Final NPRD, 2021
Final NPRD, 2021
Final NPRD, 2021
FOR
1. BACKGROUND
7. POLICY DIRECTION
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1. Background
a. To review the national Policy for Treatment of Rare Diseases, 2017 and to suggest
amendments/changes as may be required.
b. To define Rare Diseases for India.
c. To draft National Policy for Rare Diseases.
d. To suggest vision and strategy in country’s context.
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Pending reframing the policy, the earlier policy has been kept in abeyance vide a non-
statutory Gazette Notification dated 18-12-2018, till the revised policy is issued or till
further orders, whichever is earlier.
Based on the report of the Expert Committee and with the approval of the
competent authority, the draft National Policy for Rare Diseases was finalized and
placed in the public domain on 13.1.2020 inviting comments/views from all the
stakeholders, general public, organisations and States/UTs.
The field of rare diseases is complex and heterogeneous. The landscape of rare
diseases is constantly changing, as there are new rare diseases and conditions being
identified and reported regularly in medical literature. Apart from a few rare diseases,
where significant progress has been made, the field is still at a nascent stage. For a long
time, doctors, researchers and policy makers were unaware of rare diseases and until
very recently there was no real research or public health policy concerning issues related
to the field. This poses formidable challenges in development of a comprehensive policy
on rare diseases. Nevertheless, it is important to take steps, in the short as well as long
term, with the objective of tackling rare diseases in a holistic and comprehensive
manner.
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2.1 The varying definitions of rare diseases
WHO defines rare disease as often debilitating lifelong disease or disorder with a
prevalence of 1 or less, per 1000 population. However, different countries have their own
definitions to suit their specific requirements and in context of their own population,
health care system and resources. In the US, rare diseases are defined as a disease or
condition that affects fewer than 200,000 patients in the country (6.4 in 10,000 people).
EU defines rare diseases as a life-threatening or chronically debilitating condition
affecting no more than 5 in 10,000 people. Japan identifies rare diseases as diseases with
fewer than 50,000 prevalent cases (0.04%) in the country. A summary of the prevalence
based definitions of rare diseases used in various countries is tabulated below:
1 USA 6.4
2 Europe 5.0
3 Canada 5.0
4 Japan 4.0
6 Australia 1.0
7 Taiwan 1.0
Source: The I.C. Verma Sub-Committee Report ‘Guidelines for Therapy and Management’
The use of varying definitions and diverse terminology can result in confusion and
inconsistencies and has implications for access to treatment and for research and
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development. According to a study1, that reviewed and analysed definitions across
jurisdictions, most definitions, as discussed above, appear to consider disease
prevalence, but other criteria also apply sometimes, such as - disease severity, whether
the disease is life-threatening, whether there are alternative treatment options available,
and whether it is heritable. The study found that relatively few definitions included
qualifiers relating to disease severity and/or a lack of existing treatments, whereas most
definitions included a prevalence threshold. The average prevalence thresholds used to
define rare diseases ranges among different jurisdictions from 1 to 6 cases/10,000
people, with WHO recommending a prevalence less than 10/10,000 population for
defining rare diseases. The study concluded that attempts at harmonising the differing
definitions, should focus on standardizing objective criteria such as prevalence thresholds
and avoid qualitative descriptors like severity of the disease.
However, it has been contested that disease prevalence alone may also not be an
accurate basis for defining rare diseases, as it does not take into account changes in
population over time. Hence, some have suggested that a more reliable approach to
arriving at a definition could be based on the factors of – a) location - a disease which is
uncommon in one country may be quite common in other parts of the world; b) levels of
rarity - some diseases may be much more rare than other diseases which are also
uncommon; and c) study-ability - whether the prevalence of a disease lends itself to
clinical trials and studies.
This underscores the need for further research to better understand the extent of
the existing diversity of definitions for rare diseases and to examine the scope of arriving
at a definition, which is best suited to the conditions in India. It shall be done on a priority
basis as soon as sufficient data is available. Steps have already been taken for creation of
a hospital based National Registry for rare diseases in India by ICMR.
1. 1Richter, T., Nestler-Parr, S., Babela, R., Khan, Z. M., Tesoro, T., Molsen, E., & Hughes, D. A. (2015).
