The Qualitative Value of Facilitated Regulatory Pathways in Europe, USA, and Japan: Benefits, Barriers to Utilization, and Suggested Solutions

Comparison of the Latin America Regulation Landscape and International Reference Health Authorities to Hasten Drug Registration and Clinical Research Applications

INTRODUCTION

Promptly providing new drugs to fulfill unmet medical needs requires changes in drug development and registration processes. Health Authorities (HAs) considered as reference due to their experience and acknowledgement (Food and Drug Administration [FDA] among others) already consider innovative clinical trial (CT) designs and flexible approval procedures, but Latin America (LATAM) regulations are still far. A comparison was performed to identify gaps.

MATERIALS AND METHODS

CT requirements for drug Marketing Authorization Application (MAA) and CT approval regulations were compared between LATAM and reference HAs (FDA/European Medicines Agency [EMA]/Health-Canada/Swissmedic/Therapeutic Goods Administration [TGA]/Pharmaceuticals and Medical Devices Agency [PMDA]), as of August 2022. Procedure included reference HAs regulations review, item selection, identification in LATAM regulations, and International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH) guidelines (ICH-E6[R2]/ICH-E8[R1]) implementation revision.

RESULTS

For MAA, specific application requirements or ICH guideline M4(R4) on common technical document (CTD) adoption are generally stated, and phase-I/III performance is mandatory (explicitly/implicitly). Faster patient access procedures are infrequent: Priority-drug programs, conditional authorizations, or expedited procedures are scarce or non-existent. Regulatory reliance procedures are adopted through different pathways. Regarding CT approval, innovative/complex CT designs are not prohibited but usually omitted. Some countries implemented adapted CT conducting during the COVID-19 pandemic. Early scientific advice meetings (HA-sponsor) are occasionally considered. Most countries are not formally ICH-joined.

CONCLUSIONS

LATAM regulations must adapt to new regulatory standards (FDA/EMA/ICH) through implementation of frequent updates, reliance/expedited procedures, early HA-sponsor interactions, innovative/complex CTs, mandatory phase-III reaching elimination, and decentralized elements for CT conducting.

A Survey of Industry Perceptions of Facilitated Regulatory Pathways in Drug Development in Australia

BACKGROUND

In Australia, facilitated regulatory pathways (FRPs) became available with the introduction of priority review (PR) in 2017 and provisional approval (PA) in 2018, which aim to facilitate expedited review and approval for novel medicines. The pathways were developed in consultation with a wide range of stakeholders and have since been utilised by pharmaceutical companies for various therapeutic products. However, the perceptions of the firsthand users of these pathways have not been evaluated in Australia.

OBJECTIVES

We have conducted a survey of Australian regulatory professionals aiming to solicit the perceived benefits, barriers to utilisation, shortcomings and proposed modifications to utilising these pathways. We have also solicited the users' perspective on key aspects of the pathways, including overall satisfaction, regulatory burden, availability and ease of use of guidelines, regulator support, impact on company strategy and recommendations for improvement.

METHODS

A survey was developed and distributed to Australian regulatory professionals from the pharmaceutical industry who had submission experience of new medicine applications via either PR, PA or the standard registration pathway to the Therapeutic Goods Administration (TGA). The questionnaire consisted of 44 questions with a skip logic and the option for free text comments.

RESULTS

We received responses from 16/42 companies that had utilised these new pathways. Nine respondents had experience with the PR pathway and ten with the PA pathway. The respondents were generally satisfied with the effectiveness of the PR process in expediting registration approvals, but they were ambivalent towards the PA pathway in terms of overall satisfaction and timelines. Respondents expressed a desire for further improvements in the speed of approval, earlier access for patients across various pathways and introduction of new Health Technology Assessment processes for medicines approved under PA.

CONCLUSION

While the FRPs have been an important and positive development in the Australian regulatory landscape, there remain opportunities for further improvements, some of which have been highlighted by this study and may help inform future regulatory decisions.

Regulatory Pathways Supporting Expedited Drug Development and Approval in ICH Member Countries

Regulators and pharmaceutical companies across the world are intensifying efforts to get increasingly complex and innovative drugs to patients with high unmet medical need in the shortest possible time frame. This article reviews pathways to expedite drug development and approval available in member countries of the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use and Australia. It is concluded that the increasing availability of expedited regulatory pathways and associated modernisation of regulatory systems changes the current regulatory paradigm and requires sponsors to rethink drug development and regulatory strategy. A transformation of the current sequence of regulatory submissions, favouring those countries/collaborations that are best regulatory equipped to make innovative medical need drugs available to patients in the shortest time frame is imminent.

Drugs quality supervision strategy of different distribution channels in pharmaceutical supply chain

Aiming at the dual-channel pharmaceutical supply chain, which consists of two distribution channels, offline medical institutions, and online e-commerce platforms, and taking into account the impact of different strategic choices made by relevant stakeholders on the drugs quality of different distribution channels, this article constructs an evolutionary game model involving the participation of government regulator, pharmaceutical enterprises, medical institutions, and pharmaceutical e-commerce companies. The stable equilibrium points of each participant's strategic choices are solved; the stability of strategic combination is analyzed by Lyapunov's first method, and MATLAB 2020b is used for simulation to verify the influence of each decision variable on the strategic choice of different participants. The results show that, first, the purpose of punishment is to ensure the drugs quality in the pharmaceutical supply chain, but when the fine is too high, it will restrain the economic behavior of pharmaceutical enterprises, which is not conducive to the performance of social responsibilities by other relevant participants. Second, the probability that government regulator strictly supervises the pharmaceutical supply chain and the probability that pharmaceutical enterprises provide high-quality drugs are negatively related to their additional cost. Third, whether medical institutions and pharmaceutical e-commerce companies choose inspection is affected by multiple factors such as inspection cost, sales price, and sales cost. Furthermore, when the penalty for non-inspection of pharmaceutical e-commerce companies is greater than the threshold F _m0, it can ensure that it chooses an inspection strategy. Finally, this article puts forward countermeasures and suggestions on the drugs quality supervision of different distribution channels in the pharmaceutical supply chain.

Drug Quality Co-regulation Supervision Strategy Considering Collusion Behavior With New Media Participation

The efficiency and level of drug quality supervision are highly related to the distorted or true reporting of new media, and the collusion or non-collusion of third-party testing agencies. Therefore, based on the co-regulation information platform, considering the strategic choices of local government, drug enterprises, third-party testing agencies and new media, this article constructs a four-party evolutionary game model of co-regulation supervision. The stable equilibrium points of each participant's strategic choices are solved. The stability of the strategic combination is analyzed by Lyapunov's first method, and Matlab 2020b is used for simulation analysis to verify the influence of each decision variable on different players' strategic choices. The results show that, firstly, new media's true reporting can make up for the lack of supervision of drug enterprises by local government, and the greater the impact of new media reporting, the more active drug enterprises will be to produce high-quality drugs. Secondly, non-collusion of third-party testing agencies can improve the self-discipline ability of drug enterprises, encourage new media to report truthfully, and play the role of co-regulation supervision. Furthermore, the greater the probability of new media's true reporting, the more local government tend to be stricter, and the probability of strict supervision is positively related to the central government's accountability. Finally, increasing penalty for producing low-quality drugs and collusion will help standardize the behavior of drug enterprises and third-party testing agencies. This article enriches and expands the theoretical basis of the drug quality co-regulation supervision and proposes corresponding countermeasures and suggestions.