cofepris - Montgomery County Chamber of Commerce
Transcription
cofepris - Montgomery County Chamber of Commerce
COFEPRIS: Evolution March, 2011-August, 2013 September 2013 Pharmaceutical Policy • Mexican pharmaceutical policy is committed to increase market access to a well-supplied drug market that offers innovative medicines at low prices. To comply with this commitment, this policy rests on 4 fundamental pillars: 1. A regulatory agency that guarantees safety, quality, and efficacy of all drugs. 2. A reliable scheme to authorize sanitary registrations. 3. The removal of barriers to market entry for safe and high quality products. 4. The harmonization of the sanitary agency regulations with best international practices. Pillar 1. Backlog reduction 3 The issuance of 16,673 sanitary registrations from March 2011 to July 2013, represents a market value close to 2 billion dollars, and has a growth rate of 10,870% relative to 2010. Progress has been as follows: Issuance of 570 sanitary registrations per month, on average in the period March, 2011- July, 2013 18,000 Registros emitidos (acumulado) 16,000 13,873 13,344 13,700 14,000 12,000 10,563 15,100 14,384 14,657 16,453 16,673 15,602 16,017 11,900 11,312 11,618 10,000 7,419 8,000 6,000 4,000 2,000 152 0 2010 2011 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 Jan-13 Feb-13 Mar-13 Apr-13 May-13 Jun-13 Jul-13 • A total of 6,110 sanitary registrations have been issued from June 2012 to July 2013. This improvement implies an average of 470 monthly registrations. The issuance of sanitary registrations will continue growing given that COFEPRIS regulates 10% of GDP. Health Supplies Simplified Vaccine Liberation • The guidelines for the scheme were published in the Official Gazette of the Federation (DOF) on June 1st, 2011. • The new scheme implies a 2-month waiting time reduction. • The maximum allowed response time was reduced from three to only one month. 5 Benefits of Authorized Third Parties Prórroga Registro Average processing time for filings of drug products (months) Modificación • Third Parties issue a “Pre-dictamination” certificate, which must be submitted together with the complete paperwork when filing for a New Registration, an Extension or a Modification to an existent Registration to Cofepris. The “Pre-dictamination” certificate of Third Parties allow to reduce signifcantly the processing time of each individual filing. For example, in the case of new registrations the processing time was reduced by an average of approximately 2 years. Type of filing • Trámite COFEPRIS 30 Trámite con Pre-dictamen 4.5 Trámite COFEPRIS 6 Trámite con Pre-dictamen 3.75 2 Trámite COFEPRIS 0.5 Trámite con Pre-dictamen 0 5 10 15 Months 20 25 30 6 Authorized Third Parties • There are 10 Authorized Third Party Companies currently in operation and 365 products have been authorized in an average of less than 20 days. • The following table shows the type of procedure, the total number of filings submitted and its composition between approved and in process. Filings submitted with Pre-dictamination of Authorized Third Parties Medical Devices Procedure Number of Filings In process Information pending Approved New Registration 213 20 58 135 Extensions 38 4 5 29 Modification 174 27 10 137 New Registration 45 9 16 20 Extensions 3 0 2 1 Modification 57 5 9 43 530 65 100 365 Medicines Total 7 Pillar 2. Legal Framework Improvement to Eliminate Market Distorsions 8 The introduction of generic medicines to the pharmaceutical market have followed this pattern: Package number New registrations Date introduced 1st 31 October 5, 2011 2nd 38 November 16, 2011 3rd 66 December 13, 2011 4th 12 February 16, 2012 5th 7 May 2012 6th 15 July 30, 2012 7th 12 October 5, 2012 8th 33 April 4, 2013 9th 19 July, 2013 These medicines are used to treat the following diseases: Diabetes (type 2) Prostate cancer Anesthesia used during surgical procedures High cholesterol Erectile disfunction Osteoporosis and other bone