Antibiotic Resistance. Because of overuse and misuse, some antibiotics are losing effectiveness against highly resistant bacteria.

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Health Policy Brief                                                                                                    m ay 2 1 , 2 0 1 5

                                  Antibiotic Resistance. Because of overuse
                                  and misuse, some antibiotics are losing
                                  effectiveness against highly resistant
                                  bacteria.

                                                                                     declining, limited, or zero effectiveness. This
                                   what’s the issue?                                 policy brief primarily focuses on the dimin-
                                  Many of the world’s diseases are caused by         ishing effectiveness of many drugs specifically
                                  microorganisms such as bacteria, fungi, vi-        in fighting bacteria, referred to here as “anti-
                                  ruses, and parasites. While there are a num-       biotic resistance.”
                                  ber of drugs designed to treat these infections,
                                  resistant strains are emerging at a rate that is     With so many agencies involved in the regu-
                                  currently outpacing the development of effec-      lation and use of antibiotics, comprehensive
                                  tive new drugs. Methicillin-resistant Staphy-      solutions must focus on creating a coordinat-
                                  lococcus aureus (MRSA) alone kills more than       ed plan that touches on aspects of research
                                  19,000 Americans every year—more than em-          and development as well as enhanced infec-
                                  physema, HIV/AIDS, Parkinson’s disease, and        tion prevention and control, and stewardship
                                  homicide combined. Despite this public health      to ensure the proper use of these drugs across
                                  need, pharmaceutical companies do not have         different settings.
                                  strong economic incentives to develop new an-
                                  tibiotic drugs.                                      This brief provides an overview of antibiotic
                                                                                     resistance, including a summary of its cur-
                                    Unless new drugs are developed—together          rent impact, the factors that contribute to its
                                  with measures taken to slow the emergence          spread, and the policy recommendations put
                                  of new drug-resistant microbes—previously          in place by federal and global public health
                                  treatable infections will become major public      agencies. It also reviews the debate around
                                  health concerns, posing grave threats to in-       the regulation of antibiotic use in agriculture
                                  fected individuals and increasing the risk of      and examines new developments in policy and
                                  spreading to others. In recent years, several      research associated with multidrug-resistant
                                  global and national public health organiza-        bacterial diseases and their underlying causes.
                                  tions have highlighted the growing number
                                  of multidrug-resistant microbes as a major          what’s the background?
                                  public health priority.
                                                                                     According to the Centers for Disease Control
©2015 Project HOPE–                 The commonly used term “antimicrobial            and Prevention (CDC), at least two million ill-
The People-to-People
                                  resistance” applies to any microbe—bacteria,       nesses and 23,000 deaths are caused by anti-
Health Foundation Inc.
10.1377/hpb2015.6                 fungus, or virus—against which drugs have          biotic-resistant bacteria in the United States
                                                                                     alone. In 2013 there were about 480,000 new
h e a lt h p o l ic y b r i e f   a n t i b i o t ic r e sis ta n c e                                                               2
                                  global cases of multidrug-resistant tubercu-       in the workforce could theoretically become
                                  losis. According to the World Health Organi-       too risky to undertake at all.
                                  zation (WHO), gonorrhea may soon become
                                  untreatable as more than ten countries have          One issue that makes antibiotic resistance
                                  reported strains that are resistant to all cur-    difficult to combat is that drug-resistant mi-
                                  rently available forms of antibiotic treatment,    crobes are everywhere. According to the
                                  and no new drugs have been approved. If            WHO, in all regions of the world there are
                                  trends persist and resistance continues to rise,   high proportions of antibiotic resistance in
                                  some reports estimate that by 2050 there will      bacteria that cause common infections in the
“The more                         be ten million antimicrobial resistance–relat-
                                  ed deaths worldwide, costing the world up to
                                                                                     urinary tract, lungs, and bloodstream; and a
                                                                                     high percentage of hospital-acquired infec-
 antibiotics are                  US$100 trillion.                                   tions are caused by highly resistant or multi-
 used, the more                                                                      drug-resistant bacteria. In fact, most deaths
 opportunities                      To some degree, antibiotic resistance is un-     related to antibiotic resistance are attributable
                                  avoidable. The development of resistance is        to infections acquired in health care settings
 bacteria have to                 an evolutionary inevitability, even where an-      such as hospitals and nursing homes.
