eucomed health governance, 19 th april 2012 dario pirovano consultant regulatory affairs - eucomed
TRANSCRIPT
EUCOMEDHEALTH GOVERNANCE , 19th April 2012Dario Pirovano Consultant Regulatory Affairs - Eucomed
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A diverse sector
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Medical Devices
Patch with Cells
Cartilage Repair
KidneyReconstruction
MincerHarvester/Collector
New biomaterials (incl. biosurgicals)
Implantable electronics
Miniaturization
Contact lens with chip
Technology convergence and smart devices
Molecular and cellulardiagnostics
Next generation imagingDrug device
combinations
An exciting future
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Comparison with Pharmaceuticals
Pharmaceuticals Industry with longer history Primarily large multinationals
Medical Devices Relatively young industry 80% are small- and medium-
sized companies
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Comparison with Pharmaceuticals
Pharmaceuticals Limited number of products Development by trial and selection on
the basis of quality, safety and efficacy Therapeutic Based on pharmacology, chemistry,
biotechnology, and genetic engineering Biologically active and effective when
absorbed by the body
Medical Devices More than 10,000 products (different
sizes, models, etc.) Designed specifically to perform
certain functions based on quality, safety and performance
Diagnostic, therapeutic, monitoring Based on mechanical, electrical
and/or materials engineering Generally act by physical means
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Comparison with Pharmaceuticals
Pharmaceuticals Continuous innovation and some
improvements based on new science and technology
Innovation primarily the result of laboratory work
Extensive product lifetime and long investment recovery period
“Breakthrough drugs”
Medical Devices Continuous innovation and iterative
improvements based on new science, technology and available materials
Innovation primarily the result of insights from clinicians
Short product lifetime and investment recovery period (~18 months)
New devices bring added functions and clinical value based on incremental improvements
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Comparison with Pharmaceuticals
Pharmaceuticals Low distribution cost No service or maintenance Limited training required
(compared to high-tech medical devices)
Medical Devices High cost of distribution Training and education essential High cost of training and
education Extensive service requirements
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Comparison with Pharmaceuticals
Pharmaceuticals Randomized control trials are
‘gold standard’ Efficacy and efficiency can be
largely demonstrated prior to market
Drugs either work or don’t work: efficacy and efficiency easy to demonstrate
Medical Devices Randomized control trials not
always scientifically informative or possible and hence not ‘gold standard’
Efficacy and efficiency can be only truly be demonstrated through actual use and uptake in the market
Medical devices are part of whole system and their efficacy relies on the skills and experience of the physician, the quality of the hospital, and other factors
EU Regulatory Framework for Medical Devices
VIGILANCE SYSTEM (in case of incidents): a) Manufacturer is obliged to REPORT any incident related to his devices to the Competent Authority (Article10 and Annex II, paragraph 3.1)
b) A Member State may decide to WITHDRAW, RESTRICT or PROHIBIT the marketing of the device (Safeguard Clause, Art. 8)
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CLASSIFICATION OF MEDICAL DEVICES (MD): Manufacturer determines the CLASSIFICATION of his MD based on Annex IX of MDD and related guidelines (Meddev)
Class I (low risk) Class IIb (medium/high risk) Class III (high risk)Class IIa (low/medium risk)
CONFORMITY ASSESSMENT PROCEDURE (ART. 11):
DECLARATION OF CONFORMITY AND CE MARKING: Manufacturer issues a declaration of conformity stating that each device is in compliance with the all applicable Directives and affixes the CE marking
Manufacturer’s self-assessment of his device 1
1 For devices with measuring function or which are sold sterile there is an intervention from the Notified Body
Manufacturer must keep TD and QAS updated and adapt according to all gained post-market experience . NB regularly audits both, typically once per year (Annex II, paragraph 3.1)
Pre-market approval for class III: Manufacturer submits TD as a ‘Design dossier’ to the NB. NB assesses it and issues a ’Design-examination Certificate’ (Annex II or III)
POST- MARKET SURVEILLANCE (preventive):
a) The manufacturer must have a post-market surveillance system in place, as an integrated part of the ‘quality assurance system’ and audited by a NB, in order to collect, review and assess all information gained on a device in the post-market phase (Annex II, paragraph 3.1)
b) Competent Authorities are responsible to monitor all devices on the market , i.e. through audits, product samples, complaints (Article 2)
Last update 10 April 2012
Notified Body (NB) audit: NB assesses the TD and the QAS through an on-site inspection of the manufacturing premises, which takes 2-5 days. NB issues a Conformity Assessment ‘Certificate’ (Annex II 3.3. or Annex V 3.3.)
