• How Innovative Alternate Payment Models Are Bringing Change In Healthcare?

    How Innovative Alternate Payment Models Are Bringing Change In Healthcare?

    Drug prices in the US are the highest in the world, which necessitate new or alternate payment approaches. For instance, the new treatments for hepatitis C virus (HCV) infection are highly effective and very expensive at the same time, at least from the view of many payers, physicians, and patients. Even 5 years after these drugs were introduced, only 15% of the estimated population of more than 3 million HCV patients in the US have been treated. This can also be due to budgetary constraints of the state Medicaid programs. (1)

    In the example stated above, the ideal way to treat the HCV infection would be at the population level, treating every patient possible, at a possible speed. Since the medicine is shifting towards value-based care day by day, it is essential for patients and physicians to have flexible, innovative, and practical payment models that would facilitate better outcomes. As a result, many industry stakeholders are predicting the introduction of new alternate payment models (APMs) that are in being developed currently and will possibly be rolled out later this year. Moreover, the Centers for Medicare and Medicaid Innovation (CMMI) is responsible for the assessment of alternative payment models (APMs), such as bundled payment models that would reduce program expenditures under Medicare, Medicaid and the Children’s Health Insurance Program (CHIP) in order to increase quality and efficiency. (2) In addition, with the support of increasing evidence and momentum, APMs are the precise solution to today’s cost and quality challenge in healthcare. They promise to bend the healthcare cost curve to achieve a sustainable, long-standing future for Medicare and reasonably priced private coverage. (3)

    Having said that, Medicaid programs in several US states have limited access to treatment. For instance, Louisiana State only treated 384 HCV patients last year (2017-18) out of an estimated 35,000 Medicaid beneficiaries carrying the virus. Consequently, the Centers for Medicare and Medicaid Services (CMS) warned the states about possible violation of statutory Medicaid requirements owing to restricted access to hepatitis C treatments. (4)

    However, as a solution, Louisiana State is soon adopting the ‘Netflix Model’ that involves a licensing deal, to expand access to treatment. As per this model, instead of paying for each prescription individually, the State would pay the drug company a subscription fee for medication for several years in exchange for unlimited access to treatment, just like the consumers paying a monthly fee to stream unlimited television shows and movies. (4,5) This ‘Netflix Model’, when applied to health care, makes a lot of sense. This is because the pharmaceuticals R&D costs can be high, but the manufacturing costs, much like software, are often low. Netflix content is essentially purchased through a monthly license, where the consumers are not charged a fee every time to view a show. The basic idea here is to incentivise the content creator, not limiting the ability to watch since marginal costs are low. (4)

    Similar to the ‘Netflix Model’, researchers have also proposed drug-licensing models for health care that promise increased drug use without altering patients’ out-of-pocket spending, health plans’ costs, or drug companies’ profits. These models are based on an idea of buying annual drug licenses to ensure unrestricted access to a clinically optimal number of prescriptions over the course of a year. (6) Furthermore, new efforts are in progress in Massachusetts to figure out ways to pay for the potential million dollar price tag for an experimental one-time therapy designed to treat the devastating, rare disease of spinal muscular atrophy and its underlying genetic cause. Even in this case, similar to the ‘Netflix Model’, the health insurers are considering to pay for the treatment over several years, which if succeeded, could hopefully prove to be a viable model for the entire US. (7) Here, Novartis’s AveXis unit, the manufacturer of the gene therapy Zolgensma, has suggested a price tag of up to $5 million, and is in talks to participate.

    Evidence from literature has shown such subscription models to improve outcomes and save money at the same time. Subscriptions can better balance the public health interest in gaining rapid, extensive and inexpensive access to these drugs than traditional fee-per-dose reimbursement. This can further ensure that manufacturers’ generate enough revenues to justify the drugs’ development costs. (4-6)

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    References 

    1. Trusheim MR, Cassidy WM, Bach PB. Alternative State-Level Financing for Hepatitis C Treatment—The “Netflix Model”. JAMA 2018; 320(19):1977-1978.
    2. Landi H. Are New APMs from CMMI Coming Soon? Industry Stakeholders Forecast Bold Moves from the CMS Innovation Center in 2019. 
    3. Leavitt MO. Alternative payment models in healthcare are a must. January, 2017. 
    4. Goldman DP. When we find a cure, price it like Netflix to ensure access. September, 2018.
    5. Johnson CY. Louisiana adopts ‘Netflix’ model to pay for hepatitis C drugs. January, 2019. 
    6. Goldman DP, Jena AB, Philipson T, et al. Drug licenses: A new model for pharmaceutical pricing. Health Affairs 2008; 27(1).
    7. Court E. A revolutionary drug that could treat a rare and devastating disease is prohibitively expensive. But one state has a plan to pay for its potential $5 million price tag. January, 2019. 

