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Riding the Policy Roller Coaster in 2017: A Policy Update with Dr. Tim Franson (Ep. 13 of The Pharmcast)

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We are at a time of great change and transition in the FDA. The sitting FDA chief stepped down, just when the 21st Century Cures Act passed into law; PDUFA 6 is up for renewal this year; and the new administration has signaled hiring freezes for government agencies, including the FDA.

While many of the policy and leadership changes in 2017 may not appear to make a day-to-day impact on drug developers at first, these changes can in fact have a profound impact. 

To help us understand how 21st Century Cures, PDUFA 6, and leadership changes can affect your development plans, we sit down with Dr. Tim Franson, who is not only YourEncore's Chief Medical Officer, but also Chairman of the Board  for The Critical Path Institute, the Immediate Past-President for the USP, and a key contributor to the last few PDUFAs.


Working with the FDA: Developing a Regulatory Strategy That Works (Ep. 14 of The Pharmcast)

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On this week's episode of The Pharmcast, we explore the key elements of an effective regulatory strategy and how to drive value to patient and shareholders by working with the FDA. We also cover common ways agency decisions can destroy value if not done properly.

Dr. Tim Franson and Dr. Joe Lamendola recently gave a presentation to a group of private equity and venture capital funds to outline the importance of regulatory strategy for small biopharma companies.

The Future is Here: Using Big Data and Artificial Intelligence in Oncology (Ep. 15 of The Pharmcast)

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On this week's episode of The Pharmcast, we talk with YourEncore Expert, Philippe Barzin, on the future of big data and artificial intelligence in oncology. Based off Philippe's article, Artificial Intelligence Fighting Cancer and Transforming Public Health, we talk with Philippe on five ways artificial intelligence will transform oncology treatment, and how biopharma companies can start adopting these tools to improve performance.

7 Best Practices in Biologics Launch Communications (Ep. 16 of The Pharmcast)

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On this episode of The Pharmcast, Heidi Youngkin shares seven best practices for successful biologic launch communication.

When it costs over $2.5B dollars to develop a drug, according to the most recent Tufts study, the pressure to have a successful launch is great.  Throw in that the industry is facing tighter scrutiny on pricing and value, that the science of biologics is getting more nuanced, and that there is more competition for the patients' or prescribers' time, and the world of launch communications is getting much more complex.

To help make sense of it all, join us this week as Heidi shares her seven-point formula for successful biologic launch communication.

Welcome to the Real World: A Reality Check for Digital Health with Dr. Ron Razmi (Ep. 17 of The Pharmcast)

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This week on The Pharmcast, we tackle one of the hottest topics in the life sciences and healthcare industry: digital health. The promise of digital health is enticing, and a logical evolution of the digital economy. However, some of the early euphoria is waning as the demands of implementation, application and ROI are becoming more important, and in some cases - more elusive. 

So what is the current state of digital health for life sciences? What're some of the obstacles life sciences companies have to overcome to drive adoption? And what're some of the most promising applications of digital health for the life science companies? These are all questions we discuss with this week's guest, Dr. Ron Razmi. 

YourEncore Announces Addition of Michelle DeJonge and Dr. James Wood as Strategic Advisors for Medical Devices & Diagnostics Practice

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INDIANAPOLIS, IN--YourEncore (www.yourencore.com), a company that helps firms in the life sciences, consumer products and food sciences industries solve complex innovation, compliance and productivity challenges, announced that both Michelle DeJonge and James (Jimmy) Wood, M.D., have joined the company as Strategic Advisors for YourEncore’s Medical Devices & Diagnostics practice.

YourEncore recognizes the importance of providing cross-functional expertise for their clients, and focuses on nurturing a network of Experts rich in technical and strategic expertise.

DeJonge has an extensive background in Supply Chain and Operations leadership, which will be extremely valuable to medical devices companies. With a career spanning more than 30 years in supply chain and manufacturing for medical devices, pharmaceutical, and CPG  companies, she is the former VP of the Office of Strategy & Execution for Johnson & Johnson Supply Chain, where she was responsible for managing supply chain and operations across all segments of the organization, with a primary focus in the Medical Devices & Diagnostics division.

"I am excited to bring 30+ years of supply chain experience in solving complex challenges the medical device industry is facing. Now, more than ever, is the need for customer focused solutions in assuring continuity of quality products and services throughout the globe,” says DeJonge on her decision to join YourEncore.

The Frontiers of Rare Disease Development: Advances in Regulatory Science with Dr. Tim Franson (Ep. 18 of The Pharmcast)

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This week on The Pharmcast, we catch up with Dr. Tim Franson to discuss the leading edge of rare disease drug development. Dr. Franson has been actively helping Parent Project Muscular Dystrophy, a Duchenne Muscular Dystrophy Patient Advocacy group, which is doing pioneering work collaborating with FDA to inform benefit-risk and establish FDA guidance.

Duchenne has been a great test case, so we sat down with Tim to share his lessons learned and understand what’s happening on the frontiers of rare disease drug development.

State of the Industry: U.S. Regulatory Policy Improvements (Ep. 19 of The Pharmcast)

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In this episode of The Pharmcast, we share a recording from our May 5th webinar, State of the Industry: U.S. Regulatory Policy Overview. Parthenon-EY and YourEncore recently conducted a nationwide survey of life sciences experts to query them on recent market trends, uncover their points of view on potential regulations, refine their current business models and gain insights into what discovery efforts might yield better results. With all the rhetoric surrounding the drug industry from political, news and personal channels, we wanted to know what “those who know” think of various ways to improve the system.

We asked 10 simple questions, soliciting input from more than 50 past and present industry executives and Experts from pharmaceutical, consulting and pharmacy backgrounds. What we heard was informative, provocative and in some cases unsurprising — but important to consider. 


Ten Tips for Enterprise Technology Adoption in Pharma

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The RFP processes are robust, the ROI models are compelling, the software is best of breed, and the expectations are high. So, why do so many software deployment programs in Pharma fail to deliver their intended benefits?

This often is because after all of the effort, money, and time that is spent, the technology itself is poorly used. This may be due to any combination of misconfiguration, poor training, misaligned processes, human stubbornness, or other factors, but it doesn’t have to be that way. To this end, adoption must be a central component of planning for your next software deployment project.

How Blockchain is Revolutionizing the World and Changing Healthcare as We Know It (Ep. 20 of The Pharmcast)

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In this episode of The Pharmcast, we join YourEncore Expert, Darryl Glover, to discuss one of the hottest technologies on the market today: blockchain.

We've heard some people say that if the internet was invented today, it would be built using blockchain. So, what exactly is blockchain, and how exactly can it revolutionize the world and change the healthcare industry as we know it? 

Darryl Glover is just the person to ask. Darryl is a YourEncore Expert, and the Chief Clinical Officer and co-founder of iSolve, focused on applying blockchain-based solutions to pharma-industry problems.

 

Transparency vs. Smoke and Mirrors: Clinical Trials Debate

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The debate around clinical trial transparency is certainly nothing new. But is the answer, as some call for, "more transparency and oversight?"

I say it’s just not that simple.

As the former senior government official in charge of clinicaltrials.gov, I think it’s important to look at the facts – and the numbers.  When it comes to the clinical trial looking glass, smart transparency must replace the smoke and mirrors currently in vogue.

Read my full article in the The Morning Consult, where I ask key questions and examine critical issues surrounding the debate. 

Peter J. Pitts. Executive Partner for YourEncore, President - Center for Medicines in the Public Interest, Former FDA Associate Commissioner.

Watch the Regulatory Convergence & Divergence Expert Panel Discussion

6 Must-Ask Questions Before Adding New Biomarkers to Your Clinical Trial Protocols

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During my 18 years at a major pharmaceutical company I initiated and managed the introduction of many new technologies into both pre-clinical and clinical project teams. One of my greatest challenges was translating new biomarker discoveries into assays that could be used successfully to support clinical trials.

Discovery of new clinical biomarkers is occurring at a furious pace, which is encouraging to both drug developers and patients hoping to shorten clinical study and approval timelines. However, qualification of these new biomarkers has just begun and, while the FDA has recently outlined a proscriptive qualification process, it is unclear what biomarkers will ultimately receive regulatory approval (or how long it will take).

So, you may find yourself in the situation where you are aware of a new biomarker that could be a significant improvement over existing assays used to support clinical trials but the data to support that contention is not yet available. Under these circumstances, what is the best way to proceed?

I recommend you answer the following six questions before adding a new biomarker to your clinical trial protocol:

  1.  How will the new biomarkers be used? Using novel biomarkers for a late stage project is hard to justify, both from the standpoint of use in decision-making and high likely cost for a large trial. By comparison, including a new biomarker in an early stage project with a small number of subjects that will only be used to guide internal company decisions would be expected to be both low risk and relatively low cost.

  2. What commercial assays are available for the selected biomarker(s) and how extensive is the assay validation? If no commercially available assay is available, add at least a year to your project timeline so the assay can be developed and validated.

  3. What human biological samples will be available and what matrix should be measured (urine, serum, plasma)? Many biomarker programs rise and fall on the availability and quality of samples.

  4. What steps have been taken towards biomarker qualification and what is needed? If the desired biomarker is truly novel and ultimately expected to be used in support of regulatory filings, plan for a long timeline.

  5. What is known about the biological variability of the chosen biomarker in the general population and/or the trial population? A biomarker that is highly variable in the trial population could require very large sample sizes to obtain meaningful results.

  6. What will be the cost of the new biomarker assay? Current assays for safety monitoring, for example, can sometimes cost a dollar or less. By comparison, a new assay can be a hundred-fold higher so it would be wise to be prepared to defend the budget.

These are just a few of the important questions to answer before introducing a new biomarker into a clinical trial protocol. In my next post, I’ll describe some important practical steps for getting a new biomarker program off the ground.

Stephen T. Furlong, Ph.D., Former Discovery Medicine Director and Safety Science Lead at AstraZeneca, Current Principal at Better Biomarkers and YourEncore Expert

Watch the Regulatory Convergence & Divergence Expert Panel Discussion

YourEncore Insights Greatest Hits of 2015

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Billboard recently released its “Hot 100 Songs of 2015,” and it inspired me to think about YourEncore Insights' list of greatest hits. For those playing along at home, “Uptown Funk!” by Mark Ronson and  featuring Bruno Mars won top honors from Billboard.

While Bruno Mars is not a part of the YourEncore expert network, we are humbled to have our own rock stars as 2015 YourEncore Insights contributors, who include:

  • Former FDA Associate Commissioners and Deputy Commissioners
  • Presidents of the US Pharmacopeial, Regulatory Affairs Professional Society, and Critical Path Institute
  • VPs of Development, Regulatory Affairs, Global Patient Safety, and Medical Affairs for large pharma companies
  • Founding President and CEO of Parent Project Muscular Dystrophy
Even though we just formed this band in August, we’ve been on tour, developed a following, and produced some interesting work.  To quote Bruno, “Don’t believe me, just watch (or read on) - Hay!”

Here are our most popular Insights of 2015:

The response we've seen from our readers indicates an appetite for more. That's why in 2016, we are adding more rock star contributors, expanding our tour dates, and spending more time in the studio to produce more work. It should be an exciting year.

Let us know what topics and conversations you want to see our experts address in 2016. Contact us here or leave a comment below.

Subscribe to YourEncore Insights

FDA and NBCDs: Do Not Pass GAO

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GAO Asked to Assess Viability of FDA’s Complex Generics Pathway

The FDA has begun approving generic versions of non-biologic complex drugs (NBCDs) using the same regulatory approval pathway used for small molecule drugs. However, the House Energy & Commerce Committee is asking the Government Accountability Office (GAO) to evaluate if this approach is sufficient.

Specifically, the committee sent a letter on December 10 asking the GAO to assess whether generic versions of NBCDs that are not fully characterized present challenges in meeting generic approval standards.

