国外罕见病法律和保障体系与我国现状的对比分析

目的：为建立我国罕见病患者医药保障体系提供建议。方法：通过研究国外罕见病药物（孤儿药）研发政策和罕见病患者医药保障法律,找到我国与其他国家罕见病诊治和保障体系之间的差距和不足,并依照我国国情和医疗现状,提出建立我国罕见病患者保障体系的建议。结果：经过系统数据收集和分析后发现,发达国家和地区都有特定的部门负责制定和执行罕见病法律,罕见病的定义明确,制定了孤儿药研发的鼓励性政策并提供经费支持,罕见病的药物研发取得了极大进展,研发的积极性和研发的速度均得到了很大提高。同时,这些国家和地区的孤儿药支付体系比较健全,建立了国家基金、医疗、社会、商业保险等多重渠道不同比例的报销机制。相对来说,我国罕见病患者生存现状不佳,诊治状况不容乐观,用药不规范、依从性低。造成这些现象的原因包括治疗费用高而报销比例低,未引进相关治疗药物,供药不及时或停止供应,误诊率高等等。结论：建立我国罕见病患者保障体系是一项艰巨的工作,应从3个方面展开：一是明确我国罕见病和罕见病用药的定义、完善罕见病立法;二是将孤儿药,特别是通过药品治疗可以治愈的,以及针对儿童罕见病的药品纳入医疗保险,从而提高孤儿药的可及性;三是建立罕见病诊疗流程,提高罕见病的诊疗水平。     

Access to orphan drugs despite poor quality of clinical evidence

AIM

We analysed the Belgian reimbursement decisions of orphan drugs as compared with those of innovative drugs for more common but equally severe diseases, with special emphasis on the quality of clinical evidence.

METHODS

Using the National Health Insurance Agency administrative database, we evaluated all submitted orphan drug files between 2002 and 2007. A quality analysis of the clinical evidence in the orphan reimbursement files was performed. The evaluation reports of the French ‘Haute Autorité de Santé’, including the five-point scale parameter ‘Service Médical Rendu (SMR), were examined to compare disease severity. Chi-squared tests (at P < 0.05 significance level) were used to compare the outcome of the reimbursement decisions between orphan and non-orphan innovative medicines.

RESULTS

Twenty-five files of orphan drugs and 117 files of non-orphan drugs were evaluated. Twenty-two of 25 (88%) submissions of orphan drugs were granted reimbursement as opposed to 74 of the 117 (63%) non-orphan innovative medicines (P = 0.02). Only 52% of the 25 orphan drug files included a randomized controlled trial as opposed to 84% in a random control sample of 25 non-orphan innovative submissions (P < 0.01). The duration of drug exposure was in most cases far too short in relation to the natural history of the disease.

CONCLUSIONS

Orphan drug designation predicts reimbursement despite poor quality of clinical evidence. The evidence gap at market authorization should be reduced by post-marketing programmes, in which the centralized regulatory and the local reimbursement authorities collaborate in an efficient way across the European Union member states.     

Orphan drug development in the United States.

Drug research and development in the U.S. tends to focus on drugs to treat common diseases because of the anticipated return on investment. To stimulate pharmaceutical manufacturers to pursue the development of drugs for rare conditions, the Orphan Drug Act was enacted by Congress on January 4, 1983. Under the provisions of this Act, the FDA can make recommendations on the investigations necessary for marketing approval; exclusive marketing privileges can be obtained; tax credits for expenses incurred are allowed; availability of orphan drugs on an investigational basis is encouraged; and the Orphan Product Board is established for the coordination of research efforts and their reimbursement. The effects of this legislation are evident in the continuing increase in orphan drug designations.     

Orphan drugs for rare diseases: is it time to revisit their special market access status?

Orphan drugs are intended for diseases with a very low prevalence, and many countries have implemented legislation to support market access of orphan drugs. We argue that it is time to revisit the special market access status of orphan drugs. Indeed, evidence suggests that there is no societal preference for treating rare diseases. Although society appears to assign a greater value to severity of disease, this criterion is equally relevant to many common diseases. Furthermore, the criterion of equity in access to treatment, which underpins orphan drug legislation, puts more value on health improvement in rare diseases than in common diseases and implies that population health is not maximized. Finally, incentives for the development, pricing and reimbursement of orphan drugs have created market failures, including monopolistic prices and the artificial creation of rare diseases. We argue that, instead of awarding special market access status to orphan drugs, there is scope to optimize research and development (R&D) of orphan drugs and to control prices of orphan drugs by means of, for example, patent auctions, advance purchase commitments, pay-as-you-go schemes and dose-modification studies. Governments should consider carefully the right incentive strategy for R&D of orphan drugs in rare diseases.     

