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Innovation; issues for regulators, society and industry. Overview of Conference topics. Alasdair Breckenridge Medicines and Healthcare products Regulatory Agency London 23 September 2008.
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Innovation; issues for regulators, society and industry.Overview of Conference topics Alasdair Breckenridge Medicines and Healthcare products Regulatory Agency London 23 September 2008
“It is a frustrating aspect of benefit-risk evaluation that there is no defined and tested algorithm or summary metric that combines benefit and risk data that might permit straightforward quantitative comparisons of different treatment options, which in turn might aid decision making” CIOMS, 1998.
Current perceptions • Approval thresholds heightening • Increased focus on safety • Regulators dislike uncertainty • Increasing cost of drug development • Demand for increased transparency • Negative perceptions of pharmaceutical industry and regulators
What information do regulators and industry need to enable them to undertake benefit : risk assessments? • Are available frameworks adequate? • How can we best communicate benefit : risk to the general public?
Benefits of an agreed framework • Shared understanding of issues between industry and regulator. • Consistency in expressing benefit and risk. • Transparency of regulatory decisions • Tool to compare products
Methods of assessing benefit • Nature of disease-incidence • natural history • impact of treatment • consequences of no intervention • Purpose of treatment-prevention prevention of recurrence • symptomatic treatment • cure • Assessment of benefit-morbidity mortality symptoms quality of life
Methods of assessing risk • Development or post marketing • ADRs affecting different systems • Seriousness of ADRs
Under-reporting Reporting bias Quality of reports Cannot estimate frequency of events • Spontaneous reports of ADRs
Knowledge Time
Timing of market authorisation MA Knowledge Time
Earlier to market? MA Knowledge Post-licensing assessment Time
“A systematic approach to population based drug safety surveillance which seeks to ascertain the number of adverse events by means of a continuous pre-organised process.” • Active Surveillance
Record of drug exposure Record of outcomes Access to detailed information about individual cases • Data requirements for • active surveillance
Computerised databases of users and non users Medical records • Sources of information for • active surveillance
British Society of Rheumatology Biological Register(1) • For patients with severe RA prescribed anti TNF αmedicines. • To receive drug, patient must be entered on central register. • Short and long term ADRs documented. • Cohort of similar patients prescribed conventional DMARDs
British Society for Rheumatology Biological Register(2) • Rheumatologists contacted 6 monthly about specific patients • Data on severe infections and hospital admissions obtained • Patient diaries • Patients flagged with ONS to ascertain new cases of cancer and deaths • Over 20000 patients on register
GPRD: population figures • Contains 6.1 million acceptable patients from 464 active practices • Currently collecting data on 3.58 million active patients from 405 up to standard practices • >45% of patients have 5 or more years of follow-up, >60% have at least 3 years • Contains over 40 million patient-years data • Geographically representative
The Benefit-Risk Spectrum RISK The worst balance Forrestricted use only Balance may require further study major Acceptable balance minor Excellentbalance minor major BENEFIT
Principle of three • Seriousness, duration, incidence as applied to adverse reactions • Seriousness, chronicity, extent of control or cure as applied to benefit Describe verbally or numerically
Aspirin 3 = high, 2 = medium, 1 = low, 0 = no effect
Shortcomings of models • Do not enhance objectivity of benefit-risk decision making • Time consuming • Conflict between stakeholders in assessment
Benefit-risk : outstanding issues • Need for lexicon of terminology • Framework for benefit: risk assessment in which different models might be used • Different models for different situations • Agreed framework would improve underlying science of innovation • Importance of taking patient preferences into account • Learning from other disciplines, including HTA • Communication difficult but crucial