Continued letters and complaints to the FDA, NIH, and HHS (Jan 2025) Advocacy 

Michael Harrop

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Since my first letters in 2018 to both the NIH and FDA, nothing has changed. Tens of millions of dollars continue to be wasted on FMT clinical trials with low-quality donors, patients continue to be harmed, and safe & effective FMT continues to be unavailable, and neither the NIH nor FDA seems to care. The researchers conducting the trials certainly do not care and have no interest in using better donors even though a patient did all the work for them and screened over a million people to find better donors. I still get nothing but silence when I write to researchers about the donor quality issue.

All this despite the fact that I'm likely the #1 world expert on FMT. You have a disabled, home-ridden patient with no funding or support outperforming the entire world's research system, and the people in that system have zero interest in the matter, and the regulatory and funding schemes not only do not support the patient but prevent them from continuing.

I want to say enough is enough, I'm going to war against these incompetent, apathetic people who are stealing my life from me. But what am I supposed to do? NIH doesn't even allow people to protest. And virtually the entire patient community for all chronic diseases are completely apathetic, and would rather sit around and moan about their situation while refusing to do anything to improve it.

I'll continue to lobby Congress to reform this extremely flawed system, but so far, it seems like most congressional offices/staffers don't care either.

It is so egregious that it has gone on for this long. Whoever is approving funding for FMT clinical trials, needs to review my work, discoveries, and complaints. They need to understand the donor-quality situation. They need to understand that the criteria for a safe and effective donor has likely already been found by a patient and is being ignored by the people running the clinical trials, and thus the people running the clinical trials continue to harm patients and prevent a likely cure from becoming available to us.

You need to stop approving funding for FMT clinical trials that do not make a genuine effort to address the donor quality aspect.

I have written directly to the NIH Director (Monica M. Bertagnolli, M.D.) and HHS Secretary (Xavier Becerra) about this, and will now be submitting this to the NIH and HHS Offices for Human Research Protections.

In all my interactions with the FDA, they seem responsive, receptive, courteous, and professional. But I think their decisions and actions in regards to regulating FMT, antibiotics, and clinical trials, are so flawed and harmful. I've continued to send them evidence and arguments. One of their worst policies is making one of the most irrelevant criteria (GMP) the main hurdle/focus instead of the most important one, by far, donor quality.

Relevant links:​


Private vs public:​


If my donors are making people worse, people are going to stop ordering from me and I'd go out of business (assuming proper informed consent and public tracking of results). They're going to say "His donors are bad, he doesn't know what he's doing or is unable to obtain good donors; don't buy from him". Whereas researchers can be as incompetent and apathetic as they want, waste hundreds of millions of dollars of public funding, use whatever low-quality donors that are the easiest for them to obtain, make people worse, and no one bats an eye. They still get paid, continue to get paid, continue to get funded by the NIH and approved by the FDA, and get automatic trust and respect from everyone other than me, and nothing changes.

Publicly funded researchers are overwhelmingly acting like mindless, incompetent, apathetic robots that don't care about patient outcomes. Thus, they need to be treated like such. You shouldn't be trusting them to design and run their own trials. Instead, they should only be trusted to carry out the robotic aspects of someone else's protocol. This appears to be what they've been trained to do, and thus all they're capable of.

So for example, I submit a proposal to the NIH of what I'm trying to accomplish, and why, and the NIH then creates a grant that any research group can apply for to help me carry out my protocol.

I should not be having to do this alone, and even worse now, not at all. I should not be having to spend the winter in my car in D.C. trying to get someone to fix this. I need a team, and the research system needs major reform.
 
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Everything that's happened over the past few months, plus these recent studies [1][2][3], was the catalyst for this post.

And despite all this, they have the audacity to constantly write stuff like: "Don't take things into your own hands; leave everything up to us. We're the only ones competent enough to do this."

Related is the whole Alzheimer's controversy:
 
So for example, I submit a proposal to the NIH of what I'm trying to accomplish, and why, and the NIH then creates a grant that any research group can apply for to help me carry out my protocol
That sounds like a good idea. I'm happy to try to help with that. I don't have any relevant experience though just my own research on the microbiome and FMT. I know one person in academia who has some experience writing grants that I can ask for some advice on the process though.
 

HHS Office for Human Research Protections (OHRP)​

I submitted a complaint via https://oashsps.my.site.com/ohrpwebforms/s/complaint-web-form.

The result: Case closed, we don't care, you have to do a ton of work for us, it's not our job to prevent this harm to patients.


The first response:
Hello,

Thank you for submitting a complaint to the Office for Human Research Protections (OHRP). Based on the information provided, we are unable to determine if this issue falls under our office’s authority. OHRP takes all complaints about seriously. In order to assess this complaint, additional information is required. Please provide the following information:

The name of the researcher(s) for each study

The specific institutions conducting the research

The name of the research project and/or grant proposal

The number of the research project

Source of research funding

The description you provided of the complaint has been included below for reference:

Low-quality donors are being used and thus harming patients and preventing safe and effective FMT from being available as a treatment/cure. Summary & lots of info here: https://forum.humanmicrobiome.info/threads/continued-letters-and-complaints-to-the-fda-nih-and-hhs-jan-2025.842/


For more information about OHRP’s authority and other organizations that might be helpful, please see our website: https://www.hhs.gov/ohrp/compliance-and-reporting/submitting-a-complaint/index.html.
Please note that this complaint will be closed in 90 days if the requested information is not received.

We appreciate your concern for the protection of human research subjects.