药品全生命周期视角下中国罕见病药物保障政策简析

通过梳理我国国家及地方罕见病药物保障方面的相关政策,从药品全生命周期的角度探析我国罕见病药物保障现状,并提出相应的对策建议。本文通过查阅相关文献,搜索国家及地方政府网站和罕见病相关组织的网络平台,梳理了2015—2020年在罕见病药物研发阶段、注册阶段、定价与报销阶段、供应阶段、上市后监管阶段(药物警戒)与罕见病诊疗等阶段的政策。近5年来,国家和各部委出台了系列罕见病药物保障政策,以及部分省市出台了罕见病药物报销政策,但目前尚未检索到我国专门针对罕见病药物上市后监管的政策。建议在多部门合作的前提下,国家能成立罕见病及其药物保障的专职部门,为罕见病患者提供多元化的保障措施。     

Cross-national comparative study of orphan drug policies in Saudi Arabia,the United States,and the European Union

BackgroundRare diseases are chronic, serious, and life-threatening conditions that have not received sufficient attention from drug developers due to their rarity. Policies have been implemented to encourage research and incentivize the development of orphan drugs. However, the implementation of these policies has been inconsistent worldwide.ObjectiveThe primary aim of this study was to compare orphan drug policies in the United States, Europe, and Saudi Arabia (SA) and assess their impact on the number of approved indications.MethodLists of all drugs granted orphan designations and authorized for marketing in the United States, European Union, and SA were extracted using orphan drug lists available in regulatory body databases. The availability of these drugs, regarding their approval for orphan indication and designation, was assessed and classified using Anatomical Therapeutic Chemical codes.ResultA total of 792 orphan drug designations with at least one authorized indication were identified in this study. Of these, 92% were designated by the Food and Drug Administration (FDA), and 27% were designated by the European Medicine Agency (EMA). The FDA, EMA, and Saudi Food and Drug Authority approved 753, 435, and 253 orphan drugs, respectively.ConclusionFewer orphan drug approvals were found in SA than in the United States and Europe. This highlights the need to focus on rare diseases and orphan drugs and for policies to be created in SA to attract pharmaceutical markets and fulfill unmet orphan drug approval needs.     

Rare diseases, orphan drugs and their regulation: questions and misconceptions

Sustained advocacy efforts driven by patients' organizations to make rare diseases a health priority have led to regulatory and economic incentives for industry to develop drugs for these diseases, known as orphan drugs. These incentives, enacted in regulations first introduced in the United States in 1983 and later in Japan, Europe and elsewhere, have resulted in substantial improvements in the treatment for patients with a range of rare diseases. However, the advent of orphan drug development has also triggered several questions, from the definition of rarity to the pricing of orphan drugs and their impact on health-care systems. This article provides an industry perspective on some of the common questions and misconceptions related to orphan drug development and its regulation, with the aim of facilitating future progress in the field.     

罕见病当前国际政策及现状介绍

目的：为我国罕见病医疗保障和用药法规的建立提供借鉴和参考。方法：介绍和分析不同国家和地区对罕见病及其药物开发的政策。结果：各主要发达国家在药品注册方面和管理方面都有一套相关政策．包括对孤儿药的认定及其开发研究的鼓励政策,值得我国在孤儿药品注册和药品管理政策制定时借鉴和参考。结论：明确罕见病的定义．制定激励措施对罕见病的研究进展有很大的推动作用。     

发达国家及地区罕见病／罕用药界定策略分析

目的：通过广泛研究发达国家及地区罕见病／罕用药政策,为我国相关政策制定提供参考。方法：应用文献研究法对发达国家及地区罕见病政策进行检索,发达国家及地区的筛选标准为联合国开发计划署发布的人文发展指数。结果和结论：多数发达国家及地区对罕见病制定了专门政策,各国罕见病界定策略大体分成三类：依照患病人数确定;依照发病率确定;无定量界定,接受民间自发呈报罕见病。罕见病／罕用药制定过程需综合考虑其自身社会发展程度、军用药可及性、人口因素。人口较多的国家倾向采用患病人数作为定量标准界定罕见病,建议我国适当借鉴并采纳。     

