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Risk Mitigation Excellence:
Innovative Models & Trends in Supporting
         REMS & RMP Programs




    Best Practices, LLC Strategic Benchmarking Research
                     REPORT SUMMARY
Table of Contents
EXECUTIVE BRIEF

STUDY BACKGROUND

BENCHMARK STUDY FINDINGS

      I. REMS Programs: Structures & Responsibilities
      II. Industry Experience in Developing & Deploying Successful REMS Plans
      III. Role of Market Research Groups in Supporting REMS Programs
      IV. REMS Approaches for New Products
      V. Leveraging Resources for REMS Efficiency & Excellence (Internal & External)
      VI. REMS Communication Plans: Current Challenges


      VII. RMP: Key Trends in Risk Management Plans for Succeeding in the European
           Market

APPENDIX: VOICES FROM THE FIELD

About Best Practices, LLC
Research Objectives & Methodology
New regulatory requirements, such as those outlined in the Food and Drug Administrations
Amendments Act of 2007, create ever greater compliance hurdles for pharmaceutical organizations.
As a result, pharmaceutical companies must develop innovative REMS program strategies to help
achieve both compliance and commercial objectives.

   Objectives:

   •   Examine how leading healthcare organizations:
        –   Structure their Risk Evaluation & Mitigation Strategy (REMS) teams
        –   Delegate key activities across functions
        –   Balance regulatory imperatives and commercial objectives associated with REMS products
        –   Use Market Research teams for maximum support and benefit
        –   Analyze Risk Management Plan (RMP) lessons from the European market to find collaborative
            opportunities and efficiencies between RMP and REMS operations


 Field Research & Insight Development:                                     Objective:
                                                               1. Provide Critical Insights into the
   Engaged 22 executives and managers from 19                  Quickly Evolving REMS Landscape
   companies in a performance benchmark
                                                               2. Highlight Opportunities for Key
                                                                  Support Functions to Deliver
   Analyzed quantitative and qualitative findings from         Leading Support to REMS Product
   several deep-dive interviews                                              Teams


                                                         3                       BEST PRACTICES,   ®
                                                                                                       LLC
Universe of Learning: Companies Participating in Study
 Research participants included 22 executives and managers from 19 leading
 pharmaceutical, biotech and medical device companies. All study participants
 contributed data through a field survey. Representatives from several benchmark
 organizations also provided additional insights through deep-dive interviews.

                             Participating Companies:




                                          4                    BEST PRACTICES,   ®
                                                                                     LLC
Most Participants Serve at Director Level or Above
Research data and insights were contributed by a veteran class of respondents, the vast
majority of who serve at the director level or higher. Throughout the healthcare industry,
a wide range of functions support REMS programs, a fact reflected in the diverse set of
functions from which study participants responded.

                          Research Participant Job Titles Include:

   • Senior VP, Chief Medical                         • Chief Medical Officer
       Officer (Regulatory / Safety)                  • Deputy Director, Medical Affairs
   • VP, Clinical Neurology & Drug Safety (R&D)       • Associate Director, Market Research
   • Head, Early Stage Commercialization (New         • Associate Director, Medical Education
       Products Marketing)                            • Associate Director, Commercial Regulatory
   • Senior Director, Global Product Strategy             Affairs
   • Senior Director, Market Research                 • Assistant Director, Global
   • Director, Risk Evaluation & Mitigation               Pharmacovigilance & Risk Management
       Strategy (U.S. Medical)                        • Senior Manager, Regulatory Affairs
   • Director, Market Research                        • Manager, Market Research
   • Director, Global Pharmacovigilance               • Manager, Regulatory Affairs
   • Director, Global Strategic Analytics             • Manager, Regulatory Affairs (QA / QC)
   • Medical Director, Risk Management (PV)           • Manager, Medical Affairs


                                                  5                             BEST PRACTICES,   ®
                                                                                                      LLC
Section Summary: Industry Experience with REMS Plans

Key data findings and insights from this section include:




  SAMPLE INSIGHT:
  SAMPLE INSIGHT:

  Companies Have Little Longitudinal Experience with REMS Products:: Most companies
  Companies Have Little Longitudinal Experience with REMS Products Most companies
  have relatively limited experience in implementing a REMS plan or executing a REMS throughout
  have relatively limited experience in implementing a REMS plan or executing a REMS throughout
  the entire product lifecycle. On average, benchmark companies have only deployed REMS plans
  the entire product lifecycle. On average, benchmark companies have only deployed REMS plans
  for 3.33 products since the advent of REMS several years ago. The most total REMS products
  for 3.33 products since the advent of REMS several years ago. The most total REMS products
  managed by one company was nine.
  managed by one company was nine.




