good review practice –communications
TRANSCRIPT
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Good Review Practice – Communications- Fundamentals of Communication for Regulatory Authorities
and Experience Sharing on Interagency communication
1st Thailand GRM Conference, Bangkok, Thailand, June 26-28, 2018
Hsien-Yi Lin, PhD
Senior Reviewer, Division of Medicinal Products
Taiwan Food and Drug Administration
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Communications
Other authority
The public The applicants
External experts
Regulatory authority
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Communications
Other authority
The public The applicants
External experts
Regulatory authority
Intra‐agency
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Intra-agency communications
• Improving efficiency by:– Collaboration among scientific reviewers– Defining roles and responsibilities
• Review team members • Leadership
– Transparency– Equal voices
• Open, clear, constructive and timely communications in:– Progress of review, sharing review findings, differing data interpretations,
resolution mechanisms, decision makings on actions
• Establishing format and process of communications– Within agency– With external stakeholders (experts, public, RA, applicants, etc.)
Evidence‐based review and decision making are critical for accountability !
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TFDA Organization Chart
Product reviews require coordination different organizational units within the RA.
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External Experts
Division of Medicinal Products Organization Chart
Division of Medicinal Products
Section 1 Drug Safety and EvaluationPost‐marketing monitoring, AE/AR report.
Section 2 New drugsRegistration/PAC/RMP of NCE, Bio, imported drug.
Section 3 Generic drugsRegistration/ PAC of domestic drugs.
Section 4 Regulatory Science
Section 5 Clinical Trial ManagementClinical trials protocol/report verification, GCP inspection.
Section 6 Pharmaceutical Management
Center of Drug EvaluationAdvisory committeesExternal
Product reviews require expertisefrom different organizational unitsWithin the RA.
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TFDA Review Process and Intra-agency Communications
Sponsor
Division of Medicinal Products
CDE
Recommendations
Division of medicinal products
Final decision
Advisory Committee
As needed
External experts
Division of Risk Management
Investigation/evaluation
GMP certificate
Division of Research and Analysis
Quality reconfirmation
certificate
(for biologics)
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Communications
Other authority
The public The applicants
External experts
Regulatory authorityInter‐agency
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Inter-agency communication
• Can increase the efficiency and quality of medical product development and review process
• Usually needs an inter‐agency agreement in a form of MOU (Memorandum of Understanding), confidentiality arrangements, and consent from the applicants
• Types of communications‐– Published guidelines, application decisions, available review reports to
effectively facilitate the review and decision making– Actively pursuing reviews during review, e.g., non‐clinical, clinical and
inspection findings– Joint nation review of applications if possible
• Establishing format and process of communications to comply with nation’s laws and inter‐agency agreement
Application decision is still up to the Nation
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Examples of Interagency Communication with TFDA
Sharing and awareness of information:Participation of international or regional harmonization initiatives, such as
membership in APEC, ICH, IPRP and PIC/SHosting APEC GRM CoE training events Information exchanges with other regulatory authorities
– Annual joint conference of Taiwan and Japan on Medical Products Regulations– Collaboration document over Pharmaceutical regulations with NPRA– Workshops featuring experts from other authorities
Posting regulatory actions– Assessment reports for approved NCE– Information of domestic and international manufacturers conferred with GMP
certificates by Taiwan regulatory authorities
Consideration of review findings:New drugs review scheme pilot with PMDA
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Communications
Other authority
The public The applicants
External experts
Regulatory authority
With the applicants
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Communication with applicants
Before and after submissions, and during regulatory review Published available guidelines provide insights into RA’s current thinking
and expectations for better quality submissions and compliance Important timelines
– Product development or pre-IND and IND stage (getting more important)– Pre-NDA – During NDA reviews– Postmarketing requirements
Establishing format and process of communications – Formal meetings, submissions, e.g., face-to-face meeting, teleconference, or
written response only (WRO)– Preliminary comments, final meeting minutes, and responses– Including feedback mechanisms
Nothing is final until all available information has been reviewed
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Consultation system in Taiwan
Consultation System
Consultation by Request
Active Consultation
Industrial Communication
Platform
Domestic Innovative Consultation
(Early Harvest Lists)
National Research Program for Biopharmaceuticals
(NRPB)
Online Information