 evolve to defeat                 timicrobials are used properly and sparingly.
 them.”                           All microbes have the potential to mutate and        Another frequently cited factor in the emer-
                                  render drugs ineffective. Once a few have mu-      gence of multidrug-resistant strains of bacte-
                                  tated, they spread when antibiotics wipe out       ria is the misuse of antibiotics. For example
                                  the susceptible bacteria, leaving a niche for      when patients fail to complete their drug regi-
                                  the resistant ones to occupy.                      mens at home, they may allow some bacteria to
                                                                                     survive the treatment and develop resistance
                                     Antibiotic-resistant infections typically oc-   in the process. In other circumstances, anti-
                                  cur in health care–related settings, such as       biotics may be prescribed when they are not
                                  hospitals and nursing homes, where infec-          medically necessary. This can allow other-
                                  tions can spread quickly between patients          wise harmless bacteria to develop resistance,
                                  with compromised immune systems. Patients          which may then be transferred to other more
                                  who use certain medical devices, such as ven-      dangerous bacteria.
                                  tilators and catheters, are at a higher risk for
                                  infection, according to the CDC.                   Agricultural Use

                                  Overuse and Misuse                                   While these practices may contribute to
                                                                                     the spread of resistant microbes, human con-
                                    The more antibiotics are used, the more op-      sumption only makes up about 20 percent of
                                  portunities bacteria have to evolve to defeat      antibiotic sales in the United States. The vast
                                  them. The overuse of antibiotics—the CDC es-       majority of antibiotics is used agriculturally
                                  timates that up to 50 percent of antibiotics are   in beef, poultry, pork, and fish farms to pre-
                                  unnecessary or inappropriate as prescribed—        vent infection and promote growth among the
                                  in medicine and agriculture has led to a slew      animals.
                                  of so-called superbugs.
                                                                                       While it is unclear whether the larger volume
                                    The potential impact of widespread anti-         of antibiotics used in agriculture compared
                                  biotic resistance is far reaching within the       to hospitals translates to a greater contribu-
                                  health care system. When first-line and then       tion to the emergence of multidrug-resistant
                                  second-line antibiotic treatment options           strains of bacteria, the use of the drugs in food
                                  are limited by resistance or are unavailable,      production has garnered a significant amount
                                  health care providers are forced to use antibi-    of attention in media and policy spheres.
                                  otics that may be less effective and more toxic
                                  and that may require resources such as lon-          According to an investigative report by the
                                  ger hospital stays—driving up both morbidity       news outlet Reuters, antibiotics are given as
                                  rates and health care costs.                       standard practice during most of the life of
                                                                                     chickens, not just when the birds are sick. In
                                     Without new therapies to treat or prevent       every instance of antibiotic use identified, the
                                  infections, lifesaving procedures such as or-      doses were at the low levels that scientists say
                                  gan transplants, chemotherapy, dialysis, and       are especially conducive to the development of
                                  caesarian sections will become more danger-        drug-resistant strains.
                                  ous; and non-lifesaving surgeries, such as hip
                                  operations, that allow people to live active         Many of the antibiotics used agriculturally
                                  lives for longer and may enable them to stay       belong to categories considered medically im-
h e a lt h p o l ic y b r i e f    a n t i b i o t ic r e sis ta n c e                                                               3
                                   portant to humans (such as penicillin and tet-       • To enhance infection prevention and con-
                                   racyclines). Despite this evidence, the United     trol; and
                                   States (in sharp contrast to Europe, which has
                                   a long history of restricting antibiotic use in      • To foster innovations and research and de-
                                   animals) has been slow to pass any binding         velopment for new tools.
                                   legislation limiting the agricultural use of
                                   critical antibiotics.                                In 2012, as part of the Food and Drug Ad-
                                                                                      ministration Safety and Innovation Act,
                                                                                      President Barack Obama signed into law the
                                    what’s the policy?