    Written by – Ms. Tanvi Laghate

  • Tapping Payers’ Data to Document the Effect of a New Therapy in the Real World

    Tapping Payers’ Data to Document the Effect of a New Therapy in the Real World

    Traditionally, the pharmaceutical industry has always been dependent upon the ‘push’ strategy for successful market access for products. The drug approval process, involving submission of data on efficacy, safety, and tolerability to the regulatory agencies, used to be simple; which ended with the drug being marketed to the targeted physicians and dispensed by pharmacies post approval. Thus, this whole process involved a limited set of stakeholders, viz. physicians, regulatory agencies, and pharmacies. Conversely, over the years, the market access landscape has evolved primarily due to two factors: (1)

    1. Rising healthcare costs owing to an increasing prevalence of chronic diseases, growing geriatric population, and higher prices of new therapies
    2. Competitive pricing and reimbursement environment

    This has further led to the emergence of a new and diverse set of stakeholders over the years, i.e. the ‘Payer’(s), increasing the complexity of drug access to the market in general, and to patients in particular. Payer exercises the greatest degree of control over pricing and reimbursement for any new drug, and will continue to dominate the scenario to ensure successful market access. (2,3)

    Pharmaceutical advancements are increasingly conflicting as countries attempt to accommodate healthcare costs via different tools. New criteria for recognizing unique drugs and differences among those within the same therapeutic area or concerning the same molecule are being introduced, even though ‘price’ remains the main driver. (4) There is a surge of criticism towards the increasing prices of drugs that adds growing pressure on pharma companies and manufactures to limit future price increases, and eventually on payers to be more cost-effective in their approach to setting budgets and managing costs. (5) Global pharma operations need to keep up with the pace of these changes to approach pharma tendering as a strategy that spans pricing and commercialization.

    In order to document the effect of a new therapy in the real world, pharma companies are trying to justify prices by tapping payer’s data. Payers encourage pharma to collect post-launch evidence of product performance in the real world, thus turning it in pharma’s favor. This can help verify a price agreement or even clarify uncertainties about the clinical and/or safety outcomes outlined at registration. (6)

    The successful market access will involve collaborative team work between sales and marketing departments. The strategy itself should be well equipped to respond to market evolution and also, to accommodate all known interactions. There is no ‘one-size-fits-all’ solution. The challenges in the market will constantly vary as per the product, therapy area and the setting in which the treatment will be used. (1,6)

    Payers are increasingly focusing on “real-world” outcomes to form their decisions, encouraging new policies to be formed, in order to assimilate evidence from different sources. These policies prioritize the evidence that goes beyond information collected during clinical development in randomized controlled trials (RCTs), required by regulatory authorities for marketing approval. ‘Administrative data’- that normally use retrospective or real-time patient data – are an example of the real world data sources, as they are collected primarily for reimbursement, but contain some clinical diagnosis and procedure use with detailed information on charges. Retrospective analyses (longitudinal and cross-sectional) of clinical and economic outcomes at patient, group, or population levels can be performed with the help of claims databases. Such analyses can be performed in short time and at low costs. (7)

    In conclusion, payer’s data from real-world such as claims data can most certainly impact the sound coverage, payment, and reimbursement decisions. It is critical that payers recognize – a) the benefits, limitations, and methodological challenges in using these data, and b) the need to carefully consider the costs and benefits of different forms of data collection in different situations.

    Become an Certified HEOR Professional – Enrol yourself here!

