Challenges in Psychedelic Medicine – Part One – FDA Rejection of MDMA Therapy

Disclaimer: The views and opinions expressed in this article are those of the authors and do not necessarily reflect the official policy or position of the Chemical Collective or any associated parties.

Introduction

Wellness culture is often centred around healing—from stress, dissatisfaction, trauma, toxic relationships, to poor physical health. It encourages a journey toward betterment, frequently promoting various methods, and often substances purported to provide relief and even lasting transformation. However, focusing solely on the healing aspects of substances or patterns of behaviour can sometimes become counterproductive. When the focus is solely the act of pursuing self-improvement by any means, constantly hunting for the next therapy, or, miracle cure this can potentially exacerbate existing mental health issues, or actively promote negative patterns. This paradox illustrates the recent developments surrounding the use of MDMA-assisted psychotherapy to treat post-traumatic stress disorder (PTSD), particularly the FDA’s rejection of Lykos Therapeutics’ application to approve MDMA for PTSD treatment. 

On August 9, 2024 the Food and Drug Administration (FDA) delivered an unexpected decision that sent ripples through the psychedelic research community. Lykos Therapeutics, a company that had invested years and significant resources into clinical trials for MDMA-assisted psychotherapy, saw its application rejected. This was surprising, given the current ‘psychedelic renaissance’ we find ourselves in, the company’s confidence and the public’s growing expectation. Their latest trial strongly suggested that over 86% of participants experienced a significant reduction in their PTSD symptoms. Not only that, these effects appeared to persist for a prolonged period. However, despite these seemingly promising numbers, the FDA’s decision highlighted deeper issues that warrant a closer examination prior to continuing down this road.

A Promising Solution?

MDMA, commonly known as Ecstasy or Molly, was first synthesised by Merck chemist Anton Köllisch in 1912. It remained relatively obscure but in the 1970s it was (for a very short period) introduced into psychotherapy. It was not until the late 80s/90s that it began to gain mainstream popularity as a recreational drug. MDMA induces feelings of emotional closeness, empathy, and reduced fear, as opposed to the life-changing revelations, powerful visuals and full-blown hallucinations traditionally associated with psychedelics such as psilocybin or LSD. It is these qualities that seem to intuitively suggest it may make an excellent adjunct to psychotherapeutic practice. For those individuals who struggle with PTSD, who are plagued by traumatic memories and flashbacks due to the overwhelming nature of their prior experiences, MDMA-assisted therapy may offer a glimmer of hope.

Clinical trials by organisations like the Multidisciplinary Association for Psychedelic Studies (MAPS) have already begun to show the potential of MDMA in a therapeutic context. At the conclusion of Phase 2 trials studying individuals who had undergone a course of MDMA-assisted therapy, significant numbers no longer met the diagnostic criteria for PTSD. These findings have fueled the optimism that MDMA could completely revolutionise the treatment of PTSD, safely and comfortably. The condition affects millions of people around the world and is often resistant to traditional therapies and medications.

The Risk of the ‘Perfect’ Solution

However, in just the same ways that wellness culture can encourage an unhealthy obsession with self-improvement, the fervour surrounding MDMA therapy may have led to critical oversight. Nothing is ever a ‘perfect’ solution, so, the relentless pursuit of a ‘perfect’ solution will naturally narrow focus. This can lead to studies ignoring potential issues which require more attention and further study. This parallels how individuals in wellness culture might fill their lives with classes, retreats, and positive habits in the name of healing, only to find themselves exhausted and disillusioned.

In the context of Lykos Therapeutics specifically, this may have manifested as an overemphasis on positive outcomes without adequately addressing methodological and ethical concerns. The drive to present MDMA-assisted therapy as a flawless remedy might have overshadowed the need for rigorous scientific scrutiny. The fact that this could, and more than likely was, as a result of financial pressures also cannot be ignored.

The FDA's Concerns

The FDA’s rejection was rooted in significant concerns about the quality and integrity of Lykos’s clinical trials. Shortly after the decision was released, the journal Psychopharmacology retracted three papers related to MDMA research, citing ‘unethical conduct.’ Allegations emerged about misconduct by an unlicensed therapist at one of the trial sites. Several authors of these retracted papers were affiliated with Lykos, deepening the controversy.

