Development of a Guideline on the Off-Label-Use of Drugs. Maria Luise Bauer, M.Sc. 1 st February 2014

Similar documents
Commissioning Medicines for Children in Specialised Services. Reference: NHS England: /P

NHS Lanarkshire Policy for the Availability of Unlicensed Medicines

The more you link, the more you risk... a focus group study exploring views about data linkage for pharmacovigilance

Process and methods Published: 23 January 2017 nice.org.uk/process/pmg31

The Medicines for Children Research Network: building on current success as we move forward

POLICY. Use of Antipsychotic Medications in Nursing Facility Residents. Preamble. Background

Questions and answers on the procedure of PIP compliance verification at EMA, and on paediatric rewards

South East London Interface Prescribing Policy including the NHS and Private Interface Prescribing Guide

Safer use of anticoagulants: the NPSA patient safety alert Steve Chaplin MSc, MRPharmS

Uncontrolled when printed NHS AYRSHIRE & ARRAN CODE OF PRACTICE FOR MEDICINES GOVERNANCE. SECTION 9(a) UNLICENSED MEDICINES

Disclosures. Legal Issues and Prescribing. Objectives. The Basics. Rights Required of Prescribers. Laws You Should Know 10/27/2015

Corporate Induction: Part 2

Linking NHS data for pediatric pharmacovigilance: Results of a Delphi survey

FRAMEWORK BRIEF. Parenteral Nutrition

...FREEDOM TO EXPLORE YOUR REGULATORY NEEDS

Unlicensed Medicines Policy

Non Medical Prescribing: medicines management and use review: are you prescribing cost effectively?

Rapid Review Evidence Summary: Manual Double Checking August 2017

Draft EU Guidance on Medication Errors

Section Title. Prescribing competency framework Catherine Picton, Lead author

Introducing Paediatric Pharmacy

NHS GREATER GLASGOW AND CLYDE POLICIES RELATING TO THE MANAGEMENT OF MEDICINES SECTION 9.1: UNLICENSED MEDICINES POLICY (ACUTE DIVISION)

How NICE clinical guidelines are developed

Isotretinoin : Review of the Pregnancy Prevention Programme

Bulletin Independent prescribing information for NHS Wales

UKMi and Medicines Optimisation in England A Consultation

Medication Reconciliation in Transitions of Care

Literature review: pharmaceutical services for prisoners

Policy and procedures for the use of unlicensed medicines

Continuous Professional Development of Health Professionals European Context

Unlicensed Medicines Policy Document

ALABAMA BOARD OF NURSING ADMINISTRATIVE CODE CHAPTER 610-X-5 ADVANCED PRACTICE NURSING COLLABORATIVE PRACTICE TABLE OF CONTENTS

Community Nurse Prescribing (V100) Portfolio of Evidence

Code of Conduct for business registrants

NATIONAL PATIENT SAFETY AGENCY DRAFT PATIENT SAFETY ALERT. Safer Use of Injectable Medicines In Near-Patient Areas

ALABAMA BOARD OF MEDICAL EXAMINERS ADMINISTRATIVE CODE CHAPTER 540-X-8 ADVANCED PRACTICE NURSES: COLLABORATIVE PRACTICE TABLE OF CONTENTS

Alert. Patient safety alert. Actions that can make anticoagulant therapy safer. 28 March Action for the NHS and the independent sector

Educating nonmedical prescribers

HEALTH CARE: TRUST, MISTRUST, VOICE OR CHOICE?

MedDRA User Group. Paris, April 16, 2015 Victoria Newbould, European Medicines Agency. An agency of the European Union

All areas of the Trust All Trust staff All Patients Deputy Chief Nurse & Chief Pharmacist Final

Best Practice Guidance for Supplementary Prescribing by Nurses Within the HPSS in Northern Ireland. patient CMP

Pharmaceutical Services Report to Joint Conference Committee September 2010

RULE RESPONSIBILITIES OF A PHYSICIAN WHO ENGAGES IN DRUG THERAPY MANAGEMENT WITH A COLORADO LICENSED PHARMACIST

Terms & Conditions of Award

TITLE: Pill Splitting: A Review of Clinical Effectiveness, Cost-Effectiveness, and Guidelines

5.3: POLICY FOR THE MANAGEMENT OF REQUESTS FOR MEDICINES VIA PEER APPROVED CLINICAL SYSTEM (PACS) TIER 2

Changes in practice and organisation surrounding blood transfusion in NHS trusts in England

National Medication Safety Network. Observatory Erskine David UKMI, Guy s and St Thomas NHS Foundation Trust

The U.S. Food and Drug Administration s Food Safety Modernization Act: Current & Future Requirements

