Decision points in current vs. future processes by stakeholder groups, and resource implications for a roadmap for implementation (D3.02)
The introduction of a new concept introduces new dynamics to which the involved stakeholders need to adapt. When considering the feasibility and practicalities of being involved in an adaptive pathway to medicines – which includes multi-stakeholder interactions, iterative cycles of development and assessment, and long term real-world data (RWD) collection – each stakeholder must have a clear understanding of their remit (current or new), the type of input requested from them (advice or decisions), and the appropriate resources needed.
At present it is unlikely that each stakeholder will have the required capacities such as time, finance and remit, or capabilities such as specific expertise, to be an active participant in MAPPs. Therefore, the views of each stakeholder on the resources they would need to engage in MAPPs were gathered through a joint effort between D2.05 (Seamless pathway) and D3.02 (Decision points) through consensus building and workshops.
Being part of a multi-stakeholder initiative in adaptive pathways requires some specific knowledge of basic research, clinical development and regulatory requirements such as;
- Science: Disease and product-specific knowledge.
- Processes: Understanding of the MAPPs concept, regulatory tools (such as parallel scientific advice and conditional marketing authorisations), pricing and reimbursement mechanisms, cost effectiveness assessment, managed entry agreements, and prescription control tools and measures.
- Methodologies: Clinical trial design, data analysis, real world evidence generation, and small population studies.
The recommendations presented in this document should always be read in combination with the seamless pathway report (D2.05) as it builds on the key decision points identified in that document. The remits of each stakeholder remain, but new roles are emerging and the most impacted stakeholders, in terms of new resource needs and capacity to mobilize them effectively, were considered to be pricing and reimbursement authorities (including HTA), patients, and healthcare providers (HCP).
The multiple Member State-specific remits and structure for pricing and reimbursement authorities are very challenging to map in detail. They are normally not involved in early discussions, and the centralized and broad concept of MAPPs may not be applicable across all Member States. New initiatives like the joint EMA and European Network of HTAs (EuNeHTA) platform may be very important in establishing coordinated advice on development plans for early scientific advice and post-launch evidence generation.
Patient involvement is often voluntary. A mechanism to further support, educate, and expand their involvement needs to be considered, including how best to provide funding. Streamlining and prioritising involvement via a centralized broker like the European Patients’ Forum (EPF) or European Organisation for Rare Diseases (EURORDIS) or umbrella organisations could help.
Healthcare professionals would need knowledge on the MAPPs concept, instructions on how to optimise real world data collection in clinical practice, and specific information on the product in question. This could be implemented via risk management plans or other tools, and co-ordinated through European Reference networks or other competent bodies.
For the adaptive pathway to become an operational multi-stakeholder tool for medicine development, we recommend to further explore 3 key components: i) The political mandate for stakeholders in member states to engage in some advising role, to enable patient-centred medicine development; ii) Leveraging existing overarching platforms to streamline resources, expertise and knowledge that will advance MAPPs capacity building for all stakeholders; and iii) Broker trust between stakeholders by exploring opportunities and methods to ensure stakeholders execute, over time, on their commitments without being bound by requests that turn out to be unreasonable or unfeasible.