(Another) open letter to Dr Fielden: generic imatinib

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I don’t take any pleasure in having to follow-up letters that haven’t been replied to, especially letters about something so important. I also dislike having to copy senior people in to force a reply out of someone, it feels childish and wastes time.

But, I’m left with no other option. The letter speaks for itself and I’ve linked PDFs to the two letters that have gone unanswered. I hope that this provokes a dialogue that reassures patients about the generic process. Thanks, Kris

 

Dr Jonathan Fielden
Director of Specialised Commissioning – NHS England
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17th March 2017

Dear Dr Fielden,

RE: Imatinib – your reference JF 16-1201.1

Sorry to have to write again but it has been a month since I asked for a swift response to my letter dated 16th February 2017. I should also note that the reason I sent the letter in February is because I didn’t receive a reply to the letter dated 21st December 2016.

I am concerned by your lack of communication and so are the CML patients that I represent, numbering around 2,000. I have copied the Secretary of State for Health, the Chief Executive of NHS England and my local MP who I hope will encourage you into dialogue with me. I have attached my previous communication and if need be my local MP, Mark Garnier, will vouch for my credibility, he is aware of my advocacy and has been incredibly supportive over the years.

At a time when you are expecting blood cancer patients to make significant changes to their treatment, I am appalled by the lack of communication and care that has been shown. I hope that we can kick-start this relationship and give CML patients some reassurances that their questions and concerns are being taken seriously and explored. Given the amount of money that the switch to generics will save the NHS, it is surely the very least that can be done.

With stretched budgets, patient advocates and charities are under increasing pressure to fill gaps. I am proud to represent my fellow patients and I will not stand by and be done unto and I will not go away. We are a ground-breaking bunch of cancer survivors and I expect to be treated with the same amount of dignity and respect by NHS England that we are shown at all other touchpoints within the NHS.

I’m sure you appreciate how important it is for patients to have faith in the system, I look forward to answers in full for all my questions including this addition to my previous letter.

  1. Some patients are reporting that consultants aren’t fully briefed on the switch. What measures have been put in place to ensure information has been disseminated and how is the data from new side-effects being monitored and centrally collated? Some patients are reporting new and different side-effects after switching.

The concerns I had in my previous letter still stand; the process that brought generic imatinib to market is flawed and this is now being realised. I hope that you can provide the reassurances that are needed.

Yours sincerely,

Kris Griffin (Mr)
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CC: Secretary of State for Health, The Right Honourable Jeremy Hunt MP
CC: Chief Executive of NHS England, Simon Stevens
CC: MP for Wyre Forest, Mark Garnier
CC: CML-UK Facebook Group
CC: CML-Worldwide Facebook Group
CC: Access CML Drugs blog

 

Letter to Dr Fielden dated 21st December 2016 – PDF
Letter to Dr Fielden dated 16th February 2017 – PDF

 

Open Letter to Dr Fielden: generic imatinib

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Due to a lack of response from Dr Fielden and the number of patients waiting for clarification on aspects of generic imatinib, I’ve taken the decision to make my most recent letter to Dr Fielden public. Let’s hope that he replies to this one. Kris

 

Dr Jonathan Fielden
Director of Specialised Commissioning
NHS England
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16th February 2017

Dear Dr Fielden,

RE: Imatinib – your reference xxxxxxx

I’m writing in response to my letter dated 21st December 2016 to which I’ve yet to receive a reply. I would appreciate a swift response to this letter given the troubling nature of the contents and the outstanding queries from previous communication.

  1. If a patient who has had a successful period on branded imatinib then switches to generic and cannot tolerate new side effects, are they able to revert to branded imatinib, considering it’ll likely to be cheaper than the other TKIs available?
  2. In a previous letter, you listed Leukaemia Care as an organisation who have been involved in drafting the guidance. Leukaemia Care aren’t aware of any such involvement. Please can you clear this up?
  3. Are you aware of a national shortage of Wockhardt (generic imatinib)? I’ve come across two instances now where patients have been without treatment. If you are aware, why has this happened?
  4. Are you aware of the labelling issue with at least two form of generic imatinib? This is the issue that suggests that the drug, for adults, is for blast crisis only and not chronic or accelerated phases. This issue has the ability to mislead and worry patients. What action are you taking and how did this issue escape what I hope would be a rigorous checking procedure?

