Controls
on medicines — launching a new medicine
<
Influencers contents
|
Print
this page
Launching
a new medicine
Once a product
licence is issued, a summary of product characteristics (SPC) is
made available to prescribers. Thereafter, the price will be set,
the marketing campaign begins and the product will be advertised
and promoted by medical sales representatives in hospitals and general
practice. Unlike the USA, the Medicines Act forbids direct advertising
to patients. The marketing launch can be expensive but the Pharmaceutical
Price Regulation Scheme (PPRS), which also controls the profits
made on branded drugs, regulates what can be spent. NHS influencers
might like to read Pharmaceutical
Price Regulation Scheme: sixth report to Parliament.
These reports are normally dry and boring. However from this report
NHS influencers would draw useful background material on supply-side
and demand-side pressures on the industry. Links are also made to
the Pharmaceutical Industry Competitiveness Task Force (PICTF).
The PICTF publications would also be useful for NHS influencers
to examine.
The DH launched
an early consultation with the NHS on the next five-year PPRS scheme
due to commence in October 2004. Please see the PPRS
discussion paper, which basically suggests a limited
number of future options — rolling forward the current scheme,
a bit of deregulation or brand new ideas. Annex B contains the results
of a study into the extent of competition in the supply of branded
medicines to the NHS and suggests, amongst other things, that there
is little evidence as yet that the demand-side initiatives that
have been implemented have had much effect on prescribers on the
relative prices of competing drugs. The executive summary of this
is well worth the read. Note that amongst the stakeholder groups
the government took soundings from before the renegotiations started
formally were NHS management — particularly SHA, acute trust
and PCT chief executives.
In DH
press release 2003/0320 we discover that 'PPRS limits
the prices of branded prescription medicines to the NHS by regulating
profits.' The last renegotiation led to a mandatory price cut and
the same is expected this time around.
Pharmaceutical
companies are free to set their own prices on new drugs, which are
often set high, not only in order to pay for further R&D but
also because in effect, once set, prices are difficult to increase
at all during the patent period. It is worth pointing out that the
price of more than 60 per cent of all medicines is below the prescription
charge.
The Medicines
Act provides for the control of misleading or untruthful promotion,
making it unlawful to publish advertisements incompatible with the
wording of the product licence. The Association of the British Pharmaceutical
Industry has a voluntary code of practice for its members, governing
the ethics and conduct in marketing. Breaches of the code are widely
published.
Medicine
categories
There are three legal categories of medicines, classified
into:
- Prescription only medicines (POM)
- Supply under the supervision of a pharmacist
(P)
- General sales list (GSL)
A new chemical entity will initially almost certainly
be given a POM license. As the patents on more branded medicines
expire, more POMs are being reclassified to P and some of these
to GSL. Note then that omeprazole (10mg tablets) has been reclassified
to P (supplied under specific conditions), as has the cholesterol-lowering
drug, zocor (simvastatin). Zovirax cold sore cream has been reclassified
to GSL. These changes are significant as this relates to independent
prescribing by nurses, who are able to prescribe all P and GSL medicines.
But the reclassification
of simvastatin has caused considerable debate. In a stinging editorial,
The Lancet journal echoed the Consumers’ Association
in saying that no trials of over the counter (OTC) simvastatin have
been conducted, and added its concerns that individuals purchasing
the statin must be encouraged to make important lifestyle changes,
such as giving up smoking and losing weight. While the US knocked
back two applications for OTC statins in 2000 because of insufficient
evidence of their efficacy in this setting, The Lancet
claims the UK — the first country to make a statin available
OTC — will become ‘guinea-pigs in this large-scale OTC
experiment.’
With 1.8m people prescribed statins in the UK, at
a current cost to the NHS of £700m per year and expected to
rise to £2bn by 2010, the journal says: ‘It is difficult
to avoid concluding that the motive behind the government’s
decision is saving money.’ The Lancet also believes
the OTC move will increase health inequalities, with only the better
off able to afford the anticipated £15 per month cost, and
stresses that the UK must implement a surveillance system to evaluate
the risk-to-benefit ratio of using statins in this setting. See
www.thelancet.com
and Wellard’s
NHS news, May 2004.
Patent
expiries
‘Patent
expiries — how should they affect prescribing advice?’
in October 2003’s Pharmaceutical Journal is a worthwhile
read for all NHS influencers. It is a review on trends in the generic
drugs market and how these should influence the policy decisions
of primary care organisations (PCOs). The piece replays the fact
that PCOs had looked forward to windfall savings when products came
off patent but that there is increasing evidence that it is now
taking much longer for the NHS price of generic drugs to fall by
an amount significant enough to affect prescribing budgets. There
is a useful discussion on branded and generic statins, generic omeprazole,
formulary inclusion and switches and the fact that some PCOs have
already built anticipated savings into their budget projections.
'Where this is the case, these PCOs are likely to be left facing
a search for additional economies in order to deliver a balanced
financial position as the year progresses,' the article says.
Generic
medicines
The government
has also introduced a brand new system of reimbursing the cost and
supply of generic medicines. Four generic medicines (simvastatin,
omeprazole, lisinopril and doxazosin) have seen their reimbursement
prices reduced twice in 2004. The new scheme replaces the ‘maximum
price scheme’, introduced in 2000 following concerns raised
over costs and availability of generic medicines. For the latest
consultation letter, please see the DH’s
ongoing consultation section.
Yellow
Card scheme
NHS influencers
might like to know that the Medicines and Healthcare Products Regulatory
Agency (MHRA) extended its suspected adverse drug reaction reporting
scheme (the Yellow Card scheme) in 2003 to all nurses, adding around
330,000 NHS health professionals to the scheme. The scheme now accepts
reports from doctors, dentists, pharmacists, nurses, midwives and
health visitors. The extension is also being supported by the introduction
of an electronic Yellow Card, which can be used by all health professionals
to enable quicker and easier submission of reports. The e-Yellow
Card can be found on the MHRA
website. To strengthen the scheme still further the
MHRA is working with NHS Direct to enable patients to report through
NHS Direct telephone lines and to use NHS Direct Online. So patients
who experience side effects from their medication can now report
problems to medicines experts directly rather than having to see
their GP. The intention is that the scheme will be rolled out across
England. Patients suffering from adverse effects from a medicine
will also for the first time be able to report them directly to
the MHRA and the Committee on Safety of Medicines. Reporting cards
will be placed in GP surgeries and ‘patients are not expected
to use conventional scientific or medical language in their report’.
Over
the counter medicines
The MHRA has
also published plans to remove legal restrictions on advertising
a range of over the counter (OTC) medicines. The vast majority of
OTC products may already be advertised to the public. However, the
current UK legislation lists a number of diseases for which this
is not the case, although they can be purchased through pharmacies
or more widely through retail outlets. The MHRA consultation sought
views on the removal of these restrictions. Medicine advertising
is already tightly controlled through voluntary codes of practice
operated by the industry and advertising regulators. This is backed
by statutory controls enforced by the MHRA. All these safeguards
will remain, including the ban on direct to consumer advertising
of prescription only medicines. The full proposals are available
on the MHRA
website.
|