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Curricular Track I: REMS and Regulation Updates to Promote Medication Safety Activity No. 0217-0000-14-115-L05-P, 1.5 contact hours; Knowledge-based activity.
Tuesday, October 14 10:15 a.m.–11:45 a.m. Convention Center: Grand Ballroom D
Moderator: Laura B. Borgelt, Pharm.D., FCCP, BCPS Professor, University of Colorado Anschutz Medical Campus, Skaggs School of Pharmacy & Pharmaceutical Sciences, Aurora, Colorado
Agenda
10:15 a.m. The Evolution of Risk Evaluation and Mitigation Strategies (REMS): Updates That Pharmacists Need to Know Katie Stabi, Pharm.D., BCPS Clinical Coordinator, Drug Use Policy and Compliance, Department of Pharmacy Services, University of Chicago Medicine, Chicago, Illinois
10:45 a.m. The Food and Drug Administration (FDA) and Institute for Safe Medication Practices (ISMP): Teaming Up to Reduce Medication Errors Rebecca H. Stone, Pharm.D., BCPS, BCACP Clinical Assistant Professor, University of Illinois Chicago, Chicago, Illinois
11:15 a.m. Applying Recent FDA Safety Communications into Your Everyday Practice Mandy C. Leonard, Pharm.D., BCPS System Director, Drug Use Policy and Formulary Management, Department of Pharmacy, Cleveland Clinic, Cleveland, Ohio
Conflict of Interest Disclosures
Laura B. Borgelt: no conflicts to disclose. Mandy C. Leonard: no conflicts to disclose. Katie Stabi: no conflicts to disclose. Rebecca H. Stone: no conflicts to disclose.
© American College of Clinical Pharmacy 1
Learning Objectives
1. Briefly explain the goals and scope of Risk Evaluation and Mitigation Strategies (REMS). 2. Determine strategies for the implementation of the more complex REMS requirements. 3. Given patient specific information, design a successful REMS plan to perform the
required functions and provide appropriate information. 4. Evaluate the barriers and outcomes of implementing REMS, including information and
knowledge provided to patients and health care professionals. 5. Compare and contrast medication error reporting programs for the Food and Drug
Administration (FDA) and Institute for Safe Medication Practices (ISMP). 6. Using case examples, analyze the most common medication safety issues reported to
ISMP with successful practices to mitigate the error potential for each. 7. Apply the collaborative initiatives between the FDA Center for Drug Evaluation and
Research (CDER) and ISMP to prevent harm from medications. 8. Through the FDA’s Safe Use Initiative, design effective strategies for health care
providers and patients to collaboratively reduce medication errors. 9. Describe various Food and Drug Administration (FDA) drug safety communications,
including the MedWatch program. 10. Examine the risks and benefits of patients taking medications involved in FDA safety
communications. 11. Assess the significance of various FDA safety warnings based on evidence. 12. Develop appropriate therapeutic plans for patients impacted by a FDA safety warning.
Self-Assessment Questions Self-assessment questions are available online at www.accp.com/am
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 2
2014 ACCP Annual Meeting
REMS and Regulation Updates to Promote Medication SafetyKatie L Stabi, PharmD, BCPSOctober 14, 2014
Conflict of Interests
Nothing to disclose
Learning Objectives
Briefly explain the goals and scope of RiskEvaluation and Mitigation Strategies (REMS)
Evaluate the barriers and outcomes of implementingREMS, including information and knowledgeprovided to patients and health care professionals
Determine strategies for the implementation of themore complex REMS requirements
Given patient specific information, design asuccessful REMS plan to perform the requiredfunctions and provide appropriate information
REMS Programs
Strategy by the FDA to manage a known or potentialserious risk associated with a drug or biologicproduct
Support safe access to drugs that have knownserious risks and would otherwise be unavailable
REMS is “necessary to ensure that the benefits ofthe drug outweigh the risks of the drug”
Am J Health-Syst Pharm 2009;66(Suppl 7):S3-S5.
REMS Components
Medication guide (MedGuide)
Communication plan
Elements to assure safe use (ETASU)
Implementation system
Assessment
Am J Health-Syst Pharm 2009;66(Suppl 7):S3-S5.Hosp Pharm 2010;45(7):576-580.