If the agency concludes that meeting approval standards presents challenges, the House Energy & Commerce Committee has asked GAO to make recommendations based on five key areas, which I outline in my full article on DrugWonks.com.

Peter J. Pitts. Executive Partner for YourEncore, President - Center for Medicines in the Public Interest, Former FDA Associate Commissioner.

Watch the Regulatory Convergence & Divergence Expert Panel Discussion

 

Regulatory R.A.N.T. - Biomarkers, Pediatrics, Benefit-Risk - Oh my!

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To protect sustainable innovation, it is vital to look beyond present conditions and develop proactive interventions for anticipated environmental changes. With development times for new biomedical medicines and devices now spanning years (and sometimes over a decade), regular audits (at least yearly) are essential in recognizing and adapting to key "climate changes."

Given the importance of both identifying new trends and their impact on the development and commercialization of every product and process, YourEncore gathered an eclectic entourage of experts with deep experience in regulatory and industry leadership after the recent RAPS meeting in Baltimore. We call these sessions R.A.N.T.s - Relevant Assessments, New Trends.  We turned the panel discussion into a white paper, full of insider insights on the changing face of biomarkers, pediatric studies and benefit-risk, all of which are integral factors in development planning that exist in a state of constant flux.

The discussion is particularly timely if you've read the FDA's recently released 2016 Guidance Agenda.  We trust you will find this material useful in preparing for the upcoming guidance season as well as informing your product/portfolio management and regulatory strategies.

Download the white paper now. 

The YourEncore expert panel includes:

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Tim Franson, M.D. (Moderator) – the Chief Medical Officer for YourEncore, Board Member for the Critical Path Institute, and Immediate Past President of the USP Convention.

Martha Brumfield, Ph.D. – is the incoming President of the RAPS Board and President and Chief Executive Officer of the Critical Path Institute.

Stephen P. Spielberg, M.D., Ph.D.– a YourEncore senior advisor, former FDA Deputy Commissioner for Medical Products & Tobacco, Dean of Dartmouth Medical School, and Editor-in-Chief of the Drug Information Association’s (DIA) journal, Therapeutic Innovation and Regulatory Science.

Peter J. Pitts– a YourEncore Executive Partner, former FDA Associate Commissioner, current Chief Regulatory Officer for Adherent Health Strategies and Founder/President of the Center for Medicine in the Public Interest.

Don Therasse, M.D.– a YourEncore Executive Partner, former VP, Global Patient Safety and Global Medical Affairs at Lilly. He led Lilly’s pharmacovigilance organization and established Lilly’s global medical affairs, benefit-risk assessment and bioethics organizations.

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A Biotech’s Guide to FDA’s 2016 Agenda

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It is often said that the FDA loves ambiguity – because it gives the agency unlimited authority.  As a former regulator, I know that’s true. However, what’s more important to the men and women of the FDA is to be an innovation accelerator. And that means the agency has to lead through … clarity.

That wish is apparent when you study the FDA’s recently released 2016 Guidance Agenda, which outlines what the agency views as its top priorities for 2016.

The document is worth perusing in its entirety, but to save you some time, I have assembled what I view as some of the more interesting items for biotechs to watch.

The Debate Over Off-label Communication

Manufacturer Communications Regarding Unapproved, Unlicensed, or Uncleared Uses of Approved, Licensed, or Cleared Human Drugs, Biologics, Animal Drugs and Medical Devices.

Why should this be of interest to the biotech industry? Well, if you have a product on the market or under development that has applications beyond its (current or potential) FDA label – you should be paying very close attention.

The New Gold Standard

Adaptive Design Clinical Trials for Drugs and Biologics; Revised Draft

Meta-Analysis of Randomized Controlled Clinical Trials to Evaluate the Safety of Human Drugs or Biologic Products

Multiple Endpoints in Clinical Trials

Let’s face it. Big, expensive randomized clinical trials may have been the gold standard for 20th-century blockbusters, but in today’s world of precision medicine, genomics presents many opportunities for smaller, more adaptive protocols. And that can potentially mean smaller, subpopulation trials. Sound interesting?

For the Biosimilar Brotherhood, Three Things to Consider

Considerations in Demonstrating Interchangeability With a Reference Product

Labeling for Biosimilar Products

Statistical Approaches to Evaluation of Analytical Similarity Data to Support a Demonstration of Biosimilarity

Now that we’re living in a world with US biosimilars for filgrastim and infliximab, how will the agency’s thinking on issues ranging from extrapolation to post-market surveillance evolve?  And what will this mean for both innovators and biosimilar manufacturers? Market-share is waiting.

The Evolution of Discussing Risk Information

Presenting Risk Information in Prescription Drugs and Medical Devices Promotion; Revised Draft

Postmarketing Safety Reporting for Human Drugs and Biological Products Including Vaccines

What you say can and will be held against you – and what you don’t say may cause you even more problems. Since the FDA formed its new Super Office of Pharmaceutical Quality, post-marketing safety and surveillance are taking on a far more robust place in the regulatory spectrum. Are you ready?

What’s on CDER’s list is interesting … as well as what is not.

2016 is going to be an exciting year.

Let’s talk.

Peter J. Pitts  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

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From Snake Oil to Fish Oil: The Need for a New Approach to Off-Label Communication

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As you well know, off label communications is on my short list of regulatory policy and public health issues that keep me up at night.  

Why?  There is a leadership vacuum on the topic, and absent clear leadership, federal judges are starting to dictate regulatory policy through the Amarin case and others.  If existing policy has evolved to protect the public from snake oil, the recent Amarin decision is precarious precedent for communications about fish oil – and beyond.   

To help find better solutions to this important issue, on February 18th the new Duke-Margolis Center for Health Policy held a conference titled, “Off Label Communication in 2016: Meeting Information Needs through New Policy Options.”

Those new options are detailed in an important new paper:
Policy Options for Off-Label Communication: Supporting Better Information, Better Evidence, and Better Care

I am honored to be one of the co-authors and to have had the opportunity to speak at the event. 

Just about every speaker pointed to the need for FDA leadership though bold action and … clarity.  The paper lays out what we refer to as Guiding Principles for Lasting Solutions. They are:

  • Promote well-informed clinical decision-making to improve public health.
  • Support FDA’s central role in reviewing, approving, and enforcing efficacy claims.
  • Reduce inconsistencies across agencies’ enforcement decision-making.
  • Avoid continued cycles of litigation through greater policy clarity.
  • Promote more evidence development and data submission to FDA.

You can read a more detailed analysis on DrugWonks.com, detailing the recommendations we laid out in the paper.

Nature abhors a vacuum. All of the participants in the conference and all the authors of the white paper were in complete agreement that absent strong and forward-looking FDA leadership, the off-label debate will result in public health chaos.

Peter J. Pitts  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

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FDA's Abuse-Deterrent Commissioner

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Yesterday the FDA Science Board discussed the agency’s approach to opioids.

FDA presenters included agency point-man Doug Throckmorton (Deputy Director for Regulatory Programs, CDER), Janet Woodcock (Director, CDER), Sharon Hertz (Division Director, Division of Anesthesiology, Analgesia and Addiction Products), Gerald Dal Pan (Director, Office of Surveillance and Epidemiology) – and newly confirmed FDA Commissioner Rob Califf.

Califf was there at the beginning of the meeting (expected) and stayed through the entire length of the day-long affair (unexpected). An important signal that he intends to be a hands-on leader.

I was chosen to speak during the open public comment part of the hearing, and spoke about using real-world information to provide providers and patients with information beyond the limited world of pivotal trials. Here are my brief remarks:

Former Canadian Prime Minister Pierre Trudeau once said, “There's no place for the state in the bedrooms of the nation.“ But what’s the appropriate place for the state in examination rooms, pharmacies and medicine chests – particularly for opioids? There is no such thing as a medicine that is 100% abuse-proof. The only abuse-proof medicine is one that is never prescribed – and for the tens of millions of Americans suffering from chronic pain that isn’t a viable option.

Advancing the manufacturing science of abuse deterrence is an important step in the right direction. According to the Journal of Pain, in a real-world study, abuse by snorting, smoking, and injecting prescription opioids declined by 66% after the reformulation of a drug with abuse deterrent properties. And the New England Journal of Medicine reported that a new formulation decreased abuse from 35.6% of respondents to 12.8% in 21 months. But cutting the Gordian Knot of abuse means more than advancing the science of abuse deterrence. It means working with the providers of Continuing Medical Education to develop better curricula. It means more targeted Risk Evaluation and Mitigation Strategies. It means enhanced and validated reporting tools for post-marketing surveillance. And it means using real world data to provide real world advice. It means using that data for better social science tools that can assist prescribers in determining which patients are likely to abuse.

“Abuse deterrence” isn’t just a formulation question – it’s a systems question.

What about the issues surrounding opioid misuse – at present the poor public health stepchild of abuse? And how can better physician education defer or deter the prevalent “opioids first” prescribing philosophy of many practitioners? 

In the U.S., the use of opioids as first-line treatment for chronic pain conditions follows neither label indications or guideline recommendations. 52% of patients diagnosed with osteoarthritis receive an opioid pain medicine as first line treatment as do 43% of patients diagnosed with fibromyalgia and 42% of patients with diabetic peripheral neuropathy.

Payers often implement barriers to the use of branded, on-label non-opioid medicines, relegating these treatments to second line options – along with new abuse-deterrent opioid formulations. The result is a gateway to abuse and addiction.

Various pieces of state legislation are trying to correct this, but there has to be a better way.

The FDA can play an important role in working to develop and share (with a broad constituency) validated tools for physicians to use in determining which patients may be more prone to slide into abuse so they can choose their therapeutic recommendations more precisely.

The FDA has announced labeling changes and post-market study requirements for opioids, and the agency has signaled interest in using real world outcomes data to amend and update labeling. That’s not regulatory mission creep; it’s the appropriate application of the agency’s Safe Use of Drugs initiative. The way you make a drug “safer” is to ensure that it is prescribed to the right patient and used in the proper manner.  

A logical next step is to utilize that real world data to amend product-specific abuse-deterrent labeling to indicate lessons learned outside of the rarified world of the randomized clinical trial environment to assist physicians in using the right product for the right patient. Such changes mark important steps in highlighting the value of individualized patient pain-management programs.  

Abuse-deterrent technologies are an important step in the right direction. They are part of the solution, but they’re not the whole solution.  

It’s important to remember that the vast majority of people who use opioids do so legally and safely. In fact, government statistics show that 78.5% of those who abuse prescription pain medication did not obtain the drugs from a doctor in the first place.  

Abuse deterrence is a worthy goal and will only evolve when all the players work together in a more regular and synchronistic fashion. As the Japanese proverb goes, “Don’t fix the blame, fix the problem.”

The original article first appeared on drugwonks.com and is reposted here with permission from the author.

Peter J. Pitts  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

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FDA Advisory Committee Mistakes to Avoid

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Advisory Committee meetings are an incredibly intense and high stakes endeavor within the drug development process. Millions in R&D costs, potential revenue, and patients served can come down to an eight hour meeting. When the FDA ultimately sides with the Advisory Committee’s recommendation approximately 85% of the time, these meetings have to go well.

Over the course of my 25+ year regulatory career, I’ve participated in numerous Advisory Committee meetings across a variety of therapeutic areas. Some went smoothly, and others didn’t. In my experience, when things don’t go well, it’s usually because of three main problems.

1. Lack of Preparation


There is no such thing as over preparing. I cannot emphasize this point enough. Teams should begin serious preparation four to six months in advance. What does this look like? 

Teams must know every benefit and potential risk in their application and prepare for every question or issue that could possibly arise from the panel and committee members. You might have your presentation and narrative laid out,  but the committee can take the discussion wherever they want.  Prepare for these detours by outlining likely Q&A, conducting mock panels, and polishing slides and backups.

