Approaches To Priority Setting
Approaches To Priority Setting
Approaches To Priority Setting
3.1 Introduction
This chapter reviews the various approaches which have been used to set priorities for
health research — both at the international and national level — and explains the
rationale for the choice of methods used in this Project (see 2004 Report, Background
Paper 3 and present Report, Background Paper 3). The key message underlined in the
2004 Report and reiterated here is that all methods of priority setting have limitations
and that different methods need to be used, depending on the particular circumstances.
A combination of methods has therefore been used in this Report.
Priority setting is a challenge at all levels (global, national and local) and for all
contexts in health systems. Both consumers and funders are demanding greater
accountability for how limited health resources are used to meet health system goals.
As a result, public and private sector research funders have to make difficult decisions
about which fields and specific studies to support.
There are two broad approaches to setting priorities for health research: the use of
technical analyses, which rely on quantifiable epidemiologic, clinical, financial or other
data; and the use of interpretive assessments, which rely on consensus views of
informed participants. Technical approaches depend on the availability of data, and
priorities tend to be based on measurable units such as diseases (burden of disease) or
interventions (with respect to their costs and use). The difficulty with quantitative
methodology is that it hides value judgments that might reflect those of stakeholders
not involved in the methodology, such as users and payers of health care services.
Interpretive or consensus stakeholder approaches relying on the subjective judgments
of participants are, in theory, capable of dealing with value judgments and
multifaceted assumptions, and they have been used for research priority setting in
large, governmental agencies like the United States National Institutes of Health
(NIH),2 the Science and Technology Council of Australia,3 or even large pharmaceutical
companies.
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Priority Medicines for Europe and the World 2013 Update
INTUITION
Quality of Quality of
Intuition Analysis
ANALYSIS
MODE: 7 6 5 4 3 2 1
Source: Dowie J. In Health Care Priority Setting. Oliver A. ed. Nuffield Trust, UK
There have been several literature reviews in this fairly active area since 2008.1,4, 5, 6, 7, 8
Reports have evaluated priority setting against an ethical framework. The factors that
impact priority setting have been studied as well, such as amount and type of
stakeholder engagement, cultural factors supporting explicit priority setting, decision
maker/group composition (size and clarity of process, local ownership and awareness
and representation), and management of local politics. These are summarized in
Background Paper 3. A key conclusion of this review for the present updated report is
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3. Approaches to priority setting
that there is still very little information on how funding decisions are developed for
biomedical research.
The regulatory authorities of the EU, Canada and the United States determine whether
a medicine should be a “priority” for regulatory purposes. The European Medicines
Agency (EMA) and the United States Food and Drug Administration (FDA) have
established categories of medicines, based on whether or not they demonstrate
improvement over existing medicines. Such a designation facilitates the registration
process. 9 Although not intended for use in prioritizing research, in practice this
designation is intended to reward successful research (see Background Paper 3).
European Union
In November 2005, one year after the publication of the 2004 Priority Medicines Report,
accelerated assessment was introduced by revised EU pharmaceutical legislation.
Companies can request accelerated assessment provided they are able to demonstrate
that their product responds to unmet medical needs or constitutes a significant
improvement over the available methods of prevention, diagnosis or treatment of a
condition. 10 An accelerated assessment is conducted in a maximum of 150 days
although if major objections to this are uncovered during the assessment, the timing is
reverted to the normal timetable for the centralized procedure, which allows a
maximum assessment period of 210 days. In 2007, the medicinal product, eculizumab,
from Alexion Europe SAS, was the first medicinal product for which an accelerated
assessment procedure was concluded successfully.
Two other pathways to address 'unmet medical needs' are the conditional approval
and the exceptional approval pathway.11,12 In case of conditional approval, marketing
authorization is granted based on a smaller package of clinical data, with follow-up
obligations to submit additional clinical efficacy and safety evidence of the product.
For some products, such as certain orphan medicinal products for extremely rare
diseases, it will usually never be possible to assemble a full dossier. These products
may be approved under an ‘exceptional approval’ scheme, without further post-
approval obligations.
The classification system of the FDA assigns all new drug approvals to categories
representing distinct levels of innovation, and this classification is of particular
relevance here as it highlights the different meanings of the term innovation. The FDA
reviews new drug applications (NDAs) and awards priority status based on chemical
type and therapeutic potential. With regard to the latter, a drug qualifies for priority
review if it offers a potentially significant improvement over marketed products. With
regard to the former, a new molecular entity (NME) is a drug whose active ingredient
has never before been approved by the FDA for the USA market. An incrementally
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Priority Medicines for Europe and the World 2013 Update
modified drug (IMD) is one that relies on an active ingredient present in a drug already
approved for the USA market (or a closely related chemical derivative of such an
ingredient), and has been modified by the manufacturer. Drugs are classified as other if
they rely on an active ingredient that is already available in an identical marketed
product. A standard drug is a product that does not qualify for priority review and it
can be a NME, IMD or other. Most United States observers would view priority NMEs
as the most innovative type of new drug.
