Obtain a personal health passport, connect the "My Health Bank" with one click, and avoid complicated login procedures, so that when you see a doctor in various hospitals and clinics, you can quickly view medical treatment and medication information on the medical terminal with one click, avoiding repeated communication of medical records and symptoms .
If you want to access the medical records of patients, you need to go to the hospital to apply for it. Even your own medical records may require additional administrative processing fees. However, the medical treatment and medication information services help people obtain their own health passports. Keys connected to "Keep Savings SDK" to avoid complicated login process The program allows you to quickly check the medical treatment and medication information on the medical terminal with one click when you see a doctor in various hospitals and clinics, so as to avoid repeated communication of medical records and symptoms. "One phone in hand, medical records and passports are unimpeded", you only need to download "Yibingtong", and activate "My Data" through simple two steps, help People connect their medical records to their mobile phones, and can confirm their medical records with one click anytime, anywhere. No matter if there is a special disease or medication, they need to remind the medical staff of the medical record status, which can be clearly used for communication between doctors and patients. Step 1: Register and open "Yieyitong" Step 2: Click "My Data" and connect "Health Passbook" with one click (Follow the steps on the phone screen to complete the authorization, and you can open your exclusive medical record passport!)
"Yieyitong" connects the health insurance SDK with blockchain technology to solve the problem of patient identity authentication, protect the rights and interests of health passbook owners to obtain medical records, and then quickly confirm the patient support plans and welfare resources that can be applied for. The service description is as follows:
1)"My Data" to download medical records: online authorization to serialize and preserve the passbook, download medical records, and save the time and fees for hospitals to apply for medical records
2)"My data" creates a health passport: cross-diagnosis consultation and troubleshooting, one-click sharing of medical records and medication details.
3)"Health Plan" Welfare Resources: Just like a health supermarket, it provides members with a series of health and welfare plan information.
4)The "Health Plan" application is very simple: one-click review to apply for a health plan, and identity authentication through "My Data", eliminating the need for repeated administrative procedures for submitting patient identity documents.
Provide the public with one-stop collection and one-click matching of eligible and applicable health welfare plans, so that the benefits of patients are not missed.
At the same time as health management, what health welfare plans can be applied for, but the public does not know anything about it? health plan benefits package to help people According to their own medical records, one-click matching of health welfare plans that can be applied for helps the public save a lot of time and eliminates the need to understand health information one by one and exclude unqualified health plans. It only needs one-click to join the plan, which will be reviewed by the background Confirm that the conditions are met, you can get Comprehensive Health Benefits Program. The health and welfare consultation plan provides you with a mobile phone, a comprehensive grasp of various health and welfare plans, and only two steps to help the public get a qualified health and welfare plan with one-click matching: Step 1: Connect the health passbook and open "My Data" (for the first login, you need to prepare the health passbook registration password and the health insurance card number) Step 2: Click "Health Plan", join the relevant plan with one click, and wait for the review result to get the relevant information Health benefits!
"Yieyitong" connects the health insurance SDK with blockchain technology to solve the problem of patient identity authentication, protect the rights and interests of health passbook owners to obtain medical records, and then quickly confirm the patient support plans and welfare resources that can be applied for. The service description is as follows:
1) "My data" to download medical records: online authorization to serialize and preserve passbooks, download medical records, and save the time and fees for hospitals to apply for medical records.
2)"My data" creates a health passport: cross-diagnosis consultation and troubleshooting, one-click sharing of medical records and medication details.
3) "Health Plan" Welfare Resources: Just like a health supermarket, it provides members with a series of health and welfare plan information.
4) The "Health Plan" application is very simple: one-click review to apply for a health plan, and identity authentication through "My Data", eliminating the need for repeated administrative procedures for submitting patient identity documents.
The drug cost trial calculation service provides you with simple input of indications and estimated prescription drug information, and will assist you in evaluating the trial cost of the overall course of treatment according to the standard treatment,helping you to properly plan and prepare for drug costs, and evaluate whether to start the course of treatment.
Easily log in to the insurance policy you already own, and you can grasp the rights and interests of multiple insurance policies at one hand, and you can grasp the relevant medical benefits such as the daily hospitalization amount, the amount of major injury and disease compensation, etc. with one-click trial calculation.
Buying an insurance policy was a matter of decades ago. Now I only remember when to pay the premium, but I don’t know the detailed policy benefits? Even if you know that there may be a need for treatment in the future, but you don’t know the amount of insurance that you can apply for without applying for a claim? There are too many insurance companies' policies, but it is difficult to collect and understand themselves Integrity interest assessment? Private insurance rights consultation plan does not need to enter personal information, only need to enter the policy name, no matter one, three, or even five or more different insurance companies, as long as you log in your policy name, you can compile your own personal policy in one stop rights, allowing you to actually develop Before starting the course of treatment, you can know the amount of benefits you can get if you stay in the hospital for one day, or receive chemotherapy once. (Note: The actual claim amount should still be paid according to the actual application status of the insurance company, and the calculation and evaluation amount is for reference only.)