To answer all these questions, it's also important to gather the appropriate expert team. I would commonly have a core team comprising the moderator, clinical experts, and clinical safety experts. I would also have about a dozen other experts in the bull pen.  Come prepared to demonstrate that the team has thought of everything: plans to address weaknesses, lifecycle studies, future development plans, and safety of the drug in the marketplace, etc.

2. Lack of Credibility


You need to show the Advisory Committee that you are the world’s top authority on the disease and therapy. How do you do that? First, know your data better than anyone else. Know its strengths and its flaws inside and out.

Second, you must be transparent about the flaws – and it’s okay to have some flaws. It’s a fatal mistake, however, to take a defensive posture and not proactively address these problems head-on. Also, never be dismissive of a safety question – another fatal mistake. Take them seriously and demonstrate that you have thoroughly considered them. Hiding vulnerabilities that eventually are discovered erodes your credibility. Once an FDA reviewer loses trust in you, the review process becomes more difficult. 

Third, pick your moderator very carefully. His or her presence at the microphone is an opportunity to set the tone of scientific credibility. The moderator must understand the quality of the data and be able to triage questions to the appropriate team member, who can articulate benefits, risks, and the science behind it.

3. Lack of Communication


Avoid surprises at all cost. How? Through good communication. Throughout the entire review process, a good regulatory professional and FDA project manager will stay in constant contact to make sure no surprises come up. There are opportunities throughout the review process to communicate and align with the FDA. Take advantage of all of them.

Through proper communication, you can establish a good working relationship and alignment with the FDA before the meeting.

Parting Advice for the Big Day.

Whether this is your first AdComm Meeting or your 21st, remember that there is nothing more important than scientific credibility.

Be thorough. Be transparent. Be proactive.

Joe Lamendola, Ph.D. is the Senior Vice President of YourEncore's Regulatory Practice and the former Vice President of U.S. Regulatory Affairs at Bristol-Myers Squibb, where he was responsible for 20+ approvals across 10+ therapeutic areas.

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Roundtable: Driving Down Healthcare Costs

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Everybody wants to lower healthcare costs, but nobody agrees on the best way to do so. And what about those pesky unintended consequences?

I was asked by Healthcare Sales & Marketing Magazine to lead a panel of three experts on this timely/thorny topic. My co-conspirators include Ben Locwin (President, Healthcare Science Advisors), Bill Soucie (Vice President of Market Access at Xenoport), and Matt Wallach (Co-Founder and President, Veeva Systems).

As the lead-in to the the panel says, "Something needs to be done."

Read the full article to hear the panel’s take on the causes and possible cures for rising healthcare costs.

Download the full article Roundtable: Driving Down Healthcare Costs


Peter J. Pitts
  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

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Understanding and Maximizing Interactions with the Califf FDA

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image source: fda.gov

Does it really matter who sits in the corner office at the FDA?

Isn’t PDUFA VI already a done deal?

Can one person really change the direction of an agency that is almost entirely staffed by career civil servants?

Why bother with a new Commissioner with only one year left in the Administration?

These are all good questions, and the right answers depend on specifically who is leading the FDA.  Thanks to his recent confirmation, we now know that man is Dr. Robert Califf.

For some answers, insights, and prognostications to the questions above, I sat down with Dr. Tim Franson, Chief Medical Officer of YourEncore, to discuss what industry can expect and how to maximize future FDA interactions. 

Listen to the 40 minute discussion.  It’ll be 40-minutes well spent.

Peter J. Pitts  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

webinar understanding and maximizing the Califf FDA watch the recording Franson Pitts headshots

FDA Gets Out In Front on Single Source Problem

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National Public Radio’s Marketplace program reports:

The Food and Drug Administration recently said it’s going to prioritize any generic drug application when there’s currently just one manufacturer.

Here’s why:

At the University of Utah Healthcare, pharmacist Erin Fox said in about a year, the heart medication Isuprel went from $50 a dose to $1800 after Valeant purchased the drug.

She said they had always stocked on crash carts.

“Basically, it’s the kind of [drug] you might see on TV, code blue, cardiac arrest, everyone is rushing around,” she said. It’s the kind of medication that can save a life, she said.

But at $1800 a dose, it got pulled off the carts, only to be used in extreme emergencies. This is what happens when a company has a lock on a given drug.

Some estimate there are 500 generic drugs – for everything from cancer, to multiple sclerosis to heart disease – that currently have virtual monopolies. And companies like Valeant and Turing have taken advantage.

“This is a good circumstance of the FDA actually getting out in front of a problem before it becomes serious,” said Peter Pitts, a former associate FDA Commissioner. “I think this is a program that’s going to have significant impact.”

Pitts said cutting the application process from 2-3 years to as short as six months will help clamp down on some of the price gouging. The FDA says it has 125 current submissions for drug approvals that will be expedited. 

Former industry CEO George Zorich wondered if that’s enough of an incentive.

“If I’m a manufacturer, I’m hard pressed just to drop everything without some discussion from the FDA and some real frank discussions with the [FDA],"  he said.

Some major generic manufacturers – and the industry trade group - declined interview requests. In statements, several simply said competition is important.

Perhaps an indication that speeding up the FDA process is just one step needed to drive more competition.

Listen to the NPR story here.

My conversation with the reporter also included the issues related with inadequate CMS reimbursement policies as a cause for single source products – but it didn’t make it into the brief radio report.

We need to focus on the perverse economic incentives of Average Sales Price (ASP) as a key factor behind the problem.

We need legislation to deal with:

Price Stability— Change the Medicare reimbursement rate for generic injectable products with 4 or fewer active manufacturers from Average Sales Price (ASP) + 6% to Wholesale Acquisition Cost (WAC) in order to achieve market price stability.

Medicaid/340B Rebate Exemption— Exempt generic injectable products with 4 or fewer active manufacturers from Medicaid rebates and 340B discounts in order to achieve market price stability.

The FDA has done its part. Now it’s time for Congress to step up to the plate.

See more at: drugwonks.com

Peter J. Pitts  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

watch the recording - alternative regulatory pathways - franson and lamendola

 


Transparency Isn't a One-Way Proposition

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Transparency in medicine isn't a one-way street.

The transparent truth is that the prices patients actually pay aren't set by drug manufacturers — they're determined by pharmacy benefit managers, insurers, hospitals and pharmacies.

A majority of Americans believe increased health care transparency should be a top national priority. It's easy to understand why. Rising health care costs, coupled with high-profile stories of price-gouging at some small pharmaceutical companies, have left consumers feeling ripped off, especially when it comes to drug prices.

But most drug companies aren't whimsically increasing prices. In fact, if the health care industry was really transparent, people could see the truth: drug companies often aren't the culprits behind high costs. In fact, they're the best hope for dramatically lowering health care spending.

The transparent truth is that the prices patients actually pay aren't set by drug manufacturers — they're determined by pharmacy benefit managers, insurers, hospitals and pharmacies.

And these third parties frequently engage in … price-gouging.

Consider the "prescription price shell game" uncovered in Minneapolis, where a local CVS jacked up the price of a kidney medication to more than $6 per pill from 87 cents. Or the Levine Cancer Institute in North Carolina, which collected nearly $4,500 for a colon cancer drug that hospitals typically buy for $60.

Unfortunately, the media largely ignores such abuses, preferring to concentrate just on alleged misbehavior or greed by pharmaceutical companies. When one drug maker released a breakthrough Hepatitis C cure, headline after headline blasted the company for the drug's initial $84,000 price tag.

Few follow-up stories have noted that, because of competition from other drug makers, the manufacturer granted such big discounts — often in excess of 50 percent — that the medicine now costs less in the United States than in price-controlled Europe.

Even fewer stories put America's health care spending in perspective. Name-brand drugs accounted for just 7 percent of $100 billion increase in health care spending from 2013 to 2014.

That 7 percent accounts for some of the most promising advances in treatment in decades. By addressing once-untreatable symptoms and complications, these advances help patients avoid expensive surgeries and lengthy hospital stays — which account for a far larger share of health care spending than pharmaceuticals do.

Journalists crying page one crocodile tears over high drug costs aren't just ignoring hospitals' and insurers' roles in jacking up retail prices. They're ignoring the fact that massive decreases in health care spending will only come about due to pharmaceutical cures. Better MRI machines are not going to end the scourge of cancer. New drugs could — and do.

Of course, medicines aren't cheap to create. The average cost of developing an FDA-approved prescription medication is $2.6 billion, according to the Tufts Center for the Study of Drug Development. That represents a 145 percent increase over the past decade.

For every successful new compound, hundreds of others once deemed promising end up abandoned. Research chemists at pharmaceutical companies may spend an entire career in the lab without working on a single drug that gets to market.

Understandably, pharmaceutical companies don't love to publicize their frequent failures. As a result, everyday Americans only see the successful, profitable drugs — and the high price tags that stem from the cost of research plus the markups tacked on by third parties.

Consumers are justifiably mad about health care costs. But their anger is misdirected. If the health care industry was truly transparent, Americans would see who's really to blame for rising prices. With rare exception, it's not the companies creating lifesaving medicines.

Reposted with permission from drugwonks.com.

Peter J. Pitts  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

 

 webinar understanding and maximizing the Califf FDA watch the recording Franson Pitts headshots

Alternative Regulatory Pathways for Rare Disease: Breaking the ICE

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There is a heightened sense of urgency by all stakeholders to accelerate development of therapies for rare disease.  The FDA shares this urgency, but it also must protect the public safety and follow the well-defined laws and regulations governing the process.

The challenge (or opportunity) is to develop creative approaches, which accelerate access and stay within the regulatory boundaries – or find ways to shape the boundaries.  Intermediate Clinical Endpoints, or ICE, could represent one such approach. 

I sat down with Dr. Joe Lamendola on April 7th to discuss this approach, and you can listen/watch the full converation below

You can download the slides for your referience, and leave a comment below if you have questions.  I hope you enjoy.

 

 watch the recording - alternative regulatory pathways - franson and lamendola

[Recording] EU Medical Device Regulation Presentation

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How has your company been preparing for EU MDR?

Minnie Baylor-Henry and Jon Lange discussed this topic during one of our most well attended webinars last month. If you missed the live event, you can now watch the recorded presentation below.

 

This presentation by leaders from YourEncore and Ernst & Young included in-depth content and insights. One section of the presentation included a list of basic questions to start assessing risk:

  • What proportion of our portfolio’s are implicated by the restrictive substance changes?
  • Will we have extensive Clinical Investigations to be conducted for our high risk devices?
  • How does UDI under MDR/IVDR differ from the US UDI solution?
  • How does language specific labelling impact packaging design ?
  • Will the current ‘artwork’ process be capable of handling the MDR/IVDR labelling complexity?
  • Can current processes handle the anticipated volume of complaints and questions  from the authorities?
  • What level of change do we have in our technical files?
  • How many of our products have up to date PMS plans?
  • How will our re-certification plans be impacted in the transition period?
  • Do we need to align with our NB’s on how the new MDR/IVDR will be assessed?
  • Is our QMS up-to-date and able to deal with all the changes?
  • Which companies will revise their business model?
  • What new market strategies will be developed by competitors?
  • Which companies will withdraw products from the market?
  • To what extent is incremental innovation still adding business value when compliance costs increase? Is a more radical approach more profitable?

Don't miss out! Click here to view the last webinar session. 

 

[Watch] No Surprises: Improving Medical Devices Due Diligence

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Donna Godward and Dr. Janet Vargo recently presented a lunch briefing on improving medical devices due diligence.

Acquiring and selling innovative medical devices or diagnostics is standard business for small and large device companies – but doing it well is not standard business.

In this session, Donna Godward and Dr. Janet Vargo discussed the areas often overlooked in due diligence efforts that can lead to expensive or even show-stopper surprises once the acquisition is complete and later development and commercial efforts are underway. Understanding what to look for (or present) during due diligence will reduce risks and lead to a better evaluation for the transaction. 