23,000
                                                                                      Generating Antibiotic Incentives Now (GAIN)
                                   Combating antibiotic resistance will require       Act of 2011. These provisions added a five-year
                                   coordination on behalf of a complex web of         extension to the exclusivity period during
                                   stakeholders. The National Institutes of Health    which antibiotics that treat serious or life-
                                   funds research, including studies that per-        threatening infections could be sold without
deaths                             tain to the development of new antimicrobial       generic competition. The intention of the act
                                   products. The Food and Drug Administration         was to increase the potential for profits from
According to the CDC, at least
two million illnesses and 23,000   (FDA) approves them for marketing and sale.        new antibiotics—giving drug companies more
deaths are caused by antibiotic-   The Department of Agriculture and the FDA          time to recoup their investment costs and en-
resistant bacteria in the United   have roles overseeing their agricultural use.      courage the development of new antibiotics.
States alone.
                                     The CDC, in addition to its role in surveil-       In 2014 the WHO published its first global
                                   lance, prevention, and control, tracks diseases    report on surveillance of antimicrobial resis-
                                   and engages in public education campaigns to       tance, with data provided by 114 countries.
                                   inform doctors and patients how the drugs          The WHO has already initiated a collaboration
                                   should be used in humans. The Biomedical           with partners across many sectors to identify
                                   Advanced Research and Development Author-          strategies and actions to mitigate antimicro-
                                   ity engages the drug development industry in       bial resistance. Those partners have included
                                   an integrated, systematic approach to devel-       the World Organisation for Animal Health and
                                   oping and procuring drugs in tackling public       the Food and Agriculture Organization of the
                                   health emergencies. The Department of De-          United Nations to promote best practices to
                                   fense (DOD) and the Department of Veterans         avoid the emergence and spread of antibacte-
                                   Affairs (VA) determine appropriate use and         rial resistance, including optimal use of anti-
                                   monitoring in military patient populations.        biotics in both humans and animals.
                                   And the State Department determines the US
                                   trade policy on prescription drugs.                  In January 2014 President Obama again
                                                                                      mentioned antibiotic resistance—this time in
                                     In recent years, several global and federal      his State of the Union address. In March 2014
                                   health agencies have attempted to call atten-      he announced he would add $30 million to the
                                   tion to the issue of antibiotic resistance and,    budget to fund monitoring and research into
                                   more broadly, antimicrobial resistance. In 2011    drug-resistant bacteria. Then in September
                                   the theme of World Health Day was “Antimi-         2014 he issued an executive order on com-
                                   crobial resistance: no action today, no cure to-   bating antibiotic-resistant bacteria. In it, he
                                   morrow.” The initiative resulted in a six-point    called for the establishment of a “task force for
                                   policy package designed to assist countries        combating antibiotic-resistant bacteria...to be
                                   with tools to combat antimicrobial resistance.     co-chaired by the secretaries of Defense, Ag-
                                   In summary, the points were as follows:            riculture, and [Health and Human Services]”
                                                                                      with the mission of creating a five-year Nation-
                                     • To commit to a comprehensive, financed         al Action Plan that would include goals, mile-
                                   national plan with accountability and civil so-    stones, and metrics for measuring progress.
                                   ciety engagement;
                                                                                        In March 2015 President Obama urged Con-
                                     • To strengthen surveillance and laboratory      gress to double the federal funding available
                                   capacity;                                          for antibiotic resistance surveillance and pre-
                                                                                      vention, bringing the total to more than $1.2
                                     • To ensure uninterrupted access to essen-       million. The same month, the White House re-
                                   tial medicines of assured quality;                 leased the National Action Plan for Combating
                                                                                      Antibiotic-Resistant Bacteria that had been
                                     • To regulate and promote rational use of        promised the previous fall. The plan detailed
                                   medicines, including in animal husbandry,          five goals: slowing the emergence of drug-
                                   and ensure proper patient care;                    resistant bacteria, strengthening national
h e a lt h p o l ic y b r i e f   a n t i b i o t ic r e sis ta n c e                                                               4
                                  surveillance efforts, improving rapid diagnos-      biotics would be a major blow to the indus-
                                  tic tests for resistant strains of bacteria, pro-   try, resulting in sicker animals and inferior
                                  moting research, and fostering collaboration.       consumer products. PAMTA was introduced
                                                                                      to Congress in 2007, 2009, 2011, and 2013. It
                                    Under each goal, the action plan lays out key     was referred to committee multiple times but
                                  milestones for the next one, three, and five        was never heard in the House Committee on
                                  years. For example, the plan calls for routine      Energy and Commerce.
