Professional Documents
Culture Documents
program specifies new timelines (effective Octo- competitive markets. The FDAs move to reduce
ber 1, 2014) for the review of applications for review times for applications is one such policy.
generic drugs in exchange for user fees; by 2017, It could also help for Congress to authorize fee
regulatory action will be required on 90% of new waivers for entrants into generic-drug markets in
applications for generic drugs within 10 months which there are shortages of raw materials or
after submission. The Office of Generic Drugs similar factors contributing to exits from the
also expedites applications for generic drugs that market or price increases, although the current
are critical to public health or have the potential user fee for applications for generic drugs
to mitigate drug shortages.3 ($58,730) is small as compared with those for
The FDA has a long track record of success- new drugs ($2,335,200) or high-risk medical
fully meeting the requirements of user-fee pro- devices ($250,895). However, exorbitant generic-
grams for the review of drugs, and we are well drug prices can have other causes (e.g., demand
on our way to meeting the GDUFA commitments. may fluctuate or improper business practices
Although no provision exists in the GDUFA for may reduce competition artificially).1 In response,
waiving user fees for the review of generic drugs the federal government could offer long-term
even for drugs of which there are shortages purchasing contracts for some generic drugs, as
having firm timelines in place will allow mar- it does for childhood vaccines, and policymakers
kets to adjust more quickly to pricing anomalies. should enhance the ability of state and federal
Kathleen Uhl, M.D. government payers to respond to high prices.2,3
John R. Peters, M.D. An array of interventions may be needed to en-
Keith Flanagan, J.D. sure that essential generic medications will con-
Food and Drug Administration tinue to be available to and affordable for the
Silver Spring, MD patients who need them.
kathleen.uhl@fda.hhs.gov
Aaron S. Kesselheim, M.D., J.D.
No potential conflict of interest relevant to this letter was re-
Brigham and Womens Hospital
ported.
Boston, MA
1. Alpern JD, Stauffer WM, Kesselheim AS. High-cost generic
drugs implications for patients and policymakers. N Engl J
Jonathan D. Alpern, M.D.
Med 2014;371:1859-62. William M. Stauffer, M.D., M.S.P.H.
2. Generic Drug User Fee Amendments of 2012 (GDUFA). Silver University of Minnesota
Spring, MD: Food and Drug Administration (http://www.fda.gov/ Minneapolis, MN
ForIndustry/UserFees/GenericDrugUserFees/default.htm). Since publication of their article, the authors report no fur-
3. Manual of policy and procedures: MAPP 5240.3 Rev. 1: pri- ther potential conflict of interest.
oritization of the Review of Original ANDAs, Amendments,
and Supplements, revised 8/1/2104. Silver Spring, MD: Food 1. Silverman E. Justice Department probes generic companies
and Drug Administration (http://www.fda.gov/downloads/ after price hike reports. Wall Street Journal Pharmalot. Novem-
aboutfda/centersoffices/officeofmedicalproductsandtobacco/cder/ ber 10, 2014 (http://blogs.wsj.com/pharmalot/2014/11/10/justice
manualofpoliciesprocedures/ucm407849.pdf). -department-probes-generic-competition-after-price-hike-reports).
2. Kesselheim AS. Why are some generic drugs skyrocketing in
DOI: 10.1056/NEJMc1415471
price? Testimony before the Senate Committee on Health, Edu-
cation, Labor & Pensions, November 20, 2014 (http://www.help
The Authors Reply: When prices of generic .senate.gov/imo/media/doc/Kesselheim.pdf).
3. GovTrack.us. Text of the Medicaid Generic Drug Price Fair-
drugs are high because fewer manufacturers ness Act (S. 2948) (https://www.govtrack.us/congress/bills/113/
make these products, appropriate policy solu- s2948/text).
tions can facilitate the reestablishment of strong, DOI: 10.1056/NEJMc1415471
A B C
Patient 1 Patient 2
G304R R202Q
T C G G T C A C C R G G T C C R G C T G C
Patient
T C G G T C A C C G G G T C C G G C T G C
E F
Control
Figure 1. MEFV Mutations and Clinical and Pathological Findings in Two Patients with the Myelodysplastic Syndrome and Lesions Consistent
with Sweets Syndrome.
