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<strong>PHTD</strong> <strong>2012</strong> <strong>Spring</strong> <strong>Meeting</strong>, Baltimore MD<br />

48<br />

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F Regulation ahead of product quality. ‘‘The Gold Sheet’’<br />

Manufacturers’ perceptions that they must throw an exorbitant amount of resources<br />

at low-risk problems found during agency inspections is just one of three<br />

PHARMACEUTICAL & BIOTECHNOLOGY QUALITY CONTROL<br />

roadblocks to quality outlined in “Understanding Barriers to Medical Device Quality,”<br />

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Quality,” lists possible solutions for FDA and manufacturers], so it’s critical that we are inspecting for the right things,” CDRH<br />

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ing a company’s bottom line and allowing<br />

Elsevier Business Intelligence<br />

to] get them focused – and ourselves focused – on what matters most.”<br />

CDRH to better utilize its resources,” CDRH<br />

The streams PUbLISHeD<br />

of process analytical data that<br />

$1,935 A Year<br />

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Director Jeffrey Shuren said. A goal for FDA One way FDA might modify its inspectional approach drug makers is to instruct increasingly WeeKLY<br />

its investiga- produce could<br />

tors to place more emphasis on QSR requirements support that regulatory greatly affect compliance the quality by showing<br />

anufacturers, compendial authorities and FDA officials recently explored<br />

is to collaborate with industry to create a<br />

set of robust, commonly understood quality of devices – such as design controls and supplier that processes controls – are and validated less weight and batches on<br />

ways the pharmaceutical industry could use sophisticated statistical meth-<br />

practices ...........................Cover<br />

areas of the regulation that are not as quality-centered. releasable. A recent PQRI meeting explored M ods to unlock the regulatory compliance potential of vast amounts of pro-<br />

how to make it happen. ............................Cover cess analytical data it is generating.<br />

‘‘The Further, inspections could be structured to concentrate more on products with a<br />

FDA quality report Gray singles out Sheet’’ ®<br />

history of quality failures, such as infusion pumps. Inspections also should target Discussions at a recent Product Quality Research Institute workshop focused<br />

seven areas where manufacturers can<br />

known company-specific quality weaknesses, the A coming report out notes. party for China’s GMPs mainly on batch release testing for content uniformity. Manufacturers typically<br />

boost quality ...........................5<br />

m e d c a l d e v c e s a n d d a g n o s t c s China is sending inspectors abroad to see<br />

rely on a compendial end-product testing method that can demonstrate compli-<br />

The report is an attempt by CDRH to understand why device quality problems<br />

Warning Letters<br />

how the rest<br />

ance of a 10- to 30-tablet sample, but that does not address the likelihood that<br />

continue to occur. Offering a menu of action items, it is Vol. of<br />

intended 37, the No. world 50 complies with<br />

as a starting the sample actually represents the batch.<br />

December Respironics cited 12, for 2011<br />

its new GMPs so they can learn how to in-<br />

MDR violations in point for the agency and industry as they work to remove quality hurdles.<br />

spect that kind of quality into China’s do- They talked about alternatives for statistically analyzing these small-sample re-<br />

relation to its Trilogy Continuous Venti-<br />

Manufacturer use of any recommendations in mestic the quality industry. report What is will completely this mean for sults to gain greater batch-wide insights.<br />

lators; SterilMed was selling its Femo- voluntary; FDA has no authority to prescribe to multinational firms how to corporations? make their products. ...................... 8<br />

Stop Gold compression device without<br />

But the main focus of the Sept. 12-13 sample size workshop in Bethesda, Md., was<br />

top news CardioMEMS’ Heart Failure Monitor<br />

Continued > Page 3<br />

FDA approval ......................10<br />

on tapping the treasure trove of process analytical data that constitutes much<br />

Foiled At panel By FDA Inspection FDA deferring CMC changes ‘wish list’ larger and therefore more representative data sets.<br />

CMS pre-payment Close-Out reviews Letters ..................12<br />

In Their Words FDA explains why it’s setting aside industry’s<br />

The existing compendial approach under USP General Chapter 905, Uniformity<br />

Anxiety may be unfounded Findings Of Study Bias<br />

‘wish list’ as it focuses on clarifying draft<br />

News In Brief<br />

of Dosage Units (UDU), for tablets and capsules is also not relevant in the new<br />

Zach Miners guidance on downgrading CMC changes to<br />

The jury is still out on whether Medicare<br />

z.miners@elsevier.com<br />

This quality initiative will allow small firms to dedicate their<br />

quality-by-design manufacturing paradigm where in-process testing and control<br />

