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Khalil R, Macdonald JC, Gustafson A, Aljuburi L, Bisordi F, Beakes-Read G. Walking the talk in digital transformation of regulatory review. Front Med (Lausanne) 2023; 10:1233142. [PMID: 37564043 PMCID: PMC10411640 DOI: 10.3389/fmed.2023.1233142] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [Key Words] [Track Full Text] [Figures] [Journal Information] [Subscribe] [Scholar Register] [Received: 06/01/2023] [Accepted: 06/20/2023] [Indexed: 08/12/2023] Open
Abstract
Cloud-based regulatory platforms have the potential to substantially transform how regulatory submissions are developed, transmitted, and reviewed across the full life cycle of drug development. The benefits of cloud-based submission and review include accelerating critical therapies to patients in need globally and efficiency gains for both drug developers and regulators. The key challenge is turning the theoretical promise of cloud-based regulatory platforms into reality to further the application of technology in the regulatory processes. In this publication we outline regulatory policy journeys needed to effect the changes in the external environment that would allow for use of a cloud-based technology, discuss the prerequisites to successfully navigate the policy journeys, and elaborate on future possibilities when adoption of cloud-based regulatory technologies is achieved.
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Beierle J, Algorri M, Cortés M, Cauchon NS, Lennard A, Kirwan JP, Oghamian S, Abernathy MJ. Structured content and data management-enhancing acceleration in drug development through efficiency in data exchange. AAPS OPEN 2023; 9:11. [PMID: 37193559 PMCID: PMC10164450 DOI: 10.1186/s41120-023-00077-6] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [Key Words] [Track Full Text] [Figures] [Journal Information] [Subscribe] [Scholar Register] [Received: 02/01/2023] [Accepted: 03/27/2023] [Indexed: 05/18/2023] Open
Abstract
Innovation in pharmaceutical therapeutics is critical for the treatment of serious diseases with unmet medical need. To accelerate the approval of these innovative treatments, regulatory agencies throughout the world are increasingly adopting the use of expedited pathways and collaborative regulatory reviews. These pathways are primarily driven by promising clinical results but become challenging for Chemistry, Manufacturing, and Controls (CMC) information in regulatory submissions. Condensed and shifting timelines present constraints that require new approaches to the management of regulatory filings. This article emphasizes technological advances that have the potential to tackle the underlying inefficiencies in the regulatory filing eco-system. Structured content and data management (SCDM) is highlighted as a foundation for technologies that can ease the burden on both sponsors and regulators by streamlining data usage in regulatory submissions. Re-mapping of information technology infrastructure will improve the usability of data by moving away from document-based filings towards electronic data libraries. Although the inefficiencies of the current regulatory filing eco-system are more evident for products that are filed using expedited pathways, it is envisioned that the more widespread adoption of SCDM, across standard filing and review processes, will improve overall efficiency and speed in the compilation and review of regulatory submissions.