Elements to Assure Safe Use
Prescribers have specific training, experience, or specially certified
Settings that dispense the drug are specially certified
Drugs dispensed to patients only in certain healthcare settings
Drug dispensed only with evidence or other documentation of safe‐use conditions
Patient can be subject to certain monitoring
Patient may be enrolled in a registry
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM184128.pdf Am J Health-Syst Pharm 2009;66(Suppl 7):S3-S5.
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 3
ETASU Inpatient Pharmacist Responsibility
Prescribers: specific training, experience, or certified
Verify certified prescribers
Hospital: certified None
Drug: dispensed only for inpatients None
Safe-use conditions: documentedVerify documents / labs completed /
additional requirements
Patient: monitoring required Verify monitoring completed
Patient: enrolled in a registryVerify patient enrollment / enroll
patient
Elements to Assure Safe Use REMS Programs
144
32
35
6
Released REMS REMS with ETASU
REMS without ETASU Shared System
N = 217; Updated 8/12/14http://www.fda.gov/drugs/drugsafety/postmarketdrugsafetyinformationforpatientsandproviders/ucm111350.htm
REMS Programs
0 1 1
99
33
6 41 5 8 7 5 4 23 6 94 5 3 5
0 0 1 1 2 2 00
20
40
60
80
100
2008 2009 2010 2011 2012 2013 2014
Num
ber
Year
Released REMS REMS with ETASU
REMS without ETASU Shared Systemhttp://www.fda.gov/drugs/drugsafety/postmarketdrugsafetyinformationforpatientsandproviders/ucm111350.htm
N = 217; Updated 8/12/14
Barriers and Outcomes of Implementing REMS
Primary Barrier
Awareness
Knowledge
Education
Who needs it? Health Care Professionals
REMS Representatives
Addressed ETASU
Prescribers have specific training, experience, orspecially certified
Drug dispensed only with evidence or otherdocumentation of safe-use conditions
Patient can be subject to certain monitoring
Patient may be enrolled in a registry
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 4
Medical license = certified, right? Who is certified?
Ask prescriber Verify with REMS program
Call REMS program for list Call REMS program with possible prescriber names
REMS program hours Online database of certified prescribers
Information needed to log-in not available Incorrect information typed by REMS representative Need to know prescriber’s enrollment ID to verify
Outpatient requirement only, right?
Challenges of Certified Prescriber Requirement
Challenges of Documented Safe-use Conditions Risk:benefit discussion occurred
How is this verified? Enrollment form signed
How is this verified? Labs obtained
Documentation required? Patient enrolled in REMS
Prior to dispensing drug or start paper work? Medication guide dispensed
Who does this? Patient registered with REMS program
Which registry? Can an inpatient pharmacy even dispense the drug?
Outcomes of Successful REMS Implementation Staff educated Pharmacists able to explain requirements
Services consulted, as needed
Electronic support
Hospital specific REMS information readilyavailable
Patient able to obtain drug without interruption Order entry → Order verification → Dispensing
Strategies for Implementing REMS
Where to Start
Build a REMS infrastructure
Designate a coordinator Standardization, efficiency, reference
Prioritize programs Determine what is formulary
Determine true nonformulary, not stocked
Determine what needs to be home medication use
Identify ETASUs that affect inpatient use Not just if stocking and dispensing drug
If drug stocked, who signed all the paperwork?
Education Pharmacists Primary service groups
Determine required versus optional ETASUs Start with required Determine if optional ETASUs will be enforced
Create a Checklist / working document FDA REMS documents Company websites Contracts and information provided by wholesalers Representatives of REMS Programs contacted
Next Steps
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 5
Pharmacy Enrollment and Responsible Persons Duties
Procurement and Storage of Medication
Medication Guide Requirements and Process
Prescriber Enrollment and Pharmacy Notification
Patient Enrollment and Verification
Dispensing the Medication
Laboratory Monitoring
Electronic Software Updates
Additional Considerations
Patient Discharge
Checklist: REMS Program Considerations
Common Inpatient ETASU
Certified prescriber Facility specific list
Patient:Physician Acknowledgement Form Scan into medical record
Labs documented Display in drug file
Patient registration with REMS Alert verifying pharmacist
Electronic Support
Alerts in the medical record
Policies and procedures posted
Medical record support Scanned forms
Formulary software
Intranet
Alerts
Order Entry Alerts
Ordering instructions
Order Verification Alert
This drug has a Risk Evaluation and Mitigation Strategy (REMS) Program that requires a certified prescriber to place the order. Consult one of the following:
REMS Drug: Click here to verify all REMS requirements have been met.
