By adopting a proactive business strategy for pharmacovigilance, biopharma firms can gain competitive advantage by delivering higher quality, lower cost products that the market requires, while improving quality of life for patients.
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Pharmacovigilance: A Practical Approach to Reshaping Patient Safety
1. • Cognizant 20-20 Insights
Pharmacovigilance: A Practical Approach
to Reshaping Patient Safety
Executive Summary • Rigorous analysis, interpretation and “real-
time” decision making on safety signals and
Ensuring the safety and efficacy of pharmaceu-
proactive remediation.
ticals and biotechnology products is one of the
top challenges in healthcare today. With drug • Leveraging pre- and post-marketing safety
recalls continuing to make headlines, consumers patterns and insights for clinical trial design
and other stakeholders across the healthcare and safety analysis to balance the risk-to-
ecosystem are demanding more oversight and benefit ratio of new products, therapeutic
regulators around the globe are responding to directions and early “go, no-go” decisions
these pressures by increasing their scrutiny and advancing drug candidates.
compliance requirements from the industry. • Allowing for convergence of the evolving
regulatory environment and the integrated
Despite the heightened focus on drug safety PV/safety operations and analytics into a source
and the direct link between reactive safety of innovation and competitive advantage.
and numerous risks to business — financial,
regulatory, brand loss, etc. — many biopharma- This paper will examine the key challenges faced by
ceutical companies today still have inefficient the industry, some of the practical approaches to
drug safety operations and detect safety signals overcome these challenges and tangible benefits
with suboptimal latency. Inefficiencies and redun- that can be realized in implementing proactive
dancies in pharmacovigilance operations result pharmacovigilance as a business strategy.
in higher costs and undermine efforts to signifi-
cantly increase overall performance. Global Drug Safety: Key Challenges
and Solution Approaches
As the pharmaceutical, biotechnology and
Based on our experience helping biopharma
medical device industries renew their focus on
companies with thorny PV challenges, we
becoming lean and more effective in bringing
recommend the following.
safer, newer products and therapeutic value to
patients in a timely manner, they must transform • Establish a safety and compliance culture.
their drug safety operations. Proactive phar- Until recently, many companies have adopted
macovigilance — enabled by globally integrated a piecemeal approach to managing safety
process, people and technologies — can help and compliance. What is required, however, is
the industry achieve its objectives. This can be a holistic vision and approach — one that
accomplished by: guides the whole company towards a culture
cognizant 20-20 insights | october 2011
2. of compliance — that allows the staff to business risk management that is tracked
understand that compliance makes good and monitored for proactive remediation.
business sense. Such a cultural change cannot
be brought to bear overnight and will need
> Make informed and early decisions on “go,
no-go” on products in the pipeline based
to be implemented in a phased but timely on signals/safety analytics from launched
manner. products and products in advanced clinical
> Establish the “safety first” vision and studies.
re-emphasize the need for proactive safety
and compliance, RiskMAPs and benefits that
> Implement specific actions and programs
that are focused on “getting it right the
can be realized with the entire team — both first time” to avoid intensive/overtime fire-
internal and partners — through structured fighting work and costs.
governance/communications from execu-
tive and senior management.
> Ensure safety risk assessment as part of
Case Study >>
Proactive Pharmacovigilance
Business Situation: A biopharmaceutical com- delivery model. Cases are processed around the
pany’s global safety organization wanted to close clock, around the world, with virtual teams of
its cases within a business day, regardless of the globally-based experts and operational teams
time or locale of origination. Cases were sometimes sharing data.
backing up because of holidays, time differences
and vacations and lack of available staff (capacity). Benefits: In collaboration with the client, we are
developing a globally integrated and networked
Challenge: Achieving the 24-hour resolution goal model of operating centers that are governed by
apparently would require the company to invest a single leadership team and a set of innovative
in new call centers, case processors and medical systems/tools. We are taking accountability for
reviewers around the globe as well as virtual delivering the cases in a timely manner with
tools and workflow technologies and dashboards/ increased quality and reduced cost of operations
portals. The centers would be expensive to set up, across a scope of activities including case
staff and operate. booking, processing, medical review and closure.
Because of our participation in global clinical data
Solution: The company elected instead to work management, we also can provide insights to help
with us to adopt an outcome-based service the client to anticipate potential issues.
A Better Approach to PV
Here is how we collaborate with this client to make PV more proactive.
Objective Solution
1 “Real-time” collection of appropriate data. Pre- and post-marketing safety data
collection across the globe is critical.
2 Proactive analysis of “safety signals” and Allows early dissemination of information
prepare robust “risk ma.nagement plan.” to patients, regulators and physicians.
3 Continuously meeting the evolving global Globally harmonized process, organization
regulatory requirements. and technology.
4 Leverage automation to enable decisions Invest in seaml.essly integrated technology
(workload management). with PV processes.
5 Increase operational efficiency and Ensure ability to distribute and process safety
reduced cost of operations. cases globally within one business day.
Figure 1
cognizant 20-20 insights 2
3. • Develop/refine capabilities to manage regu- • Technology. Many global life sciences enter-
latory changes in “real-time.” Regulators prises find that drug safety data is collected
across the globe have varying and continually in silos owned by different departments.
changing reporting requirements. To operate Correlating data and signals amongst these
globally, life sciences companies must meet usually incompatible systems with their lack of
these requirements as well as local timelines, standardized data is often a labor-intensive,
reporting formats and translation require- slow process at odds with today’s real-time
ments. orientation.