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Affiliation(s)
- Jill Beierle
- Department of Global Regulatory Affairs and Strategy – CMC, Amgen Inc, CA 91320 Thousand Oaks, USA
| | - Marquerita Algorri
- Department of Global Regulatory Affairs and Strategy – CMC, Amgen Inc, CA 91320 Thousand Oaks, USA
| | - Marisol Cortés
- Department of Physiology, Johns Hopkins University School of Medicine, Baltimore, MD 21205 USA
| | - Nina S. Cauchon
- Department of Global Regulatory Affairs and Strategy – CMC, Amgen Inc, CA 91320 Thousand Oaks, USA
| | - Andrew Lennard
- Department of Global Regulatory Affairs and Strategy – CMC, Amgen Inc, CA 91320 Thousand Oaks, USA
| | - J. Paul Kirwan
- Department of Global Regulatory Affairs and Strategy – CMC, Amgen Inc, CA 91320 Thousand Oaks, USA
| | - Shirley Oghamian
- Department of Global Regulatory Affairs and Strategy – CMC, Amgen Inc, CA 91320 Thousand Oaks, USA
| | - Michael J. Abernathy
- Department of Global Regulatory Affairs and Strategy – CMC, Amgen Inc, CA 91320 Thousand Oaks, USA
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3
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Advances in application and innovation of microfluidic platforms for pharmaceutical analysis. Trends Analyt Chem 2023. [DOI: 10.1016/j.trac.2023.116951] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Indexed: 01/29/2023]
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Dynamic Regulatory Assessment: evolving the European Regulatory Framework for the Benefit of Patients and Public Health-an EFPIA View. Clin Ther 2021; 44:132-138. [PMID: 34848082 PMCID: PMC9754899 DOI: 10.1016/j.clinthera.2021.11.001] [Citation(s) in RCA: 8] [Impact Index Per Article: 2.7] [Reference Citation Analysis] [Abstract] [Key Words] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Received: 10/15/2021] [Revised: 11/03/2021] [Accepted: 11/04/2021] [Indexed: 11/23/2022]
Abstract
The European Union regulatory framework supports development, review, authorization, and maintenance of medicines to benefit public health; however, many elements are 2 decades old and undergoing review. Scrutiny was triggered by the coronavirus disease 2019 pandemic, the need to support future innovative medicines, the digital transformation of data exchange, and the need to address efficiency and capacity limitations. There are also ongoing evolutions in regulatory science for medicines (eg, cell and gene therapies), medical device combinations, and software, as well as the need to fully leverage contemporary information technology (IT). Important initiatives to address these challenges include the European Medicines Agency (EMA) Regulatory Science Strategy,1 the EU Regulatory Network Strategy,2 and the Big Data Steering Group,3 alongside European Commission-led initiatives such as the Pharmaceutical Strategy.4 Dynamic regulatory assessment (DRA) is a concept that seeks to integrate these various elements to re-imagine regulatory review interactions across the product life cycle. DRA calls for iterative regulatory dialogue, data submission, and evidence assessment, enabled by contemporary IT. DRA will facilitate iterative interaction and data assessment as it accumulates over a product's life cycle, bringing significant efficiencies for all product types. The DRA concept primarily evolved through dialogue within working groups of the European Federation of Pharmaceutical Industries and Associations. This article describes the long-term vision of the European Federation of Pharmaceutical Industries and Associations and outlines important strategic elements of progress, including: aligning on a multi-stakeholder vision for DRA in the European Union and across regions; leveraging learnings from ongoing initiatives; and advancing IT, governance, and standards considerations. Ultimately, DRA should consider outcomes that deliver optimal benefits for patients in the European Union and worldwide.
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Ahluwalia K, Abernathy MJ, Beierle J, Cauchon NS, Cronin D, Gaiki S, Lennard A, Mady P, McGorry M, Sugrue-Richards K, Xue G. The Future of CMC Regulatory Submissions: Streamlining Activities Using Structured Content and Data Management. J Pharm Sci 2021; 111:1232-1244. [PMID: 34610323 DOI: 10.1016/j.xphs.2021.09.046] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [Key Words] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Received: 08/26/2021] [Revised: 09/29/2021] [Accepted: 09/29/2021] [Indexed: 11/25/2022]
Abstract
Recent advancements in data engineering, data science, and secure cloud storage can transform the current state of global Chemistry, Manufacturing, and Controls (CMC) regulatory activities to automated online digital processes. Modernizing regulatory activities will facilitate simultaneous global submissions and concurrent collaborative reviews, significantly reducing global licensing timelines and variability in globally registered product details. This article describes advancements made within the pharmaceutical industry from theoretical concepts to utilization of structured content and data in CMC submissions. The term Structured Content and Data Management (SCDM) outlines the end-to-end scientific data lifecycle from capture in source systems, aggregation into a consolidated repository, and transformation into semantically structured blocks with metadata defining relationships between scientific data and business contexts. Automation of regulatory authoring (termed Structured Content Authoring) is feasible because SCDM makes data both human and machine readable. It will offer health authorities access to the digital data beyond the current standard of PDF documents and, for a review process, SCDM would "enrich the effectiveness, efficiency, and consistency of regulatory quality oversight" (Yu et al., 2019). SCDM is a novel solution for content and data management in regulatory submissions and can enable faster access to critical therapies worldwide.