Unfortunately, my concern with the process that brought generic imatinib to market is now being realised and I’ve very much like some answers.

Yours sincerely,

 

Kris Griffin (Mr)

 

FAO English Imatinib Patients

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It is vitally important to state that as far as we are aware, all versions of generic imatinib are the bioequivalent of the original drug (meaning they have the exact same active ingredients). If you are taking a generic, under the supervision and recommendation of your consultant, please carry on. Do not stop taking your drugs based on this information. We are CML patients and any clinical advice MUST come from a medical professional.

My good friend Nigel Deekes, who founded the CML-UK Facebook group, was switched to generic imatinib in early January. It appears he was one of the first to switch and being the diligent chap that I know that he is, he read the packaging.

The packaging on at least two of the generic drugs (as we understand it, this does not concern imatinib generics manufactured by Teva and Sandoz) suggest that the drug, for adults, is for blast crisis only and not chronic or accelerated phases. Blast crisis is an advanced form of CML. These generic drugs are not for blast crisis only and if you see this on your box or instructions it DOES NOT mean your disease has progressed. Also, it does not mean that your generic imatinib isn’t working. The generic drugs are the same and are safe but the indication on the leaflet in the box does not cover all phases.

Both Nigel and I agree that this is most unacceptable. Not only does this issue have the ability to mislead and worry patients, it is also indicative of the entire generic switch process. Be mindful that this issue was found by a patient and not through, what should be, a rigorous checking process, administered by NHS England. When we consider the lack of consultation and information provided to patients, this is not surprising.

All things being considered Nigel and I believe that generic imatinib patients who have incorrect information on their box should contact their hospital and ask to be put back on branded imatinib. We believe we are within our rights to do this as the indication on the leaflet is not for our stage of the disease. We could be accused of being pedantic but we want to be clear that patients should be prescribed the correctly licenced drug for our illness. Some patients have already swapped back to branded imatinib without any problems as their hospitals have acknowledged this issue.

The issues will take several months to resolve and at that point, we would recommend patients take up the offer of generic imatinib once again.

Our reasons for refusal are straightforward. We do not want life-saving drugs being used with information on them that has the potential to mislead the patient about their diagnosis. Generic imatinib is not the only drug available for treatment of CML, therefore there is not a risk in reverting back to branded.

If you are a generic imatinib patient please contact your consultant and ask to be put back on branded if your box indication is incorrect.

If you are a branded imatinib patient who is yet to switch, please discuss this issue with your consultant at your next appointment. Please do not be alarmed if your clinician still prescribes generic imatinib, they are able to prescribe ‘off label’ and they will discuss this with you. This information is design to ensure that you are included in this decision-making process.

PLEASE do not switch drugs or stop taking medication unless your consultant approves it.

All indication suggests that generic imatinib is good and safe to take under the direction of your consultant. It is the labelling/indication that is wrong.

For more information on generic imatinib and generic drugs please visit these useful resources from Leukaemia Care:

Generic imatinib for chronic myeloid leukaemia patients
Generic medicines – What are your rights?

Thank you.

Kris Griffin & Nigel Deekes

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Chronic Myeloid Leukemia patients call for quality and consistency when generics are introduced to treat their cancer

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PRESS RELEASE (from CML Advocates Network)

On 2-4 May 2014, patient organisations from 58 countries supporting patients and families affected by Chronic Myeloid Leukemia (CML) met in Serbia to learn from medical experts, share best practice in patient advocacy and grow their organisation’s capacity. An important topic of increasing attention discussed between patients and health professionals was the introduction of generics in CML treatment. Patients welcome that generics may improve patient access to more affordable therapies in many countries. However, patients also raise concerns about impact on their cancer when switched between different products for non-medical reasons, if these products’ equivalence in terms of quality and efficacy is uncertain.

