Position Paper
Position Statement

Potential Impact of Growth Hormone Re-Classification
To a Schedule III drug on the US Population

The MAGIC Foundation
March 10, 2008

There are more than 6,000 rare, or “orphan,” diseases that affect about 25 million Americans. (A rare or “orphan” disease is one that affects fewer than 200,000 people in the United States.) Most endocrine disorders requiring growth hormone classify as rare disorders.

How many people does the re-classification of Growth Hormone to a Schedule III affect?
United States / Frequency  from: http://www.emedicine.com/PED/topic2087.htm#IntroductionFrequency
 “By definition, 2.5% of the population is short. However, the number of children with poor linear growth is higher given the frequency of chronic diseases of childhood. The Utah Growth Study is the largest population-based survey of growth in children published to date. These investigators assessed height and growth velocity in nearly 115,000 American children. Among the 555 children with short stature”, “only 5% had an endocrine disorder. In addition, 48% of the children with growth hormone deficiency (GHD) or Turner syndrome (TS) in this large cohort had been undiagnosed or untreated.”
According to the National Institutes of Health, severe “short stature may be a symptom” caused by a treatable “medical condition”. The Pituitary Network reports that 65 million Americans suffer from pituitary and hormonal disorders.

Causes of Growth Failure  (This list is NOT all-inclusive.)

• Pediatric AIDS
• Chronic diseases such as congenital heart disease, kidney diseases, asthma, sickle cell anemia, thalassemia, juvenile rheumatoid arthritis, and diabetes
• Craniopharyngioma (brain tumors)
• Cushing's disease
• Delayed puberty 
• Hypopituitarism
• Hypothyroidism that develops before birth
• Inflammatory bowel disease
• Malabsorption disorders such as celiac disease
• Pituitary dwarfism
• Precocious puberty 
• Small for Gestational Age
• Idiopathic Short Stature
• Russell-Silver syndrome 
• Turner syndrome
http://www.nlm.nih.gov/medlineplus/ency/article/003271.htm
Following is a table outlining a small sample of conditions and the number of children impacted by Growth Hormone based on the U.S. Dept. of Health and Human Svcs., Cntrs. for Disease Control and Prevention, National Center for Health Statistics. However, in reviewing these statistics it is important to note that:

1. According to the Utah study quoted above, 48% of the children with conditions impacted by growth hormone are not diagnosed. Therefore, one could deduct that this table may only reflect half of the affected population for Turner Syndrome and Growth Hormone Deficiency.

2. Other conditions such as Kidney Disease, Brain Tumors, Leukemia, AIDS (and many others), are NOT included in these totals. Incorporating statistics from those additional illnesses would dramatically increase the number of children (and consequentially affected adults) impacted. This table reflects the more rare and little known conditions for your basic and initial understanding of how wide spread the devastation will be with a Re-classification of growth hormone to a Schedule III drug.

Medical Condition

Ratio

Source

Newborn children affected in 2005 based on the births recorded

Minimum sample number of children affected based on the last Census 2000 reporting 80M+ children under the age of 19

Noonan Syndrome

1:1,000 to 1:2,500

http://rarediseases.info.nih.gov/Wrapper.aspx?src=asp/html/resources/info_cntr.html&PageID=4

1655 (or as much as 4,138)

48,338 (but could total as many as 74,484)

Turner Syndrome

1:2,500 female births

http://rarediseases.info.nih.gov/Wrapper.aspx?src=asp/html/resources/info_cntr.html&PageID=4

 

1655

48,338

Hypopituitarism

1:333,333 (3:1,000,000)

http://www.emedicine.com/ped/topic1130.htm

12

24,000

Panhypopituitarism

 

Office of Rare Diseases (ORD) of the National Institutes of Health (NIH)

21

200,000

Congenital GHD

1:50,000 births

http://www.emedicine.com/PED/topic1810.htm

82

1,476

SOD/ONH

1:10,000

Cathy Clark, FOCUS

143

2,574

CAH

1:10,000 to 18,000

NIH

230 (but could be as high as 413)

4,140

Small for Gestational age. IUGR

14:1,000

http://www.cdc.gov/nchs/fastats/birthwt.htm

338,565 (8.2% of all babies)

6,094,170

Idiopathic Short Stature

3:100

Pediatric and Adolescent Medicine, March 2006, Vol. 160, No. 3. Joyce Lee, M.D.

 

400,000 (ages 4-15 only)

Fetal Alcohol syndrome

1:100

http://www.nofas.org/faqs.aspx?id=12

40,000

720,000

Russell-Silver Syn.

1:100,000 (some estimates are 1:50.000)

The MAGIC Foundation

41

738

Prader Willie Syn.

1:12,000 to 1:15,000

http://www.pwsausa.org/

275 (to 345)

4,950

Growth Hormone Deficiency

1:3,480 derived from Utah Study

Journal of Pediatrics 1994:125:29-35, Lindsay R, et al

1,189

22,988

TOTALS

 

 

383,867 new children each year

7,551,712 children under the age of 19

(This chart does not reflect any adults also impacted by these conditions who would also be affected by the Classification change.)
 