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Affiliation(s)
- Kabir Ahluwalia
- Department of Global Regulatory Affairs - CMC, Amgen, Inc., One Amgen Center Drive, Thousand Oaks, CA 91320, USA; University of Southern California, School of Pharmacy, 1985 Zonal Ave, Los Angeles, CA 90089, USA
| | - Michael J Abernathy
- Department of Global Regulatory Affairs - CMC, Amgen, Inc., One Amgen Center Drive, Thousand Oaks, CA 91320, USA
| | - Jill Beierle
- Department of Global Regulatory Affairs - CMC, Amgen, Inc., One Amgen Center Drive, Thousand Oaks, CA 91320, USA
| | - Nina S Cauchon
- Department of Global Regulatory Affairs - CMC, Amgen, Inc., One Amgen Center Drive, Thousand Oaks, CA 91320, USA.
| | - David Cronin
- Cognition Corporation, 24 Hartwell Ave, Lexington, MA 02421, USA
| | - Sheetal Gaiki
- Biotherapeutic Development & Supply, Janssen Pharmaceuticals, 1000 Route 202 South, Raritan, NJ 08807, USA
| | - Andrew Lennard
- Department of Global Regulatory Affairs - CMC; Amgen Ltd, 1 Uxbridge Business Park, Sanderson Road, Uxbridge UB8 1DH, United Kingdom
| | - Pradeep Mady
- Product Quality Management, Janssen Pharmaceuticals, 1000 Route 202 South, Raritan, NJ 08807, USA
| | - Mike McGorry
- Biotherapeutic Development & Supply, Janssen Pharmaceuticals, Barnahely, Ringaskiddy, Co.Cork, Ireland
| | - Kathleen Sugrue-Richards
- Department of Global Regulatory Affairs - CMC, Amgen Inc., 40 Technology Way West Greenwich, RI 02817, USA
| | - Gang Xue
- Biotherapeutic Development & Supply, Janssen Pharmaceuticals, 200 Great Valley Pkwy, Malvern, PA 10355, USA
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Hartl D, de Luca V, Kostikova A, Laramie J, Kennedy S, Ferrero E, Siegel R, Fink M, Ahmed S, Millholland J, Schuhmacher A, Hinder M, Piali L, Roth A. Translational precision medicine: an industry perspective. J Transl Med 2021; 19:245. [PMID: 34090480 PMCID: PMC8179706 DOI: 10.1186/s12967-021-02910-6] [Citation(s) in RCA: 32] [Impact Index Per Article: 10.7] [Reference Citation Analysis] [Abstract] [Key Words] [MESH Headings] [Grants] [Track Full Text] [Download PDF] [Figures] [Journal Information] [Subscribe] [Scholar Register] [Received: 02/02/2021] [Accepted: 05/25/2021] [Indexed: 02/08/2023] Open
Abstract
In the era of precision medicine, digital technologies and artificial intelligence, drug discovery and development face unprecedented opportunities for product and business model innovation, fundamentally changing the traditional approach of how drugs are discovered, developed and marketed. Critical to this transformation is the adoption of new technologies in the drug development process, catalyzing the transition from serendipity-driven to data-driven medicine. This paradigm shift comes with a need for both translation and precision, leading to a modern Translational Precision Medicine approach to drug discovery and development. Key components of Translational Precision Medicine are multi-omics profiling, digital biomarkers, model-based data integration, artificial intelligence, biomarker-guided trial designs and patient-centric companion diagnostics. In this review, we summarize and critically discuss the potential and challenges of Translational Precision Medicine from a cross-industry perspective.
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Affiliation(s)
- Dominik Hartl
- Novartis Institutes for BioMedical Research, Basel, Switzerland.