With the imatinib patent expiring between 2013 and 2019, the introduction of generic versions is inevitable in many countries. Generics to treat CML have been introduced recently e.g. in Argentina, Bosnia-Herzegovina, Canada, Chile, China, Colombia, Costa Rica, Croatia, Cyprus, Dominican Republic, Guatemala, Ecuador, Egypt, Estonia, India, Kazakhstan, Lebanon, Latvia, Lithuania, Macedonia, Malta, Nepal, Philippines, Peru, Russia, Romania, Serbia, Slovenia, Slovakia, South Africa, Turkey and Uruguay.

Following intensive discussions at the global CML Advocates Network’s global meeting of representatives of CML patient advocates on 2-4 May, CML patient groups call to governments, health authorities and healthcare professionals to minimize potential uncertainties and risks for patients with the following five measures:

  1. No generic drug to treat CML should be provided to patients without reliable proof of quality as well as equivalence of pharmacokinetics and bioavailability. Generic drugs should be approved by the appropriate authorities of the respective country or region, also reflecting a narrow therapeutic range of these cancer drugs.
  2. When treating severe cancer diseases like leukemias with generics, further comparative clinical data should be collected, demanded by regulatory bodies, and published, to ensure comparable clinical efficacy of products with the same compound.
  3. A CML patient should not be switched between products with the same compound for non-medical reasons, provided this patient already responds optimally to the current product and tolerates it well.
  4. If a switch for non-medical reasons between products with the same compound is enforced, this should not happen more frequently than once in a year, to allow a consistent follow-up of responses and side effects on the same CML treatment. If a patient loses its response or experiences a significant increase of toxicities after switching to the other product, the patient must have the option to return to the previous treatment, or switch to another treatment if available.
  5. After switching between products with the same compound, more frequent monitoring should be conducted to detect potential differences in effectiveness or side effects early.

This declaration complements the “Baveno Declaration”, signed by more than 50 CML patient organisations in 2008 to call for best practice in CML care, improved access to cancer treatment, and better adherence to international treatment guidelines.

About CML

Chronic Myeloid Leukemia (CML) is a rare cancer affecting blood stem cells. It is a form of leukaemia characterized by the increased and unregulated growth of cells in the bone marrow and the accumulation of these cells in the blood. It is caused by a genetic rearrangement in chromosomes 9 and 22.

Current oral treatments have turned CML from a lethal into a chronic disease. Still in the early 1990s, only every fourth patient survived 10 years following the diagnosis with CML. The introduction of targeted therapies in 2001 have improved the 10-year survival to 84% today, if treated effectively. However, as demonstrated in clinical trials, maintaining a stable response requires continuous effective treatment. Suboptimal dosing, low adherence or cessation of treatment has shown to lead to recurrence and acceleration of the disease in most patients. Performing a bone marrow transplantation is still the only cure of CML, and the only feasible treatment of the disease in advanced phases.

About the CML Advocates Network

The CML Advocates Network is the global network for leaders of Chronic Myeloid Leukemia (CML) patient groups. It connects more than 80 patient organizations in more than 60 countries on all continents. Its aim is to grow capacity in patient advocacy organizations, to stimulate collaboration and best practice sharing, to provide educational resources, and to work with key stakeholders in the area of leukemia care and patient advocacy.

To help patient advocates to understand the background on CML generics, it has launched a Resource & Knowledge Center, pulling together all information that is known to the patient community to date. See www.cmladvocates.net/generics

The CML Advocates Network was set up in 2005 and is run by CML patients and carers. It is hosted by the Leukemia Patient Advocates Foundation, a patient-led global non-profit organization registered in Switzerland.

CML HORIZONS 2014 DAY 2

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On a normal Saturday morning I’d be getting up early with my little boy, Luca, and waiting for him to calm down (normally takes 4-5 hours) watching football and taking it easy. It’s an honour to change that routine this weekend and at 9am I am sat in a conference in Belgrade, Serbia with over 200 delegates; patients and families, clinicians and representatives from organisations who all have a vested interest in Chronic Myeloid Leukaemia (CML).