In the article, Growth Hormone Deficiency, Updated: Apr 19, 2006, Stephen Kemp, MD, PhD, Professor, Department of Pediatrics, Section of Pediatric Endocrinology, University of Arkansas and Arkansas Children's Hospital reported that:  “Of more than 20,000 children receiving GH in the National Cooperative Growth Study (a database of patients receiving GH therapy), approximately 25% of the GH-deficient patients had an organic etiology.

These etiologies included the following:
• CNS tumor, including craniopharyngioma - 47%  
• CNS malformation - 15%
• Septo Optic Dysplasia - 14%
• Leukemia - 9%
• CNS radiation - 9%
• CNS trauma / infection- 4%
• Histiocytosis - 2%”

The MAGIC Foundation has more than 170 different medical conditions impacting children’s healthy growth referenced by parents in the database. However, worldwide the database P.O.S.S.U.M. reports in excess of 600 medical conditions correlate to growth failure. Families who have already braved their own private medical battle should not be forced to battle greater logistical issues due to constraints brought about by celebrity abuse. Who is being protected, the children, affected adults – their families or the athletes who broke the law to obtain the drug?

How will this change impact families?
The Federal Laws applied will enforce additional laws and restrictions applied on the state level and Insurance policies will all be “revisited” with regard to each child’s Growth Hormone Deficiency as it will become part of an entirely “new category” of medication. This re-evaluation could facilitate horrible delays pertaining to Insurance considerations, delay in obtaining refills and a world of paperwork nightmares which the majority of families endured when their child was initially diagnosed. Children and or adults who need this drug (for example) to avoid hypoglycemic comas could potentially face life threatening dangers without regular treatments.

One family submitted personal financial data to help us convey how Schedule III labeling and the subsequent State Schedule III laws will impact their child and family in New Jersey.  Ironically, New Jersey is not impacted as severly as families in New York and other states.

Miles (82 round trip)

$39.77

Tolls

$8.00

parking

$17.00

Co-Pay

$35.00

Lost income/trip

$344.44

Cost Per Trip

$444.21

Current Annual Cost

$1,776.86

If Schedule III is passed/ Future Annual Cost

$5,330.57

Additional Annual Cost to Family

$3,553.72


Time

Hours

Per Trip Per Adult

5 (assumes no delays in traffic nor Doctor's office)

Current Annual Time

20

Future Annual Time

60


If there were only 20,000 families affected by this legistlation:
* The additional costs incurred would be 71 million dollars
* Additional time lost would be a minimum of 800,000 work hours
* The intangible factor of the stress the additional time and effort would require, is incalcuable.

New York State Schedule III Prescription Laws
To cite one example detailing how immense the change could be for these families, we offer the State of New York’s statures regarding Schedule III drugs will be added to growth hormone families should the Federal government intervene in our children’s medical care.
To cite a specific state example of how reclassification will impact children via the subsequent New York State laws:
 §  3332. Making of official New York state prescriptions for scheduled substances.   
     3.  No such prescription shall be made for a quantity of controlled substances which would exceed a thirty day supply if the controlled substance were used in accordance with the directions for use specified on the prescription. A practitioner may, however, issue  a  prescription for  up  to a three month supply of a controlled substance provided that the controlled substance  has  been  prescribed  to  treat  one  of  the conditions  that  have  been  enumerated by the commissioner pursuant to regulations as warranting the prescribing of greater than a  thirty  day supply of a controlled substance and that the practitioner specifies the condition  on  the face of the prescription. No additional prescriptions for a controlled substance  may  be  issued  by  a  practitioner  to  an ultimate  user  within  thirty  days  of  the  date  of any prescription previously issued unless and until the ultimate user has  exhausted  all but  a  seven  day  supply  of  the controlled substance provided by any previously issued prescription.
§  3339.  Refilling  of  prescriptions  for  controlled substances.
     1. Prescriptions for a schedule II controlled substance and those schedule III  or  schedule  IV  controlled  substances which the commissioner may require by regulation may not be refilled.
    2. A prescription, except for a schedule II  controlled  substance  or those  schedule  III  or  schedule  IV  controlled  substances which the commissioner may require by regulation may be refilled not more than the number of times specifically  authorized by the prescriber  upon  the prescription,  provided however no such authorization shall be effective for a period greater than six months from the date the  prescription is signed.  In the event that the prescription authorizes the dispensing of more than a thirty day supply of schedule III, schedule IV or schedule V substances pursuant to regulations of the commissioner enumerating conditions warranting specified greater supplies, the prescription may be refilled only once.

What do we agree about?
We absolutely agree that legislation is needed to seal the gap in the current law, it should be illegal to possess Growth Hormone without a legal prescription. To correct this oversight / loophole does NOT require changing Growth Hormone to be a Schedule III drug.

What do we want?
We, the parents and affected adults who would be dramatically impacted by your decision, ask that:
       Growth Hormone retain its current legal status as a hormone not a Schedule III drug while closing the legal loophole forbidding anyone to possess this drug without a prescription.

Contact:
The MAGIC Foundation
6645 W. North Avenue
Oak Park, Illinois 60302
Tel: (708) 383-0808
www.magicfoundation.org
ContactUs@magicfoundation.org

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