Six steps to fighting non-compliant cell therapy treatments. — The stuff of grey shades, spades, ivory towers and (ahem) balls.
By Dr. Matthew Watson
Today an article entitled "Professors Critique Stem Cell Medical Tourism" appeared in the online version of The Harvard Crimson summarizing a recent panel discussion hosted in least in part by Harvard Law School assistant professor I. Glenn Cohen and University of Alberta law professor Timothy Caulfield. The article concludes thusly:
The panelists emphasized that more accurate information should be provided to the public regarding stem cell treatments.
Certainly what Cohen and Caulfield concluded is true. It has now been true for several years. We keep saying it. But are we listening to ourselves? Are we doing anything meaningful to address this? If so, is it enough?
Sadly (in my opinion, of course) the answer is 'not nearly enough'.*
For several years now, experts and organizations in the cell therapy sector have been saying that more must be done to educate and assist patients who are seeking stem cell or other cell-based treatments which do not comply with existing regulation and/or widely accepted medical or clinical research practices (hereafter called "non-compliant cell therapies").
In my opinion, attempts to address this need by the sector's professional organizations, while important, have been unnecessarily feeble, not gone nearly far enough, and legitimately appear by many to be high-minded and pedantic.
Almost all efforts to-date to address this issue by ISSCR, CIRM, ISCT and others including authors such as Caufield - as laudable and needed as they are - have been focused on helping distinguish between compliant and non-compliant treatments (and providers). This is certainly much needed. But what is left, I submit, is an even greater unmet need.
What almost all efforts to-date have failed to recognize or address is that where real help is needed is in helping patients distinguish between the many shades of grey among non-compliant treatments (and providers).
Emerging organizations like ICMS (now in partnership with AABB) have recognized and attempted to address this unmet need through a commitment to create some level of certification, accreditation or standardization of clinics participating in this business of selling non-compliant cell therapies.
While their intentions appear on-target as one meaningful way to address this unmet need and certainly their willingness to tackle this issue in a bold way is to be lauded, the ICMS is inexperienced and underfunded. I remain hopeful that now through their new partnership with AABB they will be able to provide something that really addresses this unmet need but the jury remains out on whether they will succeed.
Anyone who has followed this blog and/or my threads on LinkedIn know I have been thinking about and discussing this issue for some time. In a desire to move to very concrete suggestions, I want to recommend the following 6 steps to my industry colleagues and professional organizations:
1. 50 shades of grey. Let's admit that this issue is not black-and-white but, as is almost always, involves a broad spectrum of grey in the middle.
In addition to helping patients distinguish between compliant and non-compliant treatments (and providers) there are a lot of ways to help patients distinguish between non-compliant cell therapy treatments (and providers) which are more or less risky.

Let me use examples.
On the one end of the non-compliant spectrum I would put forward a clinical like Okyanos Heart Institute which (as I understand it) intends to provide cell therapy treatments in the Bahamas to US patients using the Cytori system for cardiac conditions as soon as such treatments are perfectly legal and available to European patients but years before such treatments will be available in the US.
Non-compliant? Yes. But certainly no evidence I'm aware of to support a belief that seeking treatment from them would be any more risky than travelling to Europe to receive the same treatment in a manner perfectly compliant with European regulations.
On the other end of the spectrum are the kinds of clinics highlighted recently by 60 minutes or which are the subject of ongoing lawsuits.
In between - in my opinion - are clinics like Stem Cell Institute and StemCellMD.
2. Step out of the ivory tower. Let's recognize that in certain circumstances patients are going to go pay for non-compliant cell therapies and we must do more to help these patients than simply shake our finger and tell them they mustn't.

This is a recognition that we cannot just abandon people because they made (or are going to make) decisions with which we ultimately disapprove. It is a recognition that sometimes the most righteous thing to do is not only to help people do what we would ideally want them to do but to help them do the best they can in their circumstances and on their terms - even terms with which we may ultimately disagree.


3. A risk-based strategy. Let's recognize that even the FDA triages their response to non-compliance and we would do well to do the same. As a regulated industry we are perfectly comfortable with risk-based assessments and it should be applied here.
Rather than treating all non-compliance as equally evil, let's apply some risk-based analysis to the situation and develop a strategy to root out the worst (highest-risk) offenders.
4. This is not just about tourism anymore - the problem has come home to roost. Let's recognize that this is no longer just a problem of patients leaving a regulated jurisdiction seeking a non-compliant treatment in a jurisdiction with no or more permissive regulation.
Non-compliant treatments are growing rapidly even in the most highly regulated jurisdictions. No where is this more true than in the United States.
5. Take responsibility. Let's recognize that we cannot expect our regulatory enforcement agencies to do it all. They are under-staffed and under-funded. They - and the people we all serve - need our active participation in dealing with offenders and those risking patient safety.
From a self-interested perspective, we owe it to our industry to help crack down on those who put the credibility and legitimacy of cell therapies at highest risk.