Our first session covered CML in real life – comorbidities and drug interaction. An outstanding review from Dr Neil Shah provided an overview of age and side effects. It was fascinating to hear the prescriptive differences that come with different age groups, essentially trying to balance tolerance and side effects. There is obviously a strong call for proper management of risks and benefits. I was also interested in the ease at which Dr Shah would move from one treatment to another, clearly not a problem when drugs are available and paid for. But, very much, the perfect scenario.

CML Horizons does a brilliant job in balancing the sessions and Professor Andrija Bogdanovic presented a localised example, from Serbia, of the situation he works in. It’s interesting to see him working with older drugs including hydroxyurea and achieving spectacular results, 78.6% complete cytogenetic response rate after 12 months! His frustrations were clear when talking about the limitations he faced when trying to fund care, “put the pressure on insurance”. Andrija works in a situation very different to Neil Shah but both remain committed, flexible and dedicated to saving lives with the resources they have in hand.

It’s critical to understand how individual our bodies are and how much what we eat affects our drug intake. Dr Annette Freidbank’s session on drug interactions provided a very specific journey into the many ways drug effectiveness can be changed. For example food increasing the effectiveness of nilotinib (Tasigna) by 82%

Once again we heard the warnings about grapefruit affecting the effectiveness of TKIs and we were all very thankful it wasn’t served at breakfast. Natural and herbal products may also cause interactions, it’s a key responsibility to be safe and informed. Therefore, the relationship we have with our doctor is critical, being able to ask advice, both Doctor and patient working together to make sure that the way the drugs are tolerable and ensure the drugs work. It’s a very topical, useful area of investigation.

After a short break we were treated to a presentation from Dr Martin Godfrey about using social media. Sadly some technical issues cut the presentation short but this approach is vital to patient organisations. Even in the 3 years I’ve been attending CML Horizons I’ve seen the conference grow digitally at an exponential rate. It’s certainly making our world much smaller and easier to connect and navigate, for a rare cancer like Chronic Myeloid Leukaemia this is imperative. Whilst this session was a little dry it did provide an overview, for beginners, as to the practical benefits of using social media.

The issues of trust, access, e-safety and misinformation are very, very real. It’s important that we don’t advocate a one-size-fits-all approach. We’re still finding our feet. I’ve seen some amazing results on Twitter and on Facebook, Nigel Deekes’ CML UK Facebook group in particular. Likewise, I’ve seen some horror stories where people have lost control of stories, access or information. Very sad. But, we mustn’t forget this can happen with any form of media, it’s just that social media is far more immediate…hence the fear factor. Only time and knowledge will overcome this.

The differentiated approach to advocacy strategy from Tamas Bereczky was very enlightening. Placing the expert patient at the heart of strategy and ensuring they work with academics, regulators and industry really works, as long as we can keep them motivated! I particularly enjoyed his approach to policy and scientific work and finding the balance between the two, maintaining credibility and increasing knowledge. Tamas is a skilled board member at the European AIDS Treatment Group (EATG) and they have become very good at advocacy work over a long period of time. There is much we can learn from them. The European HIV Testing Week initiative worked very well and was adopted widely as a community initiative.
The case study of Gilead’s Sofosbuvir, which is a life-saving treatment of HVC, was very relevant to the CML audience. The cost of the drug was restrictive and EATG took on a classic activism role to raise the issue. Perhaps we CML patients are too polite, perhaps we need to change?

Finally Tamas presented a very practical approach to advocacy work, I’d recommend looking his slides up when CML Horizons goes digital shortly after the conference. EATG have also created an advocacy manual on their website – www.eatg.org – which I am looking forward to reading.

On to the session many people were waiting for, a packed room for The New Realities: Generics and Copy Drugs in CML. Yoseph Caraco looked at how we assess generic drugs. If you are unfamiliar with the concept of generics, these are drugs where the patent expires and anyone can manufacture them and release them, typically with a 70-90% cost reduction. A huge cost reduction, surely a benefit? The issue is quality. A colleague described this as a classic song being covered by another artist, sometimes it’s still a great song…sometimes it isn’t so good.