                                  reporting of antibiotic use and resistance data
                                  by 95 percent of Medicare-eligible hospitals,          The FDA does provide voluntary guidelines
                                  as well as by DOD and VA health care facilities,    that will have the effect of regulating anti-
“In general, new                  by 2020. Over the same time period, the CDC         biotic use by producers of poultry, swine, beef
 antibiotics are                  and the FDA will create the repository and da-      cattle, and other livestock. The use of medi-
 less profitable                  tabase for resistant bacterial strains and, in      cally important antibiotics (as determined by
 compared to                      conjunction with the DOD, will provide them
                                  to diagnostic test manufacturers and research
                                                                                      the FDA) for growth promotion is scheduled
                                                                                      to be phased out by December 2016. The FDA
 other types of                   laboratories, as needed. Using these new sys-       says it also inspects the mills where animal
 drugs.”                          tems, the task force has called for the reduc-      feed is made but does not examine the feed
                                  tion of inappropriate antibiotic use over the       tickets—documents that show why the drugs
                                  next five years by 50 percent in outpatient set-    are administered.
                                  tings and by 20 percent in inpatient settings.
                                                                                        In June 2014 the FDA released a progress re-
                                                                                      port on its strategy to promote the judicious
                                   what’s the debate?                                 use of antibiotics in food-producing animals.
                                  Antibiotic Use in Animals                           According to the report, all twenty-six drug
                                                                                      manufacturers affected by the FDA’s volun-
                                  One portion of the debate surrounding an-           tary guidelines agreed to fully engage in the
                                  tibiotic resistance has to do with its implica-     strategy by modifying labels so that medically
                                  tions for animal husbandry. The WHO, the            important antimicrobials will not be used to
                                  American Medical Association, the Infectious        promote growth. At the same time, they will
                                  Disease Society of America, the Consumers           incorporate the oversight of a veterinarian for
                                  Union, the Union of Concerned Scientists, and       the remaining therapeutic uses of such drugs.
                                  about 450 other organizations support legis-
                                  lation that would eliminate routine antibiotic        Additionally, in November 2014 the Pew
                                  use in animal feed and water.                       Charitable Trusts reviewed the labels of all
                                                                                      287 antibiotic products identified as being af-
                                     Historically, policy attempts to regulate the    fected by the guidance and found that eighty-
                                  use of antibiotics in animal feed have not been     three of the labels had overlapping growth
                                  successful. In 2007 Rep. Louise Slaughter (D-       promotion and prevention dosages.
                                  NY) proposed a bill called the Preservation
                                  of Antibiotics for Medical Treatment Act, or          In April 2015 Tyson Foods, the largest poul-
                                  PAMTA, which would require drug manufac-            try producer in the United States, announced
                                  turers to prove that the non-therapeutic use of     that it would eliminate the use of human anti-
                                  their antibiotics wouldn’t contribute to anti-      biotics in its flocks by September 2017.
                                  biotic resistance. This bill would have phased
                                  out the nontherapeutic use of antibiotics in        New Drug Development
                                  animal feed and water, prohibit the use of an-
                                  tibiotics in animals that aren’t sick, and make       Another major branch of the debate has fo-
                                  it illegal to routinely give animals antibiotics    cused on what the government’s role should
                                  for disease prevention.                             be in incentivizing the development of new
                                                                                      antibacterial drugs. In general, the direction
                                    The bill was supported by medical and sci-        of new pharmaceutical research by private
                                  entific experts and opposed by meat industry        corporations is driven, at least in part, by the
                                  stakeholders, including the National Beef           expectation of return-on-investment. Compa-
                                  Packing Company, the National Pork Produc-          nies make money on drugs when they are used
                                  ers Council, the Animal Health Institute, the       in high volume, sold at a high price, or both.