> A critical activity is keeping abreast of re- > Develop a centralized database that can
gional regulatory changes for registration integrate disparate data and information
and reporting. Life sciences companies from different sources internally, third par-
need a dedicated group of analysts and ties and physicians.
regulatory experts who follow evolving
trends and provide guidance on class-wide
> Ensure the ability to draw PV information/-
insights from case report forms (CRFs) on
Risk Evaluation and Mitigation Strategies a “real-time” basis, which may have signifi-
(REMS), alignment between global regula- cant value on managing risks.
tory agencies (ICH, EU, FDA, Japan, etc.),
post-marketing data collection, integration > Implement best practice
global work flow, analyti-
and analysis, guidance on training, policies
cal tools and dashboards
Life sciences
and reporting to all stakeholders.
for real-time insights and companies need a
• Implement globally aligned processes, decision making. comprehensive people
technology and governance.
• People/capability improve- capability review
• Processes. To gather comprehensive data, ment. Focusing core pro- that includes their
life sciences companies must manage global
drug safety operations and coordination of
fessional staff on mission- own expertise as well
critical activities will have
case processing through a “single harmonized a direct impact on cost and as complementing
process” with options for local customization efficiency and the ability partners’ expertise
to fit regulatory requirements. These include: to move towards “proac- that allows for a
> A seamless operating model that integrates tive patient safety.” Retain-
flexible and scalable
case processing volumes, types and sub- ing core/strategic activities
missions timelines (“demand”) with a glob- internally while leveraging staffing model with
ally flexible and scalable resourcing (”ca- global partners to provide the right skills that
pacity”) model, across the sponsor and the transactional/operational
global partners/service providers. case handling processes can adhere to their
more efficiently at high “proactive patient
> Identifying drug risk profiles using pre-
clinical and relevant post-marketing data
quality can allow for a robust safety” vision.
people strategy.
(e.g., population diversity and sample size)
before future clinical trials are designed. > Typical internal activities include:
> Following up with subjects after comple- – Regulatory interface/submissions related,
tion of trials and analysis of adverse-event- policies and reviews.
related patient withdrawals. – Risk management/integrated epidemio-
> Ensuring that comprehensive post-market- logical and statistical analysis, risk com-
ing process including regular case handling, munication and education systems and
reporting, labelling changes and active translation of pre-clinical data.
querying.
– Signal detection/reporting: REMS and
> Signal generation, evaluation, adequate processes, complex periodic reports and
trend analysis, documentation, disposition integrated review of all emerging signals.
and archival.
> Typical external, global partners-driven
> Assessment and review of risk/benefit anal- activities include:
ysis in the context of evolving risk-based
understanding. – Best practice adverse event intake and
harmonized processing that will allow for
continuous productivity improvements.
cognizant 20-20 insights 3
4. – Global safety database management of continuous productivity improvements,
and support. synergies between case processing and IT
automation/work flow technologies, globally
– Global aggregate shared governance and oversight that a
reporting/PSUR
process. partner can leverage.
– Report templates/- • Continuous improvement, innovation and
authoring tools. transformation. Applying Lean and Six
Sigma principles along with customized
– Medical review and quality management plans (QMP) can lead to
narrative writing. measurable productivity improvements across
Life sciences companies need a comprehensive case-handling processes (e.g., data entry,
people capability review that includes their own coding). Selected initiatives and benefits from
expertise as well as complementing partners’ such efforts include:
expertise that allows for a flexible and scalable > Improving the accuracy of data entry and
staffing model with the right skills that can adhere coding by 10% to 15%.
to their “proactive patient safety” vision. This will
also allow management of case volume fluctua- > Improving the accuracy of narratives by
30%.
tions by location and therapeutic class.
> Reducing the processing time for cases by
• Structured governance. Leading life sciences 20% to 50%, per case type.
companies are making a fundamental shift to
moving drug safety and clinical development > Reducing time to write narratives by 60%.
into a single functional team that has the • More collaboration and better compliance.
mandate and authority to define and enact Life sciences companies with global pharma-
integrated clinical and drug safety policies covigilance operations will be able to partici-
and processes throughout the enterprise (IT, pate more effectively in collaborative efforts
packaging, clinical operations, quality assur- with partners, academic organizations and
ance and biostatistics) and with partners. This regulatory bodies on such efforts as REMS and
means they must: address international regulatory initiatives on
> Implement a streamlined governance struc- a proactive/reactive basis.
ture that encompasses internal teams, col- • Smarter R&D decision making allowing for
laborators and partners around the world safety as a competitive asset. Proactive
with clearly identified forums, participants pharmacovigilance also enables life sciences
(RACI) and a robust communication plan. enterprises to make better decisions about
> Identify and empower a small data stan- current and planned research and develop-
dardization unit to continuously develop ment activities. They can correlate incoming
and manage the overall safety processes, post-market and trial signals data to related
tools and data standards to ensure that product and therapy development. Such corre-
policies, new process changes and tools are lations may indicate a planned trial should be
only implemented in compliance with these redesigned or that an effort should be ended
standards. because it appears unlikely to garner satisfac-
tory trial results. Data may also indicate where
The Rewards/Benefits of Proactive ancillary development efforts could benefit
Pharmacovigilance another patient population.
Developing an integrated and reshaped patient
Moving Forward
safety organization can provide significant
benefits. These include the following: Approaching pharmacovigilance as an enterprise-
wide business strategy still is not the norm but is
• Reduced total cost of ownership. Having quickly becoming so. Life sciences companies that
uniform, global processes, systems and embrace this shift will be able to meet near-term
governance will allow efficient data and infor- demands for drug safety assurances from a range
mation capture, analysis and real-time decision of global stakeholders. Most approved products
making that can directly lead to reduced cost are subjected to risk mitigation plans of some
of operations by >30% that is a combination sort. Simultaneously, life sciences companies are
cognizant 20-20 insights 4