Questions Embedded in Drug Record
Are you a certified prescriber?
Is the patient enrolled in the registry?
Have the XXX labs been completed?
Is this a continuation of home therapy?
Has the patient signed an enrollment form?
Is the patient of child bearing potential?
no yes
no yes
no yes
no yes
no yes
no yes
Case Scenario
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 6
2014 ACCP Annual Meeting
The Food and Drug Administration (FDA) and Institute for Safe Medication Practices (ISMP): Teaming Up to Reduce Medication Errors
Rebecca Stone, Pharm.D., BCPS, BCACP
October 14th, 2014
Learning Objectives
1. Compare and contrast medication error reporting programs for the Food and Drug Administration (FDA) and Institute for Safe Medication Practices (ISMP).
2. Using case examples, analyze the most common medication safety issues reported to ISMP with successful practices to mitigate the error potential for each.
3. Apply the collaborative initiatives between the FDA Center for Drug Evaluation and Research (CDER) and ISMP to prevent harm from medications.
4. Through the FDA’s Safe Use Initiative, design effective strategiesfor health care providers and patients to collaboratively reduce medication errors.
Hierarchy
Institute for Safe Medication Practices(ISMP)
Food and Drug Administration(FDA)
MedWatch
Medication Errors
Reporting Program(MERP)
Vaccine Errors
Reporting Program(VERP)
Center for Drug Evaluation and Research(CDER)
Safe Use Initiative
(SUI)
Vaccine Adverse Event
Reporting system
(VAERS)
FDA: MedWatch
FDA Safety information and adverse eventreporting program Voluntary and confidential
Health care professionals
Consumers
FDA: MedWatch
What to reportAdverse events related to Prescription meds OTC meds Biologics Medical devices Special nutritional products Cosmetics Foods/beverages
What NOT to report Vaccines Investigational drugs Mandatory reporting by
regulated industry Dietary Supplements
ISMP: MERP & VERP
Non-profit organization adverse eventreporting program focused on system-basedcauses of medication and vaccine errors Voluntary and confidential
“Frontline practitioners” Consumer reporting system
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 7
ISMP: MERP & VERP
What to report Errors
Prescribing, transcribing, dispensing, administering, and monitoring
Wrong drug/strength/dose Look alike/sound alike Calculation or preparation
errors
Preventable adverse rxns Close calls Hazardous conditions
What NOT to report Adverse or allergic rxns Investigational drugs Mandatory reporting by
regulated industry Dietary Supplements
Where to report?
ISMPMedWatch
VaccinesClose callsSystem based errors
Medication Adverse RxnAllergic RxnMedical devices Foods/beverages CosmeticsSpecial nutritional products
All Medication ErrorsPreventable adverse Rxn
Hazardous conditions
Investigational drugsMandatory industry reporting
Dietary supplements
Patient case #1
TH is a 64 yo male with insulin dependent DM TH was seen at his primary care clinic by a medical resident for DM f/u
2 weeks ago.
He had been using a Lantus vial 30 units qhs. His poct A1C was 9.5%, fasting SMBG at goal, 2 hr postprandial SMBG all >200 mg/dl.
His provider prescribed Novolog Flexpen 5 units BID AC, continue Lantus 30 units qhs. There was limited time for patient education during his visit.
TH calls today and is triaged to the clinical pharmacist because he has been experiencing hypoglycemia in the early morning since he started using his new insulin.
ISMP ambulatory care high alert medicationsClasses/Categories Antiretroviral agents Oral chemotherapeutics Oral hypoglycemics Immunosuppressants Insulin Opioids Pediatric liquids Pregnancy Cat X
Specific agents carBAMazepine Chloral hydrate liquid UF and LMW heparins metFORMIN Methotrexate Midazolam liquid Propylthiouracil Warfarin
Patient case #1, cont’d
Further investigation by the PharmD revealsthat TH received NovoLIN N Flexpen, notNovoLOG Flexpen insulin as intended
Where did the error(s) occur?