                                  American Veterinary Medical Association, the        Developing new antibiotics—while medically
                                  National Chicken Council, the National Tur-         necessary—does not necessarily lend itself to
                                  key Federation, the Food Marketing Institute,       any of these money-making scenarios.
                                  and several major pharmaceutical companies.
                                  The companies argued that phasing out anti-
h e a lt h p o l ic y b r i e f                             a n t i b i o t ic r e sis ta n c e                                                                                         5
                                                              Antibiotics are widely used but have histori-                              ulation. The medications would need to be la-
                                                            cally been fairly inexpensive. In recent years                               beled clearly for physicians so that they could
                                                            US antibiotic prescriptions per capita have                                  effectively weigh the medications’ risks and
                                                            declined compared to all prescription drugs                                  benefits as they pertain to particular patients.
                                                            (see Exhibit 1). In 2013 antibiotics accounted
                                                            for 6.4 percent of all US prescriptions but only                               Additionally, provisions in the GAIN Act
                                                            2.6 percent by value. This discrepancy, paired                               referenced above help stimulate the develop-
                                                            with the medical need for new antibiotics, has                               ment of new antibiotics. Under the act, certain
                                                            prompted some advocates to push for govern-                                  antibacterial or antifungal drugs intended to
                                                            ment intervention in the drug approval proc-                                 treat serious or life-threatening infections can
                                                            ess specific to antibiotic development. Some                                 be designated as Qualified Infectious Disease
                                                            policy makers have suggested allowing for                                    Products (QIDPs), which receive priority re-
                                                            higher reimbursement from insurance com-                                     view and are eligible for fast-track designation.
                                                            panies as a way to incentivize new treatments.
                                                                                                                                           The act also incentivized new drug devel-
                                                              Another approach would be to alter the drug                                opment by giving drug companies five more
                                                            development pathway for antibiotics that ad-                                 years of market exclusivity without generic
                                                            dressed an unmet medical need. For drugs                                     competition. As of September 2014 the FDA
                                                            that qualify, this could reduce cost barriers to                             had granted fifty-nine QIDP designations for
                                                            get new products to market. In 2013 the FDA                                  thirty-nine different molecules. In February
                                                            held a public hearing on a potential pathway                                 2015 the FDA approved Avycaz, the fifth new
                                                            to expedite the approval of critical new drugs,                              antibacterial drug with the QIDP designation.
                                                            including antibiotics needed to treat serious
                                                            or life-threatening infections with few or no                                   The GAIN Act has increased drug company
                                                            satisfactory treatment options. This Limited                                 interest in developing antibiotics, but some
                                                            Population Antibacterial Drug (LPAD) ap-                                     critics say it’s still not enough. In a February
                                                            proval pathway would evaluate these drugs                                    2015 op-ed published in the New York Times,
                                                            using smaller trials than traditional drug de-                               oncologist and University of Pennsylvania
                                                            velopment programs.                                                          vice provost Ezekiel J. Emanuel suggested
                                                                                                                                         that the US government partner with other
                                                               The streamlined LPAD pathway, while po-                                   countries to offer a US$2 billion prize to the
                                                            tentially innovative, may come at some cost.                                 first five companies or academic institutions
                                                            There would be some uncertainty about poten-                                 to develop and get regulatory approval for a
                                                            tial risks based on smaller trials that are less                             new class of antibiotics. He reasoned that the
                                                            able to identify and predict infrequent adverse                              payment would provide a beneficial return for
                                                            events in any statistically significant way. This                            companies, as well as provide cost savings for
                                                            is less of a concern with a limited population                               the health care system, which he estimated
                                                            of patients with serious or life-threatening in-                             spends about US$20 billion per year on costs
                                                            fections and unmet medical needs, but these                                  related to antibiotic resistance.
                                                            risks would be of more concern if the drugs
                                                            were to be used in a more general patient pop-                                 A recent report released from the UK’s Re-
                                                                                                                                         view on Antimicrobial Resistance (AMR)
 exhibit 1                                                                                                                               looks specifically at ways to encourage and
                                                                                                                                         improve the development of new antibiotic
Per Capita US Prescriptions, Antibiotic and Total, 2009–13                                                                               drugs. The report recommends creating a
                                                                                                                                         global AMR Innovation Fund to boost invest-
                              1.00                                                                                                       ment in early-stage research and “de-link” a
                                                                                                                                         drug’s profit from its volume in sales.