美国与欧盟孤儿药研发上市管理制度及对我国的启示

目的通过对美国与欧盟对孤儿药研发上市相关管理政策的分析,为我国孤儿药研发上市管理提供借鉴。方法分析美国和欧盟药政管理部门公开的法规文献和数据库检索数据,总结其对孤儿药的激励政策,分析获得孤儿药资格认定和批准上市的药物特点。结果美国和欧盟对孤儿药研发均颁布实施了诸如市场独占期、政府资助、审评专家对研究方案的指导等相应的激励政策。研发机构应采取及早申请孤儿药认定、多途径发现孤儿药及孤儿药的再开发等研发策略。结论美国和欧盟对孤儿药的研发与上市激励政策,刺激了制药企业对罕见病治疗药物的研发热情,有效缓解了罕见病无药可治的现状,对我国制定相关孤儿药政策提供了有益的借鉴。国内创新型制药企业应尽早布局孤儿药的研发,应重点关注国内已经被大众接受的罕见病和治疗,以及超说明书使用的问题;重点关注生物仿制药如单克隆抗体的研发动态;重点关注国际孤儿药专业公司的研发动态,使孤儿药在国内相关法律法规建立健全后,立即有所响应,尽早抢占孤儿药研发的领先地位和市场地位。     

How Far Have We Come? Challenges to Orphan Drug Access in China, 2011-2017

Rare diseases are an important global public health issue. One significant challenge is to ensure the access to orphan drugs for patients with rare disease. This study aims to evaluate the accessibility of orphan drugs in China. Information pertaining to the availability and costs of each orphan drug in each hospital was obtained from the Chinese Medicine Economic Information database during 2011-2017. We measured the accessibility of orphan drugs from 3 aspects: availability, daily costs, and affordability to patients.The market availability rate of orphan drugs in China was 28.8% by June 30, 2017. The median availability rate at the hospital level was less than 15% but was increasing over time. The cost of a defined daily dose of orphan drugs varied significantly with a decreasing trend in all areas. Less than half of all surveyed orphan drugs had a cost of a defined daily dose no more than residents' average daily income.This study reveals the challenges of access to orphan drugs in China. The availability of marketed orphan drugs in China was relatively low and most orphan drugs placed a heavy financial burden on patients with rare disease. It is necessary to develop legislation for orphan drugs and encourage domestic generics.     

美国孤儿药资格认定及批准上市情况分析

目的： 系统了解美国孤儿药批准情况,分析资格认定和审批趋势。方法：以美国食品药品监督管理局(FDA)数据库Drugs@ FDA和孤儿药资格认定和批准在线数据库为主要数据来源,系统收集美国FDA自1983至2020年认定和批准的孤儿药信息,从审批数量、审批时间、治疗领域等方面进行统计分析。结果：1983-2020年FDA共认定孤儿药资格5757个,批准孤儿药适应症943个。从孤儿药认定身份到获批上市平均所需的时间为5.14年。批准的孤儿药适应症中抗肿瘤和免疫机能调节相关适应症最多,为 408个,占比为43.27%。结论：自1983年《孤儿药法案》实施以来,FDA授予的孤儿药资格数量和批准的孤儿药适应症数量呈现明显的增长趋势。     

Brexit and rare diseases: big risk,bigger opportunity?

The UK's planned exit from the EU will leave its national health sector in a very dangerous position. It will also have profound consequences for domestic UK law. The impact may be particularly drastic for patients for whom EU law protects the right to treatment. At a particular risk are patients with rare, ‘orphan’, diseases whose treatments are uniquely enabled at the EU level. We examine the potential effects of Brexit on the orphan sector and identify an opportunity to solve long-standing and intensifying difficulties, especially the pricing of orphan drugs.     

中国专家关注的罕见病和罕用药问题及政策建议的文献系统评价

目的：汇总中国专家提出的罕见病和罕用药问题及其政策建议,为我国未来的罕见病和罕用药政策制定提供参考依据。方法：通过对近32年（1984~2016年）国内发表的文献进行检索,较全面地获取具有代表性的中国罕见病和罕用药问题研究资料,参考国际循证卫生服务中心制定的评价标准,对所纳入文献进行质量评价和研究内容进行系统的分析。结果：最终纳入359篇文献（24.95%）,其中,271篇（75.49%）涉及我国专家关注的罕见病和罕用药问题,如罕见病缺乏明确定义,罕见病的诊断水平低,法律保障机制缺失,医药产业缺乏利润动机,罕用药的可负担性和供应及时性差等;251篇（69.91%）提出了对应的政策建议,包括明确罕见病和罕用药界定标准,提高医生的诊断水平,建立覆盖药品生命周期的激励制度,将可治疗的罕见病纳入大病医保范围,建立多元筹资机制和全国罕见病数据库。结论：罕用药蕴含着巨大市场潜力和社会价值,应促进建立罕见病与罕用药从研发到使用的激励与保障机制。     