diseases Several types of Cancer Ovarian cancer and lung cancer Breast cancer High blood pressure and heart failure Respiratory diseases such as asthma Herpes Simplex and Herpes Zoster Schizophrenia Cardiovascular diseases Alzheimer's Disease 28 active substances authorized with 233 sanitary registrations corresponding to 71% of Mexican mortality. Active Substance Innovator’s Brand Authorization Date Therapeutic Use Accumulated Saving in 4 years (millions of pesos) Registrations Atorvastatina Lipitor Oct 5 Lowers blood cholesterol Cardiovascular diseases. $1,655 10 Gemcitabina Gemzar Oct 5 Pancreatic Cancer $249 12 Pioglitazona Zactos Oct 5 Treatment for diabetes mellitus $760 15 Bicalutamida Casodex Nov 16 Treatment for prostate cancer $157 4 Olanzapina Zyprexa Nov 16 Treatment for schizophrenia $1,091 12 Sildenafil Viagra Nov 16 Treatment for erectile disfunction $1,512 22 Valsartán Diovan Nov 16 $628 6 Docetaxel Taxotere Dec 13 $570 13 Montelukast Singulair Dec 13 $1,479 38 Clopidogrel Iscover, Plavix Dec 13 Antiplatelet to prevent blood clots $1,692 20 Cisatracurio Ácido Zoledrónico Nimbex Dec 13 $301 2 Zometa Feb 16 Anesthetic Treatment for osteoporosis and Paget’s bone disease $200 3 Anastrozol Arimidex Feb 16 Treatment for breast cancer $202 11 Valaciclovir Rapivir Feb 16 Treatment for Herpes Simplex and Herpes Zoster $95 2 Treatment for high blood pressure and heart failure Treatment for several types of cancer Treatment for respiratory diseases such as asthma Active Substance Innovator’s Brand Authorization Date Therapeutic Use Accumulated Saving in 4 years (millions of pesos) Registrations Quetiapina Seroquel May Treatment for schizophrenia and bipolar disorder $89 4 Losartán Cozaar May Antihypertensive $840 6 Donepecilo Donepezil May Treatment for Alzheimer's Disease $171 3 Cefepima Maxipime Jul 30 $139 4 Escitalopram Lexapro Jul 30 Treatment for respiratory infections Treatment for depression and anxiety $618 10 Micofenolato de Mofetilo Cellcept Jul 30 Treatment for organ transplant $579 5 Imiquimod Aldara Oct Treatment for warts, keratosis and carcinoma $85 5 Lamivudina 3TC Oct Treatment for Hepatitis B and HIV $58 8 Abacavir Ziagenavir Oct $143 2 Mometasona Supridier Oct Treatment for HIV-1 and HIV-2 Treatment for allergic rhinitis, sinusitis and nasal polyposis $512 2 Irbersartán Aprovel Oct Antihypertensive $840 3 Telmisartán Micardis April 4 Antihypertensive $2,675 6 Meropenem Meronem IV April 4 Antibiotic $1,339 1 Pregabalina Lyrica July Treatment to reduce neuropathic pain $353 4 Total 28 Substances 9 Packages -- $19,032 (1.52 billion dollars) 233 • The average price decrease for the private market has been 67%. Average price of(Promedio) innovator Precio de Innovador $7,000 Average price (Promedio) of generics Precio de Genérico Decrease of 46.3% in price $6,000 Decrease of 61% in price Pesos $5,000 $4,000 Decrease of 88.3% in price Decrease of 65.3% in price Decrease of 83.1% in price Decrease of 52.7% in price Decrease of 73.2% in price Decrease of 66.7% in price $3,000 $2,000 Decrease of 71.8% in price Decrease of 72.2% in price Decrease of 72.1% in price Decrease of 79% in price Decrease of 75.7% in price Decrease of 52.8% in price Average decrease in price: $907 (Decrease of 67%) in price Decrease of 52.8% in price Decrease of 59.2% in price $1,000 $0 Source: Cofepris (2013). 12 • Analyzing the public auctions by the Mexican Institute of Social Security regarding the liberated active substances, we observed an average price reduction of generics of $428, (35 USD) which represents an average reduction of 67.8% for the population. $2,500.00 Decrease of 5% in price $2,000.00 Decrease of 91.4% in price Pesos $1,500.00 $1,000.00 Decrease of 89.7% in price $500.00 $- Decrease of 82.4% in price Decrease of 90.8% in price Average IMSS Decrease of 94.1% in price Decrease of 42.9% in price Precio Promedio en public auction Licitaciones Públicas price in 2011 IMSS 2011 Decrease of 45.8% in price Average IMSSen Precio