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Wednesday, December 12, 2012

A proposed 6-step platform for the cell therapy industry to consider in combating non-compliant cell therapy treatments


Further to my recent post, "Six steps to fighting non-compliant cell therapy treatments. The stuff of grey shades, spades, ivory towers and (ahem) balls.", I have crafted a 6-point platform that I propose to submit (with potential edits based on preliminary feedback) to several of the leading  industry and professional organizations for their consideration including ARM, ISCT, ISSCR, FACTAABB  ICMS, and perhaps, in due course, to patient groups, physician groups, disease-specific professional organizations (e.g, cardiology, oncology, neurology, cosmetic, etc).

I welcome comments and feedback. 

1. In addition to helping patients distinguish between compliant and non-compliant treatments (and providers) we must do more to help patients distinguish between non-compliant cell therapy treatments (and providers) which are more or less risky. 

2. Whatever we do in response to this issue should be done with an eye to being practical and helpful to patients in the real-life context of their decision about whether or not to buy a non-complaint cell therapy.

3. Our response to this issue should be based on a risk-based approach recognizing that not all non-compliance is created equal.  We should create a framework for risk-based analysis (both for us and our audiences) and focus initiatives around those which present the highest risk.

4. We recognize the problem of non-compliant cell therapies is not just a problem that exists in jurisdictions with little, no, or poor regulation but that is a growing problem even in the most highly regulated jurisdictions meaning the solution cannot be regulated it depends on education and enforcement.

5. We recognize regulatory agencies cannot enforce non-compliance on their own.  We as an industry need to complement their efforts through our own standards and enforcement.

6. Stakeholder groups should support the formation of a multi-organizational  initiative to, based on a risk-based assessment, spotlight the categories or signs of highest-risk offenders for use by patients and/or their physicians in identifying  whether or not treatments (and providers) they may be considering fall into the that category associated with the highest level of risk.

What do you think?


Frog said...

Lee, I'm not sure I get the point. I think we'd be better off starting with basics, like patient advocacy, evaluation of scientific merit etc. that would give patients a decision making rubric that enables them to decide if they want to be treated by some provider or not.

Barbara Hanson said...

I agree with Frog. Patients do not need a police force as you have described Lee. I am not sure why a patient and his or her own doctor would not be the ones to make such decisions anyway. The research community can help by supporting patients with useful information and encouraging clinics to adopt guidelines and track patients. Trying to discourage patients from seeking treatment or working to close clinics who offer treatment is not working nor is it warranted.

Lee Buckler said...

So I'm not suggesting a police force at all. I'm suggesting a tool that can help patient and their doctors distinguish between the clinics which are more reputable and credible than the guys who end up on 60 minutes. My belief is that the average patient considering such treatments have very little to go on other than the advertising hyperbole of these clinics. The tool could be created by patient groups such as yours, Barbara - no police force or paternalism necessary.

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