People only know their own insurance rights when they buy and use them, and when they get sick, it is also the time when they will use their insurance rights with a high probability in the future. This plan provides private Insurance benefits assist in overall assessment, help the public review your policy benefits, and help the public discuss with doctors the resource evaluation of follow-up treatment plans. Private insurance is like a fast food package. In each primary contract, Different meals (riders) can be matched according to needs, and the choice of each rider will affect the policy benefits, so by correctly registering your policy name, no matter which insurance company’s product can help you according to your own benefit category , Assist you in calculating the relevant benefit items and amounts that may be used during treatment, such as how much is a day of hospitalization? Fixed payment or real payment? How much is the amount of miscellaneous expenses, and the amount needs to be reaccumulated every few days.
Provide the public with fast matching and matching of social resources that can be applied for, so that the public can avoid spending extra time and effort in searching and screening social resources that can be applied for.
In the event of an emergency, is it difficult to afford the shortfall in medical expenses? This program provides the public with a one-stop collection of emergency resources that can be applied for. According to their own special identities, including low-middle income, low-middle-income households, cold certificates, major injury cards, or children in school, etc., one-stop Quickly match and query available social resources.
Social resources are grasped, one-stop links to various resource links for emergency medical applications, and help the public to include and link relevant social resource application information with one click. People will apply for social resources according to their special status and obtain relevant social resources.
How to find appropriate medical funds for the sudden self-paid drug demand? Provide everyone with medical and financial consulting services. According to your drug needs, after evaluation, we recommend you installment payment plans or loan information.
"The purpose of seeking to extend the payment period is to take into account the quality of life of myself and my family!" When there are better options for treatment, but you have to face the dilemma of economic decision, should you pay for family living expenses or medical expenses first? Limited by medical ethics and legal restrictions, excessive medical consumption is not encouraged. Medical financial services are different from consumer finance, starting from compliance with medical professional decisions, taking into account medical risks, evaluating clinical evidence models, and providing installment payment plans or loan introductions for patients' financial support based on patients' affordability.
Under the health insurance system, many people who want to receive new treatments encounter the dilemma of having to pay for their own expenses. Faced with the sudden demand for funds for medical expenses, they do not want to borrow money from relatives and friends. Affecting the quality of life of the family? In order to allow the public to have more time to raise funds, Medical Financial Consulting provides the public with treatment first and payment plan evaluation. Through the project-based installment payment plan or medical loan, it helps patients start the course of treatment first, and strives for More time to raise funds for drug expenses and extend the time to pay medical expenses.
The medical financial consultation plan provides the public with their own financial experience to evaluate the appropriate medical financial plan, including the project-based medical payment installment service (BNPL) or medical loan plan.
[Project-type drug payment installment plan] Cooperate with special pharmacies to design a project-based drug payment installment plan for specific project drug treatment courses to help patients start treatment as soon as possible and extend drug expenditure (dividing the entire drug fee amount into Multi-payment method, regular payment of drug fees and period payment method, so as to strive for more time to raise funds for drug fees).
【Medical Credit Program】Referring banks provide Unily Medical Credit Program for patients or family members who have a funding gap due to medical expenses, assist the public to evaluate and apply for affordable loan programs, and help start the treatment process
The introduction of the drug gifted management system helps the cooperative pharmacy to manage the drug inventory and approval list, and it can immediately grasp the flow of drugs.
The donated medicine management system helps to integrate the donated medicines of various pharmaceutical companies and products, and approves and distributes medicines according to different plans, so that cooperative pharmacies can more efficiently assist patients in supporting plans.
The free medicine management system can easily manage the subsidy schemes of different products, monitor the inventory and track the flow in real time, and can query the information of the approved patients for the approval and issuance of medicines, and leave the medicine receiving records for future inspection.
Sales of medicines/medical materials/consumer goods, e-commerce platforms for exclusive medical staff.
Want to easily place an order for medical and health care products? The quality of the international pharmaceutical factory makes people feel at ease, easy to click online, diversified payment methods, and the most important thing is OPEN 24 hours at any time, so you can order at any time without waiting!
The pharmaceutical e-commerce sales platform provides an exclusive order service system for pharmacies, medical service units, and medical staff to assist in easy order placement and related order progress tracking and customer service.
