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The FDA's perpetual process machine

paulromer.net

21–30 of 61 posts

Re: The FDA's perpetual process machine

#21
post #3

There are number of conflated regulatory problems in this piece: 1) FDA needs to move its data ingestion into the 21st century (note: large industry can be as resistant to changing current process as bureaucracy). In no rational universe should we have to mail data in 2020 2) In vitro diagnostic regulation is a mess and needs to be revamped top to bottom. Either exempt all Lab Developed Tests, rewrite the law to make…

I don't think "conflated" is the right word. Romer doesn't imply that these problems have the same cause, or are even correlated (although I suspect they are).

He just lays them out as stark examples of FDA getting in the way of the public interest in this pandemic.

Re: The FDA's perpetual process machine

#22
post #3

There are number of conflated regulatory problems in this piece: 1) FDA needs to move its data ingestion into the 21st century (note: large industry can be as resistant to changing current process as bureaucracy). In no rational universe should we have to mail data in 2020 2) In vitro diagnostic regulation is a mess and needs to be revamped top to bottom. Either exempt all Lab Developed Tests, rewrite the law to make…

In no rational universe should we have to mail data in 2020

I remember a study where the lab reports were printed on there own printer. The FedEx employee showed up with a labeled box, put the huge stack in it, and left. I think that daily stack of labs cost somewhere in the five figure range each day.

Re: The FDA's perpetual process machine

#23
post #3

There are number of conflated regulatory problems in this piece: 1) FDA needs to move its data ingestion into the 21st century (note: large industry can be as resistant to changing current process as bureaucracy). In no rational universe should we have to mail data in 2020 2) In vitro diagnostic regulation is a mess and needs to be revamped top to bottom. Either exempt all Lab Developed Tests, rewrite the law to make…

I don't think "conflated" is the right word. Romer doesn't imply that these problems have the same cause, or are even correlated (although I suspect they are). He just lays them out as stark examples of FDA getting in the way of the public interest in this pandemic.

That's a fair point. I was responding to this idea of all of these being part of a single "process machine".

Re: The FDA's perpetual process machine

#24
post #17

The sorry state of the FDA and drug development and deployment as a whole is in my opinion due to a preponderance of two types of people: Type A will happily bankrupt their customers while giving them heart failure in order to reduce allergy symptoms by 10%, and Type B would rather let ten thousand people die in unmedicated screaming agony than have a drug show up in a news story saying it killed three of them, regar…

> Type B would rather let ten thousand people die in unmedicated screaming agony than have a drug show up in a news story saying it killed three of them, regardless of how many hundreds of lives it saved. Who gets to set those numbers and by what process? And, probably more importantly, who gets the indemnification liability for the ones who die? If you don't have good, solid answers for those questions, you don't ge…

Informed consent. If you have the probability numbers let people decide if they want to risk it. Make them as well as their next of kin sign ironclad contracts releasing the hospital and manufacturer from any and all liability.

Re: The FDA's perpetual process machine

#25
post #17

Earlier quoted context omitted.

> Type B would rather let ten thousand people die in unmedicated screaming agony than have a drug show up in a news story saying it killed three of them, regardless of how many hundreds of lives it saved. Who gets to set those numbers and by what process? And, probably more importantly, who gets the indemnification liability for the ones who die? If you don't have good, solid answers for those questions, you don't ge…

Informed consent. If you have the probability numbers let people decide if they want to risk it. Make them as well as their next of kin sign ironclad contracts releasing the hospital and manufacturer from any and all liability.

1) Good luck with getting informed consent from every patient on all the myriad drugs and treatments that the FDA approves in a year. The bureaucracy that ensures that will make the FDA look like a fleet-footed fox.

2) Informed consent only holds until someone's child dies. Then you're in court no matter how good your contract is.

3) Who defines the informed consent boundaries? It's turtles all the way down. All you did was push the complexity around--you didn't get rid of it.

The FDA is where ethics and economics intersect. The problems don't have easy, magical answers.

Re: The FDA's perpetual process machine

#26

The sorry state of the FDA and drug development and deployment as a whole is in my opinion due to a preponderance of two types of people: Type A will happily bankrupt their customers while giving them heart failure in order to reduce allergy symptoms by 10%, and Type B would rather let ten thousand people die in unmedicated screaming agony than have a drug show up in a news story saying it killed three of them, regar…

Type C reduces people to the caricatures demonstrated in Type A and Type B?

Not that it's impossible that either type exists, but we know that plenty of drugs make it through the system and are regularly prescribed that nevertheless have non-trivial risks, so the idea that the FDA is only evaluating the downsides seems pretty limited in its explaining power.

And as posters frequenting HN should know, systems are hard. Good systems over a domain of any complexity aren't trivial even when incentives are aligned. Economic and political incentives in medical domains aren't always well-aligned.

I'm sure the FDA and industrial incentives could both be improved, but I think it's going to take sharper and more detailed insights than imagining a personality binary.

Re: The FDA's perpetual process machine

#27
post #20

Unfortunately, we need to be skeptical about almost every decision and communication from the CDC, FDA, and a number of other federal agencies. The current administration has done a remarkably effective job of bending these agencies to their will and forcing out anyone who doesn't fall in line.