                                                6
                                                                        BEST PRACTICES,   ®
                                                                                              LLC
SAMPLE DATA SLIDE:
“Specific Leadership Roles Vary Drastically per Activity”
 The chart below distills two critical insights into the nature of REMS management. First, a handful of
 different functions all help to lead REMS development and execution. Second, this lead function varies
 greatly depending on the activity. For example, while Regulatory Affairs often leads Medication Guide
 activities, it is not uncommon for a commercial group (e.g., Marketing / Brand Teams) to take the lead
 for Communication Plans.


            Q5. What group has the primary leadership role for each of the following REMS plan
                                   components? (Check all that apply)



                                           Regulatory       Medical   Clinical   Marketing    Market
                                     PV      Affairs        Affairs   Affairs    / Brands    Research   Other

      Medication Guides              14%      48%            38%        0%          0%          0%       0%

      Communication Plans            24%      10%            24%        0%         33%         0%       10%

      ETASU (e.g., diagnostic
      tests, physician training)     14%      19%            43%       14%          5%         0%        5%
      Implementation Plans (e.g.,
      certifying physicians,
      distributors; patient
      registries)                    29%      14%            19%       14%         14%         0%       10%
      Please indicate the group to
      which you belong:              14%      29%            19%        5%          5%         19%      10%


                                                                                                         (n=21)

                                                        7                                BEST PRACTICES,   ®
                                                                                                               LLC
SAMPLE DATA SLIDE:
“REMS Collaboration with Other Organizations Limited”
 Though not prevalent, collaboration between healthcare organizations – especially those
 with similar therapies – in the development of certain REMS Plan components is not
 unheard of. Thirty-five percent of companies report some level of such collaboration.


   Q23. Have you (either as an organization or as a market research group) collaborated with other
    companies with similar treatments in developing any facets of your REMS plan components?




                            Yes

                                        35%


                                                        65%             No




                                                                                            (n=17)

                                                   8
                                                                             BEST PRACTICES,   ®
                                                                                                   LLC
SAMPLE DATA SLIDE:
“Internal Research Drives Most REMS Preparation”
 Across all REMS Plan components, research is mostly done internally, with approximately 84% of
 Medication Guide research, 77% of Communication Plan research, and 73% of Implementation
 Plan research managed from within the organization. The most frequently outsourced research
 type is ETASU; roughly 30% of ETASU research is managed by external vendors.


      Q15. What percentage of research associated with the following REMS Plans are conducted
                         internally versus outsourced to external vendors?



                                        Internal Research (%)    External Research (%)

          Medication Guides                     83.9%                    16.1%

          Communication Plans                   76.9%                    23.1%

          ETASU (e.g., diagnostic
          tests, physician training)            69.6%                    30.4%
          Implementation Plans (e.g.,
          certifying physicians,
          distributors; patient
          registries)                           72.9%                    27.1%


                                                                                              (n=18)

                                                9                       BEST PRACTICES,   ®
                                                                                              LLC
SAMPLE DATA SLIDE:
“MR Groups Test Educational Material for RMPs”
 A majority (54%) of benchmark Market Research groups support RMPs by testing new
 labeling. The most common activity for Market Research teams is testing educational
 material, practiced at 62% of companies. A full 23% of study participants selected “N/A,”
 indicating a lack of MR involvement in the company’s RMP program.


            Q36. How are you using Market Research to support your Risk Minimization Plan?




   Testing educational material                                                         62%


          Testing new labeling                                                   54%


          Testing packaging
        communication of risk
                                                                         46%


                           N/A                     23%


                         Other      8%
                                                                                             (n=13)

                                                  10                      BEST PRACTICES,     ®
                                                                                                  LLC
Learn More About Our Company




 Our company is an internationally recognized thought leader in the field of best practice
 benchmarking®. We conduct research and consulting based on the simple yet profound
 principle that organizations can chart a course to superior economic performance by
 leveraging the best business practices, operating tactics and winning strategies of world-class
 companies.


