The infectious disease community has mixed feelings
about the 21st Century Cures Act, a new health care
bill that is supposed to revolutionize health care
in this country. The bill (H.R. 6) was approved by
the House but is just beginning to make its way
through the Senate.

If the Senate approves the measure and it is signed into
law, proponents claim it will create a 21st Century
health care infrastructure that emphasizes innovation,
funding new cures for rare and fatal diseases. Opponents
claim it will lower the standards for new drug and
device approvals, potentially enabling ineffective or
harmful products to come to market.
Nearly everyone supports the measures that will
increase general funding for the stagnating National
Institutes of Health (NIH) budget, which has
suffered from sequester and other cuts, and a
separate allocation of $1.86 billion a year for five
years to create an NIH Innovation Fund. The monies
would be dedicated to innovative research for rare
and fatal diseases with a medical need for better
and more innovative treatments. As always, however,
the
devil
is in the details.
Many in the infectious disease community support this
much-needed funding for research, as well as the efforts
that will be made to find new antimicrobials and promote
antibiotic stewardship to fight the development of
resistance. However, they are less enamored by the
provisions in the act that cover how vaccine
recommendations are made in this country.
The ACIP
Section 2141 of H.R. 6 states that the Advisory
Committee on Immunization Practices (ACIP), which
sets the U.S. vaccination schedule, must review any
vaccine or new indication for a vaccination at its
next regularly scheduled meeting. The ACIP meets
three times a year.
“For the first time, the ACIP has been provided a
countdown, basically, that has a maximum of 120 days
from licensure to recommendation,” said Jon Temte, MD,
MS, PhD, former chair of the ACIP.
“We are charged with making the best recommendation
for application of vaccines and other associated
biologics for use in the civilian population based
on a number of different issues, specifically, the
effectiveness of a vaccine, the safety of a vaccine,
some consideration of costs, and also implementation
issues, equity and so on,” said Dr. Temte, a
professor in the Department of Family Medicine and
Community Health at the University of
Wisconsin-Madison School of Medicine and Public
Health. “That is a lot of information to consider.”
Typically, the ACIP forms a working group to start
considering a vaccine about the same time when the
company applies for licensure, he explained.
Although individuals are looking at many of the
above issues before a vaccine is approved, the ACIP
is statutorily required to make a recommendation
only after that vaccine has been licensed.
“Although we will hear about the vaccine
prelicensure, we don’t really start considering all
the issues until licensure has occurred [and they
have all the data about the vaccine and its
potential effect on millions of individuals],” he
said.
Amanda Jezek, the vice president of Public Policy
and Government Relations at the Infectious Diseases
Society of America (IDSA), in Arlington, Va., said
there is concern that this push to recommend a
vaccine before the ACIP has reviewed the evidence
would completely “jeopardize the integrity of ACIP’s
recommendations.”

Most of the vaccinations given in this country are
received by those younger than 2 years of age, so
assuring the safety and efficacy of vaccines is
paramount. Every year, more than 40 million vaccines
are given to children younger than 1 year of age,
usually between 2 and 6 months of age, Dr. Temte
said. At this age, infants are at greatest risk for
certain serious medical adverse events, including
high fevers, seizures and sudden infant death
syndrome, according to the U.S. Vaccine Adverse
Event Reporting System. Therefore, it is important
for the ACIP to consider carefully the risks versus
the benefits before making a recommendation rather
than be on a forced schedule that suits the
manufacturer as opposed to the patient.
In addition, the ACIP is tasked with choosing the
components of the annual influenza vaccination,
which changes every year as the virus mutates
throughout the season. Experts around the world
track these mutations to predict which flu strains
will be predominant in the following season. The
ACIP makes recommendations about the strains to
include in next year’s flu vaccination. Just under 1
million U.S. infants, children and adults received
the influenza vaccine during the 2012-2013 flu
season.
Every situation surrounding a recommendation is
different, Dr. Temte said. For instance, the
pneumococcal conjugate vaccine (Prevnar 13, Pfizer)
is recommended to protect against pneumococcal
disease. The vaccine has been indicated for children
for some time, but received a new indication for
adults older than 50 years of age in December 2011.
The vaccine received accelerated approval by the FDA
for the adult indication without clinical data to
show efficacy in adults. Those data did not come
until the company conducted a postlicensure trial
involving 84,000 individuals. It was almost two
years after the new indication was granted before
the ACIP had the safety and efficacy data to make a
good recommendation about the vaccine.
“I’d like to get some explanation about how we can
compress the acquiring of information into a very
limited time frame,” Dr. Temte said.