    References

    1. Kumar A, et al. Pharmaceutical market access in emerging markets: concepts, components, and future. Journal of Market Access & Health Policy 2014; 2:10.3402/jmahp.v2.25302.
    2. McClearn C, et al. Big pharma’s market access mission. Deloitte University Press; 2013. 
    3. Arx RV, et al. Leveraging success factors for market access in the life sciences industry. Capgemini Consulting and Cegedim dendrite; 2009.
    4. Skinner JS. The costly paradox of healthcare technology. September, 2013. 
    5. Pharmaceutical pricing and market access 2017. 
    6. Wechsier J. Measuring the value of prescription drugs. Pharmaceutical Executive 2017; 37(5).
    7. Garrison LP Jr. Using real-world data for coverage and payment decisions: The ISPOR Real-World Data Task Force Report. Value Health 2007; 10(5):326-225.
  • Importance of Tapping Payer’s Data to Document the Effect of a New Therapy

    Importance of Tapping Payer’s Data to Document the Effect of a New Therapy

    Traditionally, the pharmaceutical industry has always been dependent upon the ‘push’ strategy for successful market access for products. The drug approval process, involving submission of data on efficacy, safety, and tolerability to the regulatory agencies, used to be simple; which ended with the drug being marketed to the targeted physicians and dispensed by pharmacies post approval. Thus, this whole process involved a limited set of stakeholders, viz. physicians, regulatory agencies, and pharmacies. Conversely, over the years, the market access landscape has evolved primarily due to two factors: (1)

    1. Rising healthcare costs owing to an increasing prevalence of chronic diseases, growing geriatric population, and higher prices of new therapies
    2. Competitive pricing and reimbursement environment

    This has further led to the emergence of a new and diverse set of stakeholders over the years, i.e. the ‘Payer’(s), increasing the complexity of drug access to the market in general, and to patients in particular. Payer exercises the greatest degree of control over pricing and reimbursement for any new drug, and will continue to dominate the market access scenario to ensure successful market access. (2,3)

    Pharmaceutical advancements are increasingly conflicting as countries attempt to accommodate healthcare costs via different tools. New criteria for recognizing unique drugs and differences among those within the same therapeutic area or concerning the same molecule are being introduced, even though ‘price’ remains the main driver. (4) There is a surge of criticism towards the increasing prices of drugs that adds growing pressure on pharma companies and manufactures to limit future price increases, and eventually on payers to be more cost-effective in their approach to setting budgets and managing costs. (5) Global pharma operations need to keep up with the pace of these changes to approach pharma tendering as a strategy that spans pricing and commercialization.

    In order to document the effect of a new therapy in the real world, pharma companies are trying to justify prices by tapping payer’s data. Payers encourage pharma to collect post-launch evidence of product performance in the real world, thus turning it in pharma’s favor. This can help verify a price agreement or even clarify uncertainties about the clinical and/or safety outcomes outlined at registration. (6)

    The successful market access will involve collaborative team work between sales and marketing departments. The strategy itself should be well equipped to respond to market evolution and also, to accommodate all known interactions. There is no ‘one-size-fits-all’ solution. The challenges in the market will constantly vary as per the product, therapy area and the setting in which the treatment will be used.i,vi

    Payers are increasingly focusing on “real-world” outcomes to form their decisions, encouraging new policies to be formed, in order to assimilate evidence from different sources. These policies prioritize the evidence that goes beyond information collected during clinical development in randomized controlled trials (RCTs), required by regulatory authorities for marketing approval. ‘Administrative data’- that normally use retrospective or real-time patient data – are an example of the real world data sources, as they are collected primarily for reimbursement, but contain some clinical diagnosis and procedure use with detailed information on charges. Retrospective analyses (longitudinal and cross-sectional) of clinical and economic outcomes at patient, group, or population levels can be performed with the help of claims databases. Such analyses can be performed in short time and at low costs. (7)

    In conclusion, payer data from real-world such as claims data can most certainly impact the sound coverage, payment, and reimbursement decisions. It is critical that payers recognize – a) the benefits, limitations, and methodological challenges in using these data, and b) the need to carefully consider the costs and benefits of different forms of data collection in different situations.

    Become an Certified HEOR Professional – Enrol yourself here!