Promedio public auction Licitaciones Públicas price in 2012 IMSS 2012 Average decrease in price: $428.11 (Decrease of 67.75% in price) 13 Source: IMSS (2011, 2012) and Cofepris (2012). • A total of 28 active substances have been released from October 2011 to June 2013. This corresponds to 233 new registrations of generic medications addressing 71% of Mexico´s mortality causes : Number of Packages Released Substances New Drug Options Accumulated savings during the following four years (billion dollars) 9 28 233 1.52 Aditional Patients 1,081,962 14 Legal reforms regarding biotechnological medicines Comprehensive Legal Framework for Biotechnological Medicines • This new biotechnology regulation places Mexico´s legal framework among the most modern and forward looking legislation currently operating in the European Union and the United States. • In Mexico, 35% of the new applications for innovative pharmaceutical sanitary registrations are related to molecules derived from biotechonology processes, especially in fields related to cancer and neurological diseases. 1. 2009. Enactment of the Biotechnological Medicines Act. 2. October 18, 2011. Issuance of the Administrative Regulations regarding Biotechnology Medicines by the President. Enactment on April 16, 2012. 3. September 20, 2012. Issuance of specific requisites to produce and commercialize biological medicines by COFEPRIS. 15 Incentives for New Molecules • From 2011 to 2013, 88 sanitary registrations for innovative drugs corresponding to 20 different therapeutic groups were granted. This new drugs address 54% of the causes of death in the Mexican population. • The average annual cost of the treatments associated to these drugs is 8 thousand dollars while the market value of the registrations is estimated at around 9.3 million dollars. Number of Sanitary Registrations Therapeutic Classes Average Annual cost of treatments (thousands of dollars) 88 20 8 Deaths associated to Market value of Therapeutic classes as emitted registries (%) of total deaths (millions of dollars) 54% 9.3 16 Equivalence Agreement on New Molecules • In the past, new molecules in Mexico took an average of 360 days to enter the market. • The agreement on new molecules represented an effort to strengthen the access of Mexican families to medicines, reduce health care costs and encourage innovation in three key areas: 1. Foster projects of innovation in Mexico. 2. Strengthen the entry of molecules from other countries to the Mexican market. 3. Mexico becoming a first country to market an innovative drug. 17 The Equivalence Agreement for new molecules is implemented through: 1. Framework to foster projects of innovation in Mexico Before the agreement, research projects of domestic firms were not supported by a regulatory framework. As a consequence there were not any incentives for innovation. The new agreement considers the following: • The creation of a Subcommittee to Evaluate Developing Products within the Committee for New Molecules. • The Subcommittee together with the corresponding Mexican firm will conduct the research process of the new drug. • Once the process is concluded, the approval and registration is granted within 60 days. 2. Equivalence Agreements with national regulatory agencies of Australia, Canada, European Union, Switzerland and United States. Before the Equivalence agreements, COFEPRIS had to repeat the analysis these agencies had done. This situation delayed the access of new medicines to the Mexican market. The new agreement considers: – Recognition of Sanitary Registration of New Molecules from these agencies. – Along with the registration, COFEPRIS tests the quality, safety and efficacy of the products. – Provided the results of tests are positive, COFEPRIS issues a resolution within 60 days after presenting the 18 3. Reform to Promote the Clinical Research in Mexico In the past, Laboratories had to present a sale certificate of other country in order to commercialize a medicine