"Watch No Surprises - Improving Medical Device Due Diligence"

   

innFusion a better brainstorming and problem solving approach

Getting Real World About Outcomes Data

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I’ve just returned from a cold, blustery and wet London where I attended the annual Pharma Access Leaders Forum.

But the meeting was hot.

In fact, piping hot when you consider the tectonic changes being felt in the world of healthcare technology assessment (HTA) and their implications on both patient access and innovation. And the linkages couldn’t be more profound.

Wither HTA in the EU? A key red thread through a series of potent discussions was real world evidence (aka, “outcomes data”). Head honcho HTA officials from across Europe (including England and Scotland – both still in Europe as of last report) returned again and again to the value of outcomes not just for the evolving world of Risk Sharing Agreements, but for the acceleration of reimbursement science.

Reimbursement science? In July 2012, when Sir Michael Rawlins was chairman of NICE, he told the House of Commons that value, “is based on the collective judgment of the health economists we have approached across the country."

"It is," Sir Michael said, "elusive."

When it comes to HTA – the times they are a-changin’.

One key insight came from Finn Børlum Kristensen, Chairman of the Executive Committee, European Network for HTA (EUnetHTA), who reminded the conference of JM Eisenberg’s advice, “Globalize the evidence, localize the decision.”

Just as we’ve finally come to realize the urgency of regulatory science (adaptive clinical pathways, imaging, bioinformatics, biomarker validation, 21st century bioequivalence, etc.) to the future of healthcare, so too must we understand and encourage the development of reimbursement science. And high up on the list of items to consider is the validity and utility of outcomes data. We’ve come a long way from the 2007 NICE/Velcade risk-sharing arrangement. Today the stakes are higher and the battle has ratcheted up to a higher level.

When it comes to reimbursement science, we are still in early days. For example, while many HTA bodies in Europe have moved beyond accepting evidence exclusively “the old fashioned way” (via the traditional RCT “gold standard”), there are exceptions – such as Germany. As Detlef Parow (Head of Care Management at DAK-Gesundheit) pointed out, IQWiG will only look at outcomes data “only in exceptional cases.” (This is in keeping with the IQWiG “Principle of Prohibition,” where “Everything is forbidden if it is not expressly permitted.”)

The always-insightful Francois Meyer (Advisor to the President, Director of International Affairs for HAS — France’s Haute Autorité de Santé) wisely suggested more formal early dialogues on scientific advice – similar to the regulatory science initiatives that drive the conversations between FDA and innovators. This would give HTA bodies the opportunity to identify key issues and receive draft company positions, discuss divergent views and try to reach consensus before any final submissions or decisions are made. Sometimes the most common-sense recommendations are the toughest to implement.

But, as with FDA and the advancement of regulatory science, much depends on willingness and ability to implement based on infrastructure, capabilities, and trust. The end goal is the same for all stakeholders – ensuring optimal use of resources for healthcare systems; improving access to value-adding medicines for patients; and appropriate reward for innovation.

In a 2009 white paper, I wrote, “We need to develop proposals that modernize the information used in the evaluation of the value of treatments. Just as the key scientific insights guiding the FDA Critical Path program are genetic variations and biomedical informatics that predict and inform individual responses to treatment, we must establish a science-based process that incorporates the knowledge and tools of personalized medicine in reimbursement decisions: true evidence-based, patient-centric medicine.”

Today, right now, we need a Critical Path for Healthcare Technology Assessment to begin the process of developing a similar list of ways new discoveries and tools (such as electronic patient records) can be used to improve the predictive and prospective nature of clinical outcomes. In an era of personalized medicine, one-size-fits-all treatments and reimbursement strategies are dangerously outdated. Accepting real world evidence does not mean discarding the randomized “gold standard” – it means augmenting it.

It’s a complicated proposition—but such a goal is as simple as it is essential – cost must never be allowed to trump care, and short-term savings must not be allowed to trump long-term outcomes. Just as we need new and better tools for drug development, so too do we need them for HTA.

A health technology assessment model for the 21st Century should reflect and measure individual response to treatment based on the combination of genetic, clinical, and demographic factors that indicate what keep people healthy, improve their health, and prevent disease. A rapidly aging society demands a new healthcare paradigm capable of providing for its needs in the 21st Century. Equality of care must be matched with quality of care.

This article originally appeared on Morning Consult and is shared here with permission.

Peter J. Pitts  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

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If Brexit, Whither EMA?

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If Brexit, whither EMA?

Will Great Britain become like Norway and Iceland, attending committees such as the CHMP, where their views and votes are not of the same standing as those of members of the EU, or choose to follow a different route? There’s a lot at stake for the future of the MHRA and the British public health.

But what about the impact of removing MHRA expertise from EMA?
According to “Perplexit,” by BioCentury’s Steve Usdin, there’s a lot for EMA to worry about. “Since the start of EMA, MHRA has been a major supplier of resources and scientific expertise,” former EMA Executive Director Thomas Lönngren told BioCentury.

Of the 3,678 scientific experts listed in an EMA database, 281, or 8%, are from the U.K. “Taking a leading role in providing scientific and regulatory advice at the European level is a position the agency is familiar with and has maintained this year,” MHRA stated in its 2015 annual report. The U.K. drug regulator noted that in 2014-15 it was given 166 appointments to coordinate CHMP Scientific Advice Working Parties, a figure which represented “the highest number of any member state and reflects the high regard in which the agency’s scientific and regulatory expertise is held.”

MHRA also continued to “have the highest number of rapporteur/corapporteur appointments in Europe” in 2014-15. The agency said the workload is an acknowledgement of the “widely respected knowledge of the MHRA and its assessment processes.”

Since EMA’s creation, MHRA officials have served as rapporteurs for 16.5% of CHMP assessments and as co-rapporteurs for 10% of assessments.
MHRA experts have played a major role in pharmacovigilance assessments, serving as rapporteurs or co-rapporteurs for 29% of Pharmacovigilance Risk Assessment Committee (PRAC) safety investigations.

In addition to leading assessments of applications submitted under EMA’s centralized procedure, the U.K. and MHRA are a top choice for companies using the decentralized procedure to obtain marketing authorizations in several EU countries.

Applicants can select a reference member state (RMS) for decentralized authorizations. In 2014-15 the U.K. “remained the preferred RMS responsible for leading on 195 (45%) of all procedures in which the U.K. was involved,” according to the MHRA annual report.

The U.K. agency has taken a leading position in developing EMA regulatory policies, BioIndustry Association CEO Steve Bates told BioCentury. He cited initiatives to revamp the clinical trials directive into a regulation that will facilitate multisite, multinational trials, EMA’s policies on advanced therapies such as gene and cellular therapies, and the PRIority MEdicines (PRIME) initiative, EMA’s version of FDA’s breakthrough therapies program.

Whatever arrangement is negotiated, a Brexit will likely force EMA and its 890 employees to leave its base in London’s Canary Wharf. EMA employs 60 British nationals, and about 10% of its management positions are held by Brits.
 
With EMA moving to the continent, and MHRA’s loss of status within EMA, will pharmaceutical companies to move their regulatory hubs out of the U.K. To do otherwise, according to Grant Castle, a partner in the London office of the law firm Covington & Burling, “would be like having European marketing authorizations maintained by staff in the U.S., Switzerland or Japan.”
 
Warsaw here we come?

Real World Evidence: Times They Are a (Slowly) Changin'

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Per the FDA’s PDUFA VI "commitment letter," the agency will face some real world deadlines to advance the use of real world evidence. But, since we’re dealing with the real world, let’s get real – guidance is unlikely until the end of 2022 at the earliest. (That's the timeline agreed to via the PDUFA VI negotiations.)

Step One towards these new 21st century rules of the regulatory road will be a series of public meetings and regulatory workshops. It will be curious to see who shows up at the table.

PDUFA VI User fees will support agency policy development in the area, and FDA has pledged to meet the following benchmarks:

  • End of FY 2018 – Convene one or more public workshops with key stakeholders, including patients, biopharmaceutical companies, and academia, to gather input into issues related to real world evidence (RWE) use in regulatory decision-making.

  • End of FY 2019 – Initiate (or fund by contract) appropriate activities (e.g., pilot studies or methodology development projects) aimed at addressing key outstanding concerns and considerations in the use of RWE for regulatory decision-making.

  • End of FY 2021 – Publish draft guidance on how RWE can contribute to the assessment of safety and effectiveness in regulatory submissions, for example in the approval of new supplemental indications and for the fulfillment of post-marketing commitments and requirements. FDA will work toward the goal of publishing a revised draft or final guidance within 18 months after the close of the public comment period.

Ground Zero for a real-world evidence regulatory pathway will be Sentinel, the existing public/private program aimed that uses a variety of databases to track, collect and analyze adverse event reports about drugs, vaccines and medical devices.

Medtech Valuation Killers

Modeled after successful programs such as the Centers for Disease Control and Prevention’s Vaccine Safety Datalink, Sentinel allows FDA to conduct safety surveillance by actively querying diverse data sources, primarily administrative and insurance claims databases but also data from electronic health record (EHR) systems, to evaluate possible medical product safety issues quickly and securely.

Sentinel, mandated under the Food and Drug Administration Amendments Act (FDAAA), will get a $50m boost over five years under PDUFA VI. Sentinel currently has information on over 100 million patients.

Similarly, efforts are underway to establish a National Device Evaluation System (NDES). As currently envisioned, the NDES would be established through strategic alliances and shared governance. The system would build upon and leverage information from electronic real-world data sources, such as data gathered through routine clinical practice in device registries, claims data, and EHRs, with linkages activated among specific data sources as appropriate to address specific questions.

As FDA Commissioner Rob Califf and Deputy Commissioner Rachel Sherman recently commented:

"Creating knowledge requires the application of proven analytical methods and techniques to biomedical data in order to produce reliable conclusions … There must be a common approach to how data is presented, reported and analyzed and strict methods for ensuring patient privacy and data security… Rules of engagement must be transparent and developed through a process that builds consensus across the relevant ecosystem and its stakeholders … To ensure support across a diverse ecosystem that often includes competing priorities and incentives, the system’s output must be intended for the public good and be readily accessible to all stakeholders."

When it comes to the regulatory science of real world evidence, we are still in early days, but the times they are a changin.’ (And you better start swimmin' or you'll sink like a stone.)

This article originally appeared on DrugWonks.com and is shared here with permission.

Peter J. Pitts  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

 Medtech Valuation Killers


Embracing Satan's PDUFA

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Monday’s public meeting on the FDA’s PDUFA VI Commitment Letter was a love-fest (mostly) – but as Theresa Mullin, Director of CDER’s Office of Strategic Programs, wisely noted, “the devil is in the details." Indeed.

The meeting was in three panels: Pre-Market Review and Post-Market Safety, Regulatory Decision Tools, and Administrative Enhancements.

A few highlights and comments.

Register for Aug 23 Lunch Briefing: 9 Biotech Value Killers - Daniels, Therasse


Opening up the day, CDER Director Dr. Janet Woodcock commented that, since the introduction of the first PDUFA in 1993, “It’s a brave new world.” That’s certainly true, but some have been braver than others. As Aldous Huxley wrote in his novel, A Brave New World, “Most human beings have an almost infinite capacity for taking things for granted.”

Janet (and later on others) spoke about PDUFA VI building a Patient-Focused Drug Development (PFDD) “Bridge.” In other words, moving from holding meetings to developing “fit-for-purpose tools to better reflect the benefit/risk calculus of patients.” A key point, via Janet, is that by doing this the FDA will not be the PFDD “bottleneck." The devil is in the details.

She also pointed to a fully operational and funded Sentinel as a linchpin not just for advancing safety specifically pharmacovigilance more broadly, but also for accelerating the ecosystem of Real World Evidence. RWE was a major focus of the meeting. More to follow. Albeit to say – the devil is in the details.

