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2.
Personal communication between author and Alok Srivastava, Head of the Department of Hematology, Christian Medical College, Vellore, India, May 9, 2008.
AgichG. J., “Ethics and Innovation in Medicine,”Journal of Medical Ethics27, no. 5 (2001): 295–296.
7.
LombardoP. A., “A Historical Perspective: The More Things Change, The More They Remain the Same,”Cleveland Clinic Journal of MedicineSupplement 6 (2008): S65–S66.
8.
FreedmanB., “Equipoise and the Ethics of Clinical Research,”New England Journal of Medicine317, no. 3 (1987): 141–145.
9.
CosgroveD. M., “Ethics in Surgical Innovation: Vigorous Discussion Will Foster Future Progress,”Cleveland Clinic Journal of MedicineSupplement 6 (2008): S6.
10.
Id.
11.
KochP., “Emerging Concepts in Neural Stem Cell Research: Autologous Repair and Cell-Based Disease Modeling,”The Lancet Neurology8, no. 9 (2009): 819–829.
12.
Id.
13.
BifflW. L., “Responsible Development and Application of Surgical Innovations: A Position Statement of the Society of University Surgeons,”Journal of American College of Surgeons206, no. 6 (2008): 1204–1209.
14.
This critique also assumes too narrow of a view. Interventions that are not FDA-approved might still be offered overseas, and to shrug off any further discussion of stem cell-based innovative therapies based on current FDA standards would be to advance a U.S.-centric response to the international problem of stem cell tourism, much of which involves American patients traveling abroad. The question of whether and how to regulate stem cell-based innovative therapies is an issue for all countries, not just the U.S. Furthermore, as I argue in this section, the thorny issues raised in this essay cannot be resolved simply by depending on current American regulations.
15.
21 C.F.R. § 312 and § 316 (2009), at 40900.
16.
Id., at 40899 and 40900.
17.
Id., at 40906, my brackets.
18.
Id., at 40921.
19.
DresserR.FraderJ., “Off-Label Prescribing: A Call for Heightened Professional and Government Oversight,”Journal of Law, Medicine & Ethics37, no. 3 (2009): 476–486.
20.
GillickM. R., “Controlling Off-Label Medication Use,”Annals of Internal Medicine150, no. 5 (2009): 344–347.
21.
RadleyD. C., “Off-label Prescribing among Office-Based Physicians,”Archives of Internal Medicine166, no. 9 (2006): 1021–1026.
22.
See DresserFrader, supra note 19.
23.
AnsamiN., “Innovative Off-Label Medication Use,”American Journal of Medical Quality21, no. 4 (2006): 246–254.