ISSCR backed down on their stem cell tourism initiative after being threatened by lawsuits. Who has stepped up in their absence? Individual bloggers and authors like Paul Knoeplfer, Alexey Bresenev, Leigh Turner, and myself all who have been threatened with litigation several times for having the audacity to call certain non-compliant clinics out for what we deem - in our own risk-based analysis - to be the worst offenders.
By way of example, several of my colleagues have recently committed to doing all they can do to call out David Steenblock and his non-compliant cell therapy treatments, many of which are provided at his clinic in California for a plethora of conditions. In their opinion, many of his treatments represent some of worst examples of non-compliance in the United States right now. There are many faces or fronts to his practice including http://www.davidsteenblock.com, http://www.stemcellmd.org, http://www.strokedoctor.com, http://www.davidsteenblock.net, etc.
If, as an industry, we act with more cohesion (collaboratively applying a risk-based assessment of non-compliant clinics) and speak with a more cohesive voice in terms of calling out those clinics and treatments which we conclude pose the greatest risk based on an objective set of criterion, this will present a multi-pronged, formidable and existential threat to clinics that they can't ignore or threaten away.
___
I will be taking these 6 recommendations to any organization who will listen. I hope you will consider doing the same.
In the meantime - as always - I welcome your comments.
___
* This is my opinion not necessarily the opinion of any clients I represent or organizations I serve. Judge me - not them - accordingly.
- 001 Stem cells for a Webby! [Last Updated On: April 28th, 2010] [Originally Added On: April 28th, 2010]
- 002 Latest Cell Therapy Approval by FDA. Dendreon's Provenge. [Last Updated On: April 30th, 2010] [Originally Added On: April 30th, 2010]
- 003 Google to Invest in Regenerative Medicine [Last Updated On: May 5th, 2010] [Originally Added On: May 5th, 2010]
- 004 Biotech tax credit appears perfectly designed for cell therapy companies to recoup research dollars spent in 2009-10 [Last Updated On: May 22nd, 2010] [Originally Added On: May 22nd, 2010]
- 005 The changing face of PR and why it matters to regenmed [Last Updated On: June 12th, 2010] [Originally Added On: June 12th, 2010]
- 006 FDA files injunction again Regenerative Sciences citing Regenexx violates regulations [Last Updated On: August 12th, 2010] [Originally Added On: August 12th, 2010]
- 007 Careers in cell therapy & regenerative medicine [Last Updated On: October 11th, 2010] [Originally Added On: October 11th, 2010]
- 008 The LinkedIn Cell Therapy Industry Group - 1,000 members strong [Last Updated On: January 15th, 2011] [Originally Added On: January 15th, 2011]
- 009 Cell Therapies: Commercializing a New Class of Biopharmaceuticals [Last Updated On: February 12th, 2011] [Originally Added On: February 12th, 2011]
- 010 In vivo cell trafficking just took a leap forward [Last Updated On: July 3rd, 2011] [Originally Added On: July 3rd, 2011]
- 011 Cell Therapy's Got Talent Technology Showcase - A Call for Cell Therapy Manufacturing Technology Presentations [Last Updated On: July 10th, 2011] [Originally Added On: July 10th, 2011]
- 012 Clinical trial costs [Last Updated On: July 31st, 2011] [Originally Added On: July 31st, 2011]
- 013 Good Data? $100. Good Product Development? $100. Good Commercialization Strategy? Priceless. [Last Updated On: August 14th, 2011] [Originally Added On: August 14th, 2011]
- 014 Potential far-reaching implications of the ongoing fight over point-of-care autologous cell therapy [Last Updated On: September 18th, 2011] [Originally Added On: September 18th, 2011]
- 015 Commercial-stage Cell Therapy Companies and Products [Last Updated On: September 18th, 2011] [Originally Added On: September 18th, 2011]
- 016 Cell Therapy & Regenerative Medicine Domains Available [Last Updated On: September 25th, 2011] [Originally Added On: September 25th, 2011]
- 017 Commercializing Cell-based Regenerative Medicines [Last Updated On: November 13th, 2011] [Originally Added On: November 13th, 2011]
- 018 Sabrina Cohen Foundation Thanks Stem Cell Researchers [Last Updated On: November 27th, 2011] [Originally Added On: November 27th, 2011]