PARTICULARS, SCHEDULE 2 THE SERVICES, A Service Specification. 12 months

Non-Medical Prescribing Passport. Reflective Log And Information

One or More Errors in 67% of the IV Infusions: Insights from a Study of IV Medication Administration

Non Medical Prescribing Policy Register No: Status: Public

Policy for the Administration of the First Dose of an Intravenous Antibiotic to Adult and Paediatric Patients by Nurses

SALE, SUPPLY AND ADMINISTRATION OF MEDICINES BY ALLIED HEALTH PROFESSIONALS UNDER PATIENT GROUP DIRECTIONS

The most widely used definition of clinical governance is the following:

CLINICAL PROTOCOL FOR THE DEVELOPMENT AND IMPLEMENTATION OF PATIENT GROUP DIRECTIONS (PGD)

NHS and Private Interface Prescribing Guide

NHS public health functions agreement Service specification No.2 Neonatal BCG immunisation programme

5. returning the medication container to proper secured storage; and

CARE OF THE DYING IN THE NHS. The Buckinghamshire Communique 11 th March The Nuffield Trust

QUALITY MANAGEMENT IN HEALTHCARE A EUROPEAN CHALLENGE THE GERMAN EXPERIENCE AMBULATORY SURGERY - HYGIENE FRAMEWORK CONDITION

Guidance on the prescribing of medication initiated or recommended either after a private episode of care or a referral to a tertiary NHS centre

Adverse Drug Events and Readmissions: The Global Picture

A web-based service for improving conformance to medication treatment and patient-physician relationship

The French Space Operation Act

Consultation on initial education and training standards for pharmacy technicians. December 2016

European Commission consultation on measures for improving the recognition of medical prescriptions issued in another member state

Health Education England

Best Practice Guidelines - BPG 9 Managing Medicines in Care Homes

GDPR DATA PROCESSING ADDENDUM. (Revision March 2018)

NMC programme of change for education Prescribing and standards for medicines management

NHS. The guideline development process: an overview for stakeholders, the public and the NHS. National Institute for Health and Clinical Excellence

Guidance for registered pharmacies preparing unlicensed medicines

Zukunftsperspektiven der Qualitatssicherung in Deutschland

Tackling the challenge of non-adherence

Resource impact report: End of life care for infants, children and young people with life-limiting conditions: planning and management (NG61)

Making medicines safer for children guidance for the use of unlicensed medicines in paediatric patients

SUPPLEMENTARY PRESCRIBING: PHARMACIST PRACTITIONERS

MANDATORY SOCIAL WORKER REGISTRATION. A Discussion Paper. Prepared by: The Social Workers Registration Board Kāhui Whakamana Tauwhiro

CASE STUDY ON THE MANAGEMENT OF MEDICATION ERRORS AND NEAR MISSES: MALAYSIA PERSPECTIVE

Evaluation of case write-up: Assessment of prescription writing skills of fifth year medical students at UKM Medical Centre

A step by step guide to using IRAS to apply to conduct research in or through the NHS/HSC.

MEDICATION ERRORS: KNOWLEDGE AND ATTITUDE OF NURSES IN AJMAN, UAE

Maryland Patient Safety Center s Annual MEDSAFE Conference: Taking Charge of Your Medication Safety Challenges November 3, 2011 The Conference Center

Safeguarding public health. The New PV Legislation its Impact on PV & MI

Announcing the launch of the NICE BNF and NICE BNFC apps in Scotland, Sir Andrew Dillon, NICE Chief Executive, said:

S2 and Directive routes: guidance for commissioners

Improving compliance with oral methotrexate guidelines. Action for the NHS

RULES - Copernicus Masters 2017

Medication Errors Assessment and Prevention by a Clinical Pharmacist in Pediatric Wards. Peshawar, KPK-Pakistan. Original Article.

Improve patient safety and clinical outcomes Optimise medication therapy Provide patient care

Professional Student Outcomes (PSOs) - the academic knowledge, skills, and attitudes that a pharmacy graduate should possess.

Risk Evaluation and Mitigation Strategies: Improving Benefit-Risk Counseling Between Providers and Patients 4/14/2016

North Carolina Board of Nursing

Health Sciences Department or equivalent Division of Health Services Research and Management UK credits 15 ECTS 7.5 Level 7

abcdefghijklmnopqrstu

Process and methods Published: 30 November 2012 nice.org.uk/process/pmg6

Explanatory Memorandum to the Mental Health (Secondary Mental Health Services) (Wales) Order 2012

Transcription:

Development of a Guideline on the Off-Label-Use of Drugs Maria Luise Bauer, M.Sc. 1 st February 2014

Structure Motivation Off-Label-Use in Pediatrics Definitions of Off-Label-Use Off-Label-Use in Germany Liability in Germany Comparison to Other Countries Questionnaire Summary 1