                                   Best Practices, LLC
                             6350 Quadrangle Drive, Suite 200
                                  Chapel Hill, NC 27517
                                      919-403-0251
                                 best@best-in-class.com
                                 www.best-in-class.com
                                              11

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Risk Evaluation and Mitigation Strategy Excellence: Innovative Trends in Supporting REMS & RMP Programs

  • 1. Risk Mitigation Excellence: Innovative Models & Trends in Supporting REMS & RMP Programs Best Practices, LLC Strategic Benchmarking Research REPORT SUMMARY
  • 2. Table of Contents EXECUTIVE BRIEF STUDY BACKGROUND BENCHMARK STUDY FINDINGS I. REMS Programs: Structures & Responsibilities II. Industry Experience in Developing & Deploying Successful REMS Plans III. Role of Market Research Groups in Supporting REMS Programs IV. REMS Approaches for New Products V. Leveraging Resources for REMS Efficiency & Excellence (Internal & External) VI. REMS Communication Plans: Current Challenges VII. RMP: Key Trends in Risk Management Plans for Succeeding in the European Market APPENDIX: VOICES FROM THE FIELD About Best Practices, LLC
  • 3. Research Objectives & Methodology New regulatory requirements, such as those outlined in the Food and Drug Administrations Amendments Act of 2007, create ever greater compliance hurdles for pharmaceutical organizations. As a result, pharmaceutical companies must develop innovative REMS program strategies to help achieve both compliance and commercial objectives. Objectives: • Examine how leading healthcare organizations: – Structure their Risk Evaluation & Mitigation Strategy (REMS) teams – Delegate key activities across functions – Balance regulatory imperatives and commercial objectives associated with REMS products – Use Market Research teams for maximum support and benefit – Analyze Risk Management Plan (RMP) lessons from the European market to find collaborative opportunities and efficiencies between RMP and REMS operations Field Research & Insight Development: Objective: 1. Provide Critical Insights into the Engaged 22 executives and managers from 19 Quickly Evolving REMS Landscape companies in a performance benchmark 2. Highlight Opportunities for Key Support Functions to Deliver Analyzed quantitative and qualitative findings from Leading Support to REMS Product several deep-dive interviews Teams 3 BEST PRACTICES, ® LLC
  • 4. Universe of Learning: Companies Participating in Study Research participants included 22 executives and managers from 19 leading pharmaceutical, biotech and medical device companies. All study participants contributed data through a field survey. Representatives from several benchmark organizations also provided additional insights through deep-dive interviews. Participating Companies: 4 BEST PRACTICES, ® LLC
  • 5. Most Participants Serve at Director Level or Above Research data and insights were contributed by a veteran class of respondents, the vast majority of who serve at the director level or higher. Throughout the healthcare industry, a wide range of functions support REMS programs, a fact reflected in the diverse set of functions from which study participants responded. Research Participant Job Titles Include: • Senior VP, Chief Medical • Chief Medical Officer Officer (Regulatory / Safety) • Deputy Director, Medical Affairs • VP, Clinical Neurology & Drug Safety (R&D) • Associate Director, Market Research • Head, Early Stage Commercialization (New • Associate Director, Medical Education Products Marketing) • Associate Director, Commercial Regulatory • Senior Director, Global Product Strategy Affairs • Senior Director, Market Research • Assistant Director, Global • Director, Risk Evaluation & Mitigation Pharmacovigilance & Risk Management Strategy (U.S. Medical) • Senior Manager, Regulatory Affairs • Director, Market Research • Manager, Market Research • Director, Global Pharmacovigilance • Manager, Regulatory Affairs • Director, Global Strategic Analytics • Manager, Regulatory Affairs (QA / QC) • Medical Director, Risk Management (PV) • Manager, Medical Affairs 5 BEST PRACTICES, ® LLC