The FDA’s apprehensions centred on several key issues:

1. Study Design Flaws: The trials had small sample sizes and high dropout rates, undermining the reliability of the results. Approximately 40% of participants had prior experience with MDMA, potentially biassing outcomes due to their expectations. The lack of diversity among participants also raised questions about the generalisability of the findings.
2. Blinding Challenges: Maintaining a double-blind study is crucial for eliminating bias. However, the noticeable effects of MDMA made it difficult for participants and researchers to remain unaware of who received the active drug or placebo. This compromised the integrity of the study’s design.
3. Researcher Bias: Some researchers were open about their personal use of psychedelics, raising questions about objectivity. Personal beliefs and experiences might unconsciously influence study conduct and data interpretation. This is akin to a therapist projecting their own experiences onto a patient, potentially skewing the therapeutic process.
4. Ethical Violations: Reports of unethical behaviour, including inappropriate actions by a therapist, compromised the integrity of the research and violated patient trust. Such misconduct not only harms participants but also undermines public confidence in the therapeutic potential of psychedelics.

Insufficient Monitoring of Adverse Effects: The lack of thorough monitoring for adverse events was concerning, especially given the powerful nature of psychoactive substances like MDMA. Side effects such as increased heart rate, blood pressure, and psychological distress require careful assessment and management.

Excessive Self-Focus Hinders Progress

The situation with Lykos Therapeutics reflects a broader issue within wellness culture: excessive self-focus can hinder genuine progress. When individuals or organisations become too absorbed in their pursuits, they may overlook the importance of external factors and collaborative efforts. In wellness culture, this manifests as an emphasis on individual responsibility for healing, often ignoring systemic and societal issues that contribute to mental health struggles.

Similarly, the push for MDMA therapy may have neglected the broader context of mental health treatment, and of the drug itself. Once individuals or companies focus solely on a singular solution this can lead to the dismissal of other potentially valuable or synergistic therapies. Healing isn’t just about alleviating symptoms; it is about enhancing lasting overall well-being. This includes social connections, self-sufficiency, community support, and addressing systemic issues.

The Placebo Effect and Patient Suggestibility

Interpreting psychedelic research is further complicated by the power of the placebo effect. Not only that, the fact that individuals under the influence are highly susceptible to suggestion and outside influence is also a compounding issue. Psychedelics can make patients more open to new ideas during therapy, meaning the therapist’s influence and the therapeutic environment play significant roles in outcomes. Studies have shown that patients receiving placebos in psychedelic trials often report notable improvements. The fact that often these improvements sometimes rival those who received the active drug should give us pause. Is it in fact the substance itself having the positive effects, or is it the situation and context in which it is being administered.

Are the benefits observed due to the pharmacological effects of MDMA, or are they a result of the combination of therapeutic context and patient expectations?

The enhanced suggestibility during MDMA sessions can lead to profound experiences, but these may not always translate into long-term improvements. There is significant risk here of spiritual bypassing, which means you use altered states to avoid addressing deeper, underlying issues, whilst convincing yourself in the moment that you are experiencing something revelatory and lasting.

Avoidance and Ethical Oversights

Just as an obsession with wellness can lead to avoidance of deep healing, the focus on MDMA’s potential benefits may have caused researchers to sidestep crucial ethical considerations. The allegations of misconduct and insufficient monitoring of adverse effects suggest a neglect of patient safety in favour of simply promoting positive outcomes. This mirrors how wellness culture’s emphasis on individual healing can sometimes overlook the importance of professional guidance and evidence-based practices.

In both cases, there’s a tendency to reject conventional methods in favour of alternative approaches without fully understanding the implications of these approaches. While scepticism of traditional treatments can be healthy, it becomes problematic when it leads to the dismissal of valuable expertise and safeguards.

Implications for the Future of Psychedelic Medicine

The FDA’s rejection of Lykos’s application has significant implications for psychedelic medicine as a whole.

It underscores the urgent need for rigorous scientific methods, ethical integrity, and a clear separation between personal beliefs and professional responsibilities.

The enthusiasm for psychedelics must be balanced with caution and a commitment to evidence-based practices. The fact that all of this research requires capital to complete is going to place stresses and strains on those purporting to be testing potentially life-altering therapies. This further compounds the risk of, and motivation toward either ignoring or underselling any negative discoveries, and emphasising or exaggerating any genuine benefits.

The risks of this are not limited to specific studies. These substances are just beginning to reach a point where they are accepted culturally as potential solutions. If we rush into applying them in contexts in which we are unsure of the outcome we risk tarnishing the field of study as a whole. 

For years, advocates have championed substances like MDMA as the future of mental health treatment, especially for conditions resistant to conventional therapies. The FDA’s decision introduces greater uncertainty, prompting a reevaluation of research practices and ethical standards within the psychedelic community. It also serves as a reminder that shortcuts cannot be taken at the expense of patient safety and data integrity.