Motivation Off-Label-Use: is widely practiced and recommended throughout the medical society is a legal cross-section concerns drug law, liability law, health insurance law and professional rights has no legal concept in Germany 2

Motivation >20% of physicians are not familiar with the term offlabel-use 1 73% of all off-label-uses have little to no scientific support 2 >80% of pediatricians feel that the information about the risks and benefits of an off-label-use is inadequate 3 1) Ekins-Daukes S, Helms PJ, Taylor MW, McLay JS. Off-label prescribing to children: attitudes and experience of general practitioners. Br. J. Clin. Pharmacol. 2005;60(2):145 9 2) Radley DC, Finkelstein SN, Stafford RS. Off-label prescribing among office-based physicians. Arch. Intern. Med. 2006 166(9):1021 6 3) Saullo F, Saullo E, Caloiero M. A questionnaire-based study in Calabria on the knowledge of off-label drugs in pediatrics. J. Pharmacol. Pharmacother. 2013 3

Off-Label-Use in Pediatrics Children are not just small adults 20% of the European population is aged under 16 4 50-90% of all medicines are not tested on children 5 Prevalence of off-label-use in children is 13%-90% 6-7 High risk of adverse drug reactions 4) European Commission. Better Medicines for Children From Concept to Reality. 2013 5) Conroy S, Choonara I, Impicciatore P. Survey of unlicensed and off label drug use in paediatric wards in European countries. BMJ. 2000;320:79 82 6) Buecheler R, Schwoerer P, Gleiter CH. Off-Label-Verordnungen in der Paediatrie. Bundesgesundheitsblatt - Gesundheitsforsch. - Gesundheitsschutz. 2003 ; 46(6):467 76 7) O Donnell CPF, Stone RJ, Morley CJ. Unlicensed and Off-Label Drug Use in an Australian Neonatal Intensive Care Unit. Pediatrics. 2002 4

Reasons for the Lack of Pediatric Studies Studies with children are much more expensive and time consuming Few experts in pediatric pharmacology Need for special formulations Low market potential and low profitability 5

Pediatric Regulation (EC) 1901/2006 Pediatric Investigation Plan (PIP) Waiver or deferral possible Pediatric Committee (PDCO) Pediatric Use Marketing Authorization (PUMA) Creation of financial incentives 6

Definitions of Off-Label-Use No legal term for off-label-use in Germany: Can lead to uncertainties concerning liability and patient safety Great need for a single, uniform legal definition for both patients and medical staff 7

Definitions vs. Off-label-use is: The use for an indication, dosage form, dose regimen, population or other use parameter not mentioned in the approved labeling. (FDA Modernization Act) The use of a drug which has a marketing authorization but is used for a condition, at a dose, via a route or for an age that is not listed in the Summary of Product Characteristics for that drug. (British NHS Guideline) 8

Definitions in the Scientific Literature Off-label-use is the use of an approved drug for medical treatment that is not described or intended in the drug labeling and that would require a corresponding adjustment or amendment of the drug approval or a new drug approval. (Plate et al.) 8 Considering the drug approval an off-label-use will not come about after a violation of 22 para. 3 AMG, but rather the off-label-use only exists, when the drug is used in a way that causes an amendment of the drug approval according to 29 para. 2a AMG or a new drug approval according to 29 para. 3 AMG. (Schroeder-Printzen & Tadayon) 9 8) Plate, V. et al. Wohin treibt der Off-Label-Use?. A&R, 2008, H. 6, 261-269 9) Schroeder-Printzen, J. and Tadayon, A. Die Zulässigkeit des Off-Label Use nach der Entscheidung des BSG vom 19.3.2002. SGB 12 (2002): 664. 9

Off-Label-Use in Germany Expert Group Off-Label Assigned by the Federal Ministry of Health (BMG) in 2002 Reviews on the scientific knowledge on the off-label-use of certain medicinal products Submits learned information to BMG and Federal Joint Committee (G-BA) G-BA decides whether off-label-use is covered by health insurance 10

Verdict of the Federal Social Court B1 KR 37/00 R Coverage of off-label-drugs by health insurance if: 1. Serious disease 2. Lack of treatment alternative 3. Reasonable prospect for a successful treatment with the drug in question according to the state of scientific knowledge Affirmed by Federal Constitutional Court in 2005 11

Liability in Germany 84 para. 1 German Medicine Act: Legal responsibility lies with the producer only if a medicinal product is used in the designated way. Is off-label-use a designated use? 12

