• What Makes Medical Devices Costly?

    What Makes Medical Devices Costly?

    Medical devices may well sound like a modern invention but they have helped us control and treat diseases for centuries. Medical gadgets play a considerable role in our lives, many of them so ubiquitous that we at times take them for granted. Some of the examples for such medical devices include clinical thermometer, hypodermic needle, spectacles, X-ray imaging, blood glucose monitor and many others.

    Sales of medical devices have grown at an annual rate of 9 percent for the past decade. It has been estimated that the total cost of quality for the medical device industry—including day-to-day quality costs as well as cost and revenue loss from non-routine events—is at $17 billion to $26 billion per year, or 12 to 18 percent of industry revenue. In a study conducted by AdvaMed, it was found out that during 23-year period from 1989 to 2011, a significant driver of changed medical practice has been the development of new medical devices—from stents to implantable defibrillators to artificial hips and knees to new imaging modalities, diagnostic tests and surgical tools.

    Further it has been documented that the average cost to bring a low-to-moderate 510(k) product from concept to market is $31 million. More than 77 percent of that, $24 million, was spent on FDA-dependent or related activities. High-risk Pre Market Approval (PMA) costs averaged $94 million, with $75 million spent on FDA-linked stages, nearly 80 percent of the total cost of bringing devices to market (average cost for FDA to review a marketing application was $870,000 and the average cost to review a 510(k) submission was $18,200).

    Manufacturers make decisions about pursuing new devices based in part on the cost of their development. Additional regulatory requirements may escalate these costs, while other incentives, such as tax breaks or market exclusivity extensions, may diminish them. The medical device industry is highly influenced by factors such as country’s GDP, regulatory environment, general healthcare expenditure, level of public spend on healthcare compared to private sector, taxation, population responsiveness of the treatment options and their reception of the certain device based therapy and reimbursement options.

    In the recent times, the medical device industry has experienced increasing pressures, including cost competitiveness, globalization and supply chain tiering. If the device development cost is too high, the eventual result may be that consumers are denied access because new products are not developed or brought to market. Access problems have led to proposals for, and the enactment of, incentives to develop medical devices for rare diseases and paediatric populations.

    In order to overcome these problems, medical device manufacturers must concentrate on the needs of the customers, product features as well as the product design. Leading companies should try hard to deliver the features their customers most value, at the lowest possible cost. While many companies invest heavily in product cost reduction, they usually do so by examining existing designs and identifying opportunities for incremental savings. Using “Design to Value” concept, companies can first work to understand the likely limits of product cost reduction. Starting with a blank sheet and using knowledge of industry best practices for materials, processing and labor costs, they can further build an estimate of the most efficient way to deliver the desired feature set.

    The Indian medical devices sector is worth about USD 3 Billion and is rising at a CAGR of 15%. The medical devices market in India is subjugated by imported products, along with products manufactured using imported material, which comprises approximately 75% of the total sales. The major players in the Indian market are: Hindustan Syringes & Medical Devices, Opto Circuits (India), Wipro GE Healthcare, 3M India, Medtronic, Johnson & Johnson, Becton Dickinson, Abbott Vascular, Bausch & Lomb, Baxter, Zimmer India, Edwards Life Sciences and many others. Although the cost of labor and production in India is significantly lower than other countries, the ultimate price of the goods is on the higher side due to multi-layer and multi-stage levy of indirect taxes. As an end result, the growth of the Indian industry, together with the medical devices industry, has been diminutive.

    In June 2015, the Times of India reported that regulators were investigating charges that imported products, such as stents and other cardiovascular implants, were marked up significantly, and that Indian patients paid between three and four times the price of the landed product.  The National Health Systems Resource Center (NHSRC) in India has submitted a new report strongly urging the National Pharmaceutical Pricing Authority (NPPA) to cap the prices of both bare metal and drug-eluting cardiovascular stents. According to the NHSRC, the deficiency of price regulation has led to consumer exploitation, especially with imported stents but according to the manufacturers the report does not consider stent quality or overall hospitalization costs.

    As per the Department of Pharmaceutical (DoP) pricing of medical devices should be different from that of drugs. It should be done in such a manner so as to ensure sufficient incentives in terms of returns on investment for the manufacturers. In Jan’ 2016, the core committee under the ministry of health had called for a meeting with the manufacturers of medical devices and stakeholders on the need for capping prices of cardiac stents and implants. The government task force has recommended that prices of medical devices, including cardiac stents and implants, be regulated under a mechanism that is distinct from medicines. The committee has taken the view that costs of medical devices should balance consumer and medical industry interests so that the volume of business provides a sufficient incentive to manufacturers.

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  • Biosimilar: Does It Burn Your Pocket?

    Biosimilar: Does It Burn Your Pocket?

    The high cost of pharmaceuticals, especially biologics, has become an important issue in the battle to control healthcare costs. In order to overcome this impediment, biosimilar unlike generics were first marketed in Europe in the year 2007. The Affordable Care Act (ACA), which includes the Biologics Price Competition and Innovation Act (BPCIA), defines biosimilar as having “no clinically meaningful differences between the biological product and the reference product in terms of safety, purity, and potency.”