What steps/tools can be utilized to reduce therisk of error(s)?
http://www.ismp.org/tools/default.asp [Accessed August 15, 2014]
ISMP Tools
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 8
http://www.ismp.org/tools/highalertMedications/default.asp [Accessed August 15, 2014]
ISMP Tools
http://www.ismp.org/tools/personal_med_form/default.asp [Accessed August 15, 2014]
ISMP Tools
http://www.ismp.org/tools/personal_med_form/default.asp [Accessed August 15, 2014]
ISMP Tools
Patient case #1, cont’d
Error analysis revealed that the NovoLOGFlexpen prescription was written correctlywhen entered, but was filled incorrectly by thepharmacy.
What tools are available from ISMP for errorrisk assessment during the dispensingprocess?
Risk of error evaluation
High-Alert Medication Modeling and Error-Reduction Scorecards (HAMMERSTM )
Free tool designed to help community pharmacies: Identify their unique set of system and behavioral risks
associated with dispensing certain high-alert medications
Estimate how often an error or adverse drug event reaches a patient
http://www.ismp.org/tools/HAMMERS/default.asp [Accessed August 15, 2014] http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm297644.htm#1 [Accessed August 15, 2014]
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 9
Collaboration: ISMP & FDA’s Center for Drug Evaluation and Research (CDER)
"As a part of its ongoing effort to fight [medication error] risks, [FDA] has entered into an agreement with ISMP to develop collaborative efforts to reduce preventable harm from medicines…”
"The collaboration is also designed to provide more informational and educational materials for both consumers and health care professionals.”
“The relationship will broaden FDA's ability to reach out to [consumers and health care professionals] when there are issueswith product safety and effectiveness."
http://www.fda.gov/ForConsumers/ConsumerUpdates/ucm297644.htm#1 [Accessed August 15, 2014]
Collaboration established 2012
ISMP reviews all FDA MedWatch reportswhich contain information about medicationerrors
As a MedWatch partner, ISMP promotesFDA’s initiatives to reduce adverse drugreactions
Hierarchy
Institute for Safe Medication Practices
(ISMP)
Food and Drug Adminstration(FDA)
Medication Errors
Reporting Program(MERP)
Vaccine Errors
Reporting Program(VERP)
Center for Drug Evaluation and Research(CDER)
Pooled error report data
ISMP promotes findings to reduce adverse events
MedWatchSafe Use Initiative
(SUI)
Vaccine Adverse Event
Reporting system
(VAERS)
ISMP electronic newsletters
ISMP Medication Safety Alert!®
Acute Care edition
Community/Ambulatory Care edition
Nurse Advise-ERR
Long-Term Care Advise-ERR
Safe Medicine
ISMP QuarterWatch: Monitoring FDAMedWatch Reports
http://www.ismp.org/newsletters/default.asp [Accessed August 15, 2014]www.ismp.org/quarterwatch/default.aspx [Accessed August 15, 2014]
Patient Case #2
DR is a 32 yo F, pregnant at 25 wga, andwas diagnosed gestational DM today basedon her OGTT Her newly hired high risk OB/GYN provider wants
to start her on a weight based basal/bolus insulinregimen of NPH and regular insulin
Patient case #2, cont’d
The MD searches “insulin regular” and is presentedthe following options
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 10
Patient case #2, cont’d
DR’s OB/GYN provider was not aware of thedifferences between U-100 and U-500 insulin U-500 insulin was incorrectly selected The community pharmacist caught the error when
the dose in U-500 formulation was unable to beeasily measured in insulin syringes
What steps/tools can be utilized to reduce the riskof error(s)?
Medication Safety Alert!®
Specify problem based on recent errorreports and recommendation for avoidance
https://www.ismp.org/newsletters/acutecare/showarticle.aspx?id=62 [Accessed August 15, 2014]
Patient case #2, cont’d
Community pharmacist was aware ofincreasing U-500 insulin errors Tuberculin syringes recommend for U-500
Facility updated order entry
FDA: Safe Use Initiative
“The goal is to reduce preventable harm byidentifying specific, preventable medicationrisks and developing, implementing andevaluating cross-sector interventions withpartners who are committed to safemedication use.”
http://www.fda.gov/Drugs/DrugSafety/SafeUseInitiative/default.htm [Accessed August 15, 2014]
http://www.fda.gov/drugs/drugsafety/safeuseinitiative/ucm188762.htm [Accessed August 15, 2014].