- 019 Active phase III or II/III cell therapy trials [Last Updated On: December 11th, 2011] [Originally Added On: December 11th, 2011]
- 020 Recently approved cell therapy products [Last Updated On: December 18th, 2011] [Originally Added On: December 18th, 2011]
- 021 Inactive and recently failed or terminated phase III or II/III cell therapy trials [Last Updated On: December 18th, 2011] [Originally Added On: December 18th, 2011]
- 022 2011 EMA Committee for Advanced Therapies (CAT) classification record. What can be learned? [Last Updated On: January 1st, 2012] [Originally Added On: January 1st, 2012]
- 023 Predicting the Success of the Late-Stage Cell-Based Cancer Immunotherapy Pipeline? [Last Updated On: March 11th, 2012] [Originally Added On: March 11th, 2012]
- 024 Another > $100M month for companies in the cell therapy space [Last Updated On: May 6th, 2012] [Originally Added On: May 6th, 2012]
- 025 Cell-based Cancer Immunotherapies. Some metrics.. [Last Updated On: May 20th, 2012] [Originally Added On: May 20th, 2012]
- 026 Industry-sponsored cardiovascular cell therapies. Some metrics. [Last Updated On: May 27th, 2012] [Originally Added On: May 27th, 2012]
- 027 Bioreactor Design and Bioprocess Controls for Industrialized Cell Processing [Last Updated On: June 17th, 2012] [Originally Added On: June 17th, 2012]
- 028 FDA 1. RSI 0. Regenerative Sciences (Regenexx) vs FDA (2012) [Last Updated On: July 29th, 2012] [Originally Added On: July 29th, 2012]
- 029 Is the cell therapy sector outperforming the major indices? [Last Updated On: August 12th, 2012] [Originally Added On: August 12th, 2012]
- 030 Are some cell counts too good to be true? Why some companies' product data may mislead. [Last Updated On: September 2nd, 2012] [Originally Added On: September 2nd, 2012]
- 031 Two lessons I learned this week. [Last Updated On: September 16th, 2012] [Originally Added On: September 16th, 2012]
- 032 The cost of clinical trial data bias/loss, FDA's new job and the need for bold leadership. [Last Updated On: September 30th, 2012] [Originally Added On: September 30th, 2012]
- 033 Anticipated short-term cell therapy industry clinical milestones [Last Updated On: September 30th, 2012] [Originally Added On: September 30th, 2012]
- 034 Cell therapy portfolio outperforms major indices year-to-date [Last Updated On: October 14th, 2012] [Originally Added On: October 14th, 2012]
- 035 CIRM addresses some tough questions. Is it all just glass towers and basic research? [Last Updated On: October 21st, 2012] [Originally Added On: October 21st, 2012]
- 036 GEN's "Cellular Therapy Wave Finally Cresting". An overview and data set. [Last Updated On: November 4th, 2012] [Originally Added On: November 4th, 2012]
- 037 Cell Therapy Industry Group Welcomes its 4,000th member [Last Updated On: November 11th, 2012] [Originally Added On: November 11th, 2012]
- 038 A proposed 6-step platform for the cell therapy industry to consider in combating non-compliant cell therapy treatments [Last Updated On: December 16th, 2012] [Originally Added On: December 16th, 2012]
- 039 The ROI on pant-wearing and other social media tips [Last Updated On: December 16th, 2012] [Originally Added On: December 16th, 2012]
- 040 The Accuracy of Adipose Stem Cell Doses [Last Updated On: December 23rd, 2012] [Originally Added On: December 23rd, 2012]
- 041 Cell Therapy Blog welcomes 2013 [Last Updated On: January 6th, 2013] [Originally Added On: January 6th, 2013]
- 042 2013 Annual Regenerative Medicine Industry Report [Last Updated On: April 21st, 2013] [Originally Added On: April 21st, 2013]
- 043 Commercialization of Regenerative Medicine: Learning from Spin-Outs [Last Updated On: April 28th, 2013] [Originally Added On: April 28th, 2013]

Share
Comments are closed.
Personalized Gene Medicine
| Mesenchymal Stem Cells
| Stem Cell Treatment for Multiple Sclerosis
| Stem Cell Treatments
| Board Certified Stem Cell Doctors
| Stem Cell Medicine
| Personalized Stem Cells Therapy
| Stem Cell Therapy TV
| Individual Stem Cell Therapy
| Stem Cell Therapy Updates
| MD Supervised Stem Cell Therapy
| IPS Stem Cell Org
| IPS Stem Cell Net
| Genetic Medicine
| Gene Medicine
| Longevity Medicine
| Immortality Medicine
| Nano Medicine
| Gene Therapy MD
| Individual Gene Therapy
| Affordable Stem Cell Therapy
| Affordable Stem Cells
| Stem Cells Research
| Stem Cell Breaking Research