Rebuilding Trust

Moving forward, addressing the concerns highlighted by the FDA is essential:

1. Improving Study Designs: Future trials need to rectify methodological issues. Larger sample sizes, increased diversity among participants, and strategies to maintain blinding are crucial. Using active placebos that mimic some effects of MDMA without therapeutic benefits can help mitigate bias.
2. Strengthening Ethical Oversight: Robust protocols must protect participants from misconduct. This involves thorough vetting of therapists, clear professional boundaries, and effective mechanisms for reporting and addressing ethical violations. Independent ethics committees should oversee trials to ensure compliance.
3. Ensuring Objectivity: Researchers should maintain objectivity by setting aside personal experiences and focusing on empirical evidence. Disclosing potential conflicts of interest is crucial, and independent oversight can help mitigate biases. Peer review processes should be rigorous and transparent.
4. Transparent Communication: Sharing all data openly, whether positive or negative, fosters trust and collective learning. Pre-registering trials and publishing results in peer-reviewed journals, regardless of outcomes, are vital practices. This transparency helps build credibility and advances the field responsibly.

Collaborating with Regulatory Bodies: Engaging constructively with organisations like the FDA can help align research efforts with regulatory expectations. Open dialogue can address concerns proactively, ensuring that treatments meet safety and efficacy standards.

A Holistic Approach

As discussed, wellness culture often neglects the social aspects which affect healing. Our interconnectedness and the impact of societal factors on mental health. Similarly, psychedelic research must consider the broader context of mental health treatment. Incorporating a holistic approach means recognising that:

Psychedelics are not a magic bullet.

They can be valuable tools within a comprehensive treatment plan that includes therapy, support networks, and addressing the underlying societal factors which affect treatment. Individual trauma, inequality, and even access to any adequate care at all must be a priority when considering the viability of any potential therapy. Just as wellness culture needs to move beyond individualism to be truly effective, psychedelic medicine must move towards a multifaceted strategy for mental health care.

The Role of Community and Connection

Healing is fundamentally relational. Our well-being is deeply tied to our connections with others, our environment, and our sense of purpose. Wellness practices that isolate individuals or emphasise self-reliance to the exclusion of community can exacerbate feelings of disconnection.

In the context of psychedelic therapy, integrating communal and relational aspects could enhance outcomes. Group therapy sessions, community support groups, and involving loved ones in the healing process may provide additional layers of support. This aligns with traditional uses of psychedelics in indigenous cultures, where communal rituals play a central role.

Addressing Systemic Issues

Mental health cannot be separated from its societal context. Factors such as economic instability, discrimination, and social injustice contribute to psychological distress.

Focusing solely on individual treatment without addressing these systemic issues limits the potential for genuine healing.

Advocating for policy changes, increasing access to mental health services, and promoting social equity are essential components of a holistic approach. Researchers and practitioners in the psychedelic field have an opportunity to contribute to these broader efforts, recognising that individual well-being and collective well-being are entirely interrelated.

Conclusion

The potential of psychedelics to transform mental health treatment remains significant and should not be undersold. An increasing number of studies covering a wide range of substances are showing promising results.

However, realising this potential requires a grounded, methodical, and ethically sound approach.

The FDA’s rejection of Lykos Therapeutics’ application serves as a stark reminder that enthusiasm, and motivation to bring a product or service to market must be matched with adequate scientific rigour and ethical responsibility.

Addressing the shortcomings in MDMA research isn’t just about meeting regulatory requirements, it is about honouring the trust of patients and the broader community. By embracing rigorous methodologies, strengthening ethical oversight, and fostering transparent communication between researchers and regulatory bodies, the psychedelic research community can rebuild credibility and contribute valuable tools to mental health care.

Healing is a complex journey that cannot be rushed or oversimplified.

Just as an obsession with wellness can inadvertently hinder personal growth, overlooking essential scientific and ethical practices can impede advancements in psychedelic medicine. The path forward may be challenging, but with diligence and a commitment to safety and individual needs, the hope for new, effective treatments can become a reality for those who need them most.

Wellness culture and psychedelic medicine share the common goal of alleviating suffering and enhancing well-being. Both must navigate the delicate balance between innovation and responsibility. By learning from recent setbacks and integrating holistic, ethical, and community-oriented approaches, we can move toward a future where healing is accessible, effective, and truly transformative.

David Blackbourn | Community Blogger at Chemical Collective

David is one of our community bloggers here at Chemical Collective. If you’re interested in joining our blogging team and getting paid to write about subjects you’re passionate about, please reach out to David via email at blog@chemical-collective.com