’Technical documentation’ (TD): to be created by the manufacturer. It demonstrates the safety and performance of the device by proving that all ‘Essential Requirements’ laid down in the MDD are met (Annex I) and includes a clinical evaluation (Annex X) and a risk assessment . All are based on clinical data.
‘Quality Assurance System’ (QAS): to be set up by the manufacturer. Ensures that each individual device fully meets the standards defined in the technical documentation. Achieved through clearly defined procedures for every step of the manufacturing process, from design phase to final inspection (Annex II or V).
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Revision could sort out weaknesses of current system?
Lack of Transparency = Lack of trust in System Overly “confidential” system
Different expertise/performance of Notified Bodies
Perception that Authorities are divorced from the process, particularly for complex class III devices
Transparency of overall system, in particular no visibility of what’s on the market
Poor perception of system by those external to EU
Challenges to Innovation = Threat to patients’ choice Public Health Authority understanding of new technologies
Lack of Guidance including regulatory predictability and agreed clinical guidelines, in particular on innovative new technology
Fragmented Market = Threat to legal market access Multiple national registrations and overly bureaucratic processes
National ‘safeguard’ measures create multiple national requirements
Multiple national approaches to vigilance, borderline and classification
6 steps to a smarter legal framework for medical devices:
Only the best Notified Bodies
One approach to vigilance and
market surveillance
Strengthened harmonized standards
Consistent implementation
of guidelines
Increased transparency
An integrated approach: Better coordination and
management
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4 5
2 3
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October 2011: Eucomed favours JRC
Coordinating Committee of Member Stateswith Administrative Support from:
Oversight by Member States
Directorate in EMA
Standalone Agency
Option 1
Option 3
Option 4
= Commission
= Member States (Heads of Agency approach)
= Agency
Assistance of DG Research’s Joint Research Centre and/or DG SANCO’s Executive Agency for Health and Consumers
Option 2
Commission: Public consultation /
Impact Assessment
Commission: Legislative Proposal
Parliament and Council: First reading
Parliament and Council: Second reading
(and Conciliation)
National and local authorities: Implementation
Commission and Court of Justice:
Surveillance / enforcement
Expected timeline for the MDD revision
Q2/2012
08/2011
2014/15
2017/18
08/2008
DK, CY
IE, LT
EL, IT
LV, LU
EU Presidencies
NL, SK
June 2014EP
Elections
Why a European Trade Association?
The rules of the game are changing
Increasingly, policy-makers are staying
ahead of industry
What to do to stay engaged?