Imatinib has a low penetration rate, around 30%, with CML patients worldwide. This is due to the high cost. We were shown that some generics only showed very slight underperformance compared to the parent drug, however it still presents a risk, I certainly wouldn’t want to be part of the 2% that could lose their response. I find it very concerning that we would switch for price alone. When clinical trials are undertaken and quality assurance is given the reassurance means everything to the patient.

Cheryl-Anne Simoneau from the CML Society of Canada took the baton and presented patients as informed decision makers. Canada has a very proactive generic market as the prices are capped to 18%-20% of branded drug prices. Cheryl advocates patient power, ensuring that PCR results are known, tracked and monitored very closely. It is vital that patients are aware of the prescription they are given and if anything changes they report it immediately – this includes packaging as well as any side-effects, “your CML journey is unique to you”. The society is looking to lead by being an promoting the example of an autonomous, informed, engaged patient.

Andrija Bogdanovic and Qian Jiang, both haematologists, discussed generics from their perspective. A variety of issues: no practical experience, different forms, not enough published data, lots of conflicting data in the media and bad experiences. It was noted that the Serbian solution was to switch all 220 CML patients to generic imatinib (Anzovip). Within 3 months 7 patients lost response, they were placed back on the previous drug and regained response. There was a slightly higher loss of response from newly diagnosed patients, after 12 months, who started on imatinib (Anzovip) (IRIS trail comparison). It’s clear that the Serbian haematologists are monitoring the situation very carefully and their clinical approach to generics is very commendable.

Qian Jiang’s focus was whether bio-equivalence is the same as clinical equivalence. She presented an overview of the situation in China where many generics are being released, a differentiation in provincial funding confused the matter even further. The practical advice followed Cheryl-Anne Simoneau’s patient power, ask questions, risk mitigate, wait for the right moment and clinical evidence before switching. She ended by stating that, “generics should not be recommended to patients without solid evidence of clinical equivalence in spite of bio equivalence”.

There are lots of questions being asked of generic drugs, there is no clear answer on whether they are good or bad. It’s about risk mitigation and from a patient perspective not taking a risk, this is life or death after all. Whilst I understand, I have an issue with this coming down to cost. Without clinical trials, which increase the cost, I fear we won’t get the answer we are looking for. For the patient who has no choice, there are no branded drugs available to them at all, generics present a very real opportunity to cling to life…

After a enjoyable night out with friends, I sit writing this blog, contemplating whether it’s worth giving up family time. Nothing is that important, but sometimes we have to make sacrifices. It’s been a good day and I have plenty to take home with me, there’s still a day left. Sunday is just around the corner.

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NEW CML Resource & Knowledge Centre

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Trust those great people at CML Advocates Network to drop a brilliant new resource in our lap. This is well worth checking out. K

Over the next three years, CML patients in more and more countries will be facing the use of generic TKIs and copy drugs to treat CML.

To provide patient organizations with background information on this important issue which has so far been quite difficult to find, we have launched a Resource & Knowledge Center on CML generics, copy drugs and substandard drugs.

Please see new section here: http://www.cmladvocates.net/generics

It provides:

  • an unofficial directory listing all CML tyrosine kinase inhibitors (TKIs) that are – to our knowledge – available to date:  http://www.cmladvocates.net/generics/cml-drugs-register
  • the results of our survey on generics, copy drugs and substandard drugs in CML which was conducted by CML Advocates Network in collaboration with iCMLf in March 2013. The survey summarizes 86 responses from 55 countries – the data is also available for download.
  • the webstreams of our session on CML generics and substandard drugs at “CML Horizons 2013”, which featured a presentation of the WHO, of the CML Association of Serbia and the CML Advocates Network
  • an index of scientific articles on the use of generic drugs in CML treatment: http://www.cmladvocates.net/generics/generics-publications
  • our blog on CML generics. (This is only available after login for members of the CML Advocates Network to keep discussions private in the community) http://www.cmladvocates.net/generics/generics-blog
  • a glossary with key terms and definitions in the area of drugs and generics: http://www.cmladvocates.net/generics/glossary

We will soon complement this by a “Best Practice Toolbox” for advocacy on generics in a few weeks, which is currently under construction. The “toolbox” will provide useful advice and tools on how to address this topic as an advocacy organization when generics or copy drugs are being introduced in your country.

