Menu Close

Drugmakers Use Flawed (or Fraudulent?) Generic Drug Trials

Last year, the European Medicines Agency banned about 700 medicines across Europe after an investigation revealed data tampering in some trials of generic drugs in India. The questionable trials were conducted by “contract research organizations” or CROs in India on behalf of major international durgmakers located in other countries around the world.

International medical experts said that volunteers undergoing back-to-back clinical trials endangers the health of patients participating. It can also compromise clinical data gathered through these trials, on the basis of which drugmakers seek approval to sell generic medicines around the world.

“The time gap between participation in two different trials should be 90 days minimum,” said Stephanie Croft, a lead inspector at the WHO. “When [data] is incomplete or incorrect it could pose a serious risk to patients.”

Yet, some of the “volunteers” in India who participate in drug studies for international drugmakers who use Indian CROs are “addicted” to the money and find ways to violate the rules and do not wait the required 90 days between participating in clinical drug trials.

Half of more than a dozen volunteers interviewed by Reuters across four cities – Chennai, Hyderabad, Bengaluru, and New Delhi – said they waited much less than 90 days between trials. In the past three-to-four years, they said they spent several months at a time in different cities so that they could participate in as many studies as possible.

One volunteer, Vasudeva Prakash, a former mechanic, said he was never asked by CROs, and their ‘agents’ who approached him for studies, about whether he had recently taken part in another trial.

“Everybody does it. Once you start getting the money, it’s very hard to quit. It’s like an addiction,” said Prakash.

He said after the first study, he began to regularly receive messages on his phone and Facebook, often from agents working on behalf of CROs, informing him about ongoing clinical trials where volunteers were required. Such messages included three key things: the city where the trial was being conducted, the total pay offered, and the “blood loss”, or the amount of blood the volunteer will need to provide.

Prakash provided Reuters with documentation proving he underwent trials with short gaps at Apotex Research Pvt Ltd, owned by Canadian drugmaker Apotex Inc; Lotus Labs, owned by U.S. generics giant Actavis; Ethics Bio Lab, owned since last year by U.S. drugmaker Par Pharmaceutical Inc; and India’s Semler Research Center Pvt Ltd, among others.

In addition to the questionable status of volunteers, several CROs have been accused of outright data tampering. For example, CRO, Quest Life Sciences, was found last year to have manipulated clinical data on certain trials, according to inspection reports from the WHO and the UK’s medicines authority.

Several large international drugmakers, including Teva Pharmaceutical Industries Ltd and Mylan NV, rely on CROs in India to carry out tests on cheaper versions of branded drugs. The aim of these so-called “bioequivalence” studies is to gauge whether non-branded drugs are equally safe and effective. The faster the trials are undertaken, the faster the drugs can come to market.

In the wake of trial data manipulation scandals at CROs in the past three years, many large drugmakers including Swiss firm Novartis, have been shifting more critical trials back to the United States and Europe, according to consultants and industry executives.

International and local regulators have struggled to keep its oversight in line with the growth of an industry that expanded rapidly in the 2000s, as drugmakers shipped clinical trial work to India to save money. The market is estimated to have crossed $1 billion in 2016, according to consultants Frost and Sullivan.

Are There Compensable Consequences from NSAID Use?

A new study published in the American Journal of Epidemiology and summarized in Ruters Health says that regular use of pain relievers over many years may increase the risk of hearing loss.

Researchers analyzed long-term data on almost 56,000 U.S. women and found using non-steroidal anti-inflammatories (NSAIDS) like naproxen (Aleve) and ibuprofen (Motrin) as well as acetaminophen (Tylenol) for six years or more was tied to a greater risk of hearing problems than taking these drugs for a year or less.

“Hearing loss is extremely common in the United States and can have a profound impact on quality of life,” said senior study author Dr. Gary Curhan, a researcher at Harvard University and Brigham and Women’s Hospital in Boston.

Risks of the painkillers in the study go beyond hearing loss and patients should do their best to avoid long-term use, Curhan added by email.

“Even though these medications are sold without requiring a prescription, they do have potential side effects, one of which is a higher risk of hearing loss; they have also been shown to be associated with a higher risk of hypertension (high blood pressure) and other important medical conditions,” Curhan said.

“They are generally safe when taken in usual doses for short periods of time,” Curhan noted. “However, there should be strong justification for long-term use.”