More frequent exchange of views and
updates on key policy dossiers are
vital
Early warning on evolving crises
Coordinate messages and timing on
advocacy on key issues
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Eucomed Secretariat Organisational Chart
In Interim (as of J anuary 2012)
John Brennan Director
Regulatory & Technical Affairs
VACANT Director
Economic Affairs
Florence Poncin Senior Manager
HR & Administration
Luciano Cattani
Chief Executive
Sonja Kropidlowska All-round Assistant
Rubie Santos Admin. Assistant
Tanja Valentin Senior Manager
Public Affairs
Dario Pirovano Consultant
Regulatory Affairs
Thomas Lindemans Senior Communications
Officer
Brett Kobie Communications Officer
Sophie Koettlitz Economic Affairs Officer
– EHTI (Part-time)
Cristian Manoiu Manager Economic Affairs – Data Analyst
Thecla Sterk
Regulatory Affairs Officer
Andy Vaughan Consultant
Environnement (Part-time)
Petra Grigorovova Data Analyst
Christopher Breyel Manager Membership
Services & Events
Laurence Couturier Communication & Events
Officer
Ingmar de Gooijer Director
Communications
Aline Lautenberg Senior Legal
Counsel
Zuzana Fikarova Economic Affairs Officer
Merlin Rietschel Manager
Regulatory & Technical Affairs Valentina Ancona
Public Affairs Officer
Jelena Merkurjeva Data Analyst
Kristina Smailyte J unior Legal Officer
Yves Verboven Consultant EHTI
EUCOMED and Medical Technology Industry
Eucomed represents the medical technology industry in Europe. Our mission is to make modern,
innovative and reliable medical technology available to more people.
Based in Brussels, Belgium
24 staff
Members:
25 national industry associations
3 associate Members
58 direct corporate members
Medical technology industry in the EU
About 22,500 medical technology companies in EU
80% SMEs
95 billion EUR annual sales; 8% re-invested in EU
Nearly 500,000 employees
> 500,000 products (10,000 generic groups)
One new European patent every 38 minutes*
* OECD 2010; European Patent Office 2006
European MedTech Industry
Source: World Bank, EDMA, Espicom and Eucomed calculations, 2009Europe refers to EU-27 plus Norway and Switzerland
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Global Healthcare Expenditure
The total Global healthcare expenditure accounts for 5.7 trillion US$ in 2009*
Total Healthcare vs. Medical Device Expenditure, Europe
Source: Espicom, World Bank, Eucomed calculations, 2009 *IVD are not included
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Eucomed is active in the following spheres:
Economic affairs; including market data collection, health economics, funding and
reimbursement, health technology assessment and new trends (homecare)
Regulatory affairs; including vertical legislation (such as medical devices directives and
advanced products regulation), horizontal legislation (e.g. environmental) and standards
Science and innovation; including medical nanotechnology and other emerging technologies,
research and innovation projects
International affairs; including global regulatory harmonization (GHTF), relations with the US,
Japan, China and India
Ethics; including enforcement of the Eucomed Code of Business Practice
Public affairs; including outreach to and relations with the European institutions and the
Member States
Communications and external relations; including partnerships with patient groups and
medical associations, events, publications and media relations.
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Main sector groups at Eucomed are:
1. Ophthalmic surgery & vision care
2. Orthopaedic
3. Cardiovascular
4. E-health
5. Patient Safety Groups
6. Community Care
7. Surgical care
Ambition
Be a center of competency for policy-
makers;
Show and demonstrate that the medical
technology industry offers innovative and
cost-effective solutions to improve patient
lives;
Engage healthcare influencers across
government, industry, patient advocacy,
healthcare professionals to work toward
consensus on health policy issues.
Strategic Actions
Short Term
1. Demonstrating the value proposition of the industry is critical
• Communications (Eucomed/NA)• Public Affairs Machine (Eucomed/NA)• Ethical Campaign (Eucomed/NA/ADV)• Data generation
2. Address threats and opportunities to address value
• Regulatory burden (MDD Revision) (Eucomed)• Reimbursement / Procurement / Late Payment (Eucomed/NA)• Shaping HTA Environment (Eucomed/NA)
Alignment of actions Eucomed and NA
Likely scenario to support all sectors
Mid Term of validations and trends/scenarios by key internal groups (NA, sector…)
1. Determine the optimum scenario2. Align future position of the industry3. Define action plan of Eucomed / NA4. Build value proposition thorough targeted stakeholders
• Patients• HCP• Governments• Payers
5. Monitor e-Health Development
React Influence Drive
Programme and registration at www.medtechforum.eu
Early bird rates: Save up to 20% by registering before 30 June!
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