in Mexico. Laboratories had no incentives for clinical innovation in Mexico since they had to introduce medicines in other country before they could sell in Mexico. Mexico could not be their first market. – On October 9, 2012, a regulatory reform was introduce replacing the sale certificate of another contry, with a report of clinical research in Mexican population. – As a result, Mexico could be the first market for innovative drugs, encouraging clinical resarch in the country. – The above has been possible because COFEPRIS has been certified by PAHO as a «National Regulatory Agency of Regional Reference» Certification the PAHO with regard to vaccines and medicines. • As a result of this Agreement, the days to authorize a registration decreased from about 360 days to 60, implying a decrease in the regulatory burden of about 82% of the waiting days. Decrease in Days to Process Registrations with the Agreement 60 days AEMI Molecules from Abroad 360 days Before the agreement MNFN 60 days New Molecules Manufactured in Mexico Before the agreement 240 days 0 50 100 150 200 Number of Days 250 300 350 400 19 • The new regulation provides a framework by which Mexico became the fastest country to authorize the marketing for new molecules while, at the same time, ensures the eficacy, security and quality of medicines. • The main goal: Improve the health of Mexican population. Days to Grant Registration for Innovative Drugs 360 300 300 290 270 220 203 200 180 180 150 120 120 100 90 60 éxico (con acuerdos) Brasil India Argentina Reino Unido Estados Unidos China Australia España Singapur Arabia Saudita Canadá 0 México (antes) Number of Days 400 20 Pillar 3. Regulatory Reform and Deregulation 21 Removal of the requirements to have a manufacturing plant on national soil q In 2011 the Mexican Government removed the requisite to have a manufacturing plant in Mexico to market a medicine q Approval of the first 218 registrations in this category which had been requested more than 10 months before. Impact: BENEFITS: • Increase the supply of pharmaceuticals. • Availability of new molecules for research and development. Investment above 100 million dollars in the next five years. 100% increase in the workforce of the firms involved. 22 Issuance of Registrations through Equivalence Agreements • The scheme is based upon the recognition of the registrations issued by FDA, Health Canada, and Japan for medical devices of any class and COFEPRIS will issue the corresponding registration in a maximum period of 30 working days. Received Applications Market Value of the applications Reduction in the Regulatory Burden Approved Applications The Incoming Applications Correspond to: (Medical Devices) 2,846 245.1 million dollars in the Mexican market (1.5 million pesos each registration). 40% 68% from FDA 30% from Health Canada 2% from Japan 34% Class 1 39% Class 2 27% Class 3 • To this date 2,024 sanitary registrations have been approved by COFEPRIS. Regulation on advertisement of «Miracle Health Scams» • On January 18, 2012 the Health Law was amended aiming to prevent and stop misleading advertisement of fake miracle cures. 70 60 60 58 52 50 47 45 49 CANIPEC agreement 47 41 40 38 PROFECO agreement March 13, 2012. 40 31 30 Copy Advice´s starts 30 20 Orders suspension and refusal of advertising Publication 10 Preparation and consensus reforms RLGSMP Forfeiture 6 to CV Directo and Innova 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 Jan-13 Feb-13 Mar-13 Apr-13 May-13 Jun-13 Entry into force 0 In 12 months, with the implementation of the comprehensive strategy by COFEPRIS, the advertisement of unauthorized products was reduced in 100%, from 58-0 products with media appearances. Jul-13 Feb-12 Jan-12 Dec-11 Nov-11 Oct-11 Sep-11 Aug-11 Jul-11 Jun-11 May-11 Apr-11 Mar-11 Feb-11 0 24 From January 2011 to March 2012, media appearances of such “miracle” cures was reduced about 87.4%. In July, 2013 there were no media appearances. 