The FDA has also granted priority status to some IMDs, indicating that they provide
therapeutic advances even though they are derivatives. Priority IMDs are also
moderately innovative. The FDA, however, rates many NMEs as standard and,
although based on new compounds, these drugs usually have the same mechanism of
action and outcomes as other drugs on the market. Standard NMEs may have different
safety and efficacy profiles from other marketed drugs in the same class. Thus,
standard NMEs may enhance clinical outcomes even if they do not demonstrate
significant improvement over other medicines already available.13
The FDA’s fast track process is designed to facilitate the development, and expedite
the marketing review, of drugs that both target “serious” diseases and fill an “unmet
medical need”. Determining whether a disease is “serious” is generally based on
whether the drug will have an impact on factors such as survival, day-to-day
functioning, or the likelihood that the disease, if left untreated, will progress from a
less severe condition to a more serious one. Filling an “unmet medical need” is defined
as providing a therapy where none exists or providing a therapy which may be
potentially superior to existing therapy. If there are existing therapies, a fast track drug
must show some advantage over available treatment, such as: showing superior
effectiveness; avoiding serious-side effects of an available treatment; improving the
diagnosis of a serious disease where early diagnosis results in an improved outcome;
or decreasing the clinically significant toxicity of an accepted treatment. Most products
that are eligible for “fast track” designation are likely to be considered appropriate to
receive a priority review. A drug that receives “fast track” (and probably also priority
review) designation is eligible in effect for more frequent contact with the FDA as well
as eligibility for a third component of prioritisation, “accelerated approval” i.e.,
marketing approval on an effect on a surrogate, or substitute endpoint reasonably
likely to predict clinical benefit. All of these procedural measures indicate a willingness
of the FDA to `prioritize` applications to accelerate regulatory review prior to market
authorization.
Another FDA initiative, priority review vouchers are, in essence, a prize incentive for
companies to invest in new drugs and vaccines for neglected tropical diseases. A
provision of the Food and Drug Administration Amendments Act (HR 3580) awards a
priority review voucher to any company that obtains approval for a treatment for a
neglected tropical disease. The voucher, which is transferable and can be sold, also
entitles the bearer to a priority review for another product.
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3. Approaches to priority setting
At the time of the 2004 Report, only four institutes of the NIH - the National Cancer
Institute (NCI), the National Institute of Child Health & Human Development (NICHD,
the National Institute on Aging (NIA) and the National Institute of Environmental
Health Studies (NIEHS) - had the facility to retrieve bibliometric data to track the
publications and assess the potential public health impact of their grantees. Of these,
three institutes (NIEHS, NICHD and NIA) have collaborated to develop a database to
improve the priority-setting process.15 The Office of Portfolio Analysis (OPA) was only
recently established in 2011 by the NIH as a whole to “enable NIH research administrators
and decision makers to evaluate and prioritize current, as well as emerging, areas of research
that will advance knowledge and improve human health.”16
With regard to the practical output of awarding NIH grants, there is still inadequate
linkage between NIH awards and literature/citation data. Some preliminary
bibliometric analysis suggests that the effect of a publication’s “impact factor” is more
predictive of the fate of R01 grants than the number of subsequent citations of the
investigators. At a Portfolio Analysis Workshop in July 2012, a survey of over 500
participants showed that 47% thought that measuring the impact of NIH grants would
be the most important task in the work of the OPA.16
Since the late 1980s, there have been many attempts by various international
organizations and less formal groups to develop methods for prioritizing health
research (see also 2004 Report Chapter 3, Annex 3.1). During the 1990s, a series of
commissions undertook studies aimed at priority setting for health or for health
research, but none of these specifically focused on pharmaceutical research. The
studies are summarized below in roughly chronological order:
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Priority Medicines for Europe and the World 2013 Update
The Essential National Health Research (ENHR) approach was developed to define:
who sets priorities and how to get participants involved; the potential functions, roles
and responsibilities of various stakeholders; information and criteria for setting
priorities; strategies for implementation; and indicators for evaluation. It was designed
to not only specify broad research areas but also give a detailed listing of priority
possibilities/options as well as to involve a broad range of stakeholders and significant
engagement with experts. Significantly, discussion and decisions on funding are
supposed to be based on tapping the skills and knowledge of scientists from a wide
range of disciplines.17
The World Development Report (1993) was produced by the World Bank in
conjunction with the WHO and used a key measure of the burden of disease and
disability called the Disability Adjusted Life Year (DALY), which has also been used in
this Project (see Background Paper 4).18
The Ad Hoc Committee on Health Research (1996) was established in 1994 by the
WHO. It identified a systematic “five-step” process which is the basis of the conceptual
model used in this project.19 Briefly, these five steps include: 1. Calculate the burden of
the conditions or risk factor (look at the magnitude); 2. Identify the reason why the
disease burden persists (look at determinants); 3. Judge the adequacy of the current
knowledge base (assay knowledge); 4. Assess whether new R&D would improve
population health and at what cost (understand cost and effectiveness); 5. Assess the
adequacy of the current level of effort.