Women in the study who used NSAIDs at least twice a week for six years or more were 10 percent more likely to report hearing loss than participants who used these drugs for less than one year.

With acetaminophen, regular users for at least six years were 9 percent more likely to report defective hearing than short-term users, researchers report in the American Journal of Epidemiology.

Researchers did not find a statistically meaningful association between hearing loss and the duration of aspirin use.

Aspirin has been linked to ringing in the ears in the past, and Vicodin, a painkiller that contains acetaminophen, has been tied to hearing loss with overuse, noted Dr. Jennifer Derebery of the House Ear Clinic and the University of California, Los Angeles.

Ibuprofen is less commonly recognized by the public as a potential cause of hearing damage, Derebery, who wasn’t involved in the study, said by email.

Previous research has found a similar link between painkillers and hearing loss in men, though studies to date have yet to explain how the drugs might impact hearing, said Dr. Wilko Grolman, a researcher at the University of Utrecht in the Netherlands who wasn’t involved in the study.

However, the study is observational and doesn’t prove these painkillers cause hearing impairment.

“The hearing loss was self-reported and not measured objectively with hearing tests,” Dr. David Haynes, a researcher at Vanderbilt University Medical Center in Nashville who wasn’t involved in the study, said by email.

FDA Issues Medical Device Cybersecurity Guidance

The Food and Drug Administration released its recommendations for how medical device manufacturers should maintain the security of internet-connected devices, even after they’ve entered hospitals, patient homes, or patient bodies.

First issued in draft form last January, this guidance is more than a year in the making. The 30-page document encourages manufacturers to monitor their medical devices and associated software for bugs, and patch any problems that occur. But the recommendations are not legally enforceable – so they’re largely without teeth.

The FDA has been warning the health care industry for years that medical devices are vulnerable to cyberattacks. It’s a legitimate concern: researchers have managed to remotely tamper with devices like defibrillators, pacemakers, and insulin pumps. In 2015, FDA warned hospitals that the Hospira infusion pump, which slowly releases nutrients and medications into a patient’s body, could be accessed and controlled through the hospital’s network. That’s dangerous to patients who could be harmed directly by devices altered to deliver too much or too little medication. It also means poorly secured devices could give hackers access to hospital networks that store patient information – a situation that’s ripe for identity theft.

“In fact, hospital networks experience constant attempts of intrusion and attack, which can pose a threat to patient safety,” says Suzanne Schwartz, the FDA’s associate director for science and strategic partnerships, in a blog post about the new guidelines. “And as hackers become more sophisticated, these cybersecurity risks will evolve.”

The FDA issued an earlier set of recommendations in October 2014, which recommended ways for manufacturers to build cybersecurity protections into medical devices as they’re being designed and developed. The current guidance focuses on how to maintain medical device cybersecurity after devices have left the factory. The guidelines lay out steps for recognizing and addressing ongoing vulnerabilities. And they recommend that manufacturers join together in an Information Sharing and Analysis Organization (ISAO) to share details about security risks and responses as they occur.

Most patches and updates intended to address security vulnerabilities will be considered routine enhancements, which means manufacturers don’t have to alert the FDA every time they issue one. That is, unless someone dies or is seriously harmed because of a bug – then the manufacturer needs to report it. Dangerous bugs identified before they harm or kill anyone won’t have to be reported to the FDA as long as the manufacturer tells customers and device users about the bug within 30 days, fixes it within 60 days, and shares information about the vulnerability with an ISAO.

This attempt to secure medical devices is just the beginning, says Eric Johnson, a cyber security researcher and dean of the Vanderbilt University business school, in an email to The Verge. The FDA’s Schwartz agrees, writing in a blog post: “This is clearly not the end of what FDA will do to address cybersecurity.”

DEA Targets Pharmacies for “Suspicious” Opioid Orders

A drug distributor owned by Cardinal Health Inc has agreed to pay $10 million to resolve claims it failed to alert the U.S. Drug Enforcement Administration to suspiciously large orders of addictive painkillers by New York-area pharmacies.

The settlement with Kinray LLC, a New York City-based pharmaceutical distributor, disclosed in papers filed late Thursday in federal court in Manhattan, comes amid efforts by U.S. authorities to combat the nation’s opioid drug epidemic.