                              0.95                                                                       13.5
   Antibiotic Rx per capita

                                                                                                                                         Other Policy Proposals
                                                                                                                Total US Rx per capita

                              0.90          Antibiotic Rx

                                                                                                                                            Within health care settings and medical
                              0.85                                                                       13.0
                                                                                                                                         practices, efforts to stem antibiotic resistance
                                                                                Total US Rx
                              0.80
                                                                                                                                         have focused on more judicious prescribing
                                                                                                                                         policies and infection control. In 2013 the CDC
                              0.75                                                                       12.5                            estimated that four out of five Americans are
                                                                                                                                         prescribed antibiotics each year. Part of this
                                     2009            2010        2011               2012          2013
                                                                                                                                         is as a result of physicians’ prescribing anti-
source Kevin Outterson, John H. Powers, Gregory W. Daniel, and Mark B. McClellan, “Repairing the
Broken Market for Antibiotic Innovation,” Health Affairs 34, no. 2 (2015):277–85.
h e a lt h p o l ic y b r i e f   a n t i b i o t ic r e sis ta n c e                                                               6
                                  biotics defensively, even if their patients most   teixobactin that targets polymers that build
                                  likely will not benefit from them.                 the bacterial cell wall. The drug’s pathway—
                                                                                     examined in mice but not yet in humans—is
                                     Options for curbing this practice have in-      similar to vancomycin, another antibiotic of-
                                  cluded incentive payments and feedback sys-        ten used as a last-resort treatment for resistant
                                  tems, but these programs can be expensive          strains of bacteria such as MRSA. In their pa-
                                  and have had limited success. One technique        per, the researchers highlighted how the tech-
                                  that has shown some promise is to educate pa-      nology used for this discovery might help lead
                                  tients about the proper use and prescription of    to additional drug discoveries.

50
                                  antibiotics. A 2014 study found that a simply
                                  worded poster placed in exam rooms helped             While it is tempting to assume that a po-

       % of                       reduce unnecessary antibiotic prescriptions
                                  for respiratory infections during flu season
                                                                                     tential new human antibiotic means that the
                                                                                     pharmaceutical industry’s interest in develop-

antibiotics                       by approximately 20 percent.                       ing new antibacterial drugs will spring back
                                                                                     into gear, it’s important to consider that the
The CDC estimates that up to        It is not just prescription drugs that have      failure rate for antibiotics from early discov-
50 percent of antibiotics are     come under stricter scrutiny. In May 2015          ery stage to actual drug approval is 97 percent.
unnecessary or inappropriate as   the FDA proposed a rule that would require         In general, new antibiotics are less profitable
prescribed.                       companies that manufacture hand sanitiz-           compared to other types of drugs, as their use
                                  ers used in hospital settings to submit new        is tightly controlled by hospitals trying to pre-
                                  studies looking at key safety issues, including    vent the emergence of new resistant strains,
                                  possible hormonal effects and contributions        and yet drug companies are not able to com-
                                  to antibiotic-resistant bacteria. Products that    pensate for slow adoption by charging more
                                  could not be proven safe and effective by 2018     because they’d have to compete with inexpen-
                                  would have to be reformulated or removed           sive generic antibiotics. In 2011, for example,
                                  from the market.                                   Pfizer, one of the few drug companies to work
                                                                                     on developing new antibiotics, closed its re-
                                                                                     search lab in Connecticut.
                                   what’s next?