The factoid of the day was that in FY2015 (to date), the FDA has held over 3000 PDUFA meeting requests. Don’t even bother doing the math, because that doesn’t include the intense meeting preparation division staff must undertake prior to any actual face-to-face (or teleconference) encounters. This is a highly significant statistic insofar as there was much discussion on enhancing sponsor-agency communications. Is more always better? It depends. As Walter Gropius said, “Less is more. But more tastes better.” Communications must now be more about quality than quantity but, from a PDUFA perspective, how can that be measured?

In a small but important improvement, the FDA will provide 72-hour notice to all manufacturers whose products will appear in the quarterly FDAAA-mandated Public Notification of Emerging Postmarket Medical Device Signals (921 Safety Notices).

Per Sentinel, it was mentioned a number of times (including on an FDA slide) that it will be used to “inform important regulatory decisions.” Does this mean Sentinel data will be used “beyond risk” to also “inform” FDA thinking on potential new benefits? Will Sentinel become a tool for validating Real World Evidence? That was not discussed – but maybe it’s time for it to be put on the table, perhaps at one of the RWE meetings promised in the agency’s commitment letter.

As promised, the FDA will publish an updated version of its Structured Approach to Benefit/Risk Assessment in Drug Regulatory Decision-Making. It’s been an arduous journey. It’s important to remember that the key tenet of the PDUFA philosophy isn’t speed, but predictability, and the ability to understand regulatory decision-making (and, ultimately reproducibility) is crucial. This is important for many reasons, not the least of which are the ever-increasing costs of drug development.

There was (Finally! At last!) much discussion about “staff capacity.” Not just more, but better. Not just quantity, but quality. One specific conversation focused on the need for better reviewer understanding of and training in adaptive clinical trial design models. Let’s face it, there aren’t a lot of people inside the FDA considered expert in (among other things) Bayesian statistical design. Better MAPPS and SOPPS (Manual of Policies & Procedures, Standard Operating Policies & Procedures), that were promised, and they will help. There have to be internal rules of the 21st century regulatory road as well as external guidance but – the devil is in the details.

Some positive forward motion on biomarker prequalification. Among other things, the FDA will create a website listing the biomarkers it’s working on. Per the FDA presentation, this is designed to help stimulate further development. It’s a start and more needs to be done. (More, always more! But without the internal expertise, how is the FDA to parse its expert resources?) Maybe it’s time for a more serious discussion of intramural cooperation. FDA needs adequate resources – beyond PDUFA funding -- to provide advice and oversee review and decision-making. One solution is to partner with an external entity (an Intramural Biomarker Consortium-IBC) to develop early advice and serve as an expert sounding board for nascent biomarker efforts. The IBC could be a required or voluntary resource in the review process, especially for initial data package reviews. This approach would allow FDA staff to focus on their primary role of product review and regulatory oversight.

PDUFA is an important path, but it isn’t the only one.

All present (FDA staff, patient groups, industry representatives) were very excited about the opportunities of PFDD next steps and Real World Evidence. But how to get there? As BIO’s Kay Holcombe said, “We cannot put anecdotes on the drug label.” Real World Evidence is the new star on the precision medicine horizon. But the tool set for using this treasure trove of healthcare information is nascent and the tasks as are daunting as the opportunities. Patient passion is important to share. When combined with data and a more dispassionate understanding of regulatory paradigms, a patient-driven pathway can and must evolve into a tool used to impact regulatory decision-making. The devil is in the details.

The most decidedly unsexy but most honest and important part of the meeting came last – a discussion of “administrative enhancements” including electronic submissions and data standard activities, hiring capacity, and financial management. It’s important to note that PDUFA VI is the first time that “hiring capacity” has been directly addressed – and it’s about time. The FDA must have the firepower to not only retain but to aggressively recruit the best and the brightest. Again, it’s not just about body count (quantity) but quality. Quality is not what you put in. It’s what you get out. “Staff capacity” means more (a lot more) than PDUFA-measurable hiring numbers. We need a PDUFA quality metric.

In the immortal words of Admiral Hyman Rickover, “The devil is in the details, but so is salvation."

Register for Aug 23 Lunch Briefing: 9 Biotech Value Killers - Daniels, Therasse

 

This article originally appeared on DrugWonks.com and is shared here with permission.

Peter J. Pitts  is an authority on global regulatory policy issues and an Executive Partner at YourEncore. He is a former FDA Associate Commissioner, the Chief Regulatory Officer for Adherent Health Strategies, and the President of the Center for Medicine in the Public Interest, a policy institute he founded in 2004.

FDA 483 Response: Four Tips to Avoid a Warning Letter

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The receipt of a 483 at the conclusion of a facility inspection notifies a company of conditions the FDA believes are in violation of the Food, Drug & Cosmetic Act. If 483s are not properly addressed, the FDA can take further enforcement action to protect the public health – including issuing Warning Letters. Warning Letters not only indicate potential risks to patients, but also bring unwanted publicity, erode patient trust, and potentially restrict the approval of future products significantly impacting revenue. Therefore, companies must know how to mount a competent response.

In a recent webinar hosted by YourEncore, we outlined four steps medical devices companies can take after receiving a 483 to successfully allay FDA concerns and prevent further enforcement actions.

  1. Understand the process. Once an inspection takes place and deficiencies are found by the FDA, a Form 483 is issued. It is important to respond to the FDA within 15 days to ensure that the FDA considers your response before taking further enforcement action. The response should detail how the company is addressing the FDA concerns and specifically how these problems will be avoided in the future.  How these issues are addressed will determine whether or not the FDA will take additional action.

  2. Address and avoid common problems. Deficiencies tend to fall into three main areas: insufficient complaint handling, poor Corrective and Preventative Action (CAPA) procedures, and deficient Critical to Quality (CTQ) control in the supply chain. In a follow-up inspection, the FDA will look for data to prove that the company has found and fixed deficiencies, so they won’t happen again.

  3. Provide competent responses. A good response must convey a sense of urgency to address the problem. Lay out a specific plan with action items, dates and commitments. The timetable should provide scientific justifications. The plan also should include a commitment to allocate the necessary resources to make the needed corrections. This includes not just addressing the individual item listed by FDA, but also larger systemic issues. Outline a commitment to long-term quality and speak about changes as enhancements to existing policies and procedures.

  4. Speak to issues. The most important thing in communicating with FDA is to show why the problem won’t reoccur, so document the root cause and corrective action. Speak to the specific concerns of FDA. FDA wants to know exactly what’s being done and who is doing it. Clearly document the situation, include specifics, and explain how the corrective action will address the problem. 

Regulatory inspections are required as part of FDA oversight of medical device companies. Knowing how to handle 483s quickly and thoroughly can have a major impact on the success of your company.

To listen to the FDA 483 Response Best Practices webinar, click here. To talk with a YourEncore expert who can guide you through the FDA process, contact Mary Ellen Schipp (Maryellen.Schipp@yourencore.com).

About Victor Chance:Mr. Chance is a Strategic Advisor and member of YourEncore’s Medical Devices Practice. Previously, he was the Vice President of External Operations and Chief Supply Chain Chief Procurement Officer for J&J Medical Devices and Diagnostics, and he also served as Worldwide Vice President of Operations for J&J’s Cordis franchise.

About Judith Meritz, J.D.:Ms. Meritz is a Strategic Advisor and member of YourEncore’s Medical Devices Practice. Previously, she was the Associate General Counsel at Covidien/Medtronic and specializes in compliance counseling concerning FDA and other international regulatory authority matters including inspections, enforcement actions, product approval strategies, marketing and advertising programs, and complaint handling.

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Drug Pricing – What’s the Answer to High Cost Off-Patent Medicines?

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In the wake of the Turing, Valeant, and Mylan EpiPen pricing controversies, YourEncore Insights coordinated a conversation with two top experts to discuss potential solutions to some drug pricing dilemmas.  I interviewed Peter J. Pitts, former FDA Associate Commissioner and President of the Center for Medicine in the Public Interest, and Dr. Tim Franson, YourEncore’s Chief Medical Officer and former VP of Global Regulatory Affairs for Eli Lilly and Company.

The transcript is provided below: 

Combs:  In the U.S. there is a lot of news and attention being brought to Mylan recently with their EpiPen pricing, which has increased 500% to 600% in the last eight years according to sources.  Many are calling for price control, including politicians, but Peter Pitts, what say you? 

Pitts:  The right answer is to drive competition.  Competition is what lowers prices.  And in the U.S. when it comes to generic drugs and devices, it lowers prices quite significantly.  When you have a product like EpiPen that has been off patent for a while but has no generic competition for a number of reasons, the company is free to price the product however they see fit.  So I think it’s an opportunity for the FDA to put senior resources against applications, like Teva’s, that introduce competition to Mylan’s EpiPen, while ensuring they’re brought to market safely and effectively and lower cost.  At the end of the day, minus competition you’re not going to really have any on prices, whether it’s generic or on-patent competition within the same therapeutic category.

Combs:  Is there anything specifically FDA could do to help foster competition, particularly as it relates to high quality generics?

Pitts:  Yes. Last March, Rob Califf, the FDA commissioner, said the agency was going to prioritize generic applications for products that don’t currently have generic competition, from two to three years to six months.  That’s something the FDA said a couple of months ago, and the Mylan thing happened subsequent, so I would hope the FDA is beginning, with its new GDUFA funding, to really get serious about that.  But, you can’t just push the button and have things change; these things are a process.  It’s also important for people to understand that when products don’t come to the market as quickly as they’d like, or if they don’t come to the market at all, it’s not necessarily the FDA’s fault.  There are lots of things that go on that aren’t seen by the public, because some information is confidential, proprietary to the company.  If the company wants to share it, that would be permitted, and I think they probably should answer some questions.  But at the end of the day, the best thing the FDA can do is really work with companies to help them solve problems and get these products to the market as quickly as they can.

Combs: To your point around FDA involvement, with any organization there are resource constraints, and the FDA is no different.  There’s always more needs than there are people, so where does high-quality generics fit into the broader to-do list of the FDA? 

Pitts:  High-quality generics is very high on the list of things the FDA wants to do, needs to do, and in fact is doing.  And this is especially true for first-to-market generics because not only is it an issue of price competition and access, it’s also an issue of avoiding drug shortages.  When you only have one manufacturer for a product, if that manufacturer has manufacturing issues, drug shortages can occur and that’s a public health crisis as well as a pricing crisis, which is really what everybody wants to talk about.  All of these things places high-quality generics and certainly first-to-market generics, very high up on the list of FDA’s priorities.

Combs:  And I think I’ll bring Tim into this conversation as well.  Tim obviously has a lot of experience in industry as well.  I suspect that in your career some products in your portfolios faced some price scrutiny, just as probably every pharma company has.  What’s your perspective on drug pricing and the public response?

Franson:  Well, that’s an interesting question, Jim.  I like Peter’s responses, and I do think that when these issues like with Mylan or Turing come up, they’re clearly not mainstream.  They’re not representative of what general pricing issues are.  But they raise some interesting discussions about pricing as a surrogate for trust and transparency.  And certainly although pricing has been quite in play in the political environment, on the transparency piece I guess I’ve never understood why industry has not taken a much higher profile approach to the value of their benefit over risk for certain products.  In other words, the last big pricing brouhaha we saw in the press several years ago was with the new hepatitis C compounds.  And on the face they look excessive in price, but if you looked at the overall value, you were talking about transitioning patients from multiple courses of interferon or other long term treatments to something that over six months would cure them, an absolute cure.  Now, what is the value of that?  And how can one avoid minimizing that value by focusing only on price?  So I think there are some very important examples we can work with to help us re-achieve price-value balance.  And to me, the balance comes back to very objectively assessing benefit and risk for patients.

