Protocol for Disaster?
May 2nd, 2014
The study protocol for the systematic review of ME/CFS was posted by
the Agency for Healthcare and Research Quality yesterday. It's a
recipe for disaster on its own, and within the broader context of the
NIH P2P Workshop it's even worse. Let me show you some of the reasons
Remind Me What This Is
The systematic evidence review is the cornerstone of the P2P process.
The P2P meeting on ME/CFS will feature a panel of non-ME/CFS experts
who will produce a set of recommendations on diagnosis, treatment, and
Because the P2P Panel members are not ME/CFS experts, they need
background information to do their job. This systematic evidence
review done by the Oregon Health & Science University under contract
to AHRQ will be that background information. The systematic evidence
report will be presented to the Panel in advance of the public P2P
meeting, and will be used to establish the structure of the meeting as
The systematic review is the foundation. If done correctly, it would
be a strong basis for a meaningful workshop. If done poorly, then
everything that follows – the workshop and the resulting
recommendations – will crumble. Based on the protocol published
yesterday, I think "crumble" is putting it mildly.
The Key Questions
"You can't get the right answer if you don't ask the right questions".
(Dr. Beth Collins-Sharp, CFSAC Minutes, May 23, 2013, p. 12)
As I wrote in January, the original draft questions for the evidence
review included whether CFS and ME were separate diseases. That
question is GONE, my friends. Now the review is only looking at two
- What methods are available to clinicians to diagnose ME/CFS and how
do the use of these methods vary by patient subgroups?
- What are the benefits and harms of therapeutic interventions for
patients with ME/CFS and how do they vary by patient subgroups?
These questions are based upon a single and critical assumption: ME
and CFS are the same disease. Differences among patient groups
represent subtypes, not separate diseases. The first and most
important question is whether the ME and CFS case definitions all
describe one disease. But they're not asking that question; they have
already decided the answer is yes.
The study protocol and other communications from HHS (including
today's CFSAC listserv message) state that the P2P Working Group
refined these study questions. The implication is that since ME/CFS
experts and one patient served on the Working Group, we should be
satisfied that these questions were appropriately refined. But what
I'm piecing together from various sources indicates that the Working
Group did not sign off on these questions as stated in the protocol.
Regardless of who drafted these questions, they cannot lead to the
right answers because they are not the right questions. And when you
examine the protocol of how the evidence review will be conducted,
these questions get even worse.
The real danger signals come from the description of how this evidence
review will be done. The issue is what research will be included and
assessed in the review. For example, when asking about diagnostic
methods, what definitions will be considered?
This evidence review will include studies using "Fukada [sic],
Canadian, International, and others", and the Oxford definition is
listed in the table of definitions on page 2 of the protocol. That's
right, the Oxford definition. Oxford requires only one thing for a CFS
diagnosis: six months of fatigue. So studies done on people with
long-lasting fatigue are potentially eligible for inclusion in this
The description of the population to be covered in the review makes
that abundantly clear. For the key question on diagnostic methods, the
study population will be: "Symptomatic adults (aged 18 years or older)
with fatigue." There's not even a time limit there. Three months
fatigue? Four? Six? Presence of other symptoms? Nope, fatigue is
There is a specific exclusion: "Patients with other underlying
diagnosis," but which conditions are exclusionary is not specified. So
will they exclude studies of patients with depression? Because the
Oxford definition does not exclude people with depression and anxiety.
We've seen this language about excluding people with other underlying
diagnosis before – and it results in lumping everyone with medically
"unexplained" fatigue into one group. This protocol is set up to
result in exactly that. It erases the lines between people with
idiopathic chronic fatigue and people with ME, and it puts us all in
the same bucket for analysis.
And what about the key question on treatment? What studies will be
included there? All of them. CBT, GET, complementary/alternative
medicine, and symptom-based medication management. It's not even
restricted to placebo trials; trials with no treatment, usual care,
and head-to-head trials are all included.
Let's do the math. Anyone with unexplained fatigue, diagnosed using
Oxford or any other definition, and any form of treatment. This adds
up to the PACE trial, and studies like that.
But it's even worse. The review will look at studies published since
January 1988 because that was the year "the first set of clinical
criteria defining CFS were published." (page 6) Again, let's do the
math: everything published on ME prior to 1988 will be excluded.
Finally, notice the stated focus of the review: "This report focuses
on the clinical outcomes surrounding the attributes of fatigue,
especially post-exertional malaise and persistent fatigue, and its
impact on overall function and quality of life because these are
unifying features of ME/CFS that impact patients." (page 2) In other
words, PEM = fatigue. And fatigue is a unifying concept in ME/CFS. Did
anyone involved in drafting this protocol actually listen to anything
we said at last year's FDA meeting?
Maybe you're thinking it's better for this review to cast a broad net.
Capture as much science as possible and then examine it to answer the
key questions. But that's not going to help us in this case.
This review will include Oxford studies. It will take studies that
only require patients to have fatigue and consider them as equivalent
to studies that require PEM (or even just fatigue plus other
symptoms). In other words, the review will include studies like PACE,
and compare them to studies like the rituximab and antiviral trials,
as if both patient cohorts were the same.
That assumption – that patients with fatigue are the same as patients
with PEM and cognitive dysfunction – is where this whole thing falls
apart. That assumption contaminates the entire evidence base of the
In fact, this review protocol makes an assumption about how the
Institute of Medicine study will answer the same question. It is
possible (though not assured) that IOM will design diagnostic criteria
for the disease characterized by PEM and cognitive dysfunction. But
this evidence review is based on an entirely different patient
population that includes people with just fatigue. The conclusions of
this evidence review may or may not apply to the population defined by
the IOM. It's ridiculous!
But it's the end use that really scares me. Remember that this
systematic evidence review report will be provided to that P2P Panel
of non-ME/CFS experts. The Panel will not be familiar with the ME/CFS
literature before they get this review. And the review will conflate
all these definitions and patient populations together as if they are
equivalent. I think it's obvious what conclusion the P2P Panel is
likely to draw from this report.
I would love to be wrong about this. I would love for someone to show
me how this protocol will result in GOOD science, and how it will give
the P2P Panel the right background and foundation for the
recommendations they will draft. Please, scientists and policy makers
who read this blog – can you show me how this protocol will produce
good science? Because I am just not seeing it.
What Do We Do?
This protocol is bad news but it is by no means the last word. Plans
are already in motion for how the advocacy community can respond. I
will keep you posted as those plans are finalized.
Make no mistake, this evidence review and P2P process are worse than
the IOM study. We must respond. We must insist on good science. We
must insist that our disease be appropriately defined and studied.