Private practice with Dr Seth Bilazarian

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Why doesn't the FDA trust us with dabigatran dosing?

May 20, 2011 11:00 EDT


The FDA sends out a clear message relating to its recent ruling on dabigatran dosing: clinicians and patients can't be trusted to get the dosing of dabigatran right. What other rationale can there be for this decision?

See:

Beasley BN, Unger EF, Temple R. Anticoagulant options--Why the FDA approved a higher but not a lower dose of dabigatran. New Engl J Med 2011; 364:1788-1790. Available here.

FDA explains decision on dabigatran 110-mg dose








Your comments
Why doesn't the FDA trust us with dabigatran dosing?
# 1 of 1
July 21, 2011 12:16 (EDT)
Dr. W
Well there are several points to consider regarding dabigatran and FDA's recent NEJM publication. First, the authors of that paper do not and have not practiced medicine or seen patients in many years, if at all--they are in fact bystanders.  Second, when the FD&C Act was amended in the early 1960's Congress prohibited FDA itself from the "practice" of medicine.  In other words, it was not FDA's mandate to tell physicians "what" drug to prescribe and to whom. Third, FDA has always maintained that dose response is very valuable evidence and perhaps the most compelling evidence of a drug effectiveness for condition or disease.  A dose response for effectiveness parameters and safety parameters is the most desired statistic of all.  In dabigatran, a dose response was evident for effectiveness and safety.  Instead of elaborating on this compelling finding in the product label and allowing physicians to decide which dose to use, FDA made a decision for every practicing physician and withheld approval of an effective dose.  In doing this, FDA ignored the variance around mean or average data and "lumped" all patients into 2 groups:  one dose dose for those with renal impairment and one dose for those without.   In the practice of medicine, the "one size fits all approach" has failed despite Pharma's best marketing efforts. But in this case, no one will know how badly "one dose fits all" will fail.   FDA has set a very dangerous precedent and ignored its own approval standards and scientific disclosure policy in the product label.  FDA has now distinguished itself from every other Western Civilized Country which has approved the 110 mg dose by withholding approval of the 110 mg dose because statistical reasons.   FDA's decision was made without transparent consultation from the practicing physicians.  The publication was just too late and for most part inadequate to justify the "one size fits all" decision. Expect more of this in the future.  

 


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About Dr Seth Bilazarian
Seth Bilazarian MD has been a Clinical and Interventional Cardiologist at Pentucket Medical Associates in Massachusetts since 1993. He is board certified in Internal Medicine, Cardiovascular Medicine, Nuclear Cardiology, Vascular Ultrasound, Interventional Cardiology, and Vascular and Endovascular Medicine.

Dr Bilazarian performs coronary and peripheral interventions at Lahey Clinic and Massachusetts General Hospital. He has been an investigator in the interventional laboratory for new devices including drug-eluting stents, distal protection devices, imaging devices (OCT and InfraRed), and anticoagulant pharmacotherapy.

Dr Bilazarian is an active participant in clinical trials in congestive heart failure, hypertension, coronary disease prevention, prediabetes management, anemia, atrial fibrillation, and anticoagulation/antiplatelet therapies in the outpatient setting. He has authored numerous papers and book chapters in clinical cardiology. He was appointed as a physician advisor to the circulatory device panel of the FDA in 2008.
About this blog
My intent is to create a forum for dialogue on issues pertinent to private practice cardiology around topics such as:

  • Integration of new data and guidelines on inpatient and outpatient practice in clinical and interventional cardiology
  • Practice approaches to the extra clinical issues in dealing with managed care insurers
  • Strategies for navigating the restrictions of pharmacy benefits managers (PBMs) on pharmacologic therapies for our patients
  • Experiences with restrictions on testing and imaging
The video blog (VLOG) will provide an opportunity to share broadly different approaches to the common conundrums we face in caring for patients. My hope is that this forum will provide useful data points for practice outside of tertiary and academic centers and a look inside community hospitals and physician?s practice patterns in the office, starting with mine.