Another example was Sanofi’s high-dose influenza
vaccine for seniors. The company had every intention
of doing a postlicensure study in a large group of
seniors, but that flu season was pretty mild and
there were little data—for another year—for which
the ACIP could base its recommendation.
Other recommendations can be quite rapid, Dr. Temte
noted. In the case of the meningococcal B vaccines,
they received a category A recommendation for a
limited high-risk population right after they were
approved.
“Sometimes, the ACIP can be quite fast,” he said. “At
other times, we require more information to make a good
recommendation, and that more information could be
issues dealing with safety; it could be clinical
efficacy. The process really does involve having good
information.”
In addition, the bill takes exception to the grading
recommendations that the ACIP uses and wants the
Centers for Disease Control and Prevention to
conduct a review of the process to ensure it is
consistent. The ACIP uses the Grading of
Recommendations, Assessment, Development and
Evaluation (GRADE) approach to review and analyze
scientific data, Dr. Temte said. “GRADE was brought
in to have a well-accepted, uniform and very
transparent methodology for making recommendations,”
he said.
“There are individuals who do not like the GRADE,
but I think the problem is that people do not
understand it. The legislation talks about grading
economic, as well as scientific, evidence. We have
not applied GRADE to economic data,” he said. The
GRADE system classifies the scientific evidence that
supports a recommendation, he explained. For
example, low-quality evidence would be expert
opinion; high-quality evidence would be a randomized
clinical trial. However, the ACIP considers all the
evidence, he said.
When the ACIP made the recommendation for the
meningococcal B vaccine, it received a category B
recommendation, which meant that the ACIP
recommended the vaccine “for anyone for whom the
clinician and the patient, through discussion,
determined it was appropriate.”
He explained: “That’s a little cumbersome, but it is
a recommendation for individual clinical
decision-making, not for universal use.”
When making the recommendation, the ACIP not only
considered all the science, but also heard from many
individuals and associations that provided anecdotal
evidence, personal history, values and preferences
before making a recommendation. “That is part and
parcel of what we do,” Dr. Temte said. “I think it
is very important that our stakeholders and the
American public know that we take safety as a
paramount issue in terms of vaccines. I think the
ACIP does a very good job of coming up with good
recommendations on a timely basis,” he said.
Antibiotics
The antibiotic proposals will help expedite the
development and availability of much needed
antimicrobials, IDSA’s Ms. Jezek said. “We have a lot
more positive things to say about these provisions [than
the vaccine proposal],” she said.
The IDSA and others said that the bill will
complement the president’s National Action Plan for
Combating Antibiotic-Resistant Bacteria that was
released earlier this year, which calls for
increased investing in research and development, as
well as antibiotic stewardship and surveillance to
reduce resistance.
“One of the biggest challenges that we are
seeing—the greatest unmet need—are for serious
life-threatening infections that are still occurring
in a relatively small number of patients,” Ms. Jezek
said.
Because the number of patients is small, it is
difficult to hold large, clinical trials. Therefore,
using nonclinical susceptibility and pharmacokinetic
data, which the 21st Century Cares Act supports, is
important. However, under Cures, new antibiotics
would still need data from human clinical trials in
order to be approved by the FDA. The bill just
allows the trials to have fewer patients, which is
important because that is all that is feasible.
Elizabeth Jungman, the director of public health
programs at The Pew Charitable Trusts, reiterated
the need for new and better antimicrobials. “With
infections, if you stand still you lose ground,” she
said. “So, there is this constant arms race between
the ability to develop new drugs and the bugs’
ability to develop resistance to them.
“We need a robust pipeline.”
She said that on the one hand, there is a 30-year
gap in the development of new classes of
antibiotics, and many companies have pulled away
from this area of new drug development, and on the
other, infectious disease physicians with a number
of patients who have no options. “We are
particularly concerned about the need for
antibiotics to treat resistant infections,” Ms.
Jungman said.
There is concern that the accelerated antibiotic
development pathway will lead to an increase in
medication safety errors, according to Thomas J.
Moore, a senior scientist of Drug Safety and Policy
at the Institute for Safe Medication Practices, in
Horsham, Pa., and lecturer in the Department of
Epidemiology and Biostatistics at The George
Washington University, Milken Institute School of
Public Health in Washington, D.C.
However, Ms. Jezek said that the new antimicrobials
will be indicated and labeled for a small, specific
group. In addition, the use of the drugs will be
closely monitored by the Department of Health and
Human Services.
“The FDA provided a lot of technical assistance for the
development of this particular piece of the bill,” Ms.
Jezek said.
“The issue of antibiotic resistance includes the
need to develop new drugs as well as to
appropriately steward these resources,” said Ms.
Jungman.