Panel A shows sequence analysis of MEFV in Patient 1 and Patient 2. The upper row shows the MEFV sequences from the two patients,
and the lower row shows two sequences without the mutations. The arrows indicate the heterozygous mutations. In Patient 2, Sweets
syndrome was manifested as a lesion in the left preauricular area (Panel B) and in bilateral intramuscular liquefactive necrosis and ab-
scess formation in the lower legs with perforation to the skin (Panel C). A computed tomographic image shows multiple bilateral intra-
muscular areas of necrosis in the thighs (Panel D). Pathological examination of samples obtained from the left preauricular area and
right lower leg showed neutrophil-based inflammatory-cell infiltration from the deep dermis to the subcutaneous adipose tissue associat-
ed with Sweets syndrome (Panels E and F, hematoxylin and eosin).
MDS subtype that included refractory anemia observed when the MDS was controlled with the
with excess blasts, which was classified as very use of azacitidine or azacitidine plus lenalido-
high risk, according to the revised International mide (Fig. S1 in the Supplementary Appendix).
Prognostic Scoring System (IPSS). Patient 2 had Sequence analyses of MEFV revealed hetero-
an MDS subtype that included refractory cytope- zygous mutations that have been identified as
nia with trilineage dysplasia, which was classi- causes of familial Mediterranean fever (G304R in
fied as high risk, according to the revised IPSS Patient 1 and R202Q in Patient 2, both in exon 2)
(Table S1 in the Supplementary Appendix, avail- (Fig. 1A). Colchicine was then administered with
able with the full text of this letter at NEJM.org). no effect in either patient. In Patient 1, skin
Both patients had a history of periodic flares lesions that included facial erythema, genital
of inflammatory symptoms, including antibiotic- ulcers, and bilateral orbital cellulitis were ob-
resistant high fever with marked neutrophilia, served sporadically. It was suspected that the
systemic arthralgia, pericarditis, and enterocoli- lesions were caused by Sweets syndrome, but
tis, symptoms that resembled those of familial the diagnosis was not confirmed on skin bi-
Mediterranean fever. Such symptoms were not opsy. In Patient 2, a lesion developed on the face
(Fig. 1B), and liquefactive necrosis and abscess Therefore, sequence analysis of MEFV should be
formation subsequently developed in multiple considered in patients with MDS who have
muscles in the bilateral lower legs (Fig. 1C), as marked neutrophilia and high fever, as well as
shown on computed tomography (Fig. 1D), in those with Sweets syndrome.
with marked neutrophilia. Pathological exami- Tatsuro Jo, M.D., Ph.D.
nation showed neutrophil-based inflammatory- Kensuke Horio, M.D.
cell infiltration in two samples obtained from Japanese Red Cross Nagasaki Genbaku Hospital
the left preauricular area and the right lower leg Nagasaki, Japan
(Fig. 1E and 1F). firetj@nagasaki-med.jrc.or.jp
Generally, Sweets syndrome presents as one Kiyoshi Migita, M.D.
of three clinical types: classic, cancer-associated, Nagasaki Medical Center
Omura, Japan
or drug-induced.3,4 On the basis of the clinical
Disclosure forms provided by the authors are available with
courses of the two patients, the skin lesions the full text of this letter at NEJM.org.
could not be classified as drug-induced. In a
1. The International FMF Consortium. Ancient missense muta-
healthy Japanese population, E148Q (exon 2) is tions in a new member of the RoRet gene family are likely to
the most prevalent mutated allele in MEFV (pres- cause familial Mediterranean fever. Cell 1997;90:797-807.
ent in 23.0% of persons with this mutation), 2. Chae JJ, Komarow HD, Cheng J, et al. Targeted disruption of
pyrin, the FMF protein, causes heightened sensitivity to endo-
whereas the R202Q and G304R alleles are rela- toxin and a defect in macrophage apoptosis. Mol Cell 2003;11:
tively rare.5 By themselves, heterozygous muta- 591-604.
tions R202Q and G304R in exon 2 were not 3. Raza S, Kirkland RS, Patel AA, Shortridge JR, Freter C. In-
sight into Sweets syndrome and associated-malignancy: a review
sufficient to induce inflammatory symptoms in of the current literature. Int J Oncol 2013;42:1516-22.
either patient. Therefore, the second factor was 4. Sweet RD. An acute febrile neutrophilic dermatosis. Br J Der-
an unknown trigger induced by MDS, which matol 1964;76:349-56.
5. Sugiura T, Kawaguchi Y, Fujikawa S, et al. Familial Mediter-
activates the inflammasome. Our findings raise ranean fever in three Japanese patients, and a comparison of the
the possibility that MEFV mutations may be iden- frequency of MEFV gene mutations in Japanese and Mediterra-
tified with some frequency in both the classic nean populations. Mod Rheumatol 2008;18:57-9.