Liability in Germany 84 para. 1 German Medicine Act: Legal responsibility lies with the producer only if a medicinal product is used in the designated way. Liability in case of adverse drug reaction following off-label-use? MAH is liable, if off-label-use is common practice Physician is liable even if off-labeluse is evidence based Red hand letter or contraindication? Obliged to tell patient that he alone is liable? 13

Health Care in the UK Department of Health supervises the National Health Service (NHS) Publicly funded Individual regulations in England, Wales, Scotland and Northern Ireland: National Health Service (England) Health and Social Care in Northern Ireland (HSCNI) NHS Scotland NHS Wales 14

National Institute for Health and Clinical Excellence (NICE) Establishes guidelines for: - Use of health technologies within the NHS - Clinical practice - Guidance for public sector workers on health promotion and ill-health avoidance NHS must cover all NICE-recommended treatments 15

Off-Label-Use in the UK NHS Guideline for Unlicensed and Off-Label-Use Medicines: Definition of off-label-use Checklist for practitioners Register of unlicensed and off-label-use of medicines NICE Evidence Summaries: Unlicensed/Off-Label Medicines (ESUOM) 16

Liability in the UK Marketing Authorization Holder (MAH) are generally not liable for harm as a result of unapproved use, but: NHS Trust accepts liability, provided the NHS Guideline has been followed Patient has to be informed about unlicensed drug use 17

Health Care in France Close to best overall health care in the world 10 Government has responsibility for the financial and operational management Insurers are non-profit agencies 70% of most health care costs are refunded, 100% of costly or long-term ailments 10) http://www.who.int/whr/2000/media_centre/press_release/en 18

Off-Label-Use in France Temporary Recommendations for Use (TRU): Granted for a maximum of three years by ANSM Aims to assess risks and benefits and collect scientific information on designated off-label-use Reimbursment for designated indication If there appears to be a risk to public health, ANSM can suspend or modify the TRU 19

Questionnaire Main Topics Definition of off-label-use Main problems of off-label-use for physicians Reimbursement and liability Off-label marketing 20

Questionnaire Definitions of Off-Label-Use Perfect agreement on the following definition: Off-label-use means the use of a licensed medicinal product outside the terms of the marketing authorization issued by the national or European competent authorities. 21

Questionnaire Reimbursement Agreed main problems of off-label-use for physicians are liability and recourse claims Many doctors are afraid of prescribing off-label, even if it is in the best interest of the patient, because of possible recourse claims Most physicians argued that it would be in the best interest of the patient, if the reimbursement of off-labeldrugs was regulated similar to the NHS-system 22

Questionnaire Liability No agreement on liability: Some questionees stated that MAH should be liable in case of common off-label-uses Others argued that there should be a system based on the British NHS Guideline or an independant fund 23

Questionnaire Marketing All agreed, that there is a great need for more information for physicians, but: most argued, that information should not be provided freely by MAHs but by independent experts or as part of planned expanded approvals and only available to the medical society 24

Summary Legal term for off-label use is highly needed and should be implemented Recourse claims and liability issues are a great problem for both physicians and patients A combination of the French TRU decree and the British NHS Guideline should be applied to German law Need for information on off-label-drugs could be adressed similar to the ESUOM 25

List of references 1) Ekins-Daukes S, Helms PJ, Taylor MW, McLay JS. Off-label prescribing to children: attitudes and experience of general practitioners. Br. J. Clin. Pharmacol. 2005;60(2):145 9 2) Radley DC, Finkelstein SN, Stafford RS. Off-label prescribing among office-based physicians. Arch. Intern. Med. 2006 166(9):1021 6 3) Saullo F, Saullo E, Caloiero M. A questionnaire-based study in Calabria on the knowledge of offlabel drugs in pediatrics. J. Pharmacol. Pharmacother. 2013 4) European Commission. Better Medicines for Children From Concept to Reality. 2013 5) Conroy S, Choonara I, Impicciatore P. Survey of unlicensed and off label drug use in paediatric wards in European countries. BMJ. 2000;320:79 82 6) Buecheler R, Schwoerer P, Gleiter CH. Off-Label-Verordnungen in der Paediatrie. Bundesgesundheitsblatt - Gesundheitsforsch. - Gesundheitsschutz. 2003 Jun 1;46(6):467 76 7) O Donnell CPF, Stone RJ, Morley CJ. Unlicensed and Off-Label Drug Use in an Australian Neonatal Intensive Care Unit. Pediatrics. 2002 8) Plate, V. et al. Wohin treibt der Off-Label-Use? A&R, 2008, H. 6, 261-269 9) Schroeder-Printzen, J. and Tadayon, A. Die Zulässigkeit des Off-Label Use nach der Entscheidung des BSG vom 19.3.2002. SGB 12 (2002): 664. 10) http://www.who.int/whr/2000/media_centre/press_release/en 26