Pitts:   That’s exactly right.  It comes down to getting the right medicine to the right patient at the right time.  The hepatitis C situation is a great example, because now people are being cured twice as regularly with half the amount of treatment, and the value to the U.S. healthcare system is going to be enormous.  It’s going to far outweigh the short-term cost, and that’s what many analyses have shown.  Of course, the initial out-of-the box reaction was, “Oh my gosh, these drugs are so expensive.”  But to Tim’s point, we need to talk about the value in the long term rather than the price in the short term.

Combs:  And so, Peter, there are a lot of calls right now for price controls, but what is the problem with controls?  Why not go that direction?

Pitts:  Price control would make the problem worse.  Price controls stifle innovation.  And without innovation you don’t get new products.  And without new products you don’t have competition.  I think that’s the last thing that we want.  It’s a very facile, soundbite, political solution, unfortunately in the political season to say price controls.  But that’s what happens when companies have a strategy of raising prices to increase their profits and also to allow insurance companies to demand a larger discount.  It’s an ecosystem of pricing and value.  Right now people are only focusing on the pharmaceutical industry, but to Tim’s point, whether you’re looking at Mylan or you’re looking at Turing Pharmaceuticals, these are not innovator companies.  These are generic companies.  And generic drugs in the U.S. are cheaper, are less expensive than the same generic product in Canada or Europe.  People forget that.  And when they think about the price of drugs, they also generally mean their copay at point of dispensation at the pharmacy.  And that is something that is not necessarily a pharmaceutical issue; it’s as much an insurance issue as anything else.  It’s easy to say “price controls,” it resonates and people like to hear it, it creates a bad guy that you can aim at, but it would only make the problem worse and also stifles innovation which would be the ultimate sacrifice.

Combs:  Peter, you supervised the FDA’s Office of Public Affairs and have some background in external relations.  What would be your counsel to companies that are considering a price increase?  There are many justifiable reasons for raising pricing in any industry, but is every pharma company going to face the same kind of scrutiny?  Are there any lessons learned or any guidance you would give to not just Mylan but also the broader industry as they think about their pricing going forward?

Pitts:  That’s about a five-hour conversation.  But I think the quick answer is:  Pay attention to what you’re saying, and certainly in a political season.  When Heather Bresch, the president of Mylan, says “Hey, I’ve got a business to run,” that’s not going to calm people’s anger. It’s only going to fan the flames.  People don’t understand the pharmaceutical business. That’s not their responsibility.  But it is the responsibility of the pharmaceutical industry to prioritize being in the public health business rather than being in the profit-making company business.  They’re both important and they’re both legitimate, but I think the pharmaceutical industry needs to stand up and become the poster child for responsible players in healthcare as opposed to being painted as the profiteering bad guys.

Combs:  Excellent.  Well with that, I think we can wrap up here.  But before we do, any kind of parting thoughts, Tim, that you’d like us to end on?

Franson:  I’ll just offer one.  And that is reflecting back on when I started in the field of medicine over three decades ago, I’m trying to imagine if innovation was stifled then by price controls what a different world we’d be in.  We wouldn’t be looking at the way we treat ulcer disease now with pills instead of major surgery.  We would not see all the innovations with devices, robotic surgery.  And I think we should be very cautious when we talk about price controls and the potential chilling effect on innovations of any of those kind of measures.  We’ve done pretty well as a society in terms of improving health and survival via policy support for innovations, and let’s focus on those successes and how we got there.

Combs:  Excellent.  And I’ll ask the same question to you, Peter, before we wrap up.  Anything you’d like to close with?

Pitts:  Amen to that.  We’ve got to protect sustainable innovation.  We’ve got to insert competition into the marketplace any number of different ways, and the FDA plays an important role in that, and transparency is a key part to understanding how the whole system works.

Are You Ready for EU MDR?

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Back in 2010 when European regulators announced plans to overhaul legislation on how the European Union oversees medical devices, the industry knew that it would take time for changes to take effect. With the EU reaching agreement on the regulation, it appears that the final Medical Device Regulation (EU MDR) may take effect as early as January 2017. 

I sat down with Jon Lange, a Principal in the Advisory Services practice of EY and its EU MDR lead, to outline how medical devices companies can prepare. Interestingly, during the webinar, only 26 percent of participants said they had completed an assessment of their EU MDR readiness, while 74 percent said EU MDR readiness either wasn’t on their radar or they were waiting until the regulations were final before beginning major prep.

There are two areas in which medical devices companies must prepare for EU MDR—strategy and compliance—and doing the strategic work early will position medical devices companies favorably.

In my conversation with Jon Lange, we outline the following tips:

  • Address strategic issues early. On the day regulations are published, medical devices executives will have so much to do to be compliant that the strategic aspects will fall to the wayside. Laying the business strategy early allows businesses to be in the most competitive position to move forward when regulations are published.

  • Use EU MDR as an opportunity to fundamentally transform your business. Ask questions such as: How can we enhance our brand? How will this shape our portfolio? Will this present M&A opportunities? Should we cull our SKUs?

  • Understand your risk. It’s important to map out the risk across your business, including in R&D, Supply Chain, Regulatory Affairs, Quality Assurance and Commercial. EU MDR will touch each of these areas.

  • Gather the facts. The most important aspect of planning is getting the facts. Once you have a good understanding of your risks and gaps, how the legislation is likely to impact your current product line, and the opportunities EU MDR will present, you can start mapping an EU MDR readiness plan to take to your leadership team.

  • Don’t wait for 100% clarity. The time to act is now.

To listen to the EU Medical Device Regulation webinar, click here. To talk with a YourEncore expert, contact Mary Ellen Schipp (maryellen.schipp@yourencore.com) .

Pharm-ers Almanac 2016: The Butterfly Effect

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There is a saying, coined by the late Edward Lorenz, an early pioneer of the chaos theory, that “the flap of a butterfly’s wings in Brazil can set off a tornado in Texas.” This observation is known as the butterfly effect: the concept that small changes can have large downstream effects.

Today, the life sciences industry is operating at the tip of a butterfly’s wings.

This evolving milieu is characterized by a shifting regulatory environment, calls for pricing reform, mounting pressure to innovate, concerns over data quality and drug safety, and worries about the industry’s reputation.

Life sciences experts at YourEncore have identified six areas in the pharmaceutical industry that are particularly susceptible to the butterfly effect. These areas are poised for the kind of disruption that initially may seem insignificant, but may have a large and lasting ripple effect.

Each of these are discussed in detail, along with our point of view (POV) in Pharm-ers Almanac 2016: The Butterfly Effect.

 

Biosimilars Take Flight

Biologics are among the most expensive drugs in the pharmaceutical industry. With eleven biologics losing their patents this year, many biosimilars are expected to enter the market. Despite a discounted rate of 20-30 percent, a 2014 Rand analysis predicts that biosimilars will only decrease U.S. spending on biologics by about 4 percent, begging the question: is the manufacture of biosimilars a necessary evolution of the market or a distraction from big pharmaceutical’s innovation and investment in other new drugs to address unmet needs?

 

FDA Nets Drug-Device Combination Products

The popularity of drug-device combination products has been soaring. The market for combinations of drugs, biologics, and devices is expected to grow to $31 billion by 2019. However, growth in this sector is threatened by a lack of alignment with FDA, in which there are countless examples of combination products taking upward of five years to receive approval. How can drug and med device companies best operate within the regulatory framework today and in the future to deliver innovative solutions to patients in a reasonable time frame?

 

Price Puddling

With the price hike of Mylan's EpiPen making recent headlines, this hot topic is leaving the pharmaceutical industry in a difficult position. How do companies balance the thirst for innovation by patients and the value their medicines deliver with the cost of delivering that innovation and building a sustainable business?

 

CROs vs. Cocooning

Nearly two-thirds of pharmaceutical and biotech companies spent between $10 million and $50 million in 2014-15 for outsourcing. However, issues with quality have some pharmaceutical companies talking about retaining in-house resources, with nearly 35-55 percent of sponsors reporting moderate to significant dissatisfaction with a contracted project. What’s the cause of this? Does the success of a CRO engagement begin with the selection process, or does it come down to management?

 

Regulatory Wing Clipping

Legislative and regulatory changes in the pharmaceutical industry are in their chrysalis stage, and soon will be ready to radically emerge and make their impact on developers. By the looks of it, we should expect an invasion of new regulations and their interpretation, which will slow down the rate of approvals. Are all these upcoming regulations a barrier or an opportunity?

 

Inspection Migration

The rising costs of drugs and biologics calls for increased drug imports, and worries about supply chain quality are putting oversight of drug development, manufacturing, and marketing by regulators under a magnifying class. How can the pharmaceutical industry prepare for increased quality oversight?

 

Individually, any of these trends can be disruptive to a drug developer. In aggregate, they can pose a significant butterfly effect on the industry. While developers cannot stem the tide of change, YourEncore can help you anticipate and prepare for these changes.

Read more about what YourEncore experts have to say about the changing life sciences industry by downloading the highly anticipated Pharm-ers Almanac 2016: The Butterfly Effect.

 

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Considering Biosimilars – 3 Key Areas to Assess in Your Strategy

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Innovators simply cannot afford to ignore biosimilars. These products have the potential to create significant clinical and financial advantages for both patients and payers.

Originator firms must figure out how to integrate the presence of biosimilar products into a therapeutic franchise portfolio strategy — even if the innovator elects not to manufacture a biosimilar. To start, originators must develop a strategy for biosimilar products as part of building and maintaining a therapeutic franchise. This requires defining the portfolio effects of biologically similar therapies on lifecycle management as well as clinical migration. The originator needs to assess three areas:

1. Whether there is a franchise commitment to a therapeutic category

2. Whether presence in that segment is “once and done” with a specific product

3. Determine the appropriate response for the launch of biosimilar agents

Key to building this strategy is a firm understanding of how the clinical, regulatory, and commercial environment for biosimilar products is evolving. Equally important is establishing scenarios that lead to developing follow-on therapies that are clinically and economically differentiated from the originator and the biosimilar products.

Sponsors also should look at partnership opportunities available to bundle a biosimilar with a follow-on innovative therapy. Such bundles may lead to lower prices and entry into new therapeutic categories, giving sponsors the headroom needed to generate new therapies.

All this requires knowledgeable pharmaceutical executives with experience modeling the pathways to secure clinical differentiation, achieving expedited regulatory review, and building sustained value in therapeutic franchise portfolios.

This is an excerpt from Pharm-ers Almanac 2016: The Butterfly Effect. Read the full report here:

Download the Free White Paper

About the Author: David Wierz is a YourEncore expert, who regularly consults on commercial strategy for biosimilar products as well as biologics, vaccines and small molecules. He has 25 years of experience working with physician groups, payers and life science companies, including Wyeth (Pfizer), Novartis, Baxalta and Takeda Oncology to name a few.

Navigating Drug-Device Combination Product Approval

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The popularity of drug-device combination products has been soaring. These products — which comprise combinations of drugs, biologics and devices — had sales reaching $22 billion in 2014, and the market is expected to grow to $31 billion by 2019.1

However, growth in this sector is threatened by a lack of alignment within the FDA, which is slow to approve drug-device combination products.  For those considering developing a combination product, I thought it helpful to provide an FDA primer to help people navigate the approval process and understand where the challenges are.    

Medical device products range from drug-coated stents and prefilled syringes, to antibodies combined with drugs for targeted cancer therapy, and products that mimic or replace organs, such as an artificial pancreas.

Combination products pose unique challenges because they may involve new, complex technologies and because their review at the FDA usually involves the expertise of more than one FDA center. With regard to medical devices, how the product can be used is as important as the product itself.

These products are reviewed by the medical product center at the FDA that is  responsible for the constituent part providing  the product’s primary mode of action.  Manufacturers of combination products have to  submit applications through more than one center for regulatory approval, a confusing and delay-prone process. Also, differences in communication, policies, practices, systems, and application types can be challenging when the centers work together.