Former FDA Office of Compliance Direc- “<br />

annually reportable. PhRMA complains the<br />

pre-payment reviews will significantly<br />

tor Tim Ulatowski joins Becker Consult- n FDA panel limited meeting resources last week on to CardioMEMS areas that Inc they .’s draft PMA know would for its are actually Champion priorities increase supplement to fil- is emphasized, they say.<br />

reduce procedure volumes and device<br />

ing, while former compliance office implantable FDA heart – and failure that monitor is as was beneficial dominated to not them ing by requirements..................................................12<br />

the as firm’s it is to clinical<br />

consumption, but hospital execs say<br />

firms like<br />

USP officials say that they are mulling over the possibility of creating a new chap-<br />

official Larry Spears jumps from Becker A data but by findings from FDA’s pre-market clinical-site inspections pointing<br />

that outcome is unlikely .10<br />

medtronic and Johnson & Johnson.<br />

ter addressing content uniformity of large samples. Meanwhile the European<br />

to Deloitte; AAMI continues to address to bias in that data FDA wants generics more equivalent Pharmacopeia issued a proposal this year outlining new requirements for large<br />

”<br />

“alarm fatigue” .....................14<br />

The result: CardioMEMS appears to be facing an uphill battle at best for ap-<br />

– Steven Silverman, director, CDRH Office of Compliance<br />

samples.<br />

Diagnostic patent or law of nature?<br />

proval That is a disappointing surprise not only for Atlanta-based<br />

No more holding<br />

CardioMEMS,<br />

your nose and trying to<br />

but also for St Jude Medical, which holds a 19% ownership<br />

choke<br />

stake<br />

down<br />

in the<br />

smelly,<br />

firm and<br />

bulky generics. FDA One approach pharmaceutical manufacturers are talking about is adopting the<br />

Mayo v. Prometheus case argued<br />

has touted the technology as a major opportunity for its business<br />

says it wants<br />

(See<br />

them<br />

“St Jude:<br />

the same size, taste and American National Standards Institute E2709 standard, otherwise known as the<br />

before Supreme Court<br />

CardioMEMS’ Heart Failure Data Reflects Major Opportunity”<br />

smell<br />

— “The<br />

as the<br />

Gray<br />

reference<br />

Sheet,”<br />

listed drugs. ............14 CUDAL method, which ASTM approved in 2009.<br />

The court To struggled sign up last for week FREE to map ONLINE Feb ACCESS, 14, 2011 .) go to: www.ElsevierBI.com/publications/The-Silver-Sheet Officials say that CUDAL is a highly effective method in identifying nonconform-<br />

out rules for the types of method<br />

ANDAs will need more stability data ing material for both large and small sample sizes. This method can be used to<br />

claims, particularly for diagnostic<br />

FDA is drafting guidance that will call for ge- assess the likelihood that particular sample results are representative of entire<br />

methods, that should be eligible for<br />

nerics firms to submit up to 12 months of sta- batches, and could play a role in process validation studies and in lot release.<br />

patent protection 12<br />

bility data with their ANDAs, instead of just the<br />

FDA officials also pointed to published simulation studies showing that the ASTM<br />

three months of data currently required. And<br />

E2709 method is superior to the USP 905 chapter for detecting batch defects.<br />

New on the mHealth scene<br />

industry has a lot of questions about it. ...........15<br />

Qualcomm launches wireless<br />

Other statistical approaches for handling large sample sizes discussed at the<br />

health business<br />

Telecommunications firm unveils Qualcomm<br />

Life, a new health care sub-<br />

What ICH Q1A means for generics<br />

conference included parametric tolerance interval test (PTIT) and nonparametric<br />

counting test methods. Both approaches can be used to ensure dose uniformity<br />

Current stability testing requirements vs.<br />

at lot release.<br />

what ICH Q1A requires. ......................................18<br />

sidiary The company’s first product,<br />

pictured below, is a platform that will<br />

CardioMEMS’ Champion heart failure sensor is implanted via catheter to continuously<br />

Continued > Page 3<br />

allow wireless medical devices to send<br />

take pulmonary artery pressure measurements.<br />

patient data from the home to a cloud-<br />

To sign up for FREE ONLINE ACCESS, go to: www.ElsevierBI.com/publications/The-Gold-Sheet<br />

based storage site .20<br />

FDA’s Circulatory System Devices panel voted 6-4 that the benefits of Champion<br />

do not outweigh its risk at the Dec 8 meeting in Gaithersburg, Md<br />

And in spite of the fact that the trial met its primary endpoint of reducing<br />

heart-failure hospitalizations, panel members voted 3-7 against device effectiveness<br />

due largely to a level of interaction between the sponsor and clinical site<br />

investigators that FDA said went beyond the protocol outlined in the firm’s PMA<br />

submission<br />

This “auxiliary management,” as panelists came to call it, included telephone<br />

calls and certain e-mails offering medical therapy advice from CardioMEMS nurses<br />

to study investigators Most panel members agreed they could not tease out the<br />

clinical benefits of the device from the benefits of the sponsor-generated therapy<br />

recommendations<br />

“There are confounding factors that make it impossible to know if the device alone<br />

can explain the benefit,” concluded David J Slotwiner, of Long I<strong>sla</strong>nd Jewish Medical<br />