Rare Disease Terminology and Definitions – A Systematic Global Review: Report of the ISPOR Rare
Disease Special Interest Group [Electronic version]. Value in Health, 18, 906-914. Available at:
https://www.ispor.org/raredisease-terms-definitions.pdf
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2.2 Diagnosis of rare diseases
Early diagnosis of rare diseases is a challenge owing to multiple factors that
include lack of awareness among primary care physicians, lack of adequate screening and
diagnostic facilities.
Traditional genetic testing includes tests that can only address a few diseases. As
a result, physicians most often provide their best guess on which tests are to be done. If
the test is negative, further testing will be required using next generation sequencing
based tests, or chromosomal microarray which are applicable, but expensive and time-
consuming processes with interpretation and counselling issues at times.
There is a lack of awareness about rare diseases in general public as well as in the
medical fraternity. Many doctors lack appropriate training and awareness to be able to
correctly and timely diagnose and treat these conditions. According to a recent report 2, it
takes patients in United States (US) an average of 7.6 years and patients in United
Kingdom (UK) an average of 5.6 years to receive an accurate diagnosis, typically involving
as many as eight physicians (four primary care and four specialists). In addition, two to
three misdiagnoses are typical before arriving at a final diagnosis. Delay in diagnosis or a
wrong diagnosis increases the suffering of the patients exponentially. There is an
immediate need to create awareness amongst general public, patients & their families
and doctors, training of doctors for early and accurate diagnosis, standardization of
diagnostic modalities and development of newer diagnostic and therapeutic tools.
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Rare Disease Impact Report: Insights from patients and the medical community available at:
https://globalgenes.org/wp-content/uploads/2013/04/ShireReport-1.pdf
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is very small and it often results in inadequate clinical experience. Therefore, the clinical
explanation of rare diseases may be skewed or partial. The challenge becomes even
greater as rare diseases are chronic in nature, where long term follow-up is particularly
important. As a result, rare diseases lack published data on long-term treatment
outcomes and are often incompletely characterised.
3
https://www.thelancet.com/journals/landia/article/PIIS2213-8587(19)30006-3/fulltext
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2.4.2 Prohibitive cost of treatment
As the number of persons suffering from individual rare diseases is small, they do
not constitute a significant market for drug manufacturers to develop and bring to
market drugs for them. For this reason, rare diseases are also called ‘orphan diseases’
and drugs to treat them are called “orphan drugs”. Where, they do make drugs to treat
rare diseases, the prices are extremely high apparently to recoup the cost of research
and development. At present, very few pharmaceutical companies are manufacturing
drugs for rare diseases globally and there are no domestic manufacturers in India except
for Food for Special Medical Purposes(FSMP) for small molecule inborn errors of
metabolism. Due to the high cost of most therapies, the government has not been able
to provide these for free. It is estimated that for a child weighing 10 kg, the annual cost
of treatment for some rare diseases, may vary from Rupees 10 lakh to more than 1 crore
per year with treatment being lifelong and drug dose and cost, increasing with age and
weight.
Countries have dealt with this unique problem of high cost through various means
that were suited to their local needs. Instruments like the Orphan Drug Act (ODA) in US &
Canada, provide incentives to drug manufacturers to encourage them to manufacture
drugs for rare diseases. The economic incentives & safeguards offered under the Act
ensure benefits to the local patients. However, the exorbitant prices of drugs for rare
diseases have led to concerns even in the developed countries about maintaining
sustainability of the rare diseases funding/reimbursement programmes. The exorbitant
prices have led to calls for transparency in setting prices of drugs and for price control
and have even prompted scrutiny and congressional inquiries.
Data on how many people suffer from different diseases that are considered rare
globally, is lacking in India. The cases identified so far have been diagnosed at tertiary
hospitals. The lack of epidemiological data on incidence and prevalence of rare diseases
impedes understanding of the extent of the burden of rare diseases and development of a
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definition. It also hampers efforts to arrive at correct estimation of the number of persons
suffering from these diseases and describe their associated morbidity and mortality. In such
a scenario, the economic burden of most rare diseases is unknown and cannot be
adequately estimated from the existing data sets.