    References

    1. Kumar A, et al. Pharmaceutical market access in emerging markets: concepts, components, and future. Journal of Market Access & Health Policy 2014; 2:10.3402/jmahp.v2.25302.
    2. McClearn C, et al. Big pharma’s market access mission. Deloitte University Press; 2013.
    3. Arx RV, et al. Leveraging success factors for market access in the life sciences industry. Capgemini Consulting and Cegedim dendrite; 2009.
    4. Skinner JS. The costly paradox of healthcare technology. September, 2013. 
    5. Pharmaceutical pricing and market access 2017.
    6. Wechsier J. Measuring the value of prescription drugs. Pharmaceutical Executive 2017; 37(5).
    7. Garrison LP Jr. Using real-world data for coverage and payment decisions: The ISPOR Real-World Data Task Force Report. Value Health 2007; 10(5):326-225.
  • Generating Scientific Evidence (Efficacy/Safety/Cost Data) from India

    Generating Scientific Evidence (Efficacy/Safety/Cost Data) from India

    Every country exercises strict control on medicines’ market access. Typically, this requires successful completion and adequate presentation of results from phase I through phase III clinical trials, bringing forward the findings of medicine’s safety and efficacy. The USFDA approves approximately 40 new medicines for the US market each year through this process. (1) In India, this number is more than 100 new medicines annually; however, there is not enough published evidence on submitted applications or summaries of approved medicines. Therefore, concerns are being raised about the safety and efficacy around medicine approvals in India in the absence of appropriate clinical trials. (2,3)

    For instance, a recent study, which evaluated the clinical evidence on the safety and efficacy of the most common metformin fixed dose combinations (FDCs) for T2DM in India, has highlighted the growing national and international concerns about the Indian drug regulatory system. Findings from this study further show high numbers of unapproved medicines and their irrational combinations floating in the market. This study has assessed the basis of efficacy and safety of top-selling metformin FDCs in India against four WHO criteria from clinical trial guidelines for the approval of FDCs. In India, only five FDCs have been approved by the Central Drugs Standard Control Organization (CDSCO); while, in reality, the Indian FDC-diabetes market contributes to the two-third of all diabetes medicine sales. (4) Furthermore, evaluation of published and unpublished clinical trials of these approved FDCs seemed to show underpowered and poor quality evidence of safety and efficacy for the treatment of T2DM. (5)

    The overall lack of available India-specific evidence heightens the need for its generation by publishing the unpublished trial results with Indian patients. India has in place the only required registration with Clinical Trials Registry – India, the national clinical trials database, since 2009. Moreover, the unpublished trials listed in this registry merely provide basic trial information with no results or outcomes reported. The lack of trials on Indian patients, in particular, is of concern, considering CDSCO’s guidelines for drug approvals acknowledge the importance of conducting trials on the Indian population to determine safety and efficacy.4

    Additionally, the Government, with an aim to achieve Universal Health Coverage (UHC) in order to reduce huge out-of-pocket (OOP) health expenditure and ensure affordable access to essential health care for the entire population, has identified a key priority of ensuring value for money in the health budget. This requires a systematic process for generating policy-relevant evidence that can inform policy decisions regarding health resource allocation, i.e. clinical effectiveness studies, cost-effectiveness studies, budget impact studies, along with ethical, social and political feasibility studies. (6) Needless to say that the healthcare payers, regulatory authorities, and health technology assessment (HTA) agencies also make decisions on relative efficacy of the new products based on evidence generated from clinical trials. (7)

    In most western countries along with the United States, the consumer rarely pays for the product—the payer is generally a third-party private or governmental insurer. Before approving a new medical entity (medicines/medical technologies) for reimbursement, private and governmental payers analyze clinical and economic data to determine the clinical value and cost-effectiveness of the new product as compared with currently available treatments. (8) Indian health system, on the other hand, is characterized by a vast but under-utilized public health infrastructure and a largely unregulated private market catering to greater need for curative action; where high OOP health expenditures hinder access to healthcare. (9)

    We believe it is high time even insurance companies start asking for robust evidence in order to provide reimbursement of better healthcare technologies and easier access to care. India needs to bring about a major reform in its health insurance policies, wherein a keen eye for detail is given to the published trial data on safety and efficacy of a drug or relevant evidence about a medical technology.

    Become an Certified HEOR Professional – Enrol yourself here!