Patient case #3
SG is a 22 yo male who presents to the University Health Center for a same day appointment with asprained ankle from an intramural kickball incidentyesterday. He endorses 6 out of 10 pain.
Home meds Albuterol inhaler 2 puffs q 4 prn SOB OTC loratadine 10 mg po daily OTC Nyquil two tbsp “for sleep if my roommate is being loud” OTC APAP 325 mg one po q 6 hr prn pain
Social history per patient Drinks two to three beers per day Smokes five cigarettes per day
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 11
Patient case #3, cont’d
Physical evaluation of SG by his PCP issupportive of a severe sprained anklediagnosis His PCP prescribes the following
Crutches stay off ankle Hydrocodone/APAP 5/325 mg, one po q4 hr prn pain, #30,
0 RF
When SG picks up his prescription what issuesshould be addressed during counseling?
APAP- Rx container labels
APAP liver injury related to overdose remainsa serious public health issue Consumers need to be able to
Identify products containing APAP Compare active ingredients on their Rx and OTC labels Take action to avoid 2 products with APAP
APAP – Rx container labels
National Council for Prescription DrugPrograms (NCPDP) and FDA collaboration Produced “NCPDP Recommendations for Improved
Prescription Container Labels for MedicinesContaining APAP” Eliminate active ingredient abbreviations Standardize liver pharmacy warning label Format with plain language and health literacy principles Stakeholder call to action
FDA has ongoing public education campaign
http://www.fda.gov/Drugs/DrugSafety/SafeUseInitiative/ucm188762.htm [Accessed August 15, 2014] http://www.fda.gov/Drugs/ResourcesForYou/Consumers/BuyingUsingMedicineSafely/UnderstandingOver-the-CounterMedicines/SafeUseofOver-the-CounterPainRelieversandFeverReducers/ucm164977.htm#fact_sheets[Accessed August 15, 2014]
Patient case #3
Stakeholder call toaction
Utilize counseling toolsfor SG regarding thedangers of APAPoveruse
Refer SG to additionalself education “Know your dose” http://www.knowyourdose.org/
http://www.fda.gov/downloads/Drugs/ResourcesForYou/Consumers/BuyingUsingMedicineSafely/UnderstandingOver-the-CounterMedicines/SafeUseofOver-the-CounterPainRelieversandFeverReducers/UCM234237.pdf[Accessed August 15, 2014]
Summary
FDA’s MedWatch and ISMP’s MERP & VERP programsare appropriate pathways for medication error reporting
ISMP produces many provider and consumer MedicationSafety Tools and Resources for med error risk mitigation
The FDA and ISMP collaboration is designed to helpkeep healthcare providers (YOU!) informed regardingcurrent medication issues
The FDA’s Safe Use Initiative brings togetherstakeholders to implement large scale, cross-sectorinterventions at the national level to prevent med errors
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 12
2014 ACCP Annual Meeting
Applying Recent FDA Safety Communications into Your Everyday PracticeMandy C. Leonard, Pharm.D., BCPSOctober 14, 2014
Conflict of Interests
No conflicts of interest to disclose.
Learning Objectives
Describe various Food and Drug Administration(FDA) drug safety communications.
Examine the risks and benefits of patients takingmedications involved in FDA safetycommunications.
Assess the significance of various safetywarnings based on evidence.
Develop appropriate therapeutic plans forpatients impacted by a FDA safety warning.
Food and Drug Administration (FDA)
Center for Drug Evaluation and Research(CDER)
Center for Biologics Evaluation and Research(CBER)
Monitors and reviews safety information for adrug’s (or biological product’s) life cycle
Post-marketing Diverse populations
http://www.fda.gov/downloads/Drugs/DrugSafety/UCM300946.pdf [Accessed August 15, 2014].
History
In 2004, FDA initiated planning of long-termsafety changes
In 2007, Food and Drug AdministrationAmendments Act (FDAAA) granted authorityto FDA for assuring drug safety Safety First Safe Use Strengthening Drug Safety Science Drug Safety Communications
http://www.fda.gov/downloads/Drugs/DrugSafety/UCM300946.pdf [Accessed August 15, 2014].