罕见病用药现状分析

罕见病用药指用于治疗、诊断和预防罕见病或罕见症状的药物。近年来罕见病用药的研发逐渐成为一个可获利的研发策略,受到高度关注和重视。从目前国外罕见病药品市场情况、参与罕见病药物研发的公司和重点品种、美国和欧盟等发达国家和地区罕见病药物的指定和批准情况等方面对罕见病用药的现状及发展趋势进行简述。通过借鉴这些国家和地区罕见病药物发展的成功经验,为制定中国罕见病药物开发的刺激措施提出建议,为相关研发人员提供参考。     

Penny and pound wise: pharmacoeconomics from a governmental perspective

Because of growing pressure on the healthcare budget in The Netherlands, appropriate justification of current expenditures and future investments in public healthcare are becoming increasingly important. Therefore, the Dutch Ministry of Health, Welfare and Sport is expanding its use of pharmacoeconomic evaluation in informed reimbursement decision-making of new pharmaceuticals. Since June 2002, pharmaceutical companies have been invited to submit a pharmacoeconomic dossier with their reimbursement applications of innovative drugs. As of January 2005 submission of a pharmacoeconomic dossier is mandatory for all drugs claiming to have therapeutic value. Currently, several European governmental and non-governmental organisations are making efforts to harmonise pharmacoeconomic research guidelines at the EU level. Ultimately, this may facilitate a more efficient way of conducting pharmacoeconomic research and encourage the use of pharmacoeconomic data by national assessment agencies and governments. It is anticipated that international pharmaceutical companies will increasingly invest in pharmacoeconomics while government staff will become more experienced in appraising the dossiers, thus resulting in an upward momentum in the quality and usability of pharmacoeconomic data. From the Dutch government's perspective, the use of pharmacoeconomic evaluation in reimbursement decision-making should offer a true opportunity for pharmaceutical companies to present the added value for money of new drugs. Using pharmacoeconomic data, costs, benefits and effects of pharmaceuticals are increasingly being considered from a societal perspective, thus going beyond the sole consideration of the impact on the pharmaceutical budget.     

美国罕用药风险管理措施简介与分析以及对我国的启示

介绍美国罕用药的风险管理及典型案例,探讨分析罕用药的风险来源,根据美国罕用药风险监管经验,以我国罕用药现有形式为依据提出适合我国的罕用药风险管理思路,形成上市前和上市后为一体的风险监管模式。     

Economic Evaluation of Changes in Reimbursement for Medications Purchased Through the 340B Drug Pricing Program

Background: The Centers for Medicare and Medicaid Services (CMS) implemented changes to the reimbursement scheme for 340B-acquired medications on January 1, 2018, reducing payments by approximately 25%. It was recognized that these changes would have a significant fiscal impact to Medical University of South Carolina (MUSC) Health. The purpose of this assessment was to review the financial impact of changes in Medicare reimbursement for clinic-administered medications. Methods: This study was a single-center, retrospective, financial evaluation of closed outpatient encounters for Medicare beneficiaries in calendar year 2018. Actual reimbursement was calculated for 2018. To better characterize the margin obtained, exploratory analyses were completed to identify best- and worst-case reimbursement outcomes. This exploratory analysis was conducted for both the new (ASP-22.5%) and old (ASP+6%) reimbursement schemes. Results: Overall, 10 973 encounters were reviewed for inclusion. Ultimately, 8028 encounters were included in the final analysis. Of all encounters, 88 unique medications were administered. Most of the drugs (55%) were associated with oncologic indications. An unfavorable variance was found in 3761 encounters (47%). The actual reimbursement margin for 2018 was $3 193 525. Conclusion: Changes to reimbursement outlined by the CMS at the start of 2018 resulted in decreased reimbursement for 340B-eligible, clinic-administered medications. Most of the unfavorable variances were associated with 340B acquisition prices that exceeded reimbursement. Although the original intent of the 340B Drug Pricing Program was to stretch federal resources, decreased payments could reduce institutional ability to fund programs that support medically vulnerable populations.