impact of european rare disease policies on access to therapies

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1 19th International Plasma Protein Congress (IPPC) Ruediger Gatermann CSL Behring, Public Affairs Europe Vice Chair, PPTA Health Policy Steering Committee Dublin March 05, 2013 Impact of European Rare Disease Policies on Access to Therapies

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1

19th International Plasma Protein Congress (IPPC)

Ruediger Gatermann

CSL Behring, Public Affairs Europe

Vice Chair, PPTA Health Policy Steering Committee

Dublin

March 05, 2013

Impact of European Rare Disease Policies on Access to Therapies

2

Agenda for today

European challenges in health policy for rare diseases

Current healthcare challenges

European influence in health policy

EU legislation initiatives

Key EU legislation affects rare (plasma) diseases

EU Sectoral Study on Blood and Plasma (Blood Directive)

Healthcare infrastructure – patient access to therapies

National Plans for Rare Diseases

Health Technology Assessment – market access for therapies

EUNetHTA core model and assessment pilots

Rare Diseases business models and pricing challenges

3

Healthcare challenges increase in times of financial crisis

Overall healthcare costs are rising in response to key demographic and economic factors

Consequently, governments and payers across major markets are implementing numerous cost-containment policies with direct impact on drug margins

Health Technology Assessment is focusing on most expensive therapy areas, leading to new challenges for rare disorders including plasma therapies

Success of the plasma industry is determined, to a great extent, by the external environment in which we operate

Political interest for specific areas (innovation, biotech, rare diseases…) may lead to favourable sector policies despite general cost cutting efforts

Patient empowerment adds new options for alliances if mutually agreed and established in an open and transparent manner

4

On European level, EU institutions become more influential in health policy

EU Commission and Parliament increasingly take the lead

in health policy agenda setting

Rare diseases are widely recognized as health priority

Plasma disorders are unique, treatable but still often neglected

Plasma industry’s public affairs efforts are focused on positioning plasma disorders as a key area in the context of rare diseases

Recent EU policy initiatives: European Conferences on Rare Diseases

European Commission Task Force on Rare Diseases, now EUCERD

Rare Diseases in EU Community Research Framework Programme

EC Communication and Council Recommendation on rare diseases

5

On national level, for all pharmaceuticals price control policies are used extensively across major markets…

Price cuts, freezes and ceilings

Discounts & rebates

Profit controls

Reference pricing

…and reimbursement controls become even more popular

Pharmaco-economics, Health Technology Assessment (HTA)

Risk sharing

Volume limitations

Formulary positive / negative lists

Key concern: Patient access to therapies

6

EU policy agenda: Key legislation affects Rare Diseases (RD)

Cross Border Health Care Directive (new)

European Directive came into force in 2011

Clarifies patients rights on access to cross-border healthcare services

Articles 13, 15 (Rare Diseases, HTA cooperation)

Transparency Directive (under revision)

Initial Directive from 1989 - EU Commission proposal of March 2012

Commission proposal more binding for MSs (Time-limits, sanctions)

EU Parliament amendments: Time-limits extended and removal of sanctions (Tough

negotiation with the EU Council, strong opposition from MSs)

Caveat: Vehicle to push “transparency” on industrial pricing / cost structures

Clinical Trials Directive (under revision)

Change from Directive to Regulation - New EU Commission proposal of July 2012

Emphasis on EU collaboration - Strong alignment EU Commission and EU

Parliament

Major changes: Increase transparency of clinical trials data; Facilitate clinical trials in

medicines used off-label to treat particularly rare diseases

Feb-13

7

EU Commission study on blood and plasma sector

Background:

« Blood Directive » is 10 yrs old / Average life of EU legislation

EC needs to prevent potential « crisis »

Study Objectives: (European Commission / EC DG SANCO*)

Improve EC understanding of the supply chain of blood and blood components in

Europe

Identify discrepancies in the functioning of the market of blood and blood

components

Desired outcomes (PPTA):

Clear EC understanding and recognition of current EU situation (Clinical/patient

needs)

Avoid conclusions which could undermine patient access to plasma therapies

Clear distinction of blood (transfusion) and plasma (fractionation) in EU legal text

*DG SANCO = Directorate General “Health and Consumers”

Feb-13

8

EC Sector Study: Work Plan/ Milestones 2013/2014

DG SANCO to issue report at the end of the EC sectoral study

DG SANCO to address Member States regarding:

• Implementation of the current Blood Directive

• Issues for potential Blood Directive reform

• Country reports

DG SANCO to consult with stakeholders on impact analysis

DG SANCO to make recommendations for way forward to other Directorate Generals, EU Council & Parliament (?)