Safety First
Establish equal priority to postmarket safety andpremarket safety
Create collaboration via a multidisciplinaryapproach within the Offices at the FDA Equal Voice Initiative
Implement FDAAA’s drug safety provisions Postmarket studies/clinical trials Required labeling changes REMS authorities Quarterly online reports
http://www.fda.gov/downloads/Drugs/DrugSafety/UCM300946.pdf [Accessed August 15, 2014].
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 13
Safe Use
Reduce preventable drug harm caused byinappropriate use (e.g., unintentionaloverdose or inappropriate prescribing) Preventing acetaminophen toxicity Medication adherence Prescription opioids
http:www.fda.gov/Drugs/DrugSaefty/SafeUseInitiative/ucm188762.htm [Accessed August 15, 2014].http://www.fda.gov/downloads/Drugs/DrugSafety/UCM300946.pdf [Accessed August 15, 2014].
Drug Safety Science
Develop new drug safety tools Advance risk evaluation during drug
development Dedicate statistical analysis (biostatisticians) Expand epidemiology studies Understand and use pharmacogenomics Enhance adverse event surveillance Create The Sentinel Initiative
http://www.fda.gov/downloads/Drugs/DrugSafety/UCM300946.pdf [Accessed August 15, 2014].
Enhance Communication
Use a systematic approach Communicate to public as early as possible Use single format for drug safety issues Drug Safety Communications (DSC)
Study most effective communication methods Publish articles in medical journals Gain advise and expert opinion on how to
communicate drug risks
http://www.fda.gov/downloads/Drugs/DrugSafety/UCM300946.pdf [Accessed August 15, 2014].
Drug Safety Information-Guidance Important drug safety issue
Alter benefit-risk analysis; affects decision regardingprescribing or taking a drug
Serious adverse reactions identified after drugapproval
Medication errors Emerging drug safety issue
Has the potential to alter the benefit-risk analysis thatmay affect the decision regarding prescribing or takinga drug
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM295217.pdf[Accessed August 15, 2014]
Emerging Drug SafetyConcern- Identification Prompt review and analysis FDA Sponsors
Sources of data Spontaneous reports
MedWatch Vaccine Adverse Event Reporting System (VAERS)
Clinical trials Surveillance databases
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM295217.pdf[Accessed August 15, 2014]
Emerging Drug Safety Concern: Assessment
Factors considered before sending a communication Relative seriousness related to benefits Magnitude of risk Strength of evidence of causal relationship Extent of patient exposure Impact on specific populations (e.g., children/elderly) Potential for preventing or mitigating risk Alternative therapies
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM295217.pdf[Accessed August 15, 2014]
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 14
Emerging Drug SafetyConcern: Communication
Drug labeling Prescribing information Patient package inserts Medication Guides (MedGuides) Drug Facts label (over-the-counter products)
Drug Safety Communication (DSC)
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM295217.pdf[Accessed August 15, 2014]
Drug Safety Communication (DSC)
Implemented in 2010 Specific tool used by FDA to communicate
important safety information of marketed drugs Targeted to both health care professionals and
the public Standardized and posted on FDA Web site Not a “Crisis Document” Public Health Alert
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM295217.pdf[Accessed August 15, 2014]
Drug Safety Communication (DSC)
Summary of the safety issue and nature ofthe risk
Established benefit(s) of drug Recommended actions for both health care
professionals and the public Summary of data reviewed or in process of
being reviewed by FDA
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM295217.pdf[Accessed August 15, 2014]
Drug Safety Communication (DSC)
Updates to Drug Safety Communications New information Timeliness Public reminder Decision
http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM295217.pdf[Accessed August 15, 2014]
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 15
Ondansetron DSCs
Basis of original alert (9-5-11) Two published studies associated ondansetron with QT
prolongation Manufacturer required to conduct a thorough QT study to