The settlement was secured by the office of Preet Bharara, the U.S. Attorney for the Southern District of New York, who has increasingly turned his sights toward the growing opioid drug epidemic.

The Kinray settlement came after a DEA investigation of pharmacies in New York and elsewhere that had ordered unusually large and frequent shipments of oxycodone or hydrocodone, according to a lawsuit filed earlier this week.

From January 2011 and May 2012, Kinray shipped the drugs to more than 20 New York pharmacy locations in amounts that were many times greater than the distributor’s average sales of controlled substances to all of its customers, the lawsuit said.

Kinray ignored numerous “red flags” and did not report any suspicious orders to the DEA despite requirements that it do so for such highly regulated drugs, the lawsuit said.

The latest agreement stemmed from a 2012 settlement with the DEA in which its facility in Lakeland, Florida, was suspended from selling painkillers and other drugs for two years, according to Cardinal.

The 2012 deal only resolved administrative aspects of the case, not potential fines Cardinal Health faced in Florida or elsewhere. The Dublin, Ohio-based company has set aside $44 million to cover those potential liabilities.

Cardinal Health, which announced its $1.3 billion acquisition of Kinray in 2010, said on Friday it continues to work with the U.S. Justice Department to resolve the matter.

As part of the settlement, Kinray admitted and accepted responsibility for failing to report suspicious orders to the DEA, according to court papers.

The case is U.S. v. Kinray LLC, U.S. District Court, Southern District of New York, No. 16-cv-09767.

New MACI Knee Cartilage Surgery Shortens RTW Time

A new study published in the American Journal of Sports Medicine and summarized in a report by Reuters Health claims that patients receiving a graft of their own knee cartilage cells may be better off returning to full weight bearing after six weeks instead of the standard eight.

Knee surgery patients put on a six-week recovery track were able to get back to work and other activities like sports more quickly, and even reported slightly better results at 24 months than those who had followed an eight-week recovery plan after surgery, researchers report in the American Journal of Sports Medicine.

People with damaged cartilage in their knees can undergo so-called matrix-induced autologous chondrocyte implantation, or MACI, surgery to fix the defects that cause pain and swelling.

In the two-stage MACI surgery, healthy cartilage is collected from unaffected parts of the damaged knee and sent to a lab where it’s used to grow more cartilage on a scaffold-like material. The surgeon then implants this graft into the damaged parts of the knee where it’s expected to integrate with surrounding cartilage.

Standard practice has been to keep weight off the knee for at least eight weeks and up to three months for fear of damaging the delicate new tissue. But there’s evidence that the forces of weight and movement promote growth by the cartilage cells, the authors write, so putting some weight on the implant earlier might help speed recovery of the knee.

“The regimens employed internationally were very conservative in fear of overloading the early repair tissue and jeopardizing the final outcome,” lead author Jay Ebert told Reuters Health by email.

Besides the obvious lifestyle benefits of shorter recovery times, there are clinical benefits as well, said Ebert, of the University of Western Australia in Crawley. Returning to walking more quickly may reduce the amount of muscle lost and the level of joint stiffness after surgery, he said.

To explore whether people could heal as well from surgery if they only kept off of their feet for six weeks instead of eight, the study team recruited 37 MACI surgery patients between 2010 and 2014.

The participants were randomly assigned to an eight-week return to weight-bearing group or an accelerated six-week recovery group.

Overall, the results were good for both groups. There were two cases of graft failure, both in the eight-week recovery group.

The two groups had similar results on all tests of knee function, with the accelerated group performing slightly better. For instance their repaired knees, on average, had returned to 94 percent of the peak strength of the undamaged knee, compared to 88 percent in the eight-week recovery group.

The MRI scans showed the patients in the faster recovery group had significantly better healing on two out of eight visible measures, compared with the eight-week group.

Overall, 83 percent of patients in the eight-week group were satisfied with their surgery, while 88 percent of patients in the six-week group reported being satisfied.

Allstate Targets Fake LA Law Offices

Allstate went before a judge and jury to put an end to the illegal ownership, kickbacks and fraudulent operation of multiple law offices in the Los Angeles area that were owned, operated and controlled by unlicensed people posing as lawyers.

The verdict in a Los Angeles County Superior Court resulted in a judgment worth more than $11.5 million in favor of Allstate.