While preparing the policy for rare diseases in India, policies of other countries have
been reviewed. In United States of America, development of drugs for rare disease is sought
to be encouraged through the Orphan Drugs Act, which incentivises industry by way of
market exclusivity, grants to researchers and tax incentives on expenditure incurred during
evaluation of drugs for their therapeutic potential. However, critics have pointed out that
pharmaceutical companies have taken advantage of this arrangement and ‘gamed the
system’ to maximise profits. The European Joint Programme on Rare Disease mostly focuses
on research. National Health Service (NHS) England, for example, provides that the
treatment for Spinal Muscular Atrophy (SMA) will be made available to the youngest and
most severely-affected (SMA Type 1) patients immediately by Biogen (The pharmaceutical
company that manufactures treatment for SMA), with NHS England offering funding on
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National Institute for Health and Care Excellence (NICE) publication of final guidance. In
Singapore, a fund - Rare Disease Fund – has been created to fund five medicines to treat
three rare disease conditions. In Malaysia and Australia subsidised access for eligible
patients is provided for expensive and lifesaving drugs.
Rare diseases place a major economic burden on any country and especially in
resource-constrained settings. The financial capacity to support exorbitant cost of
treatment is an important consideration in public health policy development with
reference to treatment for rare diseases. In resource-constrained settings, it is pertinent
to balance competing interests of public health for achieving optimal outcome for the
resources allocated. As resources are limited and have multiple uses, the policy makers
have to make choice of prioritizing certain set of interventions over others- the
appropriate choice is then to support those interventions that would provide more
number of healthy life years for given sum of money while simultaneously looking at the
equity i.e., interventions that benefit poor who cannot afford healthcare are prioritized.
Thus, interventions that address health problems of a much larger number of persons by
allocating a relatively smaller amount are prioritized over others such as funding
treatment of rare diseases where much greater resources will be required for addressing
health problems of a far smaller number of persons.
Hence, any policy on rare diseases needs to be considered in the context of the
available scarce resources and the need for their utmost judicious utilization for
maximizing the overall health outcomes for the whole of society measured in terms of
increase of healthy life years.
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6. Definition of Rare Diseases:
6.1 There is no universal or standard definition of rare disease. A disease that occurs
infrequently is generally considered a rare disease, and it has been defined by different
countries in terms of prevalence – either in absolute terms or in terms of prevalence per
10,000 population. A country defines a rare disease most appropriate in the context of its
own population, health care system and resources.
6.2 As mentioned above, India faces the limitation of lack of epidemiological data to be
able to define rare diseases in terms of prevalence or prevalence rate, which has been
used by other countries. To overcome this, a hospital based National Registry for Rare
Diseases has been initiated by ICMR by involving centers across the country that are
involved in diagnosis and management of Rare Diseases. This will yield much needed
epidemiological data for rare diseases. In the absence of epidemiological data on
diseases considered as rare in other countries, it is not possible to prescribe threshold
prevalence rates to define a disease condition as rare.
Till the time such data is available and the country arrives at a definition of a rare
disease based on prevalence data, the term rare diseases, for the purpose of this policy,
shall construe the following groups of disorders identified and categorized by experts
based on their clinical experience:
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iii. Immune deficiency disorders like Severe Combined Immunodeficiency
(SCID), Chronic Granulomatous disease, Wiskot Aldrich Syndrome etc.
iv. Osteopetrosis
v. Fanconi Anemia
Group 2: Diseases requiring long term / lifelong treatment having relatively lower cost
of treatment and benefit has been documented in literature and annual or more
frequent surveillance is required:
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a) Disorders managed with special dietary formulae or Food for special medical
purposes (FSMP)
i) Phenylketonuria (PKU)
ii) Non-PKU hyperphenylalaninemia conditions
iii) Maple Syrup Urine Disease (MSUD)
iv) Tyrosinemia type 1 and 2
v) Homocystinuria
vi) Urea Cycle Enzyme defects
vii) Glutaric Aciduria type 1 and 2
viii) Methyl Malonic Acidemia
ix) Propionic Acidemia
x) Isovaleric Acidemia
xi) Leucine sensitive hypoglycemia
xii) Galactosemia
xiii) Glucose galactose malabsorbtion
xiv)Severe Food protein allergy
b) Disorders that are amenable to other forms of therapy (hormone/ specific drugs)
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vi) Sodium Benzoate, arginine, citrulline, phenylacetate (Urea Cycle
disorders), carbaglu, Megavitamin therapy (Organic acidemias,
mitochondrial disorders)
vii) Others - Hemin (Panhematin) for Acute Intermittent Porphyria, High
dose Hydroxocobalamin injections (30mg/ml formulation – not
available in India and hence expensive if imported)
viii) Large neutral aminoacids, mitochondrial cocktail therapy,
Sapropterin and other such molecules of proven clinical management
in a subset of disorders
Group 3: Diseases for which definitive treatment is available but challenges are to
make optimal patient selection for benefit, very high cost and lifelong therapy.