    When a biosimilar is compared to a generic product, it should be realized that the time taken for the development of the biosimilar takes 6-9 years whereas the development of the generic product usually takes anywhere between 1-3 years only. As far as the development costs are concerned, estimates for biosimilar ranges from US $20-300 million depending on whether a plant has to be developed. Customary generics’ costs around US $1-4 million. Biosimilar imbibes a great cost in its development as it entails sophisticated technologies and methods which eventually increases the riskiness of investment. In addition, there is a great deal of price difference between the biosimilar and its reference biological product itself. Various factors such as cost of development, prescriber disquiets followed by entry hurdles and the degree of competition helps to understand the price difference including discounts between the biosimilar and the reference biological product. It is a usual practice observed that most of the originator companies reduce the prices or start offering great discounts giving tough time to the biosimilar manufacturers.

    From the health economics angle, a question arises whether essential differences are observed between the biological reference product and the biosimilar with respect to the purity, efficacy and safety. This question remains unanswered till date. If effectiveness is not compromised at reduced cost then biosimilar can be suggested. If the biopharmaceutical and the biologics are not interchangeable, the savings ascending from biosimilar need to be evaluated against the impact on effectiveness and the cost of therapy. A poorer efficacy of a biosimilar possibly will result in the need for added therapy or hospitalization and may entail that the patient necessities to take additional time off work. In such cases an economic evaluation of the biosimilar is crucial.

    During the economic evaluation, the incremental cost-effectiveness ratio (ICER) of the intervention is calculated relative to the appropriate comparator. If the comparator includes a biological reference product and a biosimilar, the price of which one should be used to value costs? This decision is likely to have an influence on the cost effectiveness of the intervention. Many countries have specific guidelines laid down that serve as standards for planning and conducting the economic evaluation but no guidelines state whether the valuation of comparator costs should be based on the price of the reference biopharmaceutical product or the biosimilar.

    According to the report from American Action Forum (AAF), reimbursement policy for biosimilars will have a negative consequences for patients. In recognition that biosimilars are not simply generic versions of biologicals, the Biologics Price Competition and Innovation Act was included in the Affordable Care Act (ACA) to establish a different pathway for approval through the FDA and a different methodology for reimbursement from CMS. The law directs that biosimilars be paid based on 100 percent of their volume-weighted Average Sales Price (ASP) plus 6 percent of their reference product’s ASP. Biosimilars were given this more favorable add-on to the reimbursement rate in recognition as they are more expensive to produce than small molecule generics.

    Undoubtedly, biosimilar industry has been growing exceptionally in regions such as Europe, US, Japan and South Korea. A million dollar question stands tall is the scenario of biosimilars in India. In the year June 2015, Ahmedabad-based pharma major Intas Pharmaceuticals launched first biosimilar in India named Razumab, a biosimilar to Lucentis (ranibizumab) to treat degenerative conditions of the eye. A Deloitte survey done in India found out that physicians are willing to prescribe a first-line critical therapy if it was offered at a 60 to 70 percent discount. Access to affordable biologics in India is still poor. The engagement and the advocacy from payer in favor of biosimilars is very low. Prescribers in India are partially open to prescribing biosimilars when compared to the biopharmaceutical reference product as well as the patient’s attitude towards biosimilar in India is found to be moderate.

    While Indian companies have launched a few such products in the domestic market, where regulatory barriers are relatively low, they are being overtaken by European, American and South Korean firms in the race to supply profitable Western markets.

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  • “Voice of the Patient” in Improving Drug Access

    “Voice of the Patient” in Improving Drug Access

    Drugs which might seem very effective in clinical trials, sometimes fail in the market due to non compliance and acceptability issues from the patients. On the other hand, a drug with known and serious side effects is sometimes well accepted by the population, despite the risk involved.

    An eye opener in this regard is the case of the Tyasarbi, the drug against Multiple Sclerosis. It was approved in 2004 by the US FDA, and withdrawn hardly 3 months post its launch, after being associated with cases of PML. However; the response of Tysabri in non responsive MS patients was so radical, that in spite of knowledge of life threatening and serious side effect as PML the patients were willing to take a risk with the drug, as opposed to allowing progression of MS. This was evident as representatives of MS patients and their relatives testified to the drastic improvement shown by the drug in patients of MS. There was a strong opposition to the withdrawal of the drug by the patients, who due to the non availability of the drug were being sentenced to progression of MS and ultimately a vegetative life. Thus in 2006 FDA ultimately decided that the side effects of Tysabri though serious, were acceptable considering the benefit accrued to the patient and the risk of non availability of the drug. Subsequently the drug was also approved for treatment of non responding patients of Crohn’s Disease.

    Another case was the role played by patients is the case of patient led advocacy group for Duchenne’s Muscular Dystrophy (DMD).  A group of more than 80 representatives from the Duchennes community held discussions on their expectation from drugs, the risk they were willing to take for clinical trials and at what risk of non curative retardation of disease was acceptable to them. A guidance document intended for the industry and regulatory authorities was then submitted to the FDA to give a direction to drug development in the field. FDA in turn got actively working with the pharmaceutical company Serepta on the development of the drug Eteplirsen for DMD.