determine degree of QT prolongation Current status
6-29-12: Preliminary results of manufacturer study prompted the removal of the 32 mg IV dose from product labeling
12-4-12: Final study results prompted removal of 32 mg IV product (pre-mixed injection) from the market
http://fda.gov/Drugs/DrugSafety/ucm271913.htmhttp://fda.gov/Drugs/DrugSafety/ucm310190.htmhttp://fda.gov/Drugs/DrugSafety/ucm330049.htm
DSC Review
Do not panic (not a “Crisis Document”) Tell others not to panic Designate a “quarterback” to manage Review detail of all pertinent DSCs Evaluate cited literature in the specific DSCs Search for additional published literature Obtain input from key stakeholders
DSC Review
Understand the specific impact at institutionlevel and/or patient level
Make recommendation to governing body athospital (e.g., P&T Committee), if needed
Create consistent communication about finaldecision
QT Prolongation Significance QTc interval: 420 msec
QTc interval > 500 msec is associated with significantrisk for torsade de pointes or TdP (2- to 3-fold higher) Individual changes < 30 msec
Clinically insignificant Individual changes between 30 and 60 msec
More likely to represent a drug effect and concern aboutpotential risk of arrhythmias
Individual changes > 60 msec Clinically significant
.Drew B, et al. Circulation 2010;121:1047-60Malik M, et al. Drug Saf 2001:24(5):323-51
De Ponti F, et al. Drug Saf 2002;25(4):263-86
Risks Factors for QT Prolongation
Congenital long QT syndrome (LQTS) Clinically significant bradycardia or heart
disease Electrolyte imbalances Sodium, potassium, magnesium, calcium
Impaired hepatic/renal function Pharmacokinetic or pharmacodynamic drug
interactions (acquired LQTS)
Drew B, et al. Circulation 2010;121:1047-60De Ponti F, et al. Drug Saf 2002;25(4):263-86
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 16
Literature Regarding QT Prolongation Risk of developing TdP is proportional to the degree of QT
prolongation
Patient variability: Intra-individual and inter-individual variability; individual metabolic capacity for a given drug
QT interval measurement: Definitions, variability in heart rate
Pharmacokinetics: Timing of ECG measurements compared to peak/steady state drug concentrations
Data analysis and interpretation: Different formulas to correct for the QT interval for heart rate and definition of clinicallysignificant change in QTc
Ondansetron: Primary Literature
Design Non-randomized, observational12-lead ECG evaluations (blinded)Baseline, 1-, 2-, 3-, 5-, 10-, and 15-minutes
Participants Droperidol (n=43); Ondansetron (n=42)Operative procedure (vascular, neurosurgery, ENT, orthopedics, gynecology)No QT-interval prolonging medications with risk of TdPQTc interval prolonged at baseline: 18/85 (21%) patients(> 450 msec in males; > 470 msec in females)
Objective To describe QTc interval changes associated with administration of low-dose droperidol (0.75 mg IV) or ondansetron (4 mg IV) to treat post-operative nausea and vomiting (PONV)
Charbit, et al. Anesthesiology 2005;102(6):1094-1100
Ondansetron: Primary Literature
Results •Mean maximal QTc interval prolongation:Droperidol: 17+9 msec at 2 minute (P<0.0001) Ondansetron 20+13 msec at 3 minute (P<0.0001)•Prolonged QTc interval:Droperidol (10/43); ondansetron (8/42)•Correlated with body temperature and duration ofanesthesia
Conclusions •Associated significant QTc interval changes•Low risk of proarrhythmias (TdP: n=0)•QTc interval > 500 msec (n=10)
PracticeConsiderations
Observational study designStatistical versus clinical significancePONV versus CINV patient population and dose
Ondansetron: Primary Literature
Design Prospective, placebo-controlled, double-blindFour cross-over periods (single dose)Droperidol alone (1 mg IV); Ondansetron alone (4 mg IV); Droperidol + ondansetron; Placebo12-lead ECG (at 1 minute intervals for the first 15 minutes, then at other set times through 10 hours)
Participants Healthy volunteers (n=16; 50% male)Normal QTc interval (< 440 males:< 450 females) and resting HR (55-70 bpm)
Objective To assess the effects of droperidol IV and ondansetron IV alone or in combination on the QTc interval duration
Charbit, et al. Anesthesiology 2008;109(2):206-12
Ondansetron: Primary Literature
