MARKET RESPONSE TO FOOD AND DRUG ADMINISTRATION’S SAFETY WARNINGS: A CASE STUDY USING AN INTERRUPTED TIME SERIES ANALYSIS OF THE MEDICARE DATABASE FOR 2006-2008 Hafiz Oko-osi MS1, Benjamin F. Banahan III PhD1,2, Donna West-Strum PhD1,2, John P. Bentley PhD1,2 1Department of Pharmacy Administration, School of Pharmacy, University of Mississippi; 2Center for Pharmaceutical Marketing and Management, University of Mississippi BACKGROUND & OBJECTIVE Monthly Percentage Utilization of Thiazolidinediones by Patient Group Poor adherence to Food and Drug Administration (FDA) safety alerts and warnings has the potential to expose patients to harmful effects of drugs. There is conflicting evidence on the adequacy of safety warnings to limit drug utilization in patients contraindicated to using thiazolidinediones (TZDs) (Wilkinson et al. 2004; Shah et al. 2010). Appropriate risk management should result in decreased use of a product in contraindicated patients while retaining use in appropriate patients. The objective of this study was to evaluate the impact of FDA safety warning about the cardiovascular safety of rosiglitazone on the utilization rates of thiazolidinedione oral anti-diabetes medications among indicated and non-indicated patients. 35% Percentage of patients 30% METHODOLOGY A retrospective analysis of the five percent national sample of Medicare Part D beneficiaries for years 2006-2008 was conducted using an interrupted time series consisting of a 13-month preintervention period and a 19-month post-intervention period. Beneficiaries with at least one prescription claim for a TZD anti-diabetic during the study period were included in the sample. Beneficiaries were classified each month as non-user or rosiglitazone/pioglitazone user based on TZD possession. Beneficiaries were further classified each month during the study period into appropriate-use, at risk, and contraindicated groups based on the presence of certain comorbid conditions using ICD-9-CM diagnoses codes. Rosiglitazone and pioglitazone utilization rates were calculated each month for the beneficiaries in each appropriateness of use patient group. Segmented regression analysis was used to examine the effects of the May 2007 FDA safety warnings about the ongoing review of rosiglitazone’s potential to increase cardiovascular risks on TZD utilization rates for the different appropriateness of use patient groups. 25% 20% 15% 10% May 2007 Safety Warning 5% 0% 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Variable a. Full segmented regression model Intercept Time Intervention Time after intervention b. Most parsimonious segmented regression model Intercept Time Intervention Time after intervention Estimate Standard tError statistic P-value Estimate Standard tError statistic Rosiglitazone P-value 20.562 0.117 -2.445 -0.874 2.540 0.280 1.100 0.408 8.09 0.42 -2.22 -2.14 < 0.0001 0.6792* 0.0356 0.0421 16.455 0.744 1.247 -0.561 1.433 0.161 1.148 0.220 11.48 4.61 1.09 -2.56 < 0.0001 < 0.0001 0.2869* < 0.0001 21.506 1.173 18.33 < 0.0001 16.286 0.805 1.539 0.163 10.59 4.93 < 0.0001 <0.0001 -2.421 -0.719 1.078 0.144 -2.25 -5.01 0.0333 < 0.0001 -0.583 0.236 -2.47 Variable a. Full segmented regression model Intercept Time Intervention Time after intervention b. Most parsimonious segmented regression model Intercept Time Time after intervention Estimate Standard tError statistic 23 24 25 26 27 28 29 30 31 32 % of appropriate-use patients taking Pioglitazone % of at risk patients taking Rosiglitazone % of at risk patients taking Pioglitazone % of contraindicated patients taking Rosiglitazone % of contraindicated patients taking Pioglitazone CONCLUSIONS Full and Most parsimonious segmented regression models predicting the monthly utilization rate of rosiglitazone and pioglitazone in at risk patients. Pioglitazone 22 % of appropriate-use patients taking Rosiglitazone A graph showing the trend in TZD utilization rates by patient groups is presented. The full segmented regression model provides estimates of utilization level and trend before and after the FDA safety warning for each patient group. The full and most parsimonious segmented regression models reported below were used to estimate the relative difference in utilization rates for each patient group. There was an increasing trend in the total utilization rates of thiazolidinediones before the safety warning. Significant decline in drug utilization rates were observed at the end of the study period for all patient groups on rosiglitazone (relative difference -74.78%, -79.93%, and -90.21% in appropriate-use, at risk and contraindicated patient groups, respectively). The intervention did not have significant immediate effects on the post-intervention utilization rates of pioglitazone. However, after the intervention, a general decline in utilization of thiazolidinediones, including pioglitazone, was observed. Rosiglitazone 21 Month RESULTS Full and Most parsimonious segmented regression models predicting the monthly utilization rate of rosiglitazone and pioglitazone in appropriate-use patients. 20 Full and Most parsimonious segmented regression models predicting the monthly utilization rate of rosiglitazone and pioglitazone in contraindicated patients. Pioglitazone P-value Estimate Standar d Error tstatistic Rosiglitazone P-value 19.946 0.204 0.398 -1.200 4.120 0.439 0.998 0.653 4.84 0.47 0.40 --1.86 < 0.0001 0.646* 0.693* 0.078 20.850 0.642 1.287 -0.845 1.490 0.165 1.103 0.288 13.99 3.90 1.17 -3.71 <0.001 <0.001 0.2534* <0.001 21.607 2.053 10.53 < 0.0001 -0.909 0.209 -4.53 < 0.0001 20.707 0.699 -0.853 1.499 0.159 0.230 13.81 4.40 -3.72 <0.001 <0.001 <0.001 0.0198 Variable a. Full segmented regression model Intercept Time Intervention Time after intervention b. Most parsimonious segmented regression model Intercept Time Intervention Estimate Standard tError statistic Pioglitazone P-value Estimate Standar d Error tstatistic P-value 19.428 -0.485 -4.618 0.073 1.017 0.119 0.953 0.115 19.11 -4.09 -4.84 0.47 < 0.0001 < 0.0001 < 0.0001 0.6419* 24.790 -0.450 -1.222 0.025 0.670 0.828 0.766 0.099 36.99 -5.43 -1.60 0.25 <0.001 <0.001 0.1222* 0.8030* 19.081 -.0437 -4.598 0.744 0.055 0.941 25.64 -7.94 -4.88 < 0.0001 < 0.0001 < 0.0001 24.856 -0.487 0.554 0.029 44.84 16.83 <0.001 <0.001 The initial warning about rosiglitazone’s cardiovascular safety was effective in decreasing rosiglitazone’s utilization in the targeted population and thus appeared to achieve the desired safety effects. However, the safety warning also had spillover effects by reducing utilization in non-targeted patient groups and of pioglitazone in the targeted population. This analysis demonstrates the importance of companies managing emerging risk issues in order to create market differentiation in use among different patient populations. This tactic, of appropriately differentiating patient populations, should be considered core to the ultimate strategic goals of marketing and risk management strategies when safety issues emerge later in product life cycles. . ACKNOWLEDGEMENTS The work reported was conducted as part of thesis project internally supported by the Center for Pharmaceutical Marketing and Management at The University of Mississippi. Data access was approved by the Centers for Medicare and Medicaid Services (CMS) under DUA 21594. The views expressed are those of the authors and do not necessarily reflect those of CMS or the University of Mississippi. * Insignificant variables dropped by stepwise elimination resulting in absence in the most parsimonious models International Society for Pharmacoeconomics and Outcomes Research 17th Annual International Meeting, Washington, DC, USA. June 2-6, 2012. PCV93