2/28/2013

June 2014

New EU

Parliament

End 2014

New EU

Commission

9

National Plans for Rare Diseases – Healthcare infrastructure

EUROPLAN project (co-funded by the EC Program for Public Health 2008-2013)

EU Council Recommendation supports adoption of national plans and strategies for

responding to rare diseases (non binding EU legislation)

Policy goals

Elaborate and adopt a plan or strategy by the end of 2013 at the latest

Structure actions in rare diseases within their health and social systems

Integrate initiatives at local, regional and national levels into plans or strategies

Define a number of priority actions with objectives and follow-up mechanisms

Key areas

Definition, codification and inventory

Research

Centers of expertise and European reference networks

Gathering the expertise on rare diseases at European level

Empowerment of patient organizations

Feb-13

Member States:

Implementation?

Financing?

10

Health Technology Assessment (HTA): Cross functional strategies are needed

Medical evaluation (“assessment“)

Data collections, dossier

Evidence, (Added-)benefit

Recommendations, guidelines

Economical evaluation(“appraisal“)

„Value“

Influence of financial situation

Pricing and Reimbursement

Political framework

Inclusion of partners (“stakeholders“): Industry, patients…

Differentiation of HTA in rare diseases

Differentiation of HTA for plasma proteins

Feb-13

11

Feb-13

Timing of Health Technology Assessment - An assessment continuum rather than an “on/off switch”

Pre-clinical phase

Clinical trials

Marketing authorization

process

Scientific evaluation

of HTA

Economic evaluation

of HTA

Pricing and reimburse

ment

Product launch

HTA reassessment

Marketing authorization

„It is always too early to assess a

technology, until suddenly it is too late.“

Martin Buxton 1987

12

Feb-13

Where and how value can be demonstrated

RCTs

Clinical efficacy &

safety

Added

therapeutic value

Health system

value

Societal

value

Comparative

data

Real world data

& modeling

Various

Co

mp

lex

ity o

f d

ata

to

dem

on

str

ate

va

lue

EMA/FDA

Budget N/A

France

Drug budget

UK

Healthcare budget

Sweden

Other budgets (e.g.

social security)

Source: Mel Walker, GSK (HTA World Europe, 2010)

13

HTA: A new take on an old story… perceptions matter!

Price Innovation

Value

Evidence

Cost

Cutting

Budget

14

Model Rapid REA

Health problem &use of

technology

Technical characteristics

of the technology

Safety

Effectiveness

Cost and economic

considerations

Ethical analysis

Organizational analysis

Social aspects

Legal aspects

HTA Core Model

Health problem & use of

technology

Technical characteristics

of the technology

Safety

Effectiveness

Cost and economic

considerations

Ethical analysis

Organizational analysis

Social aspects

Legal aspects

Model Rapid REA

Health problem & use of

technology

Technical characteristics

of the technology

Safety

Effectiveness

Cost and economic

considerations

Ethical analysis

Organizational analysis

Social aspects

Legal aspects

1.

M

O

D

E

L

PILOTS

C

H

E

C

K

L

I

S

T

HTA “á la carte”?: Domains, Models and Pilots…

15

Pricing of rare disease therapies is broadly discussed by stakeholders and is now a key public policy issue

WSJ; 2013-01-30: “Drug Makers See Profit Potential in Rare Diseases”

BBC; 2013-01-16: “Orphan drugs: Remarkable drugs at remarkable prices”

Reuters; 2013-01-03: “Entering the age of the $1 million medicine”

To be continued…

Source: www.bbc.co.uk

16

Feb-13

Numerous European policy initiatives for rare diseases,

yet national market access remains challenging

Increasing recognition for differentiation of

rare disease therapies / OMPs

EunetHTA Joint Action (I) 2010 –

2012; (II) 2012-2015

(Core HTA Model, Rapid REA pilots)

Transparency Directive

(Minimizing times for

P&R processes)

National Plans on Rare Diseases

(Improving healthcare infrastructure, e.g. registries, CoE…)

Cross Border HC Directive

(Patient rights, Art. 15 on HTA Network)

DG SANCO / CAVOD

(Minimizing market

access delays – EMA /

EUNetHTA interaction)

EUCERD

(Future EU Policies and

initiatives on rare

diseases)

DG Enterprise /

MOCA

(Coordinated access to OMPs

– still under development)

New Clinical Trials

Directive / Regulation

(Greater EU collaboration)

New Pharmacovigilance

Directive

(Enhanced risk management)

17

The RD policy challenge: Dialogue for Differentiation

Better awareness and (early) diagnosis

Best practices on rare diseases care

Equal patient access to therapies, including orphan drugs

Paradigm shift: Costs = investment in health

Level playing field for market access

Differentiation

Rarity versus severity / Rare Diseases versus common diseases?

Plasma protein therapies?

Rare Disease business models and industry reputation

HTA Domains for assessment and appraisal

Pricing challenges

Dialogue

Stakeholder inclusion and alignment

Patients

Physicians

Experts

Industry

Policy makers

Regulators

Payers

18

THANK YOU FOR YOUR ATTENTION !

Contact:

Ruediger Gatermann

Director, Public Affairs Europe

CSL Behring Biotherapies for Life ™

P.O. Box 1230 | 35002 Marburg | Germany

+49 (0) 6421 39 4264 phone | +49 (0) 6421 39 5550 fax

+49 (0) 171 3035465 mobile

[email protected]