4,000 Advertisement per month (January 2011 - Julio 2013) 3,676 3,500 2,970 2,9292,950 3,000 2,571 2,468 2,222 2,012 2,500 2,000 2,307 2,212 2,133 1,973 1,903 1,386 1,500 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 Jan-13 Feb-13 Mar-13 Apr-13 May-13 Jun-13 Jul-13 Apr-12 Mar-12 Feb-12 Jan-12 Dec-11 Nov-11 Oct-11 Sep-11 Aug-11 Jul-11 Jun-11 May-11 Apr-11 Mar-11 Feb-11 0 Jul-12 175 Jun-12 500 May-12 1,000 25 • • • The strategy of sanitary surveillance includes forfeiture of tobacco, alcohol, clenbuterol, «miracle» products and health supplies. From 2011 to 2013, irregular medicines were seized in 215 establishments and a total of 43 slaughterhouses have been closed. With this strategy COFEPRIS has increased its efficacy in 50,870% during 2011-2013 compared with 2010, on average. Sanitary surveillance: Inspections and forfeiture of products (2010-2013) Product 2010 2011-2013 Growth rate Tobacco 40,000 cigarettes 156,023,161 cigarettes; 630 Kg. 400,000% Alcohol 87,175 liters 377,745 liters 333% Clenbuterol 0 closed slaughterhouses 43 closed slaughterhouses - «Miracle» products 40,000 units Health Supplies* 2.5 tons. 1,453,054 units; 117,215.4 Kg. 136.7 tons.; 55,696 units (medicines); 1’224,765 pieces (med. Devices) Source: COFEPRIS (2013). Includes data from 2010 to July, 2013. * On medicines comparison is between 2009 and the sum of inspections from 2010 to 2013. Average growth rate 50,870% 3,533% 5,368% 26 • During 2010, COFEPRIS seized only 40,000 fake «miracle» products compared to 1,453,054 products seized from January 2011 to July 2013, implying a 3,533% increase compared to the 2010 figure. The latter resulted from the inspection of 1,668 sites. Forfeiture of «Miracle» Products, 2010-2013* Type of site Points of sale (national) Laboratories CAPSLIM, Warehouse CV Directo**, Marcas de Renombre, S. A. de C. V., Gala Crom Tablets, Nutrisa***, Drug stores and Department stores**** Total Growth rate of forfeitures Seized products Date 40,000 2010 1,453,054 January, 2011 – July, 2013 1,493,054 3,533% * Data generated from January, 2011 to July, 2013. ** Seized products: CELUNUVEL, ONE WEEK ULTRA, COLD HEAT EXTREME, COLD HEAT, MALUNGAY, SKINY SHOT y otras marcas. *** Seized : 26 boxes of 30 units (120 capsules each) plus 11 units of 120 boxes each. **** Products seized: Rejuvital, Xiomega 3, Nopaesbelt, Xenadrine, Demograss, FatBlok, Redu-C2, Lipozene, New Body Slim, Jugo de Aloe Vera, Bonfibra, Emergen-C, Alcachofa, Vital Zen, Ajovit, Gastrisin, Diabetal, Pulmosin, Vari-C, Artri-R, Fortex y Prostasin, Chaparro Amargo, Ginkgo Biloba, Cardiocare, Force-C, Bronkitose, Relaxil, Hierbas Suecas, Alcachofa Diet, Stress Care, Zinestress, Gastrinat, Colesstin, Colesterol 7 días pronat pack, Canecroplan, Dieters Drink, Siluet Control, Body Slim, Redu Si, Wereke, Uña de Gato y Hierba de San Juan. Also, 8 advertisement posters were seized during June, 2012 and 61,865 units of advertisement material were seized during February, 2013. 27 New facilities for COFEPRIS Previous Scheme New Scheme Variation 27 ventanillas 60 ventanillas 33 Ventanillas (+122.2%) 31 simultaneous users 60 simultaneous users 29 users (+93%) 45 waiting minutes 25 waiting minutes -20 minutes (-44%) 600 daily procedures 1,200 daily procedures 600 procedures (+100%) 25,000 files 90,000 files 60,000 files (+260%) Previous New 28 Pillar 4. International Harmonization 29 STEP 1 Meeting with the PAHO representatives regarding future collaboration and a cooperation agreement. June 8, 2011 STEP 2 Participation in the VI Panamerican Conference for the Pharmaceutical Regulation Harmonization, Brasilia, Brazil. July 6-8, 2011 STEP 3 Formal audit in COFEPRIS with the collaboration of personnel from PAHO August 4-5, 2011 STEP 4 Informal audit and consulting by KAIZEN Consulting November 7-16, 2011 STEP 5 Informal audit in COFEPRIS with the collaboration of personnel from PAHO December 12-15, 2011 STEP 6 Informal audit and consulting by KAIZEN Consulting Feb 27–March 2, 2012 STEP 7 Informal Internal Audit