“Submitting even one false insurance claim is fraud and insurance fraud is a crime,” says Allstate’s Senior Field Vice President Phil Telgenhoff. “Fraud drives up the cost we all pay for insurance by stealing millions of dollars from insurers. This cannot and will not be tolerated in California or anywhere.”

Allstate alleged Christina Chang, Christine Suh and other unlicensed persons knowingly engaged in a fraud scheme in which they used the identity of practicing lawyers to create eight phony or “sham” law offices to make false, fraudulent or misleading claims against insurance companies so that settlement payments could be converted to their own use.

Evidence presented at trial showed that several California lawyers were paid $3,000 per month for the use of their names and law licenses. None of the licensed lawyers had significant direction or control over the operation of the fake law offices or the making and processing of claims.

Chang and Suh rented office space, hired staff, opened firm bank accounts, obtained clients, made demands to insurance companies for settlement and negotiated settlements, all in the name of licensed California attorneys, falsely making it appear as if a lawyer represented the client and claimant.

The evidence also showed Chang and Suh used remote check-cashing facilities including liquor stores and small local markets to convert the settlement proceeds into untraceable cash from deposits into client-trust accounts.

Allstate contended Chang and Suh knowingly concealed the fact that the law offices were owned, operated and controlled by unlicensed persons, all in violation of California’s Insurance Frauds Prevention Act.

“This is one of the first times I’ve seen this elaborate of an effort with setting up fake law offices and trying to defraud the industry,” says Telgenhoff. “We have seen this type of operation before with shady medical clinics across the country, but this takes the scam to a different level. Rest assured, we will fight fraud wherever it lives.”

Is Federal Comp a Lucrative “Luxury” Medical Fraud Target?

Forest Park Medical Center (FPMC) in Dallas and other Texas cities was touted as a “Luxury” hospital with a “spa-like atmosphere,” which did not accept lower-paying Medicare, Medicaid, or “in-network” managed-care insurance rates, but did allow for physician ownership, As such, it rapidly attracted the attention of physician investors and their referrals

The patients were primarily ones with high reimbursing out-of-network private insurance benefits or benefits under certain federally-funded programs. As such, it was free to set its own prices for services and was generally reimbursed at substantially higher rates than in-network providers. FPMC’s strategy was to maximize profit for physician investors by refusing to join the networks of insurance plans for a period of time after its formation, allowing its owners and managers to enrich themselves through out-of-network billing and reimbursement.

But, rather than leave money on the table, FPMC’s owners, managers, and employees also attempted to sell patients with lower reimbursing insurance coverage, namely unwitting Medicare and Medicaid beneficiaries, to other facilities in exchange for cash.

Yet worker’s compensation patients were included in the clientele accepted by this “Luxury” facility. According to the indictment, the hospital accepted the referral of patients with high reimbursing, out-of-network private insurance benefits, and benefits under certain non-Medicare and Medicaid federally-funded programs, such as the Federal Federal Employees’ Compensation Program also known as federal workers compensation.

Included in the 21 professionals indicted this December were Iris Kathleen Forrest, 56, of Dallas who was a worker’s compensation preauthorization specialist who allegedly received approximately $450,000 in bribe and kickback payments in exchange for referring patients, including those she was preauthorizing, to FPMC or to surgeons who performed medical procedures, including surgeries, at the hospital. And Royce Vaughn Bicklein, 44, of San Antonio, Texas was a worker’s compensation lawyer who received approximately $100,000 in bribe and kickback payments in exchange for referring patients, including his clients, to FPMC or to surgeons who performed medical procedures, including surgeries, at the hospital.

Although the typical arrangement in Texas would call for the carve-out of Medicare and Medicaid programs, the intent being to avoid the possibility of running afoul of the Department of Health and Human Services Office of Inspector General, (“HHS OIG”), what many fail to appreciate is the manifold number of federal healthcare programs which could be implicated. Each federal department has its own OIG. Federal worker’s compensation and federal employees health insurance benefits are guarded by the United States Department of Labor OIG. Military plans, or TRICARE, is protected by the Department of Defense OIG.

That’s what initially triggered federal jurisdiction at Forest Park, according to the indictment. The bribes and kickbacks included more than $10 million to TRICARE, more than $25 million to the Department of Labor FECA healthcare program, and more than $60 million to the federal employees’ and retirees’ FEHBP healthcare program. As a result of the bribes, kickbacks, and other inducements, from 2009 to 2013, FPMC allegedly billed such patients’ insurance plans and programs well over half of a billion dollars.