Sincerely,

OHRP DCO Team

My reply:
The studies:


These are only recent ones that all used the same bad donor source. But, as noted in the original link I provided, this issue is longstanding and applies to nearly all FMT clinical trials.

The trial (ClinicalTrials.gov identifier: NCT06026371) was conducted at Fred Hutchinson Cancer Center (FHCC)/University of Washington (Seattle, WA) and the study protocol was approved by the institutional review board (protocol #RG1123691; FDA IND #29935). Donor screening, stool testing for infectious agents, and product manufacturing (Compound MTP101-C; FDA IND #15071) were conducted at the University of Minnesota using Good Manufacturing Practices (cGMP) protocols, as described in our previous trial17. The FHCC Data and Safety Monitoring Committee (DSMC) and an independent Data and Safety Monitoring Board (DSMB) monitored the conduct of the study. Enrollment in the run-in phase started on November 1, 2023 and reached target accrual on February 14, 2024. After successful completion of the run-in phase, the randomized phase was initiated on June 12, 2024.

This work was supported by a grant from the Leukemia & Lymphoma Society (Academic Clinical Trials award #ACT9016-24) to A.R. and the National Institutes of Health’s award P30 CA015704 to the Fred Hutch/University of Washington/Seattle Children’s Cancer Consortium

I don't have access to all the studies to check the funding sources & other info for all of them. Eg: https://academic.oup.com/cid/advance-article-abstract/doi/10.1093/cid/ciae467/7756590

Their response:
Hello,

Our office deals with risk to subject in relation to specific studies. You have listed one study, but I would need a list of all HHS funded studies that you are filing a complaint about. Also, OHRP only deals with risk to subject(s). You address this risk as poor donor source, but you will need to explain how you are aware of this for each study, and their specific risk to subject. We will need this information to continue with your complaint.

My reply:
I would need a list of all HHS funded studies that you are filing a complaint about

There's no way I'm taking the time to look through hundreds of FMT studies to see which ones are HHS funded. And that's not particularly useful anyway. I think actions need to be taken to prevent it from continuing to happen, rather than punishment/retribution for instances where it already occurred. Though the latter would also be preventative if it was made public.

OHRP only deals with risk to subject(s). You address this risk as poor donor source, but you will need to explain how you are aware of this for each study, and their specific risk to subject

I detailed that in the first link I shared. To put it simply, nearly any condition can be transferred or cured with FMT:

"In a systematic review, we found that 95% of published studies (36/38) on HMA rodents reported a transfer of pathological phenotypes to recipient animals." (Jan 2020) https://www.cell.com/cell/fulltext/S0092-8674(19)31387-X

And even if a donor doesn't have a major condition, there are other factors like stool type that matter a lot. If a healthy person has type 5 stool (https://www.ecosia.org/search?q=bristol+stool+type) for example, that's a dangerous donor.

I know this based on my experiences with 15+ different donors (https://forum.humanmicrobiome.info/threads/my-detailed-experiences-lessons-from-13-different-fmt-donors-jun-2018.53/), numerous experiences from other people who have done FMT (including some who also used 15+ different donors), one study (https://forum.humanmicrobiome.info/threads/another-email-ive-been-sending-to-researchers-regarding-donor-quality.57/), and a ton of other related evidence (https://humanmicrobiome.info/fmt/#impact-factors + https://www.humanmicrobes.org/blog/the-evidence-and-rationale-supporting-our-donor-criteria).

I created humanmicrobes.org and have screened 1.2 million donors. Nearly all donors from other sources (including these clinical trials) have applied to HMorg and nearly all of them fail to qualify because I'm virtually the only person taking this seriously since I'm a patient who only wants to cure himself; I have no use for risky or dangerous donors.

I published everything publicly and sent it to hundreds of researchers (everyone who had an FMT listing on clinicaltrials.gov), and continue to email them about it.

And even if none of that was the case, the people conducting FMT clinical trials are not even attempting to deduce whether it's the case or not. They are putting in nearly 0 effort or concern in regards to donor quality.

All of this type of info is being completely ignored/neglected: https://forum.humanmicrobiome.info/threads/donor-quality-and-stool-type-hypothesis-for-fmt-fecal-microbiota-trans.142/

It's criminal neglect and needs to be stopped. You should review all the material in the first link I shared with you to understand the situation.

Their response:
OHRP Complaint #00703534 – No Action

Thank you for contacting the Office for Human Research Protections (OHRP). Based on the information you provided, your complaint does not fall under OHRP’s authority. Our office is responsible for the U.S. Department of Health and Human Services (HHS) regulations that protect people in research. Our regulations only apply to research with living individuals, if the research is funded or conducted by HHS. Note that some research may be exempt from the regulations.

OHRP does not have authority over this matter and will not be able to pursue the matter. No additional action will be taken.

For more information about OHRP’s authority and other organizations that might be helpful, please see our website: https://www.hhs.gov/ohrp/compliance-and-reporting/submitting-a-complaint/index.html.
 
Could you try complaining focusing on one specific study where harm was done (for example, the FMT study for C. diff that had to be stopped is a very clear example of patient harm being done, i.e. death) and cite the specific conditions in the donors (if you have info on the donors) that are clear risks that should be added to their poor screening criteria? For example, being overweight, too old, having seasonal allergies. Just thinking of some common conditions they hypothetically might have but are clear indications of a bad donor with direct, scientific links to the microbiome. Or do you think there is any utility someone else (like someone on here) submitting a complaint like that?
 
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