The FDA’s Office of Combination Products (OCP) oversees and coordinates this activity. OCP was created over 10 years ago with a mandate to ensure timely and consistent premarket and postmarket regulation of combination products. While OCP is charged to be the mediator and has been successful in getting the centers to talk, it has no authority to direct an outcome. When disagreements arise, OCP has no mechanism to facilitate or resolve them.

With little alignment in the FDA when it comes to the approval of combination products, there are countless examples of combination products taking five years or more to receive approval.

When looked at through the devices lens, a combination product has to meet a drug standard, which often requires large clinical studies and is not what people in the medical device industry are accustomed to. When looked at through the drug lens, it would be inappropriate to lower the standard just because there is a device delivery system.

Development of combination products often involves expanded preclinical study programs, including human factor testing to determine if patients use a device delivery system appropriately. The questions addressed by human factor studies overlap with those addressed by medication error assessments, an area of user-product interaction evaluation commonly applied to drugs.

The FDA has recommended that manufacturers and clinical researchers design human factor studies to put products through real-life circumstances with close monitoring and integration with patients. According to the FDA, studies of combination products should be conducted as part of the product design controls process, and before commencing major clinical trials. One step forward is a recent draft guidance that explains human factor studies recommended for combination products.2

With no internal alignment in the FDA around how centers can work together, it’s not surprising that there is also confusion about how to appropriate user fees, which should be used to ensure that the FDA reviews a combination product in a reasonable amount of time. With combination products, the user fee isn’t apportioned to the respective product review centers — drugs and devices. Therefore, they tend to fall to the bottom of the prioritization heap.

Another significant challenge is that manufacturing controls and quality systems vary considerably for drug and device companies, as do product labeling and postmarketing requirements. Also, it is unclear how the revision of medical device regulations by the EU authorities will impact the development and authorization of combination products.

The question is how drug and medical device companies can best operate within the regulatory framework today and in the future to deliver innovative solutions to patients in a reasonable timeframe. Until there is more alignment within the FDA, companies will need to build both drug and device expertise across regulatory, quality, clinical, and the supply chain to work with two reviewing centers simultaneously and synthesize two sets of regulatory requirements. 


Sources:
(1) “Global Markets for Drug-Device Combinations,” BCC Research, January 2015.
(2) Human Factors Studies and Related Clinical Study Considerations in Combination Product Design and Development, FDA.

This is an excerpt from Pharm-ers Almanac 2016: The Butterfly Effect. Read the full report here:

Download the Free White Paper

About the Author:Judith Meritz, J.D. is a Strategic Advisor in YourEncore’s Medical Devices and Diagnostics Practice and was previously the Associate General Counsel at Covidien/Medtronic. Ms. Meritz specializes in compliance counseling for FDA and other international regulatory authority matters for medtech companies.


Leading the Bristol-Myers Squibb Transformation (Part 1) (Ep. 1 of The Pharmcast)

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We are pleased to announce that YourEncore has officially joined the podcasting ranks with the launch of the YourEncore Pharmcast, your weekly dose of wisdom from top life science minds.   Each week we will speak with top industry experts in our network or beyond about hot industry topics, leadership, and the path to success. 

For our maiden voyage of the Pharmcast, we talk with a trio of former Bristol-Myers Squibb executives, who developed and delivered BMS’ “String of Pearls” strategy that delivered first-class medicines to patients and positioned BMS as a clear leader in the immuno-oncology space.

What follows is a tremendous case study on leadership, portfolio decisions, organizational transformation, and most importantly, developing life-changing medicine for patients.

Jim Cornelius, a current YourEncore board member and former BMS CEO, gathered some of his former colleagues: Dr. Elliott Sigal, BMS’ former Chief Scientific Officer, and John Celentano, a former SVP and also a YourEncore board member, to share their story of the BMS transformation.

We begin the conversation with Jim Cornelius, who was a recent addition to the BMS board, and in quick order, found himself offered the CEO position for Bristol.  What was originally thought to be an interim position turned out to be a three-year assignment for Cornelius, as he and his senior management team broke with conventional wisdom to spin off businesses, cut costs, and focus its development on a few winning  ideas.

What followed was a large scale corporate transformation that helped catapult the immuno-oncology revolution, delivered first in class medicines, and ultimately shaped the industry and patients lives for years to come.

We broke this discussion into two episodes, so if you like what you've heard, check out part II here

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 

 

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Leading the Bristol-Myers Squibb Transformation (Part 2) (Ep. 2 of The Pharmcast)

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A continuation of our maiden voyage of the Pharmcast, we talk with a trio of former Bristol-Myers Squibb executives, who developed and delivered BMS’ “String of Pearls” strategy, that delivered first-class medicines to patients and positioned BMS as a clear leader in the immuno-oncology space.

In part 2 of the roundtable, we start off with John Celentano, who was responsible for delivering a large organizational transformation to fund reinvestment in their innovation pipeline.

With the "string of pearls" strategy in place, it was time to figure out how BMS was going to pay for their acquisitions, and continue to fund the development of new products.

Knowing they needed to fundamentally change how they ran the business, the BMS board set out with something they referred to as "the productivity transformative initiaitive."

After restructuring the way the company ran, by shrinking the company and increasing productivity, the board members of BMS set their sites on investing in innovative products and technologies - primarily biologics. At the time, only about 6-7% of major drus were biologics. But, the BMS executives estimated that in the future, the biologic market would near 25%.

In what was, at the time, a make-or-break decision, the BMS executives made a leap-of-faith, $2.3 billion acquisition of a small company called "Medarex," a company that focused on immuno-oncology medicines.

Despite originally being heavily criticized by leaders in the oncology field for the alliance, BMS was well on their way to becoming a leader in the immuno-oncology space. 

What follows was a decade of successes, adding $100 billion in shareholder value to the company, and ultimately getting life-changing drugs out into the market. 

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 


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9 Biotech Valuation Killers (Ep. 3 of The Pharmcast)

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This week in the Pharmcast, we discuss "9 Biotech Valuation Killers" with Dr. Brian Daniels, the former SVP of Global Development for Bristol-Myers Squibb and now Venture Partner with 5AM Ventures, and Dr. Don Therasse, former VP of Global Patient Safety and Medical Affairs for Eli Lilly & Company.  

According to a global study by Mergermarket and Reed Smith, 94 percent of senior life sciences executives plan to make an acquisition in 2016, so biotech firms need to do everything possible to make sure they are properly positioned.

These gentlemen have evaluated hundreds of assets throughout their careers, so we asked them to share their best advice to biotechs looking to attract big pharma suitors and at maximum valuations.

The first rule is to have good science. This is a given. After that, follow nine rules to maximize valuations, which Drs. Daniels and Therasse present in episode 3 of The Pharmcast.

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review. 


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Billion Dollar Bets: Lessons on Innovation from a BMS Chief Scientific Officer, Dr. Elliott Sigal (Ep. 4 on The Pharmcast)

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Each week in The Pharmcast, we talk with top industry experts from our network or beyond about hot industry topics, leadership, and the path to success. This week in The Pharmcast, we catch up with Dr. Elliott Sigal, the former Chief Scientific Officer of Bristol-Myers Squibb.

In 2012, Dr. Sigal was called by Scrip Pharma Intelligence "The Best R&D Chief in Pharma," largely for helping deliver BMS' "String of Pearls" strategy that helped position BMS as a major player in the immuno-oncology space.

As referenced in both Episode 1 and Episode 2 of The Pharmcast,  Dr. Sigal, through internal development and making sizable asset acquisitions, developed a pipeline of first-in-class medicines that helped transform the company, the industry, and most importantly, the lives of hundreds of thousands if not millions – of patients. 

When asked what his "secret sauce" to success was, he said it was not just one thing, but the culmination of many things.  Below are the three of the things Dr. Sigal attributed to his success.

1) Team. Despite being called "The Best R&D Chief in Pharma," he acknowledges that this was the recognition of something greater: his team. 

2) Experience. Sigal's unique background, which combined engineering and medicine as a Physician Scientist, brought him an interesting, advantageous outlook on the large organizational issues in the pharmaceutical industry. 

3) Focus. Dr. Sigal felt he and his team benefited from having focus:  a focus on the patient, a focus on the changing landscape of medicine, and a focus of his time on areas where he uniquely could add value.

Join us in Episode 4 of The Pharmcast, as we talk more with Dr. Sigal about leadership, portfolio decisions and what made him successful in his journey. 

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 


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Holiday Wish-Lists and Watch-Outs From Regulatory Leaders (Ep. 5 on The Pharmcast)

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 This week in The Pharmcast, we asked two of our top regulatory policy Experts to give us their holiday wish-lists and top things to watch for in 2017.

Leading the discussion is Dr. Tim Franson, who is the former VP of Global Regulatory Affairs and Global Patient Safety for Eli Lilly & Company, current Chairman of the Board for the Critical Path Institute, and YourEncore's Chief Medical Officer.

Joining him is Peter J. Pitts, former FDA Associate Commissioner and current President for the Center for Medicine in the Public Interest, a policy institute he founded in 2004. Peter was named one of the "300 Most Powerful People in American Healthcare" by Modern Healthcare Magazine, and frequently contributes to national media outlets including CNBC, Fox News and the Wall Street Journal.

As Dr. Franson and Peter discuss what they're hoping for under the tree this year and what situations could potentially turn into lumps of coal – they fixate on the letter "P" and all the changes, from "people" to "policy," that could be coming to the industry in 2017.

Join us in Episode 5 of The Pharmcast as Dr. Franson and Peter begin to dissect these questions and what they're wishing for, among these and several other P-related hot topics for 2017.

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 


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From Big Pharma to Biotech C-Suite: Industry and Career Insights from Dr. June Almenoff (Ep. 6 on The Pharmcast)

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This week on The Pharmcast, we talk with Dr. June Almenoff, former President, Chief Medical Officer and Board Member of a biotech, which was recently acquired in 2014 by Actavis for $1.2 billion.

With an M.D. and Ph.D., Dr. Almenoff began her career as a faculty member at Duke University before landing a position at GlaxoSmithKline (GSK) in their medical R&D division and scientific licensing.  However, after 13 years at GSK,  a new opportunity presented itself in 2010 when Dr. Almenoff was invited to head up a small biopharma company as President & CMO, which she would soon lead into a $1.2 billion acquisition.

Almenoff helped the company successfully progress its Irritable Bowel Syndrome drug from Phase 2 through the FDA submission, which the FDA approved in 2015 on its first review cycle.

Everyone talks about learning from failure, but from our discussion with Dr. Almenoff, we learn from success.  I asked Dr. Almenoff about her keys to success, drug development trends, and the lessons she's learned across her 'big pharma' and biotech career.

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 

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Bioethics in Biopharma: Lessons on Safety, Big Data and Bioethics from Dr. Don Therasse  (Ep. 7 on The Pharmcast)

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This week on The Pharmcast, we talk with Dr. Don Therasse, former VP of Global Patient Safety for Eli Lilly & Company, and current Strategic Advisor for YourEncore.

With over 26 years of experience working with Lilly, Therasse held a diverse set of roles ranging from clinical research physician, to medical director, to medical affairs leader, and finally to patient safety leader.  Beyond drug safety, Don Therasse is a thought leader in bioethics and is credited with building Lilly's internal bioethics group.

In our conversation with Dr. Therasse, we explore experiencing a major patient safety event, building a bioethics program, the promise (and limitations) of big data in patient safety, and success formulas for transitioning into new departments within a large biopharma company. 

If you have topics you would like YourEncore to explore on future episodes of The Pharmcast, please email Pharmcast@yourencore.com with feedback or suggestions.

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 

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FDA 483 Responses: Avoiding Common Pitfalls and Deficiencies (Ep. 8 on The Pharmcast)

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This week on The Pharmcast, we explore best practices and common pitfalls in FDA 483 Responses. 