Transparency
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Expedited Programs for NDA
NDA review track
Regular
Standard Review(360 days)
Abbreviated Review
(180 days)
Unmet medical needAA applicable
Priority Review(240 days)
Priority + Abbreviated
Abbreviated Review:NCE + US FDA, EMA, MHLW approved (2 in 3) AA: Accelerated approval (AA): Surrogate endpoint CT accepted
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Review Timeline Management
Normal Review
Priority Review
(needs TFDA pre-approval)
Abbreviated Review
(needs TFDA pre-approval)
Non-NCE NDA
(w/ clinical data)
Non-NCE NDA
(w/o clinical data)
TFDA decision
(D360)(D60) (D120)
(D240)(D60) (D120)
(D60) (D90) (D180)
(D300)(D60) (D120)
(D60) (D200)(D90)
M1 M2 M3 M4 M5 M6 M7 M8 M9 M10 M11 M12
(D50)
(D50)
(D50)
(D50)
(D50)
(D100)
(D100)
(D100)
(D80)
(D80)
(D210)
(D170)
(D120)
(D180)
(D140)
Filing Meeting
Review Meeting
(D300)
(D200)
(D140)
(D240)
(D160)
Complete assessment reportInquiryRTF (Refuse
to file)
Predictability
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Communication between reviewers and sponsors
Formal pre-submission consultation Consultation on development of new drugs (domestic companies only) Letters of inquiry Sponsor requested meeting Over-the-phone information (informal) Over-phone discussions (for applications of post-approval variation only) Appeals against final decision
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Types of Advice- Examples
• Critical advice – trial design, dose selection, nonclinical study, manufacturing and facility issues
• Regulatory plans for submission • Clinical/statistical outcomes and endpoints, trial size, enrichment
designs, Pediatrics• Safety, the overall safety database, concerns related to particular
populations, post‐approval pharmacovigilance plans, risk evaluation and mitigation strategies, plans for human factors studies, issues related to evaluation of abuse potential
• Clinical pharmacology and pharmacokinetics • Nonclinical pharmacology, pharmacokinetics, and toxicology • Product quality, e.g., proposed shelf life and stability studies,
delivery systems, GMP
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Communications
Other authority
The public The applicants
External experts
Regulatory authorityWith externalexperts
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Communications with external experts
• Academics, patient and medical organizations• Enhancing the available information for better decision
making process• Timely planning the pursuit of applicable experts• Establishing format‐
– Advisory panels for public opinions– Individual invitation for specific issues– Maintaining confidentiality and conflict of interest
Still, the Nation has the final decision based on all available information
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Communications
Other authority
The public The applicants
External experts
Regulatory authority
With thepublic
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Communications with the public
• Policies and procedures for guidelines, decision‐makings, reviews, and accomplishments for public access
• Mechanisms for public input– Website postings requesting for input, surveys, public meetings, workshops, advisory boards, medical organizations, etc.
– For product development, regulatory review, and postmarketingrisk management strategies
• Clear messages avoiding public panicking
Many factors affecting RA’s ability to develop, disseminate, and oversee effective product communications in an
evidence‐based manner
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Information for the public in Taiwan
More information in Chinese website
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Publications for the public in Taiwan
Food & Drug Consumer Newsletter (weekly) Medication Safety Handbook for New Immigrants(with Thai, Cambodian, bahasa Indonesia, Vietnamese versions)
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Considerations In Issuing a Communication to the Public
• When and what to issue the communication, including if the issue has been communicated before
– Strength of the evidence• Issuing party• Target audience(s) • Key messages to communicate‐ quality, risk/potential risk,
requesting input?• Is the communication related to a regulatory action?• Are there communications to HCPs and patients that is consistent
with medical practice without unintended or unanticipated consequences?
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Dynamics of Communication
Regulatory Authority
Company
Patients
Public
Medical Community
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Challenges in Communications
The science and transparency of decision making process, especially when uncertainties of evidence occur
How to manage communication in media channels? Nation’s unique culture Moving forward- also need to seek ways to
– measure the effectiveness – understand the audiences, e.g., nations, partner organizations,
languages, and uncertainty in messages
More development on the best practice of communications may be needed
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Potential Topics for Discussions
What are the current communication practices in your institution?
Have you reached the goal of good communication in your institution? What are the gaps?
What is your planned solution to address the gaps in communication?
How do you assess the impact of improved communication?
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Thank you for your attention !