The Global Forum for Health Research (2000) created a framework (Combined
Approach Matrix) which brings together in a systematic manner all information
(current knowledge) related to a particular disease or risk factor 20 (see 2004 Report
Chapter 3, Appendix 3.6).
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3. Approaches to priority setting
The Child Health and Nutrition Research Initiative (CHNRI) (2007) approach
emphasized principles of legitimacy and fairness and provided a detailed listing of
individual research questions scored against pre-defined criteria. Technical experts
independently scored each research option against these five criteria. As in other
methods, stakeholder input was sought and used to rank the five criteria from the most
important to the least important. These rankings were then adjusted to provide relative
“weights” that determined the importance of the research option. Everything is
recorded, is repeatable, can be reviewed, and can be challenged and revised at any
time based on feedback, so this is a very dynamic process. The role of non-experts was
limited to selecting and weighing criteria. Once consensus is reached on areas of
research there is no further stakeholder involvement.22,23
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Priority Medicines for Europe and the World 2013 Update
The strength of this approach is that it clearly identifies products that the "market" is
willing to pay for and that will ensure an adequate return on investment.
Unfortunately, this approach will ignore diseases which mainly affect the poor in low-
income countries.
Figure 3.7.1 shows a plot of the DALY burden of the then EU25 countries versus the
proportion of total new chemical entities (NCEs) attributed to that condition (see
Catalá-López et al. Population Health Metrics, 2010 24).
The size of the “bubble” is the weighted fraction of each condition to the total DALY
burden. The black line is the 1:1 situation where the fraction (%) of NCEs for that
condition matches the proportional DALY burden for that condition. In the EU25,
infectious and parasitic diseases, blood and endocrine disorders, diabetes mellitus and
genitourinary diseases were all relatively over-represented with regard to NCEs in
relation to the disease burden they generate (points above the 1:1 line in Figure 3.7.1),
while the most under-represented conditions were neuropsychiatric diseases,
cardiovascular diseases, respiratory diseases, sense organ conditions and digestive
diseases (points below the 1:1 line). At the global level (data from the same source, not
presented here), the most under-represented conditions were perinatal conditions,
respiratory infections, sense organ conditions, respiratory diseases and digestive
diseases.
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3. Approaches to priority setting
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Priority Medicines for Europe and the World 2013 Update
compared. All four approaches have been presented to give a comprehensive overview
of “pharmaceutical gaps” that can be prioritized for research.
In the EU and elsewhere, governments have enacted legislation to protect the interests
of people suffering from rare (“orphan”) diseases. This requires society to spend
substantial funds on a limited number of people who suffer from rare diseases. At a
global level, based on principles of global solidarity, similar efforts are needed to
address neglected diseases, which mainly affect the poor in low-income countries, as
well as other poor populations. In response, orphan diseases and neglected diseases
have been selected as priority diseases, even though the former affect small numbers of
patients and the latter affect patients living outside the EU. Special patient groups (the
elderly, women and children) are also considered since these groups often lack
effective medicines.
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3. Approaches to priority setting
3.9 Conclusions
In this report, four complementary approaches to prioritization are used in an effort to
overcome the inadequacies of any one of these approaches when used exclusively. For
those decision makers who would like to use only evidence-based approaches, it
should be noted that absence of evidence does not necessarily mean there is no threat
or need. For those who would prefer to use a consensus-based expert opinion
approach, it should be pointed out that such expert groups have often missed
important developments. And while an approach based on the use of projections and
trends is critical in efforts to prepare for future threats to global public health, it
inevitably involves the use of judgments made on the basis of uncertain information.
For those who would use social solidarity as the sole criterion for prioritization, it is
important to note that there are many people, both rich and poor, from developed and
developing countries, who have benefited substantially from medical advances
achieved as a result of approaches based on evidence or projections and trends.
In this report a combination of methods have been used to achieve a balanced and
optimal result. By using these four approaches together, the health needs of both
Europe and the world have been taken into account in addressing pharmaceutical gaps
for diseases of current and future public health importance.
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