of Pennsaid is high, relative to other topicals. However, the posts of murray6, and available data establishes the reality of polypharmacy in many older patients. It is also a well-established fact that the most expensive treatment costs are incurred at the time of intensive care, when patients are in near-death condition. The link between COX2's, and putting patients into that expensive and ruinous condition has not been made - but many physicians are starting to raise questions, and the possibility has to be considered. If that link can be established, then the use of Pennsaid, despite its price, may turn out to be the right decision: prolonging (not decreasing) mortality, and decreasing managed-care costs. If statisitics even suggest that possibility, then the use of COX2's may turn out to be simply inhumane, never mind cost-effective. I'm speaking here of studies where data suggests a linkage, such as smoking studies, which did not prove a direct causal link to lung cancer. The case for cost-effectiveness is one that DMX has to make. Jim