    References:

    1. U.S. Food and Drug Administation. New Drugs at FDA: CDER’s New Molecular Entities and New Therapeutic Biological Products.
    2. Ministry of Health and Family Welfare, Department of Health and Family Welfare. Gazette of India, 10 March 2016. New Delhi, 2016.
    3. McGettigan P, et al. Regulatory upheaval and irrational medicines in India: a study of fixed-dose combination drugs. PLoS Med 2015; 12:e1001826.
    4. Evans V, et al. Adequacy of clinical trial evidence of metformin fixed-dose combinations for the treatment of type 2 diabetes mellitus in India. BMJ Glob Health 2018; 3:e000263.
    5. Shimpi RD, et al. Comparison of effect of metformin in combination with glimepiride and glibenclamide on glycaemic control in patient with Type 2 diabetes mellitus. Int J PharmTech Res 2009; 1:50–61
    6. Prinja S, et al. Health Technology Assessment for Policy Making in India: Current Scenario and Way Forward. Pharmacoecon Open 2018; 2(1):1-3. 
    7. Dang A, et al. Real world evidence: An Indian perspective. Perspect Clin Res 2016; 7:156:160.
    8. Gold M. Getting reimbursement for your product in the United States. June, 2003. 
    9. Prinja S, et al. Universal Health Insurance in India: Ensuring Equity, Efficiency, and Quality. Indian Journal of Community Medicine : Official Publication of Indian Association of Preventive & Social Medicine. 2012; 37(3):142-149.
  • How Are Biobetters Different From Biosimilars?

    How Are Biobetters Different From Biosimilars?

    The biologics market is rapidly growing, at almost twice the rate of pharma industry. Estimates are such that 7 of the top 10 global medicines by spending will be a biologic within the next 5 years. To add to this, a new class of biologics, known as “biobetters”, is being introduced that could compete with biosimilars for market share. While the term “biosimilar” is used for a drug that is highly similar to its reference, with no clinically significant differences from the originator product, the term “biobetter” applies to a therapy resulting from intentionally altering a biologic product improving its clinical effects, requiring less frequent administration, or enhancing tolerability. (1)

    A biobetter is a recombinant protein drug from the same class as an existing biopharmaceutical but is not identical; it is superior to the original. (2) It isn’t exclusively a new drug, neither a generic version of a drug. Biosimilars and biobetters are both variants of a biologic; with the former being close copies of the originator, while the latter ones have been improved in terms of efficacy, safety, and tolerability or dosing regimen. (3)

    To cite an example, Roche’s Ado-trastuzumab Emtansine (Kadcyla), an antibody-drug conjugate, classifies as a biobetter of Trastuzumab (Herceptin, also developed by Roche), that has been reported to hinder disease progression in HER2-positive patients with advanced cancer. Another such product is Obinutuzumab (Gazyva), a biobetter of Rituximab with a different method of action, reportedly less immunogenicity, and greater cytotoxicity than Rituximab. Since these 2 biobetters seem to be superior to the originator biologics, the term is largely used for marketing. There is no regulatory pathway to prove that an altered biologic is “biobetter” than the innovator one, although guidelines are in place for demonstrating bio-similarity of molecules.(1)

    Regulatory authorities such as US FDA are authorized to develop approval pathways for biosimilars, but the process is complicated and must address many concerns. Some drug manufacturers, however, are opting to invest in the development of biobetters instead of waiting for the regulatory process to be completed. For instance, they can be targeted to improve pharmacodynamics in order to have less frequent dosing or reduced side-effect profiles or even sustained or slow release formulations. (2,3)

    Novel biobetters possibly will provide value to patients through improvements in ease, irrespective of their improved value over originators. For manufacturers, it is necessary to optimize the clinical trial program to ensure earlier market entry. In case of payers, the willingness to pay (WTP) for a biobetter will be directly proportional to its efficacy over the originator. Assigning irrelevant elevated cost for a biobetter cannot achieve the desired commercial success in a competitive market, unless it can be justified on more levels than just primary efficacy outcomes. In the biologics market, differentiation and not just innovation will play a role to command higher prices. (3)

    Biobetters can surely face commercial success since existing treatments are not perfect. However, market understanding and developing products that offer similarity or superiority in some clinical domains will be helpful. This can be achieved by paying attention to certain considerations, viz. identifying and addressing unmet needs by engaging with clinicians and payers, addressing non-responders to current treatment, i.e. focusing on patient sub-populations that may not be responding well, or well enough, to current standards of care. Finally, securing market access for a biobetter requires scanning the market landscape for competitor products. (3)

    Biobetters are more advanced originator biologics that potentially offer added benefits to patients as well as payers. Higher or fine pricing can obstruct patients gaining access to these ground-breaking treatments, which is why firms need to provide the right evidence and strategy to secure market access.