Results •Compared with placebo, droperidol and ondansetron significantly prolonged the QTc interval Mean maximal QTc prolongation: droperidol (25+8 msec); ondansetron (17+10 msec); and droperidol + ondansetron (28+10 msec)
•Maximal QTc prolongation was significantly greater in droperidol and droperidol + ondansetron groups compared with ondansetron alone (P=0.014 and P=0.001, respectively)
•No difference between droperidol group and droperidol + ondansetron group (P=0.33)
•No ventricular arrhythmia noted during study
Ondansetron: Primary Literature
Conclusions Effect of droperidol on QTc prolongation was significantly greater than ondansetron
Droperidol alone and droperidol + ondansetron had similar effect (i.e., no additive effect) on QTc interval
No patient had QTc interval greater than 500 msec or a change from baseline > 60 msec
PracticeConsiderations
Prospective study (Harmonization E14 Guidelines for evaluation of proarrhythmic risk for non-cardiac drugs)Drug interaction studyStatistical versus clinical significancePONV versus CINV patient population and dose
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
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Ondansetron: Manufacturer Data Study conducted by manufacturer (GlaxoSmithKline) Evaluated effect of ondansetron injection on cardiac
conduction in healthy volunteers (n=58) Baseline 12-lead ECG Holter 12-lead continuous recording device (24 hours) Randomized, blinded, four way cross-over design
Ondansetron 8 mg and 32 mg (15-minute infusion) Moxifloxacin 400 mg (tablet) – positive control Placebo
Communication with GlaxoSmithKline. Study 115458.2012 http://gsk- clinicalstudyregister.com [Accessed 3/26/13]
Ondansetron: Manufacturer Data Ondansetron 32 mg:placebo (change from baseline)
19.6 msec (90% CI; 17.64, 21.49) Ondansetron 8 mg:placebo (change from baseline)
5.84 msec (90% CI; 3.92, 7.76) Predicted mean QTc interval for ondansetron:
24 mg: 14 msec (upper limit 95% CI: 16.3 msec) 16 mg: 9.1 msec (upper limit 95% CI: 11.2 msec)
No subjects had QTc interval greater than 480 msec(or experienced change from baseline > 60 msec)
Thirteen (23%) of subjects had changes on QTc intervalbetween 30 msec and 60 msec
Ondansetron: RevisedProduct Labeling (11/2012)
Warnings and Precautions: Prolongs QTc interval in dose dependent manner ECG monitoring recommended in select patients
Dose Chemotherapy-induced nausea and vomiting (CINV):
Adults: Three 0.15 mg/kg doses up to a max of 16 mg per dose First dose 30 minutes before chemotherapy and subsequent
doses 4- and 8-hours after first dose (max of 16 mg per dose)
Ondansetron: Other Considerations
PONV and CINV: Different population, dose, risk Dose of ondansetron (higher doses) Route of administration (IV versus PO) Rate of administration (IV push versus infusion) Multi-medication (multi-modal) approach to N/V 5HT3 antagonist class effect Cost of medication Cost of baseline and/or frequent ECG monitoring
Ondansetron: Application
VL is a 47-year-old female with cancer who will beundergoing first course of moderately emetogenicchemotherapy. PMH: GERD, hypercholesterolemia, seasonal allergies Medications: famotidine, simvastatin, loratidine Other: Anxious over new cancer diagnosis; non-smoker
What would you recommend for the prevention of CINVand why?A= Ondansetron 16 mg IV + steroidB= Granisetron 1 mg IV + baseline/continuous ECG monitorC= Palonosetron 0.25 mg IV + steroidD= Avoid 5HT3 antagonists and use other antiemetics
Same DSC Review Process
Azithromycin and Risk of Potentially FatalHeart Rhythms
Zolpidem and Lower Recommended Doses Sildenafil (Revatio®) and Use in Pediatric
Patients with Pulmonary ArterialHypertension (PAH)
Codeine and use in pediatrics patients aftertonsillectomy and/or adenoidectomy
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 18
Summary
Drug safety communication is the single tool used by theFDA for communicating emerging drug safety information
Drug safety communications are not crisis documents
Process should be developed to evaluate the drug safety communication and other available data
Consistent response should be developed to respond toany inquiries from health care professionals or patients
Curricular Track I: REMS and Regulation Updates to Promote Medication Safety
© American College of Clinical Pharmacy 19