- Department of Pediatrics I, University of Tübingen, Tübingen, Germany.
| | - Valeria de Luca
- Novartis Institutes for BioMedical Research, Basel, Switzerland
| | - Anna Kostikova
- Novartis Institutes for BioMedical Research, Basel, Switzerland
| | - Jason Laramie
- Novartis Institutes for BioMedical Research, Cambridge, MA, USA
| | - Scott Kennedy
- Novartis Institutes for BioMedical Research, Cambridge, MA, USA
| | - Enrico Ferrero
- Novartis Institutes for BioMedical Research, Basel, Switzerland
| | - Richard Siegel
- Novartis Institutes for BioMedical Research, Basel, Switzerland
| | - Martin Fink
- Novartis Institutes for BioMedical Research, Basel, Switzerland
| | | | | | | | - Markus Hinder
- Novartis Institutes for BioMedical Research, Basel, Switzerland
| | - Luca Piali
- Roche Innovation Center Basel, Basel, Switzerland
| | - Adrian Roth
- Roche Innovation Center Basel, Basel, Switzerland
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Macdonald JC, Isom DC, Evans DD, Page KJ. Digital Innovation in Medicinal Product Regulatory Submission, Review, and Approvals to Create a Dynamic Regulatory Ecosystem-Are We Ready for a Revolution? Front Med (Lausanne) 2021; 8:660808. [PMID: 34109196 PMCID: PMC8183468 DOI: 10.3389/fmed.2021.660808] [Citation(s) in RCA: 2] [Impact Index Per Article: 0.7] [Reference Citation Analysis] [Abstract] [Key Words] [Track Full Text] [Download PDF] [Figures] [Journal Information] [Subscribe] [Scholar Register] [Received: 01/29/2021] [Accepted: 04/12/2021] [Indexed: 11/14/2022] Open
Abstract
The pace of scientific progress over the past several decades within the biological, drug development, and the digital realm has been remarkable. The’omics revolution has enabled a better understanding of the biological basis of disease, unlocking the possibility of new products such as gene and cell therapies which offer novel patient centric solutions. Innovative approaches to clinical trial designs promise greater efficiency, and in recent years, scientific collaborations, and consortia have been developing novel approaches to leverage new sources of evidence such as real-world data, patient experience data, and biomarker data. Alongside this there have been great strides in digital innovation. Cloud computing has become mainstream and the internet of things and blockchain technology have become a reality. These examples of transformation stand in sharp contrast to the current inefficient approach for regulatory submission, review, and approval of medicinal products. This process has not fundamentally changed since the beginning of medicine regulation in the late 1960s. Fortunately, progressive initiatives are emerging that will enrich and streamline regulatory decision making and deliver patient centric therapies, if they are successful in transforming the current transactional construct and harnessing scientific and technological advances. Such a radical transformation will not be simple for both regulatory authorities and company sponsors, nor will progress be linear. We examine the shortcomings of the current system with its entrenched and variable business processes, offer examples of progress as catalysts for change, and make the case for a new cloud based model. To optimize navigation toward this reality we identify implications and regulatory design questions which must be addressed. We conclude that a new model is possible and is slowly emerging through cumulative change initiatives that question, challenge, and redesign best practices, roles, and responsibilities, and that this must be combined with adaptation of behaviors and acquisition of new skills.