by COFEPRIS´ personnel March 20-27, 2012 STEP 8 Informal audit in COFEPRIS with the collaboration of personnel from PAHO April 9-13, 2012 STEP 9 Formal audit in COFEPRIS June 18 – 23, 2012 SUMMARY OF SCORES WITH CRITICAL INDICATORS in % Critical Indicators NI EI PI I Level Regulatory System 0 0 0 100 IV Sanitary Authorization 100 IV Licensing 100 IV Market Surveillance 100 IV Pharmacovigilance 100 IV Clinical Trials 100 IV Inspections 100 IV National Laboratory 100 IV Vaccine Liberation 100 IV TOTAL 100 IV COFEPRIS is now a National Regulatory Agency of Regional Reference * This certification has to be renewed in 2014. Recognition of sanitary registrations abroad Pacific Alliance • On June 20, 2013 the Interagency Agreement between Sanitary Agencies of the Members of the Pacific Alliance was signed in Lima, Peru. The objective is to accelerate the issue of sanitary registrations to medicines in Chile, Colombia, Mexico and Peru. • As a consequence, COFEPRIS and INVIMA recognize sanitary registrations issued by both agencies. The Mexican pharmaceutical industry will now have access to a market with 47 million additional patients. • The Agreement also requests to the sanitary agencies of Chile and Peru to be certified according to PAHO standards in order to benefit from the negotiation. Central America • On July, 2013 COFEPRIS will sign an Agreement of Cooperation and Confidentiality with the sanitary agency of Costa Rica in order to provide technical support and establish a mechanism of rapid access to medicines with registration issued by COFEPRIS. The Mexican pharmaceutical industry will have access to a market with 5 million additional patients. It is expected that the sanitary registration issued by COFEPRIS doubles its coverage and reaches more than 235 million additional patients by 2014. Country Colombia Peru Chile Population, 2011 (in millions) 47 30 17 Source: World Bank (2012). Ecuador & Costa Rica El Salvador 21 5 Panamá Total 3.5 123.5 32 Recognition by the WHO of COFEPRIS for vaccines COFEPRIS began the process of recognition regarding vaccines which is granted by the WHO: 1) With the process that led to the recognition as a «national regulatory agency of regional reference» regarding medicines and vaccines, COFEPRIS has completed 80% of the WHO evaluation procedure regarding vaccines. 2) Seven critical steps have been defined in order to obtain the recognition of the WHO: STEP 1 Reunion with representatives of the WHO about future colaboration and execution of the cooperation agreement. FEBRUARY, 2013 STEP 2 Harmonization of procedure and evaluation tools WHO-PAHO. FEBRUARY STEP 3 Informal review in COFEPRIS with colaboration of WHO staff. APRIL STEP 4 Internal auditing on the fulfillment of the evaluation tool and on the quality management system MAY – JUNE STEP 5 Revision by the PAHO to assure level IV of COFEPRIS as a «national regulatory agency of regional reference» regarding medicines and vaccines. AUGUST STEP 6 Certification of Institutional Quality Management System based on international norm ISO 9001:2008. NOVEMBER STEP 7 Formal auditing to COFEPRIS by WHO regarding vaccines. DECEMBER, 2013 Initiation of PICS membership process COFEPRIS formally applied for pre-accession to the Pharmaceutical Inspection Cooperation Scheme (PICS) in 2013 • COFEPRIS began the process for pre-accession to the PICS to harmonize the inspection standards for GMPs according to the best international practices. • Membership in the PICS will represent benefits to both, the sanitary agency and the industry in terms of avoiding duplicity of inspections. This will be achieved by mutual recognition of GMP certificates among all 44 (countries) members of the scheme. • Competitiveness of the domestic industry will be favored by the reduction of barriers to the entry of Mexican exports to international markets. • Assesment of the organization is expected by the end 2013. COFEPRIS: Evolution March, 2011-September, 2013 September 2013