Insights

Optimising Orphan Drug Development in the EU

 

The legislative framework on orphan medicinal products aims at stimulating research and development of medicinal products for rare diseases by providing incentives to developers of such products. The orphan incentives facilitate the development of medicinal products to make sure patients suffering from rare diseases have access to the same quality of treatment as other patients suffering from common diseases do.

Since 2000, the European Commission has issued over 2100 orphan designations, of which up to now 164 have obtained the Marketing Authorisation (MA) and 22 have obtained an extension of indication (22 orphan medicine and 6 extended indication obtained only in 2018). The MA trend shows a significant peak from 2014 to 2018 with 94 authorizations including new medicinal products and indication extensions.

It is quite interesting to observe the distribution of the main therapeutic areas:

  • 41 % Oncology diseases;
  • 19 % Alimentary tract and metabolism diseases;
  • 8 % Nervous system diseases;
  • 8 % Hematologic diseases.

It is not always easy to define an orphan condition, for this reason and after the strong changes in the world of rare diseases in the last decade, it appeared necessary to update the definition and acceptability of an orphan condition as fundamental starting points for the evaluation of applications for the designation of orphan medicinal products.

Regulatory and HTA assessments have different timing and remits, both evaluate different medical aspects that can be analyzed with different tools but are both highly necessary in the complete evaluation of potential orphan drugs.

In order to improve the development and facilitate the evaluation of an orphan drug, it is necessary to improve the collaboration and the exchange of information between companies, regulatory bodies and patients' societies in order to face the most critical issues in the definition of orphan designations:

  • Significant benefit

More and more challenging to argue for significant benefit in orphan conditions: difficult to generate incremental innovation in rare diseases (67% orphan designations of 2018 were based on significant benefit);

 

  • Patient relevant outcomes

How to best generate patient-relevant data to support significant benefit (MCPC) and downstream access;

 

  • Innovative/complex designs

How to ensure that a single development plan is acceptable for all of stakeholders;

 

  • Balance regulatory and access with evidence generation

Regulatory knowledge very dynamic in the post-approval setting. Clarify and improve the expectation management of all stakeholders;

 

  • Regulatory decision-making with ‘’RWE’’ Evidence sources

Defining a clear place in regulation of Registry data and natural history of the disease.

 

Regulatory Pharma Net is available to provide additional information and support to develop specific strategies for Orphan Designation Applications, Marketing Authorisation Applications, Early Access and Market Access in Europe.

 

Insights

MARKET ACCESS – AIFA GUIDELINE FOR THE DEVELOPMENT OF PHARMACOECONOMIC ANALYSIS AND MODELLING IN SUPPORT OF THE P&R DOSSIER

The Italian HTA Agency (AIFA) has published the first guideline in order to harmonize the structure and the requirements for a correct development of the Pharmacoeconomic Chapter of the Pricing & Reimbursement (P&R) Dossier.

The Companies may present the following types of analysis:

  • Cost Effectiveness Analysis (CEA) and/or Cost Utility (CUA) of the medicinal product concerned, in comparison with the standard of care (SoC) identified in the Italian NHS context (time horizon of 5 years, 10 years and lifetime);
  • Budget Impact Analysis (BIA) from the NHS perspective, providing a forecast of expenditure and cost saving effects of the drug reimbursement (time horizon of at least 2 years).

The submission of these analyses is recommended for the following types of P&R applications:

  1. Orphan drugs, including any extensions of the therapeutic indications;
  2. New active substances, including reclassifications of active substances not reimbursed and associations that contain at least one new active substance;
  3. Extension of the therapeutic indications of drugs subject to patent coverage, except in case of a population extension for the indication already authorized and reimbursed.

During the Pharmacoeconomic Chapter development, the Companies are recommended to follow and respect the new guideline in order to mitigate possible questions or objections during the Pricing & Reimbursement Committee (CPR) assessment.

In addition to the AIFA Guideline, in order to verify the completeness of the information contained in the dossier regarding the pharmacoeconomic assessments, it is recommended to refer to the CHEERS Checklist (prepared by a Task Force of the ISPOR) and to the principles of good practice relating to the development of budget impact analyses, published by ISPOR (Sullivan et al 2014).

Regulatory Pharma Net can support Pharmaceutical Companies during the whole P&R process, from the development of the dossier, including the Pharmacoeconomic Chapter, to the negotiation phase with the HTA Agency.

Insights

MARKET ACCESS – SIHTA POSITION PAPER

The Italian HTA Society (SIHTA) has recently published a Position Paper which aims at indicating a possible evolution of the HTA activities carried out in Italy.

This represents a proposal for a homogeneous organizational model that could lead to the definition of an "Italian HTA System", strategically conceived for the management of health technologies, as a new benefit for the NHS.

The SIHTA proposal which summarizes the structure and governance of a possible future National HTA Agency (AIHTA) is summarized in the following points:

 

  1. Establishment of the ITALIAN AGENCY OF HTA (AIHTA) which must consider the entire world of healthcare technologies as its domain of interest (Medical Devices, Biomedical Equipment, ICT-IA Tools, Medicines, Procedures, Organizational Models, LEA , PDTA, etc.).
  2. Establishment of the HTA REGIONAL UNITS (NRHTA) capable of gathering and enhancing the skills and needs of the various structures of excellence in its territory.
  3. Establishment of the HTA HOSPITAL UNITS (UOHTA) in the IRCCS, university hospitals (public and private), large healthcare companies and regional hub hospitals.
  4. Establishment of COLLABORATIVE CENTERS (CC) to support the assessment activities conducted by AIHTA and NRHTAs.

 

In summary, this proposal, outlines a model of direction and planning of HTA activities carried out by different institutions at various levels (from national to regional / local) in order to contribute and influence the government and innovation activities of the health technologies and also to increase the chances of patient access to the benefits guaranteed by technological innovation.