Comment from Anonymous

AnonymousOpposeIndividual
Summary: A headache specialist expresses concerns regarding the feasibility and safety of the proposed action. The commenter argues that the requirements for pharmacist screening and physician diagnosis are complex, potentially impractical, and may not sufficiently address the unique risks and contraindications associated with triptans.
I appreciate the sentiment to make migraine medications accessible given the societal burden of unmet treatment needs in this population. Importantly, all persons with migraine are eligible for acute treatment so no additional patient selection is needed for acute treatment beyond diagnosis. However, as a headache specialist perhaps offering an unpopular opinion here, I have concerns. 1.The individual drug manufacturers of these products are stakeholders which would need to be aligned with this proposal. Are they supportive? 2.The extensive role of the pharmacist in mitigating safety concerns may not be universally practical to implement. The petitioner specifies: a.Pharmacist medication screening for drug interactions (the potential DDIs are not the same across triptans) b.Pharmacist screening for atypical symptoms – are pharmacists sufficiently educated and qualified to do this? c.Pharmacist screening for headache frequency? – are pharmacists sufficiently educated and qualified to do this? d.Pharmacist CV screening ? – are pharmacists sufficiently educated and qualified to do this? e.Mandatory physician diagnosis – how can this be implemented? -- This is all sounding like a physician visit. 3.Triptans have numerous and unique Warnings and Precautions, as well as Contraindications that may exceed the complexity required for general consumer appraisal. 4.A recently published target trial emulation identified increased risk of MACE for triptans as compared to non-triptans treatments (Mayo Clin Proc; 2024 Nov;99(11):1722-1731)

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