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Affiliation(s)
- Judith C Macdonald
- Global Regulatory Policy and Intelligence, Pfizer, Tadworth, United Kingdom
| | - David C Isom
- Global Regulatory Policy and Intelligence, Pfizer, Groton, CT, United States
| | - Daniel D Evans
- Global Biometrics and Data Management, Pfizer, Sandwich, United Kingdom
| | - Katy J Page
- Global Regulatory Operations, Pfizer, Sandwich, United Kingdom
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Regulatory Agilities in the Time of COVID-19: Overview, Trends, and Opportunities. Clin Ther 2020; 43:124-139. [PMID: 33353762 PMCID: PMC7703519 DOI: 10.1016/j.clinthera.2020.11.015] [Citation(s) in RCA: 8] [Impact Index Per Article: 2.0] [Reference Citation Analysis] [Abstract] [Key Words] [Track Full Text] [Download PDF] [Figures] [Journal Information] [Subscribe] [Scholar Register] [Received: 10/09/2020] [Revised: 11/20/2020] [Accepted: 11/22/2020] [Indexed: 11/23/2022]
Abstract
Purpose Crucial steps have been adopted by health and regulatory authorities around the world to respond to the COVID-19 pandemic. This review aims to highlight these steps by providing an overview of the regulatory approaches adopted during the onset of the pandemic, provide an assessment of observed trends, and offer some reflections and proposals to leverage learnings and opportunities from this current pandemic. Methods Documents and informational materials on regulating the development and management of medical products during the COVID-19 pandemic were collected and classified. These materials were sourced from official websites and press releases from health authorities and international bodies from selected markets across the globe, and covered the period between January and July 2020. Additional information to support this study was gathered through a literature review and analysis of related data available from the public domain, and was complemented with the authors' personal experience. Findings Communication has been vital in addressing the impact of COVID-19. A total of 1705 documents and informational materials related to health or regulatory response to the COVID-19 pandemic were gathered. Of these, 343 (around 20%) were identified as regulatory agilities. These agile approaches were classified into 3 categories, namely, where health and regulatory authorities had: (1) facilitated product management across the entire lifecycle, notably in expediting medical product use for COVID-19, ensuring the continuity of clinical trials, and addressing supply chain issues; (2) strengthened international cooperation; and (3) addressed regulatory burden with the adoption of electronic and digital tools. Implications While many regulatory measures have been introduced temporarily as a response to the COVID-19 crisis, there are opportunities for leveraging an understanding from these approaches in order to collectively achieve more efficient regulatory systems and to mitigate and address the impact of COVID-19 and further future-proof the regulatory environment.
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Wegner M. New Approaches to Regulatory Innovation Emerging During the Crucible of COVID-19 : In Responding to a Global Health Crisis, Industry is Discovering New, Efficient Ways of Meeting Objectives. Ther Innov Regul Sci 2020; 55:463-466. [PMID: 33237474 PMCID: PMC7687208 DOI: 10.1007/s43441-020-00239-8] [Citation(s) in RCA: 3] [Impact Index Per Article: 0.8] [Reference Citation Analysis] [Abstract] [Key Words] [Track Full Text] [Download PDF] [Journal Information] [Subscribe] [Scholar Register] [Received: 08/20/2020] [Accepted: 10/29/2020] [Indexed: 11/01/2022]
Abstract
The urgency and impact of the ongoing COVID-19 pandemic are changing global drug development and regulatory processes. The need for speed to understand the virus and develop new vaccines, medicines, and therapies for patients has provided unprecedented learning opportunities and revealed how the pharmaceutical industry can improve upon traditional processes. To stay competitive while remaining compliant with agency regulations and guidance, companies need to implement new process/tools that allow for more flexible work models, consider expanding the use of decentralized/hybrid trials, and capitalize on the use of real-world evidence (RWE) and cloud-based data systems. In addition, regulatory agencies should retain the agility exhibited during current reviews of potential new therapies, applying this momentum to other areas of unmet medical need. Further, agencies should consider a globally acceptable application platform. This article, by the Pharmaceuticals' Head of Regulatory Affairs at Bayer AG, examines how impacts of the COVID-19 crisis will continue beyond the pandemic period to the benefit of patients, drug developers, regulators, clinicians, and caregivers.
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Nam K, Larholt K, Hirsch G, Beninger P, Fritsche D, Shoda D, Ferguson J, Bourgeois FT, Palmer D, Katz K, Courtney MW. Dynamic Dossier in the Cloud: A Sociotechnical Architecture for a Real-Time and Metrics-Based Data Tracking System with Gene and Cell Therapies as a Case Study. Ther Innov Regul Sci 2020; 55:388-400. [PMID: 33118143 PMCID: PMC7864828 DOI: 10.1007/s43441-020-00227-y] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [Abstract] [Key Words] [MESH Headings] [Grants] [Track Full Text] [Download PDF] [Figures] [Journal Information] [Subscribe] [Scholar Register] [Received: 05/03/2020] [Accepted: 10/09/2020] [Indexed: 01/19/2023]
Abstract
Background Data sharing among stakeholders in the development, access, and use of drug therapies is critical but the current system and process are inefficient. Methods We take a Systems Engineering approach with a realistic use case to propose a scalable design for multi-stakeholder data sharing. Results We make three major contributions to the drug development and healthcare communities: first, a methodology for developing a multi-stakeholder data sharing system, with its focus on high-level requirements that influence the design of the system architecture and technology choice; second, the development of a realistic use case for long-term patient and therapy data tracking and sharing in the use of potentially curative and durable gene and cell therapies. Further, a bridge for the ‘awareness gap’ was found between the payer (Payer is organization which takes care of financial and operational aspects (which include insurance plans, provider network) of providing health care to US citizens. Or refer to health care insurers.) and the regulator communities by illustrating the common data tracking needs, which highlights the need for coordinated data activities; and third, a proposed system architecture for scalable, multi-stakeholder data sharing. Next steps are briefly discussed. Conclusion We present a system design for multiple stakeholders such as the payer, the regulator, the developer (drug manufacturer), and the healthcare provider to share data for their decision-making. The stakeholder community would benefit from collaboratively moving the system development proposal forward for efficient and cost-effective data sharing.