In 2015, there were an average of 175 inspections and 10 warning letters issued per month by the Center for Devices and Radiological Health alone.  Regulatory inspections and 483 findings are a part of being a life sciences company.  However, how companies respond can have a major impact on patient safety and business performance.

To share best practices, we held a special presentation with two of our top medical device experts, Victor Chance and Judy Meritz, to outline what they’ve learned over the course of their 20+ year careers in the medical devices industry.

Victor Chance is the former VP of External Operations and Chief Supply Chain Chief Procurement Officer for J&J Medical Devices and Diagnostics. Victor also served as Worldwide Vice President of Operations for J&J’s Cordis franchise and was responsible for directing the company’s global manufacturing, supply chain management and strategic sourcing functions. 

Judy Meritz, J.D., was the Associate General Counsel at Covidien/Medtronic and specializes in compliance counseling concerning FDA and other international regulatory authority matters including inspections, enforcement actions, product approval strategies, marketing and advertising programs, and complaint handling. 

We join the presentation with Victor Chance, who outlines his success roadmap to an effective 483 response.  If you would like to see the recorded presentation, you can watch here.   

If you have topics you would like YourEncore to explore on future episodes of The Pharmcast, please email Pharmcast@yourencore.com with feedback or suggestions.

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 

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No Surprises: Improving Medical Devices Due Diligence (Ep. 9 on The Pharmcast)

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This week on The Pharmcast, we discuss areas often overlooked in due diligence efforts that can lead to expensive or even show-stopper surprises once the acquisition is complete and later development and commercial efforts are underway, with two former Johnson & Johnson medical devices executives, Donna Godward and Dr. Janet Vargo.  Understanding what to look for (or present) during due diligence will reduce risks and lead to a better evaluation for the transaction.

Acquiring and selling innovative medical devices or diagnostics is standard business for small and large device companies – but doing it well is not standard business. 

Novel medical products offer the possibility of true breakthroughs in medical care but also come with the risks of developing, manufacturing, and commercializing a one-of-a-kind product where quality, regulatory, clinical and commercial pathways are yet to be paved. 

While licensing new technology and acquiring new businesses are standard business in the industry, many acquisitions do not live up to the anticipated value proposition.  Improving the due diligence efforts within a company, large or small, can provide better understanding of the value and the ultimate success of the acquisition

 

About Donna Godward:  Donna Godward is a Strategic Advisor to YourEncore and a member of the Medical Devices Practice.  Prior to assuming her current role in 2016, Donna Godward served as Chief Quality Officer, Medical Devices & Diagnostics (MD&D), for Johnson & Johnson.  Donna has extensive experience in due diligence in licensing and acquisitions. 

About Janet Vargo, Ph.D.:  Dr. Vargo is a Strategic Advisor to YourEncore and a member of the Medical Devices Practice.  Prior to joining YourEncore, Dr. Vargo served as Board Member and Head of Clinical and Regulatory Affairs for Mentor, LLC, a Johnson & Johnson Company, and she advised on clinical trial design, device and biologics safety analyses, due diligence efforts, and regulatory strategy for new-to-the-world products for the entire Johnson & Johnson Medical Device and Diagnostic sector. 

If you have topics you would like YourEncore to explore on future episodes of The Pharmcast, please email Pharmcast@yourencore.com with feedback or suggestions.

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 

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Patient Engagement: Putting Rare Disease Patients First (Ep. 10 on The Pharmcast)

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This week on The Pharmcast, we turn our attention to the topic of rare disease, and more specifically: how to engage and educate rare disease patients to advance development. It's estimated that nearly 30 million Americans, or nearly 1 in 10 people,  are living with a rare disease - and almost 95% of rare diseases don't have any FDA-approved treatment. 

One of the unique challenges and perhaps keys to rare disease development is patient engagement. Patient populations are small by definition. Roughly 50% of patients are children, and benefit-risk equations are completely different from those of more traditional diseases. To learn more about engaging rare disease patients, we sit down with Dr. Lorna Speid, to discuss her stories of rare disease drug development, outline the unique challenges of engaging the rare disease population, and her advice to developers.

Dr. Lorna Speid is the author of Clinical Trials: What Patients and Healthy Volunteers Need to  Know, and founder of the nonprofit organization, Putting Rare Disease Patients First. With an extensive background in R&D, Dr. Speid has dedicated her career to working within the rare disease space - particularly in drug development, clinical trials and patient engagement. Dr. Speid earned her Ph.D. in Safety Assessment of Medicines, Pre and Post Marketing, and has served on the NIH Committee for Therapeutics for Rare and Neglected Diseases. 

Dr. Speid began her nonprofit in 2014, after spending a year writing her book, aiming to empower and inform patients and professionals alike. With hard-to-diagnose diseases, Dr. Speid felt especially passionate about helping patients understand their disease and the pharmaceutical industry - informing them on everything from the drug development process, to genomics, to natural history, and clinical trials - through easily accessible information such as webinars and blogs. The nonprofit also uses social media to share information and offer support to patients - which is especially important in a time when inaccurate information can spread like wildfire. 

If you have topics you would like YourEncore to explore on future episodes of The Pharmcast, please email Pharmcast@yourencore.com with feedback or suggestions.

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 

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Medtech Valuation Killers: 10 Regulatory & Commercialization Traps to Avoid (Ep. 11 on The Pharmcast)

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This week on The Pharmcast, we talk with Dr. Janet Vargo and Minnie Baylor-Henry on medtech valuation killers, and the 10 regulatory and commercialization traps to avoid. Dr. Vargo penned an article on the topic for Med Device Online, and joins us today to share the common ways value can be destroyed.

Dr. Vargo is the former Head of Clinical and Regulatory Affairs for Mentor, LLC, a Johnson & Johnson Company, and she advised on clinical trial design, device and biologics safety analyses, due diligence efforts, and regulatory strategy for new-to-the-world products for the entire Johnson & Johnson Medical Device and Diagnostic sector.

Joining her is Minnie Baylor-Henry, former Worldwide Vice-President for Regulatory Affairs for Johnson & Johnson’s (J&J) Medical Devices & Diagnostics sector as well. 

After evaluating dozens of innovative new medical device products as executives at Johnson & Johnson, and now with YourEncore, Dr. Vargo and Minnie Baylor-Henry has seen firsthand the common mistakes that small companies make.  In this session, they will outline the regulatory and commercialization pitfalls to avoid that will improve your speed to market, valuation, and interest from large medical devices companies.  

If you have topics you would like YourEncore to explore on future episodes of The Pharmcast, please email Pharmcast@yourencore.com with feedback or suggestions.

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 

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NDA Mistakes to Avoid: An Interview with Dr. Joseph Lamendola (Ep. 12 on The Pharmcast)

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This week on the Pharmcast, we talk with Dr. Joseph Lamendola on four New Drug Application (NDA) mistakes to avoid.

Dr. Lamendola is the former VP of U.S. Regulatory Affairs for Bristol-Myers Squibb and Schering-Plough, and now serves as the SVP and leader of YourEncore's Biopharma practice.

Joe has over 20 drug approvals to his name, so we ask Joe to share his life lessons on how to work with the FDA to receive NDA approval and ultimately get life-changing therapies to patients.

If you have topics you would like YourEncore to explore on future episodes of The Pharmcast, please email Pharmcast@yourencore.com with feedback or suggestions.

The Pharmcast is now available for download on iTunes, Google Play, and Stitcher. If you like what you hear, share it with your friends and write a review or give us a rating on your podcast store. 

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Executive Briefing: EU Medical Device Regulation | 5 Ways EU MDR Will Impact Your Business [White Paper]

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The European Union has agreed on a new Medical Device Regulation meant to improve patient safety and data  transparency. The regulation is extensive and impactful – it touches many functions within the company and  companies that fail to comply will not be allowed to sell products into the EU. With the legislation expected to  publish in 2017, companies will have three years to bring medical devices into compliance and, under a separate new regulation for IVD’s, five years for these products.

With the EU finally reaching the agreement, the compliance clock is ticking. Although many functions are impacted, regulatory leaders will most likely be responsible for driving corporate compliance.  If you’re just starting the process, download Executive Briefing: EU Medical Device Regulation to learn five ways EU MDR will impact your business. 

Download Executive Briefing: EU MDR | Five Ways EU MDR Will Impact Your Business

About the Author

Patrice Napoda is a former Director of International Regulatory Affairs for Johnson & Johnson’s Ethicon franchise, current YourEncore expert, and frequent speaker on EU MDR readiness.  For the past two years, Patrice has helped Fortune 500 medical device companies assess their compliance risk and prepare for the final EU Medical Device Regulation. 

Improving R&D Productivity with Activity Based Costing

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Today’s prevailing wisdom is that R&D costs are on the rise while ROI on those investments are down. The Tufts Center for the Study of Drug Development puts the total costs of new drug around $2.7B (in 2017 dollars) while another study1 highlights the fact that the ROI on R&D investment has fallen to 3.7% which is the lowest figure in the past six years. As such, the pharmaceutical industry’s focus on improving productivity is a critical issue.

This debate over R&D cost and productivity declines should incent R&D executives to ascertain the true cost for their company’s R&D efforts and more importantly, whether these costs and their related time to develop/obtain regulatory approval can be better managed. As the old adage goes: “You cannot manage what you cannot measure.”

Over the last 14 years, we have been working with leading pharmaceutical companies to understand, analyze, and better manage their R&D investments which impact ROI and time to market. These efforts have helped us develop a specific methodology which helps pharmaceutical companies:

  • Determine true activity costs to run a trial (e.g. by site, therapeutic area, phase, or country);
  • Estimate protocol costs (e.g. by site, therapeutic area, phase, # of patients, and # of visits);
  • Negotiate more effectively with CRO’s using comparison analysis among CRO proposals;
  • Identify high cost areas and measure the true results of the improvements efforts; and
  • Develop a scorecard to track key performance indicators such as cost per patient, cost per site, or cost per visits.

By focusing on these key components, we have continually been able to help biopharmaceutical and biotech companies identity specific opportunities to dramatically reduce costs, improve productivity, and accelerate cycle times.

Our work with the executive leadership at a Global Pharmaceutical Company’s R&D division highlights the power of this approach. This leadership team was faced with two critical challenges. The first was how to gain deeper insights into their actual operational costs for their global drug development efforts. The second challenge was that without a full view of the costs of running global clinical trials they were unable to model cost implications such as:

  • Identifying the financial benefits of continuous process improvement activities;
  • Understanding true cost implications when decisions such as adding a new study are made, and;
  • Analyzing cost in different regions for same Therapeutic Area by trial phase and NGO as part of contracted CRO program.

Our team worked with the client for several months to help understand and address their core challenges. Our program initiated with the deep assessment phase, which included interviews with dozens of process stakeholders, led us to gain full transparency into their clinical process while mapping costs back to each activity which helped unearth specific areas for potential improvement. Our team worked with internal stakeholders to understand and fully understand each activity and the subsequent costs of each activity. This enabled us to build an end-to-end Activity Based Costing map of the process which was critical in helping the client:

  • Understand the full cost ofeach study based on numerous perspectives including:
  • Regional costs / study
  • Activity / process / phase cost per study
  • Cost per protocol or phase by region
  • Cost per therapeutic area / clinical program by region
  • Identify high-cost activities which could be streamlined or eliminated to drive cost savings without impacting studies’ quality
  • Create a governance approach to capture and regularly analyze the data to identify opportunities to continually optimize their clinical processes

Ultimately, this program provided the R&D Division a true financial view on how the applications of resources within a given study are used and where study cost and operating processes effectiveness and efficiencies can be targeted and achieved. These insights were critical in helping the client improve their portfolio decisions, vendor selection process, and optimize their improvement initiatives to drive maximum cost savings while not impacting the quality and success of clinical programs.

To learn more about how YourEncore can help improve your R&D productivity, contact Kyle Chaffee (kyle.chaffee@yourencore.com).

1. January 4, 2017 Pharmaceutical Journal






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