What would be illegal, if the prosecutors can make their case, is the alleged $40 million in bribes and kickbacks paid for referring certain patients to FPMC.

But what is interesting in this very ugly fraud case, is the inclusion of federal workers’ compensation claimants among those who were to be treated at a luxury hospital with a spa like atmosphere that bills at substantially higher rates than in-network providers. The question to be answered for taxpayers is how did this happen in the first place?

New Workplace Safety Laws for 2017

Several new laws affect workplace safety, including a package of bills that took effect June 9, 2016.

AB 1785 reaffirms the general ban on using wireless electronic devices while driving, but amends existing law to authorize drivers to use their hand to activate or deactivate a feature or function of the device with a single swipe or tap, as long as the device is mounted so as not to hinder the driver’s view of the road.

Despite the steady expansion of legislative prohibitions on the use of wireless telephones and electronic wireless communications devices while driving, and the clear dangers of distracted driving, in 2014, the California Court of Appeals for the 5th District ruled that the existing ban only prohibits a driver from holding a wireless telephone while conversing on it. In making its ruling, the court found that the legislative intent in enacting those prohibitions was merely focused on prohibiting a wireless telephone only while carrying on a conversation, not while using it for any other purpose. For that reason, law enforcement agencies find it difficult, if not practicably impossible to enforce the prohibition, as the scope of a mobile device’s functions and its contributions to distracted driving go far beyond simply making and receiving telephone calls.

The new law bans all handheld use of wireless electronic communication devices by the driver of a vehicle during its operation, without reference to the purpose of that use. An exception is provided for windshield-, dashboard-, and center console-mounted devices when the driver can activate or deactivate the feature or function he or she is using with a single swipe or tap and the placement of the mounted device does not hinder the driver’s view of the road. As such, drivers can still engage with their phones in the relatively simple ways that are most similar to other sources of distraction that society has long accepted, such as changing the channel on a car radio.

Four bills (SB-5, SB-7 and AB-5, AB-7) were signed earlier this year that extend the ban on workplace smoking. These rules took effect June 9, 2016.

Specifically AB 7 removes many (but not all) exemptions in existing law that allow tobacco smoking in certain indoor workplaces and expands the prohibition on smoking in a place of employment to include owner-operated businesses. It establishes “smoke-free laws,” which prohibit the smoking of tobacco products in various places, including, but not limited to, school campuses, public buildings, places of employment, apartment buildings, day care facilities, retail food facilities, health facilities, and vehicles when minors are present.

AB 7 prohibits employers from knowingly or intentionally permitting the smoking of tobacco products in an enclosed space at a place of employment. It defines “enclosed space” as including lobbies, lounges, waiting areas, elevators, stairwells, and restrooms that are a structural part of the building and not specifically exempt. It extends the workplace smoking prohibition to include owner-operated businesses in which the owner-operator is the only worker and there are no employees, independent contractors, or volunteers. There are no exemptions for employers of any size.

SB 1167 requires Cal/OSHA to propose a heat-illness and injury prevention standard for indoor workers by Jan. 1, 2019. SB 1167 does not specify what provisions will be included in the new rule or what types of workplaces will be covered – potentially, the new rule could include all indoor workplaces. The law is a result of litigation on this issue.

A recent Occupational Safety and Health Appeals Board (Appeals Board) decision affirms the responsibility of employers to ensure indoor heat illness is addressed through their IIPP. The case stemmed from a 2012 serious citation issued to Tri-State Staffing and warehouse operator National Distribution Center for the heat illness suffered by an employee who was working inside a metal freight container with a temperature of over 100 degrees. DOSH penalized both companies for failing to implement an effective IIPP and both companies appealed the citation winning their case before an administrative law judge (ALJ).

In March 2015, DOSH appealed that decision to the Appeals Board stating that the employers had failed to effectively correct the indoor hazard and had not trained employees on indoor heat exposure. In November 2015, the ALJ’s decision was overturned by the Appeals Board reinforcing the responsibility that employers have to protect the health and safety of their workers, including those working indoors.