3a) Based on the literature sufficient evidence for good long-term outcomes exists for
the following disorders
3b) For the following disorders for which the cost of treatment is very high and either
long term follow up literature is awaited or has been done on small number of
patients
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2. Duchenne Muscular Dystrophy (Antesensce oligoneucletides, PTC)
3. Spinal Muscular Atrophy (Antisense oligonucleotides both intravenous & oral
& gene therapy)
4. Wolman Disease
5. Hypophosphatasia
6. Neuronal ceroid lipofuschinosis
6.3. The list of diseases under Group 1, Group 2 and Group 3 are not exhaustive and will be
reviewed periodically based on updated scientific data by the Technical Committee.
7. Policy Direction
The policy aims at lowering the incidence and prevalence of rare diseases based
on an integrated and comprehensive preventive strategy encompassing awareness
generation, premarital, post-marital, pre-conception and post-conception screening and
counselling programmes to prevent births of children with rare diseases, and within the
constraints on resources and competing health care priorities, enable access to
affordable health care to patients of rare diseases which are amenable to one-time
treatment or relatively low cost therapy.
Considering the limited data available on rare diseases, and in the light of
competing health priorities, the focus would be on prevention of rare diseases as a
priority for all the three groups of rare diseases identified by Experts. Public Health and
hospitals being a State subject, the Central Government would encourage & support the
States in their endeavour towards screening and prevention of rare diseases through
Centres of Excellence under Rare Disease Policy and Nidan Kendras under Department of
Biotechnology.
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8. Prevention & Control of Rare Diseases:
The Central Government will work with the State governments to build capacity of health
professionals at various levels. The content of such capacity building would be based on
the roles of various health professionals. The Centres of Excellence would develop
Standard Operating Protocols to be used at various levels of care for patients with rare
diseases to improve early diagnosis, better care coordination and quality of life.
preventing birth of an affected child. Though not always feasible, this strategy yields the
highest returns in terms of decreasing the incidence & prevalence of rare disorders in the
population in the long run. Some of the strategies can be as follows:
Examples include avoidance of pregnancy in advanced age, or any other rare monogenic
disorder by not marrying a carrier, carrier couples not reproducing etc., but these are not
feasible options in the real world scenario. So in most situations the feasible preventive
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strategy is secondary prevention. However, a simple checklist will be made available to
primary health care providers in the health and wellness clinics to identify a couple at risk
based on disease in a previous sib or family history of that disorder.
8.2.2 : Secondary prevention: This strategy focuses on avoiding the birth of affected fetus
(prenatal screening and prenatal diagnosis), early detection of the disorders, appropriate
medical intervention to ameliorate or minimize the manifestations (newborn screening).
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medicine experts. These procedures, however, carry a small risk of fetal loss which
is very low if done by experienced specialists. This has to be explained to the family
before the procedure. Cost would primarily depend on the type of the test to be
performed on the sample. If the fetus is found to be affected, the couple has the
option for termination of pregnancy, the legal age of which in India has been
increased to 24 weeks of pregnancy.
8.2.3 : Tertiary prevention refers to provision of better care and medical rehabilitation to
those rare disease patients who present at an advanced stage of the disease. It
encompasses providing best supportive care to the affected patients with various rare
disorders including the ones for which no specific treatment is available. This would
improve quality of life of affected individuals and families. Supportive care includes
developmental assessment and intervention including early stimulation and behavioural
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intervention, physical therapy and rehabilitation, provision of visual and hearing aids and
above all emotional and psychological support to affected individuals and families.