I think you’re giving the current administration too much credit here. There’s no reason to claim a grand conspiracy to knee-cap the initial testing response. The CDC and the FDA managed to fail out of pure incompetence and ineptitude all by themselves.

I'm no fan of the CDC and FDA, but you'd have to be blind to ignore the failure of leadership at the top of the totem poll.

https://www.politico.com/news/2020/03/25/trump-coronavirus-n...

https://www.cnn.com/2020/04/18/politics/kfile-trump-official...

The links go on and on.

For most conservatives, I guess it's easier to blame the "deep state" or those "evil government bureaucrats" than admitting the leader they elected is incompetent.

Re: The FDA's perpetual process machine

#28
post #3

There are number of conflated regulatory problems in this piece: 1) FDA needs to move its data ingestion into the 21st century (note: large industry can be as resistant to changing current process as bureaucracy). In no rational universe should we have to mail data in 2020 2) In vitro diagnostic regulation is a mess and needs to be revamped top to bottom. Either exempt all Lab Developed Tests, rewrite the law to make…

Thing about these problems (and others) is that bottle necks and red tape generally are problems in just about any country.

Political leadership in this situation involves noting the regulatory and bureaucratic hurdles to action and using your authority to supersede them when a pressing situation requires it. Someone has to sit down and say "what needs to happen, what's standing in its way? What orders have to be issue to stop this today?" Someone has to say "this priority is more important than anything else at this point", etc. Just as an example, it shouldn't be hard to notice tests are only being mailed and to stop that this case, etc.

A crisis always requires political leadership because of both the this bureaucracy and the general confusion created by crisis. Many if not all bureaucracy will act ineffectively by default unless someone forces their hand.

Which is to say that the current situation is an abject failure of leadership specifically.

Re: The FDA's perpetual process machine

#29

The sorry state of the FDA and drug development and deployment as a whole is in my opinion due to a preponderance of two types of people: Type A will happily bankrupt their customers while giving them heart failure in order to reduce allergy symptoms by 10%, and Type B would rather let ten thousand people die in unmedicated screaming agony than have a drug show up in a news story saying it killed three of them, regar…

Type C reduces people to the caricatures demonstrated in Type A and Type B? Not that it's impossible that either type exists, but we know that plenty of drugs make it through the system and are regularly prescribed that nevertheless have non-trivial risks, so the idea that the FDA is only evaluating the downsides seems pretty limited in its explaining power. And as posters frequenting HN should know, systems are hard…

I said there is a preponderance of those two types, not that everyone involved falls into one of them.

Re: The FDA's perpetual process machine

#30
post #20

Earlier quoted context omitted.

I think you’re giving the current administration too much credit here. There’s no reason to claim a grand conspiracy to knee-cap the initial testing response. The CDC and the FDA managed to fail out of pure incompetence and ineptitude all by themselves.

I'm no fan of the CDC and FDA, but you'd have to be blind to ignore the failure of leadership at the top of the totem poll. https://www.politico.com/news/2020/03/25/trump-coronavirus-n... https://www.cnn.com/2020/04/18/politics/kfile-trump-official... The links go on and on. For most conservatives, I guess it's easier to blame the "deep state" or those "evil government bureaucrats" than admitting the leader they elec…

There’s no reason to play partisan politics here. If we want we can say Democrats were too busy trying to impeach Trump and calling Wuhan a “manufactured crisis” back when Trump ordered the borders closed Jan 30.

The simple fact is non-partisan non-evil, simply incompetent bureaucrats at the State and Federal levels all failed to adequately prepare (PPE stockpiles) and had actively harmful policies set in place years ago which impeded the response or even actively worsened it, and too many remained in denial once community spread became apparent.

Everything from a stranglehold on testing (FDA) to bungling the test kits (CDC) to flimsy border checks, poor initial contact tracing, to forcing COVID positive patients to nursing homes (Cuomo), to politicizing the quarantine to the point where they lose credibility (open letter from ‘healthcare professionals’ supporting protests).

There’s nothing deep state or evil about it. It’s just the typical failure I expect from my government, blue or red, every time. Sad but true.

To be fair, this was basically America’s first brush with a serious contagion in the modern era. Other countries that did better have had more practice.

Frankly, I don’t think a full fledged multi-trillion dollar response (50-state hard quarantine) was politically possible on January 20th. Trump was acquitted on Feb 5, and Senators skipping impeachment hearings to get informed on COVID were literally being threatened that they would be dragged into the Senate to sit and listen to Ukraine testimony.

From what I can tell, no one in either party was calling for measures stringent enough and early enough to have stopped the situation we have now. Senator Cotton was one who pushed particular hard to ground planes and is credited for that.

Of course at the time the perplexing WHO guidance was against travel bans. Yes, the US certainly isn’t alone in the world in its missteps.

And even if the lockdown had been harder and more consistent, there was still the flubbed testing, the flubbed medical response (ventilators), and the flubbed patient management.

CDC initial tactical teams wanted to treat COVID patients like Ebola carriers, spending what looked like $100k per person in full isolation wards — I guess they were thinking this was going to be 10 or 20 people coming into the country. Then we end up sending sick people into common areas of nursing homes. Then they told people not to wear masks for weeks... Just totally nonsensical top to bottom.

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