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    References

    1. Davio K. Will Biobetters and Biosimilars Compete for Market Share? The Center for Biosimilars. November 2017.
    2. Beck A, ed. Biosimilar, biobetter and next generation therapeutic antibodies. mAbs. 2011; 3(2):107-110.
    3. Wright J. Are biobetters better? July 2017. Accessed on 26th January 2018.
  • Adaptive Licensing and Real World Evidence (RWE)

    Adaptive Licensing and Real World Evidence (RWE)

    We all want safe and effective medicines to reach patients as soon as possible, but as we know, drug development, market authorization and payer assessment are all slow sections of a long and drawn out journey for a drug. But what if patients could have access to medicines not just months earlier, but potentially 8 years earlier? This is exactly what the European Medicines Agency (EMA) have in mind, as they lead a broad and diverse group of key stakeholders towards a root-and-branch upheaval of current practice. Adaptive Licensing (AL) (earlier known as adaptive pathways; AP), an ambitious and evolving new initiative which incorporates Real World Evidence (RWE): clinical data collected outside of a conventional randomized controlled trial. AL reforms the existing regulatory approach.

    In March 2014 EMA launched a pilot project to explore the adaptive pathways approach, a scientific concept of medicines development and data generation intended for medicines that address patients’ unmet medical needs. AL seeks to balance timely access for patients who are likely to benefit most from the medicine with the need to provide adequate evolving information on the benefits and risks of the medicine itself. AL is not a new route of approval for medicines. It makes use of existing approval tools, in particular conditional marketing authorization, which has been in operation in the European Union (EU) since 2006. It also builds on the experience gained with strengthened post-marketing monitoring tools introduced by the 2012 pharmacovigilance legislation (e.g., post-authorization studies and patient registries). The adaptive pathways concept is not meant to be applicable to all medicines, but only to medicines that are likely to offer help for a patient population with an unmet medical need, and where the criteria for adaptive pathways apply.

    Notwithstanding the classic randomized controlled clinical trials (RCTs) are Gold Standard for the regulatory approval of new technologies, their inherent generation of efficacy and safety data, are not always utilizable in the daily context. Items such as ‘homogenous populations without other diseases than the one explored in the study’, ‘placebo comparator, not the standard treatment or other active comparator’, and ‘high adherence,’ are just to nominate some points, which are far from the regular use of a medication on the part of patients and healthcare professionals. Even though currently, in parallel with clinical studies, collection programs of observational information are more and more generated, the available evidence is limited and onerous in case of necessity of large volumes; at least by means of clinical studies. This can be overcome with the help of real-world data.

    RWE refers to the planned and systematic recollection of the data generated outside the clinical studies. Adaptive approaches link decision making to an evolving evidence base, parts of which are frequently seen as being derived from analyses of observational data gathered from sources such as electronic medical records, registries or administrative databases. Acceptance of such evidence is an important issue- regulatory authorities and payers are currently prepared to accept observational data to support manufacturers’ efficacy/effectiveness claims only in limited circumstances. In the pilot project, the concept of RWE was expressly intended as wide ranging, encompassing different types of observational research that may be utilized to supplement randomized clinical trials. This was to encourage the submission of different approaches, not all of which could be foreseen at the conceptual stage, with the intent to highlight possibilities, needs and maximize the learning potential.

    RWE data collection within AL has the potential to improve our understanding of disease processes, epidemiological factors, and difficult issues such as adherence, which will in turn allow RCTs to become more efficient. Additionally, for many subpopulations, the life span approach to licensing and coverage and learning from real-world experience as advocated by adaptive pathways will become the only viable access route to new treatments in future. Additionally, in-depth knowledge of the natural history of diseases, existing baseline data, as well as other epidemiology aspects gleaned from existing databases or emerging large data networks and reanalysis of past trials helps to make RCTs more efficient and identify surrogate endpoints, and may increasingly obviate the need for concurrent control groups, e.g., in rare diseases. This knowledge and data can also be leveraged for the post-initial licensing evidence generation foreseen under AL, by providing a reference point against which the real-world performance of a treatment can be assessed.

    Further important steps towards enabling AL are currently being taken. Regulators have just begun to explicitly address and communicate “uncertainty” in their templates for benefit–risk assessment. A growing number of regulators and payer (or HTA) organizations involve patients in their decision-making processes. This can be considered as a pertinent analogy for the history of bringing new drugs to market.

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