8.2.4 : Optimal screening and diagnosis strategy: Considering the competing priorities
within available resources, universal screening of all pregnancies and/or all newborns in
the country for all rare disorders is not feasible. The policy recommends a screening and
diagnostic strategy wherein those pregnant women in whom there is a history of a child
born with a rare disease and that rare disease diagnosis has been confirmed, would be
offered prenatal screening test(s) through amniocentesis and / or chorionic villi sampling.
This strategy is in sync with the policy direction of reducing the incidence of rare diseases
in the population. In cases where, the diagnosis could not be established during the
prenatal period, it would be imperative to offer to the newborn or the infant as the case
may be and would include newborn screening for (a) small molecule Inborn Errors of
Metabolism by liquid chromatography – tandem mass spectrometry (LC-MS/MS), (b)
diagnosis of SCID by T cell receptor excision circles (TREC) and (c) diagnosis of lysosomal
storage disorders (LSDs) by microfluids / LC-MS/ MS. (d) diagnosis of disorders by newer
but economical molecular diagnostic platforms.
9.1 The Government will notify selected Centres of Excellence, which will be premier
Government tertiary hospitals with facilities for diagnosis, prevention and treatment of
rare diseases. To begin with, the following institutes would be notified as Centers of
Excellence for Rare Diseases:
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g) Institute of Post-Graduate Medical Education and Research, Kolkata
h) Center for Human Genetics (CHG) with Indira Gandhi Hospital, Bengaluru
However, more Centres of Excellence can be added for regional outreach if they are
found to be suitable in terms of infrastructure and human resources based on
recommendations of technical committee.
9.3 The proposed COEs shall be given one-time financial support up to a ceiling of Rs 5
crore for procurement of equipment as per individual centers need for strengthening
patient care services for screening, diagnosis and prevention (prenatal diagnosis) of rare
diseases based on a gap analysis. The list of equipments which are likely to be useful for
these activities is annexed.
9.4 These Centre of Excellence will take the required decision for treatment and fund
allocation on rare diseases cases within 02 weeks of receiving the fresh application.
9.5 Nidan Kendras: Nidan Kendras have been set up by Department of Biotechnology (DBT)
under Unique Methods of Management and treatment of Inherited Disorders (UMMID)
project for genetic testing and counseling services. These Nidan Kendras will be performing
screening, genetic testing and counseling for rare diseases. Nidan Kendras possessing the
facility for treatment may do so under the guidance and supervision of a CoE.
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List of Nidan Kendras is given below:
More aspirational districts will be covered in future either by setting up of more Nidan
Kendras or by adopting more than one aspirational districts by existing Nidan Kendras.
i. Financial support upto Rs. 20 lakh under the Umbrella Scheme of Rashtriya
Arogaya Nidhi shall be provided by the Central Government for treatment, of
those rare diseases that require a one-time treatment (diseases listed under
Group 1). Beneficiaries for such financial assistance would not be limited to BPL
families, but extended to about 40% of the population, who are eligible as per
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norms of Pradhan Mantri Jan Arogya Yojana, for their treatment in Government
tertiary hospitals only.
ii. State Governments can consider supporting patients of such rare diseases that
can be managed with special diets or hormonal supplements or other relatively
low cost interventions (Diseases listed under Group 2).
iii. Keeping in view the resource constraints, and a compelling need to prioritize the
available resources to get maximum health gains for the community/population,
the Government will endeavour to create alternate funding mechanism through
setting up a digital platform for voluntary individual and corporate donors to
contribute to the treatment cost of patients of rare diseases.
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care including preventive health care is included in the list in the Schedule for CSR
activities.
Treatment cost of the patient will be first charge on this fund. Any leftover fund
after meeting treatment cost can be utilized for research purpose also.
(b) National Consortium for Research and Development on therapeutics for Rare
Diseases: National Consortium can be provided with an expanded mandate to include
research & development, technology transfer and indigenization of therapeutics for rare
diseases. It will be convened by Department of Health Research (DHR) with ICMR as a
member.