                                  There are several potential directions for           For health care facilities, life science re-
                                  new antimicrobial drug research and devel-         searchers, federal agencies, and local health
                                  opment. Better diagnostic tools could affect       officials to meet many of the specific goals
                                  the way antibiotic resistance is detected, di-     outlined in the Obama administration’s re-
                                  agnosed, and reported. More rapid tests could      cent National Action Plan, they will require
                                  help to prevent overprescription of antibiotics    additional resources. To that end, President
                                  and assist with global surveillance measures       Obama’s fiscal year 2016 budget proposes to
                                  already emerging as a result of policy goals.      nearly double the amount of federal funding
                                                                                     for combating and preventing antibiotic re-
                                    There are also potential developments            sistance to more than $1.2 billion. Congress,
                                  for new drugs. Researchers at Northeastern         however, is unlikely to support and enact the
                                  University recently published a paper in Na-       president’s full budget request. n
                                  ture about a potential new antibiotic called
h e a lt h p o l ic y b r i e f             a n t i b i o t ic r e sis ta n c e                                                                              7
About Health Policy Briefs
                                             resources
Written by
Teresa Chin
Consulting Editor                           Antibiotic Resistance Project, GAIN: How a New Law         Timothy F. Landers, Bevin Cohen, Thomas E.
                                            Is Stimulating the Development of Antibiotics (Philadel-   Wittum, and Elaine L. Larson, “A Review of Antibi-
Editorial review by                         phia, PA: Pew Charitable Trusts, November 7, 2013).        otic Use in Food Animals: Perspective, Policy, and Po-
Robert Guidos
                                                                                                       tential,” Public Health Reports 127, no. 1 (2012): 4–22.
Senior Advisor to the Director
                                            Antibiotic Resistance Project, Gaps in FDA’s Antibiot-
Center for Drug Evaluation and Research
                                            ics Policy (Philadelphia, PA: Pew Charitable Trusts,       Losee L. Ling, Tanja Schneider, Aaron J. Peoples,
Food and Drug Administration
                                            November 30, 2014).                                        et al., “A New Antibiotic Kills Pathogens without De-
Kevin Outterson                                                                                        tectable Resistance,” Nature 517 (2015): 455–9.
Professor of Law and N. Neal Pike Scholar   Carol Cogliani, Herman Goossens, and Christina
in Health and Disability Law                Greko, “Restricting Antimicrobial Use in Food Ani-         Review on Antimicrobial Resistance, Antimicrobial
Boston University                           mals: Lessons from Europe,” Microbe 6, no. 6 (2011):       Resistance: Tackling a Crisis for the Health and Wealth
Associate Fellow, Chatham House             274–9.                                                     of Nations (London, UK: Review on Antimicrobial
Editor in Chief, Journal of Law,                                                                       Resistance, December 2014).
Medicine and Ethics                         Nadine Czekalski, Tom Berthold, Serena Caucci,
                                            Andrea Egli, and Helmut Bürgmann, “Increased Lev-          Brad Spellberg, Martin Blaser, Robert J. Guidos,
Rachel Zetts
                                            els of Multiresistant Bacteria and Resistance Genes        et al., “Combating Antimicrobial Resistance: Policy
Senior Associate, Antibiotic Resistance
                                            after Wastewater Treatment and Their Dissemina-            Recommendations to Save Lives,” Clinical Infectious
Project
Pew Charitable Trusts                       tion into Lake Geneva, Switzerland,” Frontiers in          Diseases 52, Suppl 5 (2011): S397–428.
                                            Microbiology 3 (2012):106.
Rob Lott                                                                                               The White House, Executive Order—Combating An-
Deputy Editor                               Michael A. Jahne, Shane W. Rogers, Ivan P. Rambler,        tibiotic-Resistant Bacteria (Washington, DC: White
Health Affairs                              Edith Holder, and Gina Hayes, “Hierarchal Cluster-         House Press Office, September 18, 2014).
                                            ing Yields Insight into Multidrug-Resistant Bacteria
Tracy Gnadinger                             Isolated from a Cattle Feedlot Wastewater Treatment        World Health Organization, Antimicrobial Resistance
Assistant Editor                            System,” Environmental Monitoring and Assessment           (Geneva, Switzerland: World Health Organization,
Health Affairs                                                                                         updated April 2015).
                                            187, no. 1 (2015): 4168.
Health Policy Briefs are produced under
a partnership of Health Affairs and the
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Cite as:
“Health Policy Brief: Antibiotic
Resistance,” Health Affairs,
May 21, 2015.

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