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Affiliation(s)
- Kevin Nam
- MIT Lincoln Laboratory, Massachusetts Institute of Technology, 244 Wood St., Lexington, MA 02421 USA
| | - Kay Larholt
- MIT Center for Biomedical Innovation, Massachusetts Institute of Technology, 77 Massachusetts Avenue, Building E19-604, Cambridge, MA 02139 USA
| | - Gigi Hirsch
- MIT Center for Biomedical Innovation, Massachusetts Institute of Technology, 77 Massachusetts Avenue, Building E19-604, Cambridge, MA 02139 USA
| | - Paul Beninger
- Public Health & Community Medicine, Tufts University School of Medicine, Boston, USA
| | - David Fritsche
- MIT Center for Biomedical Innovation, Massachusetts Institute of Technology, 77 Massachusetts Avenue, Building E19-604, Cambridge, MA 02139 USA
| | - Diane Shoda
- Greyscaling LLC, 3722 Las Vegas Blvd S, Unit 2111, Las Vegas, NV 89158 USA
| | - John Ferguson
- Pharmacovigilance Specialty Care, Sanofi-Genzyme Business Unit, 50 Binney St., Cambridge, MA 02142 USA
| | - Florence T. Bourgeois
- MIT Lincoln Laboratory, Massachusetts Institute of Technology, 244 Wood St., Lexington, MA 02421 USA
- Harvard Medical School, 300 Longwood Avenue Boston, Boston, MA 02115 USA
| | - Donna Palmer
- MIT Center for Biomedical Innovation, Massachusetts Institute of Technology, 77 Massachusetts Avenue, Building E19-604, Cambridge, MA 02139 USA
| | - Karen Katz
- FoCUS Project, NEWDIGS, MIT Center for Biomedical Innovation, Massachusetts Institute of Technology, 77 Massachusetts Avenue, Building E19, Cambridge, MA 02139 USA
| | - Matt W. Courtney
- FoCUS Project, NEWDIGS, MIT Center for Biomedical Innovation, Massachusetts Institute of Technology, 77 Massachusetts Avenue, Building E19, Cambridge, MA 02139 USA
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12
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Stewart J, Honig P, AlJuburi L, Autor D, Berger S, Brady P, Fitton H, Garner C, Garvin M, Hukkelhoven M, Kowalski R, Milligan S, O'Dowd L, Reilly E, Roberts K, Robertson AS, Taisey M, Thakkar R, Van Baelen K, Wegner M. COVID-19: A Catalyst to Accelerate Global Regulatory Transformation. Clin Pharmacol Ther 2020; 109:1390-1392. [PMID: 32990986 PMCID: PMC7536913 DOI: 10.1002/cpt.2046] [Citation(s) in RCA: 13] [Impact Index Per Article: 3.3] [Reference Citation Analysis] [Track Full Text] [Download PDF] [Journal Information] [Subscribe] [Scholar Register] [Received: 07/02/2020] [Accepted: 08/29/2020] [Indexed: 11/10/2022]
Affiliation(s)
| | | | | | | | - Susan Berger
- Bristol-Myers Squibb, Princeton, New Jersey, USA
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