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13. Increasing affordability of drug related to rare diseases
Creation of an integrated research pipeline to start the development of new drugs, for
which pharmaceutical companies would be encouraged and research organizations as
well as funding agencies would be involved in this important endeavour. Research for
repurposing the drugs and use of biosimilar would be encouraged. Approval for new
drugs and decision related to trials will continue to be provided by Drugs Controller
General of India under the New Drugs and Clinical Trial Rules, 2019.
(b) Ministry of Finance will be requested for reduction in custom duties on import of
medicines related to rare diseases.
(d) Measures for creating conducive environment for indigenous manufacturing of drugs
for rare diseases would be taken. Department of Pharmaceuticals, Department for
Promotion of Industry and Internal Trade (DPIIT) will be requested to promote local
development and manufacture of drugs for rare diseases at affordable prices and take
legal/legislative measures for creating conducive environment for indigenous
manufacturing of drugs for rare diseases at affordable prices. PSUs would be encouraged
for local manufacturing of drugs for rare diseases.
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14. Implementation strategy
i. The Government will have a hospital based National Registry for Rare Diseases at
ICMR with the objective of creating a database of various rare diseases. Steps
have already been taken in this direction by ICMR. Over a period of time, the
registry is expected to yield information on hospital based data and disease
burden.
ii. The Government shall take steps to create awareness amongst all the levels of
health care personnel as well as general public towards the rare diseases. This will
encourage people to seek pre-marital genetic counselling, identification of high-
risk couples & families and also result in prevention of births as well as early
detection of cases of rare diseases. Simple standard protocols/algorithms would
be developed for screening and diagnosis in order to avoid missing cases and
provide best possible management.
iii. Public Health and hospitals being a State subject, the Central Government shall
encourage and support the State Governments in implementation of a targeted
preventive strategy.
iv. The Government shall provide financial assistance upto Rs. 20.00 lakh (under the
Umbrella Scheme of Rashtriya Arogya Nidhi) to the entitled population, as per
PMJAY norms, for their treatment in Government tertiary hospital, for rare
diseases amenable to one-time treatment (identified under Group 1).
v. The State Governments may undertake treatment of disorders managed with
special dietary formulae or food for special medical purposes (FSMP) and
Disorders that are amenable to other forms of therapy (hormone/ specific drugs)-
diseases covered under Group 2.
vi. The Government shall notify selected Centres of Excellence at premier government
hospitals for comprehensive management of rare diseases. The Centres of
Excellence will be provided one time grant subject to maximum of Rs. 5 crore
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each for infrastructure development for screening, tests, treatment, if such
infrastructure is not available.
vii. The Government shall create a digital platform for bringing together notified
Centres of Excellence where patients of rare diseases can receive treatment or
come for treatment, on the one hand and prospective voluntary individual or
corporate donors willing to support treatment of such patients. Funds received
through this mechanism will be utilized for treatment of patients suffering from
rare diseases.
viii. In order to maintain transparency of transactions in provision of funding under
RAN/ crowd funding etc., the Centres of Excellence receiving the funds should
have linkages with the ICMR registry.
ix. The Government shall facilitate the creation of an enabling environment that
promotes research & development of diagnostic and therapeutic modalities
within the Country. Consortium of Centres of Excellence shall be created so that
research efforts are synchronized. AIIMS, Delhi will be nodal hospital to
coordinate with other Centres of Excellence for various activities.
x. State Governments will be requested to create Department of Medical Genetics
at least in one medical college in the State for imparting education and increasing
awareness amongst health care professionals. This will strengthen manpower
base in the country for managing Rare Diseases.
xi. Department of Pharmaceuticals, Department for Promotion of Industry and
Internal Trade (DPIIT) will be requested to promote local development and
manufacture of drugs for rare diseases by public and private sector
pharmaceutical companies at affordable prices and take legal/legislative
measures for creating conducive environment for indigenous manufacturing of
drugs for rare diseases at affordable prices. PSUs could also be encouraged for
local manufacturing of drugs for rare diseases.
xii. Ministry of Finance will be requested for reduction in custom duties on import of
medicines related to rare diseases.
*****
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Annexure
Suggestive List of Equipment, which may be required for strengthening of patient services at
Centres of Excellence for screening, diagnosis and prevention (prenatal diagnosis) of rare
disease.
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