Table of Contents > page 3<br />

Story continues > Page 5<br />

To sign up for FREE ONLINE ACCESS, go to: www.ElsevierBI.com/publications/The-Gray-Sheet<br />

Elsevier Business Intelligence<br />

Photo: CardioMEMS top stories<br />

Table of Contents > 3<br />

P R E S C R I P T I O N P H A R M A C E U T I C A L S A N D B I O T E C H N O L O G Y<br />

January 2, <strong>2012</strong><br />

Research Policy<br />

NIH Repurposing Of Failed<br />

Compounds Could Begin Soon<br />

NIH’s National Center for Advancing<br />

Tran<strong>sla</strong>tional Science could launch its<br />

first project in early <strong>2012</strong> with an agreement<br />

with one or more drug companies<br />

to repurpose compounds that the firms<br />

have abandoned. Negotiations with industry<br />

are very close to bearing fruit,<br />

says Kathy Hudson, an NIH deputy director<br />

and NCATS’ acting deputy director.<br />

The repurposing project would the first<br />

uniquely NCATS program..........................11<br />

Manufacturing<br />

Ranbaxy’s $500 Million<br />

GMP Settlement Would Be<br />

Second Most Expensive For<br />

Rx Manufacturing Violations<br />

Ranbaxy Laboratories’ consent decree<br />

with FDA and agreement to set aside<br />

$500 million to settle a related Department<br />

of Justice investigation appears<br />

to put the Daiichi Sankyo subsidiary on<br />

pace to pay the second highest settlement<br />

for pharmaceutical good manufacturing<br />

practice violations, according to<br />

data compiled by “The Pink Sheet”.......25<br />

European Health<br />

Technology Assessment<br />

Grunenthal CEO Views German<br />

Reimbursement Hurdle As Fair, As Pain<br />

Drug Palexia Rolls Out Across Europe<br />

German reimbursement authority’s strong<br />

emphasis on drugs’ added benefit is logical,<br />

Grunenthal’s Harald Stock says, and all<br />

health care systems will eventually move<br />

the same way.....................................................8<br />

Looking AheAd To <strong>2012</strong>:<br />

To sign up for FREE ONLINE ACCESS, go to: http://ThePinkSheet.ElsevierBI.com<br />

$2,450 A YEAR (print and online)<br />

Founded 1939 | Vol. 74, No. 1<br />

ACOs Get In Gear, Accelerating The Need to Prove<br />

Biopharma Products’ Overall Value In Health Care<br />

F<br />

Scott Steinke s.steinke@elsevier.com<br />

or any biopharma manufacturers standing on the sidelines as Medicare<br />

accountable care <strong>org</strong>anizations take shape, the time has arrived to<br />

get involved.<br />

The first group of ACOs began operations Jan. 1, and from day one, their<br />

focus is on improving patient outcomes while also reducing the growth of<br />

health care costs. Manufacturers that connect with ACOs and convince them<br />

that their products contribute to both of those goals stand to gain share in<br />

what could be a very influential program.<br />

Improving outcomes while reducing costs is a familiar phrase in the health care<br />

world. But with the creation of ACOs under the Affordable Care Act, Medicare is aiming<br />

to put that phrase into practice by allowing all of the providers who interact with<br />

Medicare beneficiaries – from primary care and specialty physicians to hospitals and<br />

long-term care facilities – to <strong>org</strong>anize into groups that will coordinate care. Through<br />

the associated Medicare Shared Savings Program, ACOs will share in the cost savings<br />

achieved or be penalized for cost over-runs based on a spending benchmark, all<br />

while having patient outcomes measured to ensure care is improving.<br />

Despite early reservations that the accountable care program would have few<br />

takers, 32 ACOs, which CMS is calling “Pioneer ACOs,” started up Jan. 1. Other<br />

Key Points<br />

Story continues > Page 4<br />

• ACO providers are responsible for overall patient outcomes and the related<br />

costs, so physicians must consider the overall value to patient care of the<br />

drugs they prescribe.<br />

• ACO P&T committees are likely to develop formularies and treatment guidelines<br />

for their physicians, so it will be essential to present the committees with good<br />

data on a product’s value to overall patient care.<br />

• Manufacturers should look for opportunities to partner with ACOs, both<br />

to ensure the overall success of the ACO model and to ensure expected<br />

outcomes for particular products are achieved, such as through working<br />

on patient adherence.<br />

• High-priced oncologics could be particularly vulnerable in ACOs to the need<br />

for high-quality data on value, since cost benchmarks cannot be adjusted to<br />

account for new therapies and cancer care is not a quality measure.<br />

• The Medicare ACO model could spill over into other health care settings, with<br />

successful ACOs potentially contracting to provide services to managed care<br />

<strong>org</strong>anizations serving commercial or Medicaid plans.

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