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      Payers' Views of the Changes Arising through the Possible Adoption of Adaptive Pathways

      brief-report
      1 , 2 , 3 , 4 , 5 , 6 , 4 , 7 , 8 , 9 , 10 , 11 , 9 , 12 , 13 , 14 , 15 , 16 , 17 , 13 , 18 , 19 , 20 , 21 , 22 , 17 , 23 , 24 , 25 , 11 , 26 , 27 , 28 , 13 , 29 , 30
      Frontiers in Pharmacology
      Frontiers Media S.A.
      EMA, adaptive pathways, payers, marketing authorization, Europe

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          Abstract

          Payers are a major stakeholder in any considerations and initiatives concerning adaptive licensing of new medicinal products, also referred to as Medicines Adaptive Pathways to patients (MAPPs). Firstly, the scope and necessity of MAPPs need further scrutiny, especially with regard to the definition of unmet need. Conditional approval pathways already exist for new medicines for seriously debilitating or life-threatening diseases and only a limited number of new medicines are innovative. Secondly, MAPPs will result in new medicines on the market with limited evidence about their effectiveness and safety. Additional data are to be collected after approval. Consequently, adaptive pathways may increase the risk of exposing patients to ineffective or unsafe medicines. We have already seen medicines approved conventionally that subsequently proved ineffective or unsafe amongst a wider, more co-morbid population as well as medicines that could have been considered for approval under MAPPs but subsequently proved ineffective or unsafe in Phase III trials and were never licensed. Thirdly, MAPPs also put high demands on payers. Routine collection of patient level data is difficult with high transaction costs. It is not clear who will fund these. Other challenges for payers include shifts in the risk governance framework, implications for evaluation and HTA, increased complexity of setting prices, difficulty with ensuring equity in the allocation of resources, definition of responsibility and liability and implementation of stratified use. Exit strategies also need to be agreed in advance, including price reductions, rebates, or reimbursement withdrawals when price premiums are not justified. These issues and concerns will be discussed in detail including potential ways forward.

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          Most cited references41

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          Pathological complete response and long-term clinical benefit in breast cancer: the CTNeoBC pooled analysis.

          Pathological complete response has been proposed as a surrogate endpoint for prediction of long-term clinical benefit, such as disease-free survival, event-free survival (EFS), and overall survival (OS). We had four key objectives: to establish the association between pathological complete response and EFS and OS, to establish the definition of pathological complete response that correlates best with long-term outcome, to identify the breast cancer subtypes in which pathological complete response is best correlated with long-term outcome, and to assess whether an increase in frequency of pathological complete response between treatment groups predicts improved EFS and OS. We searched PubMed, Embase, and Medline for clinical trials of neoadjuvant treatment of breast cancer. To be eligible, studies had to meet three inclusion criteria: include at least 200 patients with primary breast cancer treated with preoperative chemotherapy followed by surgery; have available data for pathological complete response, EFS, and OS; and have a median follow-up of at least 3 years. We compared the three most commonly used definitions of pathological complete response--ypT0 ypN0, ypT0/is ypN0, and ypT0/is--for their association with EFS and OS in a responder analysis. We assessed the association between pathological complete response and EFS and OS in various subgroups. Finally, we did a trial-level analysis to assess whether pathological complete response could be used as a surrogate endpoint for EFS or OS. We obtained data from 12 identified international trials and 11 955 patients were included in our responder analysis. Eradication of tumour from both breast and lymph nodes (ypT0 ypN0 or ypT0/is ypN0) was better associated with improved EFS (ypT0 ypN0: hazard ratio [HR] 0·44, 95% CI 0·39-0·51; ypT0/is ypN0: 0·48, 0·43-0·54) and OS (0·36, 0·30-0·44; 0·36, 0·31-0·42) than was tumour eradication from the breast alone (ypT0/is; EFS: HR 0·60, 95% CI 0·55-0·66; OS 0·51, 0·45-0·58). We used the ypT0/is ypN0 definition for all subsequent analyses. The association between pathological complete response and long-term outcomes was strongest in patients with triple-negative breast cancer (EFS: HR 0·24, 95% CI 0·18-0·33; OS: 0·16, 0·11-0·25) and in those with HER2-positive, hormone-receptor-negative tumours who received trastuzumab (EFS: 0·15, 0·09-0·27; OS: 0·08, 0·03, 0·22). In the trial-level analysis, we recorded little association between increases in frequency of pathological complete response and EFS (R(2)=0·03, 95% CI 0·00-0·25) and OS (R(2)=0·24, 0·00-0·70). Patients who attain pathological complete response defined as ypT0 ypN0 or ypT0/is ypN0 have improved survival. The prognostic value is greatest in aggressive tumour subtypes. Our pooled analysis could not validate pathological complete response as a surrogate endpoint for improved EFS and OS. US Food and Drug Administration. Copyright © 2014 Elsevier Ltd. All rights reserved.
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            The Strength of Association Between Surrogate End Points and Survival in Oncology: A Systematic Review of Trial-Level Meta-analyses.

            The strength of association between surrogate end points and survival in oncology is important to understand because surrogate end points are frequently used in oncology clinical trials, supporting US Food and Drug Administration approvals and National Comprehensive Cancer Network guideline recommendations.
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              Bridging the efficacy-effectiveness gap: a regulator's perspective on addressing variability of drug response.

