The strengths of formal research to evaluate investigational therapies are well known. In an ideal world, when a new question or problem is recognized, rigorous testing in well-designed clinical trials would be performed. However, the coronavirus disease (COVID-19) pandemic has given new meaning to the word “unprecedented”. Here, we argue that it is ethically appropriate to offer investigational agents outside of a clinical trial during an emergency, such as the current COVID-19 pandemic, and that the precedent to do so has been set in other outbreaks, such as the Ebola epidemics in Africa. The World Health Organization (WHO) has developed an ethical framework for the use of investigational agents, called MEURI, which stands for “monitored emergency use of unregistered and investigational interventions”.1 According to MEURI, the criteria for using investigational agents outside of clinical trials are the following: no proven effective therapy exists; it is not possible to initiate clinical trials immediately; data providing preliminary support for the investigational agents’ safety and efficacy exist (i.e., in vitro or animal studies and support from clinical experts); relevant country authorities and ethics committees have approved such use; adequate resources are in place to minimize risk; the patient’s informed consent has been obtained; and the use is monitored, with the results being documented and shared with the scientific community in a timely fashion. The WHO has stated that no proven therapy exists for the disease caused by the severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), and we argue that the other criteria for MEURI are met as well.
Argument 1: Research Bureaucracy Is Inefficient and Prohibitive—Lessons from Ebola
In March 2014, an outbreak of Ebola was declared in Guinea, but it was not until 5 months later, in August 2014, that the WHO declared a public health emergency of international concern. A research group developed a protocol for clinical investigation of brincidofovir, a process that took 3 months, and another 6 weeks was consumed by additional bureaucratic delay. The narrative account, published in Nature in 2015, described the pace at which the trial was started as “unprecedented” (in its rapidity), in contrast to the norm of 18 months,2 yet during that time the epidemic hit its peak,3 and affected patients had no access to potentially life-saving investigational agents through clinical trials. The author’s advice for the future was the following: “Government leaders must give the WHO the money and support it needs to ensure that the world is ‘research ready’ for the next outbreak. A properly funded and empowered WHO could oversee the design and implementation of an on-call global task force of clinical-trial staff.”
Perhaps this would be a viable strategy for a limited outbreak of a predicted pathogen; however, COVID-19 demonstrates that in a truly global outbreak, such a strategy would be grossly insufficient. We applaud the research response to COVID-19 thus far. At the time of writing, on May 14, 2020, an incredible 1486 protocols had been registered at www.clinicaltrials.gov, and many clinical trials have been initiated by the WHO and other investigators within extremely short timeframes. At the same time, however, there were more than 4.2 million confirmed cases worldwide, or about 2826 cases per clinical protocol. Of course, not all cases would be appropriate for drug therapy, but it is inconceivable that research protocols could be mobilized to enrol even a fraction of those who are eligible.
Argument 2: Variation in Research Infrastructure and Capacity May Introduce Inequities
Equity and fairness are foundational ethical principles in the management of outbreak resources.4,5 Even if rapidly mobilized, clinical research is generally associated with urban universities. Residents of smaller centres therefore have less opportunity to access investigational therapy through clinical trials, which represents a substantial inequity in the availability of potentially life-saving therapy. In addition, clinical trials often exclude those with a lower likelihood of response or deemed to be at higher risk, such as pregnant or elderly patients.6–8 The WHO’s MEURI emphasizes the ethical principle of patient autonomy or the right of patients to make their own risk/benefit assessments in accordance with their own personal values, goals, and health conditions. Excluding patients because of geography or demographic characteristics that would not exclude them from on-label drug prescriptions overrides this principle of patient autonomy.
On March 24, 2020, the British Columbia Centre for Disease Control issued a statement indicating a preference for clinical trials, with the additional proviso that where such trials are not available, compassionate use of therapies is appropriate, provided patients are advised of the risks and benefits and safety data are collected.9 These directions align with the WHO’s guidance on MEURI and with the explanation of Gostin and Berkman, in the second of the WHO discussion papers addressing ethical issues in pandemic influenza planning.10 In that document, the authors recognize the provision of investigational agents as ethically appropriate, provided that they are “proportionate in terms of benefits and burdens” and that resources for population-based research are inadequate.
Canada’s health care system may not be designed to allow equitable access to new therapies through clinical trials in the context of widespread COVID-19 infection, but it is able to support access to investigational therapies in a safe and monitored environment per the conditions of MEURI.
Argument 3: Absence of Evidence Is Not Evidence of Absence (of Positive or Negative Effects)
A common logical fallacy suggests that an untested therapy has no effect. This is a non sequitur. If the therapy is untested, the only reasonable conclusion is that its efficacy is unknown. However, the situation is rarely as simple as a complete absence of study data. Clinicians are often faced with the dilemma of poor evidence or data from one condition that they are attempting to extrapolate to another. In the absence of strong evidence, therapies are routinely prescribed that are considered unproven. Indeed, some therapies informed by low-quality evidence are commonly recommended, including aminoglycosides or ceftriaxone in enterococcal endocarditis,11 combination antibiotics for persistent methicillin-resistant Staphylococcus aureus bacteremia,12 and almost every off-label indication for any therapy.13 Investigational agents for COVID-19 may not have proven efficacy, but equally they are not proven to be inefficacious. For all of the agents currently proposed for the treatment of COVID-19, biological plausibility for activity has been demonstrated and human safety data are available, therefore meeting the WHO MEURI criteria for a scientific rationale and support of clinical experts in the field.
Conclusion
The modern world has no experience with a pandemic of this proportion. The medical and scientific community has much to learn about this virus and the associated disease. Formal acquisition of knowledge through clinical trials is highly desirable, but it accumulates at a far slower pace than the pandemic has progressed to date. The ideal for evaluation of therapy in clinical trials must be balanced against efficiency, equity, autonomy, and beneficence. We do not advocate for indiscriminate use, but we do advocate for access to reasonably safe and possibly effective therapy under clinician oversight and with informed patient consent, as suggested by guidance documents of the WHO.
Footnotes
Competing interests: Linda Dresser has received personal fees from Sunovion for an educational event outside the scope of this article. No other competing interests were declared.
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