Podiatrist Faces 10 Years in Kickback Case

United States Attorney Phillip A. Talbert announced that a federal grand jury returned an 11-count indictment against Anthony Lazzarino, 66, former Chief of Podiatry for the VA’s Northern California Health Care System, and Peter Wong, 58, founder and CEO of Sacramento based Sunrise Shoes and Pedorthic Service, charging them with health care fraud, conspiracy to pay and receive kickbacks on medical referrals, and conspiracy to commit wire fraud.

Lazzarino was a 1982 graduate of Kent State University, College of Podiatric Medicine. Lazzarino began working at the Veterans Health Administration in 2007 with a starting salary of $122,379. California records show his license status as “canceled.”

Sunrise Shoes claims on its website to provide services under most insurance plans, including workers’ compensation, and specifically the State Compensation Insurance Fund.

According to court documents, between March 2008 and February 2015, Lazzarino and Wong engaged in a scheme to defraud the VA by billing the Veterans Health Administration for custom work and services that were prescribed but not supplied in shoes delivered to veterans.

In addition, Lazzarino referred patients directly to Sunrise in violation of VA policy, and agreed with Wong to offer kickbacks in return for such referrals.

Finally, Lazzarino, Wong, and Jai Aing Chen, who separately pleaded guilty on December 6, 2016, agreed to make materially false statements and omissions to the VA regarding where the shoes were manufactured, in the course of applying for an estimated $59 million contract.

This case is the product of an investigation by the Department of Veterans Affairs, Office of Inspector General, the Department of Veterans Affairs Police Service, and the U.S. Immigration and Customs Enforcement’s (ICE) Homeland Security Investigations (HSI). Assistant U.S. Attorney Matthew M. Yelovich is prosecuting the case.

If convicted, Lazzarino and Wong face a maximum statutory penalty of 10 years in prison and a $250,000 fine for each health care fraud count, and five years in prison and a $250,000 fine for each of the two conspiracy counts.

CWCI Finds So. Cal Leads State in CT Claims

A new California Workers’ Compensation Institute (CWCI) study takes a detailed look at cumulative trauma (CT) claims in the California workers’ compensation system, identifies characteristics that differentiate CT claims from non-CT claims, and finds a strong association between attorney involvement and regional variation in the Los Angeles Basin and the high cost of CT claims.

Cumulative traumas are physical or mental injuries that arise over time from repetitive stress, motion, or exposures, rather than from a specific event or accident. Earlier this year, the Workers’ Compensation Insurance Rating Bureau reported that CT claims as a percentage of California workers’ compensation lost time cases had more than doubled over the past decade, climbing to about 18 percent of all indemnity cases in 2015. Because CT claims have become a significant cost driver in the system, CWCI initiated a study to gain a better understanding of where these claims come from, identify characteristics and factors contributing to the rapid growth in CT claims, and to compare average medical and indemnity benefits for CT and non-CT claims.

Using data from its Industry Research Information System (IRIS) database on 41,000 CT claims and 608,000 non-CT claims that received California workers’ comp benefits between 2005 and 2013, the Institute compared the claim characteristics of CT claims to those of non-CT claims, including the workers’ average age, gender, earnings, and job tenure; the mix of claims by employer premium, industry and region; the type and nature of injury; notification lag times; level of attorney involvement; presence of indemnity payments; presence of a compensability dispute; and whether or not the injured worker had filed any additional claims.

Among the key results, the study found that CT cases were far more likely to have come from the Los Angeles Basin; were most prevalent in the manufacturing sector; had a higher proportion of claims involving multiple body parts and mental disorders; had twice the attorney involvement rate of non-CT claims and 53 percent higher average claim costs; and workers claiming CT injuries were 10 times more likely to have claimed other injuries against the same employer.

Overall, nearly 56 percent of all CT claims in the study population were filed in the Los Angeles County/Inland Empire/Orange County region compared to 36.5 percent of non-CT claims.

Limiting the analysis to lost-time cases, the study noted that 91 percent of the CT claims involved an attorney, which was twice the attorney involvement rate for non-CT claims; and while CT claims appeared to have higher medical costs than non-CT claims, that difference disappeared when attorney involvement and region were factored into the equation. This result confirms a strong association between the higher costs of CT claims in the study sample and the high levels of attorney involvement and the regional variation in the L.A. Basin.

CWCI’s analysis of cumulative trauma claims has been published in a Research Note which is available from the Institute’s online store and can be downloaded by CWCI members and subscribers who log in to the Research section of the website.