Suicidality, depression, and the FDA: Health inequities and the ethical conduct of research

Objective: Persons with mental health disorders, including suicidality, are underrepresented in clinical trials, undermining the generalizability of results and possibly contributing to health inequities. This report (1) documents the exclusion of persons with suicidality in trials used to secure US Food and Drug Administration (FDA) approval for antidepressants, (2) describes barriers to inclusion, and (3) identifies possible steps for overcoming barriers. Methods: Inclusion and exclusion criteria for efficacy trials for depression or major depressive disorder described on FDA labels for 14 antidepressants approved from 1991 through 2013 were studied by reading the FDA labels, publications described on labels, and ClinicalTrials.gov entries for registered trials. Labels for drugs approved in or before 1998 were obtained through a Freedom of Information Act request filed June 26, 2018. For drugs approved after 1998, labels are on the FDA website. Publications based on the trials described on FDA labels were identified through a PubMed search on October 23, 2018, using each drug name and trial or study as the keywords and setting no date limit. Results: For drugs approved from 1991 to 2000, of 36 publications identified, 26 did not mention suicidality, 7 excluded persons with suicidality but did not describe assessing suicidality with an instrument, 2 excluded persons with suicidality and described assessing suicidality using at least 1 instrument, and 1 included persons with suicidality. For drugs approved from 2000 through 2013, of 28 publications identified, 4 did not mention suicidality, 12 reported excluding persons with suicidality but did not describe assessing suicidality with an instrument, 12 excluded persons with suicidality and described assessing suicidality using at least one instrument, and none included persons with suicidality. More stringent criteria for assessing and excluding based on suicidality very likely were applied for drugs approved post-2000. Conclusions: The exclusion of persons with suicidality from antidepressant trials is common, creating uncertainty about medication safety and efficacy in parts of the target population. Information about study populations can be beneficial for prescribing clinicians, but it is not always readily available.