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      Integrating risk minimization planning throughout the clinical development and commercialization lifecycle: an opinion on how drug development could be improved

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          Abstract

          Pharmaceutical risk minimization programs are now an established requirement in the regulatory landscape. However, pharmaceutical companies have been slow to recognize and embrace the significant potential these programs offer in terms of enhancing trust with health care professionals and patients, and for providing a mechanism for bringing products to the market that might not otherwise have been approved. Pitfalls of the current drug development process include risk minimization programs that are not data driven; missed opportunities to incorporate pragmatic methods and market-based insights, outmoded tools and data sources, lack of rapid evaluative learning to support timely adaption, lack of systematic approaches for patient engagement, and questions on staffing and organizational infrastructure. We propose better integration of risk minimization with clinical drug development and commercialization work streams throughout the product lifecycle. We articulate a vision and propose broad adoption of organizational models for incorporating risk minimization expertise into the drug development process. Three organizational models are discussed and compared: outsource/external vendor, embedded risk management specialist model, and Center of Excellence.

          Most cited references28

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          Pragmatic measures: what they are and why we need them.

          Pragmatic measures are important to facilitate implementation and dissemination, address stakeholder issues, and drive quality improvement. This paper proposes necessary and recommended criteria for pragmatic measures, provides examples of projects to develop and identify such measures, addresses potential concerns about these recommendations, and identifies areas for future research and application. Key criteria for pragmatic measures include importance to stakeholders in addition to researchers, low burden, broad applicability, sensitivity to change, and being actionable. Examples of pragmatic measures are provided, including ones for different settings (e.g., primary care, hospital) and levels (e.g., individual, practitioner, setting) that illustrate approaches to produce broad-scale dissemination and the development of brief, standardized measures for use in pragmatic studies. There is an important need for pragmatic measures to facilitate pragmatic research, guide quality improvement, and inform progress on public health goals, but few examples are currently available. Development and evaluation of pragmatic measures and metrics would provide useful resources to advance science, policy, and practice. Copyright © 2013. Published by Elsevier Inc. on behalf of American Journal of Medicine.
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            Era of faster FDA drug approval has also seen increased black-box warnings and market withdrawals.

            After approval, many prescription medications that patients rely on subsequently receive new black-box warnings or are withdrawn from the market because of safety concerns. We examined whether the frequency of these safety problems has increased since 1992, when the Prescription Drug User Fee Act, legislation designed to accelerate the drug approval process at the Food and Drug Administration, was passed. We found that drugs approved after the act's passage were more likely to receive a new black-box warning or be withdrawn than drugs approved before its passage (26.7 per 100.0 drugs versus 21.2 per 100.0 drugs at up to sixteen years of follow-up). We could not establish causality, however. Our findings suggest the need for reforms to reduce patients' exposure to unsafe drugs, such as a statement or symbol in the labeling, medication guides for patients, and marketing materials indicating that a drug was approved only recently.
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              The 5 R's: an emerging bold standard for conducting relevant research in a changing world.

              Research often fails to find its way into practice or policy in a timely way, if at all. Given the current pressure and pace of health care change, many authors have recommended different approaches to make health care research more relevant and rapid. An emerging standard for research, the "5 R's" is a synthesis of recommendations for care delivery research that (1) is relevant to stakeholders; (2) is rapid and recursive in application; (3) redefines rigor; (4) reports on resources required; and (5) is replicable. Relevance flows from substantive ongoing participation by stakeholders. Rapidity and recursiveness occur through accelerated design and peer reviews followed by short learning/implementation cycles through which questions and answers evolve over time. Rigor is the disciplined conduct of shared learning within the specific changing situations in diverse settings. Resource reporting includes costs of interventions. Replicability involves designing for the factors that may affect subsequent implementation of an intervention or program in different contexts. These R's of the research process are mutually reinforcing and can be supported by training that fosters collaborative and reciprocal relationships among researchers, implementers, and other stakeholders. In sum, a standard is emerging for research that is both rigorous and relevant. Consistent and bold application will increase the value, timeliness, and applicability of the research enterprise.
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                Author and article information

                Journal
                Ther Clin Risk Manag
                Ther Clin Risk Manag
                Therapeutics and Clinical Risk Management
                Therapeutics and Clinical Risk Management
                Dove Medical Press
                1176-6336
                1178-203X
                2015
                26 February 2015
                : 11
                : 339-348
                Affiliations
                [1 ]Colorado School of Public Health, University of Colorado, Anschutz Medical Campus, Aurora, CO, USA
                [2 ]EMD Serono, Inc, Rockland, MA, USA
                Author notes
                Correspondence: Elaine H Morrato, Colorado School of Public Health, University of Colorado, Anschutz Medical Campus, 13001 East 17th Place, Mail Stop B119, Aurora, CO 80045, USA, Tel +1 303 724 1535, Fax +1 303 724 1939, Email elaine.morrato@ 123456ucdenver.edu
                Article
                tcrm-11-339
                10.2147/TCRM.S78202
                4348129
                9360b067-3033-4fa3-8222-592c7d0a5db2
                © 2015 Morrato and Smith. This work is published by Dove Medical Press Limited, and licensed under Creative Commons Attribution – Non Commercial (unported, v3.0) License

                The full terms of the License are available at http://creativecommons.org/licenses/by-nc/3.0/. Non-commercial uses of the work are permitted without any further permission from Dove Medical Press Limited, provided the work is properly attributed.

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                Medicine
                pharmaceuticals,drug development,risk management,organizational design
                Medicine
                pharmaceuticals, drug development, risk management, organizational design

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