              Drug regulatory agencies should ensure that the benefits of drugs outweigh their risks, but licensed medicines sometimes do not perform as expected in everyday clinical practice. Failure may relate to lower than anticipated efficacy or a higher than anticipated incidence or severity of adverse effects. Here we show that the problem of benefit-risk is to a considerable degree a problem of variability in drug response. We describe biological and behavioural sources of variability and how these contribute to the long-known efficacy-effectiveness gap. In this context, efficacy describes how a drug performs under conditions of clinical trials, whereas effectiveness describes how it performs under conditions of everyday clinical practice. We argue that a broad range of pre- and post-licensing technologies will need to be harnessed to bridge the efficacy-effectiveness gap. Successful approaches will not be limited to the current notion of pharmacogenomics-based personalized medicines, but will also entail the wider use of electronic health-care tools to improve drug prescribing and patient adherence.
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                Author and article information

                Contributors
                Journal
                Front Pharmacol
                Front Pharmacol
                Front. Pharmacol.
                Frontiers in Pharmacology
                Frontiers Media S.A.
                1663-9812
                28 September 2016
                2016
                : 7
                : 305
                Affiliations
                [1] 1Pharmaceuticals Department, National Association of Statutory Health Insurance Funds Berlin, Germany
                [2] 2Department of Finance, University of Vienna Vienna, Austria
                [3] 3Independent Pharmaceutical Consultant Mellieha, Malta
                [4] 4National Institute for Health and Disability Insurance Bruxelles, Belgium
                [5] 5Zilveren Kruis Achmea Leiden, Netherlands
                [6] 6Department of Drug Management, Faculty of Health Sciences, Jagiellonian University Medical College Krakow, Poland
                [7] 7Clinical Pharmacology Service, Vall d'Hebron University Hospital, Fundació Institut Català de Farmacologia Barcelona, Spain
                [8] 8Medicinal Products Department, Health Insurance Institute of Slovenia Ljubljana, Slovenia
                [9] 9Department of Pathology, Forensic Medicine and Pharmacology, Faculty of Medicine, Vilnius University Vilnius, Lithuania
                [10] 10Medicines Reimbursement Department, National Health Insurance Fund Vilnius, Lithuania
                [11] 11National Health Care Institute Diemen, Netherlands
                [12] 12State Medicines Control Agency Vilnius, Lithuania
                [13] 13Health Economics Centre, University of Liverpool Management School Liverpool, UK
                [14] 14Scottish Medicines Consortium Glasgow, UK
                [15] 15Pharmaceutical Drug Department, Azienda Sanitaria Locale of Verona Verona, Italy
                [16] 16State Agency of Medicines Tartu, Estonia
                [17] 17Wissenschaftliches Institut der AOK (WIdO) Berlin, Germany
                [18] 18Ministry of Health and Social Welfare Banja Luka, Bosnia and Herzegovina
                [19] 19Department of Social Pharmacy, Medical Faculty, University Banja Luka Banja Luka, Bosnia and Herzegovina
                [20] 20Pharmacoeconomics and Health Technology Assessment, Department of Pharmacology and Therapeutics, Trinity College Dublin, Ireland
                [21] 21Department of Health Services, Ministry of Health Reykjavík, Iceland
                [22] 22Norweigian Directorate for Health Oslo, Norway
                [23] 23Institut de Recherche et Documentation en Economie de la Santé (IRDES) Paris, France
                [24] 24Department of Pharmaceutical and Pharmacological Sciences, KU Leuven Leuven, Belgium
                [25] 25Department of Pharmaceutical Affairs, Main Association of Austrian Social Insurance Institutions Vienna, Austria
                [26] 26Health Technology Assessment, Prices and Reimbursement Department, INFARMED - National Authority of Medicines and Health Products, I. P., Parque de Saúde de Lisboa Lisbon, Portugal
                [27] 27Department of Clinical Pharmacology, University Hospital Rijeka, Croatia
                [28] 28Barcelona Health Region, Catalan Health Service Barcelona, Spain
                [29] 29Department of Pharmacoepidemiology, Strathclyde Institute of Pharmacy and Biomedical Sciences, University of Strathclyde Glasgow, UK
                [30] 30Division of Clinical Pharmacology, Department of Laboratory Medicine, Karolinska Institutet, Karolinska University Hospital Huddinge Stockholm, Sweden
                Author notes

                Edited by: Dominique J. Dubois, Université libre de Bruxelles, Belgium

                Reviewed by: Wil Toenders, ToendersdeGroot BV, Netherlands; David Pruce, ICON, UK

                This article was submitted to Pharmaceutical Medicine and Outcomes Research, a section of the journal Frontiers in Pharmacology

                Article
                10.3389/fphar.2016.00305
                5039228
                b3f65598-1979-4339-af5a-4b9a317f3b18
                Copyright © 2016 Ermisch, Bucsics, Vella Bonanno, Arickx, Bybau, Bochenek, van de Casteele, Diogene, Fürst, Garuolienė, van der Graaff, Gulbinovič, Haycox, Jones, Joppi, Laius, Langner, Martin, Markovic-Pekovic, McCullagh, Magnusson, Nilsen, Selke, Sermet, Simoens, Sauermann, Schuurman, Ramos, Vlahovic-Palcevski, Zara and Godman.

                This is an open-access article distributed under the terms of the Creative Commons Attribution License (CC BY). The use, distribution or reproduction in other forums is permitted, provided the original author(s) or licensor are credited and that the original publication in this journal is cited, in accordance with accepted academic practice. No use, distribution or reproduction is permitted which does not comply with these terms.

                History
                : 01 July 2016
                : 26 August 2016
                Page count
                Figures: 0, Tables: 0, Equations: 0, References: 62, Pages: 9, Words: 8493
                Categories
                Pharmacology
                Perspective

                Pharmacology & Pharmaceutical medicine
                ema,adaptive pathways,payers,marketing authorization,europe
                Pharmacology & Pharmaceutical medicine
                ema, adaptive pathways, payers, marketing authorization, europe

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