Finally, we would like to stress that the Resource & Knowledge Center on CML generics, copy drugs and substandard drugs is a purely patient-driven, non-commercial initiative. It has no interest to promote, or assess, any of the drugs. The only intent is to increase transparency in a confusing environment.

We hope that you will find this Resource & Knowledge Center very useful!
We are looking forward to your active participation in the blog and the new knowledge center, and are happy to receive your feedback!

Nicole, Giora and Jan
CML Advocates Network –
http://www.cmladvocates.net

CML Horizons 2013 – Day 1 report

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After an omelette breakfast and a catch up with some friends we settled down to the first session of the day chaired by the irrepressible Tony Gavin from Leukaemia Care. This European group meeting on Health Technology Assessments (HTA) and cross border healthcare was a healthy start to the day, unlike my breakfast. HTAs and cross border healthcare is a hot topic and lacks clarity and vision, simply bringing the threads together is the challenge, perhaps digital is the answer and both speakers Martin Visnansky and David Ryner alluded to this.

The always impressive Sarunas Narbutas from Lithuania expanded on the issues of cross border healthcare by presenting the key issues and explaining the complex legal technicalities. The structural differences of healthcare systems in each EU country means that there is much work to do before legal implementation on 25th October 2013. After this date we must prepare ourselves for an influx of healthcare visitors to the UK but conversely this opens an opportunity for us to access dasatinib (a drug not readily available in the UK) from another country.

As the main conference got underway we were treated to a video message from the legendary Spanish tenor Jose Carreras, who is a leukaemia survivor. Giora Sharf then provided updates on the inspirational work of the CML Advocates Network.

After a very broad overview from the World Heath Organisation on generic and counterfeit drugs, Jan Geissler took the bull by the horns and presented hard data collated from 55 countries on the availability and occurrence of generic drugs. My concern still remains, are we debating the right issue here? Surely the proliference of generic drugs CAN be a good thing, the pharmaceuticals who developed the drugs would obviously disagree. We should be asking how we ensure standards and quality control the generic drugs. If this leads us to first-class drugs at reduced prices then I don’t have a problem, making sure this happens is the challenge.

The anzovip case study in Serbia presented by Jelena Cugurovic simply highlights the issue of regulation, transparency and quality control. How can a drug be made available to patients when it is not supported by documentation or trial data. This is an opportunity to put pressure on the pharmaceutical industry and drive prices down using the threat of quality generics. It’s clear that this issue needs some very strong guidance and legislation, the organisation in the best position to provide this , the WHO, seem incapable or unwilling. Lives are being put at risk…and I’m tired of writing that.

The final session of the day gave us an update on CML drugs and clinical developments by 3 well respected medical Doctors from Israel, Italy and Australia. We were presented with a number of areas that included the debunking of myths, the efficiency of combination therapy (with Inferferon) and the latest drug efficiency. Doctor Tim Hughes from Australia was particularly impressive with key studies showing how we can predict response rates in the first 3 months of treatment (TIDAL 1 study). The second study (TIDEL 2) showed the importance of switching treatment (from imatinib to nilotinib) after a set period of time if an optimum response isn’t achieved. The survival rate in TIDAL 2 over 4 years is 97%. Time and time again we are seeing that imatinib is a drug that is being superseded by vastly superior 2nd generation drugs. Imatinib has done a wonderful job for us in the past but ultimately we wouldn’t be using it if cost wasn’t an issue.

The day is over; dinner, beer and bed to come. The day has been intense as expected, lots to think about, take home and action. I’m looking forward to tomorrow but I’m going to have to bring my ‘A’ game when I present to over 100 delegates tomorrow. The pressure is on… Have a good evening and thanks for reading.

Kris
PS. I’ll tag the photos when I get home.

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