  • 6. Section Summary: Industry Experience with REMS Plans Key data findings and insights from this section include: SAMPLE INSIGHT: SAMPLE INSIGHT: Companies Have Little Longitudinal Experience with REMS Products:: Most companies Companies Have Little Longitudinal Experience with REMS Products Most companies have relatively limited experience in implementing a REMS plan or executing a REMS throughout have relatively limited experience in implementing a REMS plan or executing a REMS throughout the entire product lifecycle. On average, benchmark companies have only deployed REMS plans the entire product lifecycle. On average, benchmark companies have only deployed REMS plans for 3.33 products since the advent of REMS several years ago. The most total REMS products for 3.33 products since the advent of REMS several years ago. The most total REMS products managed by one company was nine. managed by one company was nine. 6 BEST PRACTICES, ® LLC
  • 7. SAMPLE DATA SLIDE: “Specific Leadership Roles Vary Drastically per Activity” The chart below distills two critical insights into the nature of REMS management. First, a handful of different functions all help to lead REMS development and execution. Second, this lead function varies greatly depending on the activity. For example, while Regulatory Affairs often leads Medication Guide activities, it is not uncommon for a commercial group (e.g., Marketing / Brand Teams) to take the lead for Communication Plans. Q5. What group has the primary leadership role for each of the following REMS plan components? (Check all that apply) Regulatory Medical Clinical Marketing Market PV Affairs Affairs Affairs / Brands Research Other Medication Guides 14% 48% 38% 0% 0% 0% 0% Communication Plans 24% 10% 24% 0% 33% 0% 10% ETASU (e.g., diagnostic tests, physician training) 14% 19% 43% 14% 5% 0% 5% Implementation Plans (e.g., certifying physicians, distributors; patient registries) 29% 14% 19% 14% 14% 0% 10% Please indicate the group to which you belong: 14% 29% 19% 5% 5% 19% 10% (n=21) 7 BEST PRACTICES, ® LLC
  • 8. SAMPLE DATA SLIDE: “REMS Collaboration with Other Organizations Limited” Though not prevalent, collaboration between healthcare organizations – especially those with similar therapies – in the development of certain REMS Plan components is not unheard of. Thirty-five percent of companies report some level of such collaboration. Q23. Have you (either as an organization or as a market research group) collaborated with other companies with similar treatments in developing any facets of your REMS plan components? Yes 35% 65% No (n=17) 8 BEST PRACTICES, ® LLC
  • 9. SAMPLE DATA SLIDE: “Internal Research Drives Most REMS Preparation” Across all REMS Plan components, research is mostly done internally, with approximately 84% of Medication Guide research, 77% of Communication Plan research, and 73% of Implementation Plan research managed from within the organization. The most frequently outsourced research type is ETASU; roughly 30% of ETASU research is managed by external vendors. Q15. What percentage of research associated with the following REMS Plans are conducted internally versus outsourced to external vendors? Internal Research (%) External Research (%) Medication Guides 83.9% 16.1% Communication Plans 76.9% 23.1% ETASU (e.g., diagnostic tests, physician training) 69.6% 30.4% Implementation Plans (e.g., certifying physicians, distributors; patient registries) 72.9% 27.1% (n=18) 9 BEST PRACTICES, ® LLC
  • 10. SAMPLE DATA SLIDE: “MR Groups Test Educational Material for RMPs” A majority (54%) of benchmark Market Research groups support RMPs by testing new labeling. The most common activity for Market Research teams is testing educational material, practiced at 62% of companies. A full 23% of study participants selected “N/A,” indicating a lack of MR involvement in the company’s RMP program. Q36. How are you using Market Research to support your Risk Minimization Plan? Testing educational material 62% Testing new labeling 54% Testing packaging communication of risk 46% N/A 23% Other 8% (n=13) 10 BEST PRACTICES, ® LLC
  • 11. Learn More About Our Company Our company is an internationally recognized thought leader in the field of best practice benchmarking®. We conduct research and consulting based on the simple yet profound principle that organizations can chart a course to superior economic performance by leveraging the best business practices, operating tactics and winning strategies of world-class companies. Best Practices, LLC 6350 Quadrangle Drive, Suite 200 Chapel Hill, NC 27517 919-403-0251 best@best-in-class.com www.best-in-class.com 11