    These incidences led US FDA to come up with a unique initiative that allows patients to voice their opinions regarding their disease, how it impacts their life, their opinions on the current treatments available and what they expect from new drugs and therapies in the future. This program is aptly called as Patient Focused Drug Development (PFDD) program. The reports of these meetings are released to the public and industry, being aptly named as ‘Voice of the Patient’ reports.

    PFDD have the following positive impact in the pharmaceutical world:

    • It helps to give the patients’ viewpoint to the type of drugs needed in the market.
    • The interaction provides the stakeholders, that is the patients & disease advocacy groups, the clinicians and researchers, and the payers, and the biopharmaceutical industry, with an opportunity to utilize this information in bringing about a positive change in the drug development process.
    • Involving patients with drug development in the early stages would enable the researchers to get a better insight to the problems and possibly, newer avenues for drug discovery.
    • Patient’s experiences would help in development of Patient Reported Outcomes (PRO) and help in Clinical Outcome Assessment(COA) in clinical trials.
    • Since payers are increasingly depending on Real World Evidence to support their decisions, having a feedback from the end users of the drug well before the launch, gives payers an insight into how the drug will be accepted post its launch.
    • For the success of any pharmaceutical product there has to be a market need, scientific opportunity to produce a drug and reimbursement or insurance coverage. PFDD ensures that the industry is made aware of the needs of the people or what they expect from the drug.
    • It would help the industry to cater to the needs of the patients and also reduce the time taken for them to gain access to new drugs.

    I believe that with the processes for systematic representation of patient’s voices, the regulatory authorities will now have a holistic outlook to how the drugs affect the patient’s life, the need for newer therapeutic options for diseases helping faster access of patients to drugs and clinical trials.

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  • How Can We Cap Skyrocketing Pharmaceutical Prices: The Even Bigger Question?

    How Can We Cap Skyrocketing Pharmaceutical Prices: The Even Bigger Question?

    To most connected with the pharmaceutical industry, it is a common knowledge that the cost of prescription medicine, even traditionally, has always defied the law of gravity. However; what is alarming today is the steep increase in the cost of specialty drugs that target everything from multiple sclerosis to cancer, blood pressure, and even erectile dysfunction.

    In India, the controversy on price control has picked up speed once again following the Supreme Court’s verdict that existing prices are set at unreasonably high levels. Accordingly, the National Pharmaceutical Pricing Authority (NPPA) has expanded the National List of Essential Medicines and the total number of drugs now affected by price controls is a whopping 700!!! Amongst the new products included are those used in treatment of diabetes (gliclazide, glimepiride, sitagliptin and voglibose); high blood pressure (amlodipine and telmisartan); and high cholesterol (rosuvastatin). Additionally the government has asked the pharmaceutical manufacturers to continue producing drugs unless they receive a nod from regulators to stop production.

    The pharmaceutical manufacturers are distressed by these stingy policies of Indian government. They argue that price control alone cannot ensure accessibility to medicine. The government needs to look at alternative methods such as universal healthcare coverage as well as increase its spending on healthcare to address the issue of accessibility.

    While these stingy pricing policies of the Indian government ensure that drugs in India are cheap, often way less expensive than the cost of the same medications in the U.S. or Europe they create another less obvious but nevertheless important downside – they delay the entry of new pharmaceutical products into the Indian market.

    It has been estimated that it takes almost five years for even half of new pharmaceutical products launched in the US to come to market in India. The Indian government must therefore decide the importance of lowering the price of available drugs, given that such policies will delay how quickly its citizens will get access to new ones.

    There is a need to strike a balance between the two important goals, of controlling costs versus expanding access.

    In my opinion price control alone cannot improve the accessibility to medicines. Value based pricing can be considered as a part of the solution to the rising price of prescription medicines. Under value-based pricing agreements, payers and pharma companies agree to link payment for a medicine to value i.e. patient outcome achieved, rather than volume.

    Getting a handle on value based pricing is however not that straightforward. Successful value-based pricing arrangement mandates a clear definition of when the medication works, and when it does not work. The process involves collection of value attributes (e.g., outcome or performance variables of interest) and subsequently aggregating and converting (using a decision rule) to evaluate whether the value metric was achieved. Data collection would need to be initiated early in the product life cycle. The basis of the higher price is always based on incremental value over other treatment options.

    Some drug companies use comparative data and indication-specific pricing to favor “clinically superior” medicines and make sure their treatments are covered across the board. An interesting example is that for erlotinib (Tarceva), a drug that extends life in patients with lung cancer by an average of about 4 months, but for only 12 days in patients with pancreatic cancer. So in indication-specific pricing, one would pay differently for the drug depending on which indication it is being given for.

    Drug pricing is no doubt a complex calculation but value based pricing can be looked upon as a one part of the solution to strike the delicate balance between availability and affordability of essential medicines.

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