Provide medical teams for training strategy training, hardware operation teaching, and coaching medical/ hospital to create a high -volume net red team.
Want to become an online celebrity medical team, want to build your own channel but don't know where to start? Shooting, scripting, recording, live broadcasting, etc., every link is knowledge, provide you with a series of courses and training courses for the Internet celebrity medical team, and help you successfully establish your own channel and build a famous Internet celebrity team!
A qualified Internet celebrity team, in addition to being able to complete independent operations and complete live broadcast or video channel material preparation, on-site shooting quality control and long-term operation management of channels and fans, including script planning, on-site layout and professional equipment understanding and use, during the live broadcast Mastering the atmosphere of the host and the editor, the long-term operation and setting of the channel, etc., each link is a knowledge, so this plan assists in providing one-stop training courses, and assists in planning and providing according to your Internet celebrity goals. Course content that suits you.
Provide the industry's various professional cooperation invitations to cooperate opportunities, such as the health promotion lectures of enterprise employees.
Assist match-matching medical experts to undertake relevant appointment and cooperation opportunities, including arranging manpower to go to the hospital for marketing and publicity of health education activities with brand owners in medical institutions, or to cooperate with relevant associations, pharmaceutical companies and other health education lecturers, and will further media To meet the needs of lecture topics in joint enterprise occupational care, and provide a variety of expert cooperation opportunities.
Help medical experts including physicians, nurses, health teachers, nutritionists, pharmacists, etc., assist in matching brand owners, drug dealers, occupational care and other related units to see if there are suitable appointment cooperation opportunities, including marketing endorsements, public health education ambassadors, Corporate health education lecturer, etc.
To solve patients at their own expense, through the control of drug -gift compliance management systems, help patients support the implementation of the plan, and provide effective and instant service and records.
The patient drug donation compliance management system-MediPASS is the first digital solution service system for patient support plans, and won the 2021 National Medical Quality Award Industry Label. Improve the application process of patient support programs in a digital way, and provide a convenient, safe and compliant service platform for clinical and patients. At the same time, it has obtained the certifications of ISO9001 quality management system, ISO27001 information security management system and ISO27701 personal data privacy information management system.
Assist patients to increase medical accessibility and help patients obtain complete treatment. Through the drug donation compliance management system, the patient support plan is implemented and managed digitally, helping medical staff, patients and caregivers to obtain the services and assistance of the support plan in a timely manner.
According to different disease areas and patient needs, we will assist in planning patient medication assistance programs:
【early stage】
1) Demand Discussion and Planning
2) Related material design and preparation
3) Standard workflow document formulation
4) Integrated communication across departments
5) Project Promotion and Adjustment
【mid stage】
1) Project Quality Management
2) Document review and control
3) Communication with relevant units
4) special event handling
【Late stage】
1) Compliance retention and archiving of documents and materials
2) Summary and analysis of execution results
Solve the plight of patients for self-financed treatment, assist patients to support the implementation of the plan through the drug donation compliance management system, and provide effective and real-time services and records.
The patient drug donation compliance management system-MediPASS is the first digital solution service system for patient support plans, and won the 2021 National Medical Quality Award Industry Label. Improve the application process of patient support programs in a digital way, and provide a convenient, safe and compliant service platform for clinical and patients. At the same time, it has obtained the certifications of ISO9001 quality management system, ISO27001 information security management system and ISO27701 personal data privacy information management system.
Assist patients to increase medical accessibility and help patients obtain complete treatment. Through the drug donation compliance management system, the patient support plan is implemented and managed digitally, helping medical staff, patients and caregivers to obtain the services and assistance of the support plan in a timely manner.
According to different disease areas and patient needs, we will assist in planning patient medication assistance programs:
【early stage】
1) Demand Discussion and Planning
2) Related material design and preparation
3) Standard workflow document formulation
4) Integrated communication across departments
5) Project Promotion and Adjustment
【mid stage】
1) Project Quality Management
2) Document review and control
3) Communication with relevant units
4) special event handling
【Late stage】
1) Compliance retention and archiving of documents and materials
2) Summary and analysis of execution results
In accordance with the needs of individual diseases and planning, assist qualified experts, including experts, nutritionists, and health teachers, etc., and use the positive circulation expert cooperation and management mechanism to assist patients to improve their advice compliance and health education knowledge Improve target settings.
In accordance with the needs of individual diseases and planning, assist qualified experts, including experts, nutritionists, and health teachers, etc., and use the positive circulation expert cooperation and management mechanism to assist patients to improve their advice compliance and health education knowledge Improve target settings.
MEDIA-WIND HEALTH STRATEGIES provided by the License Strategy Consulting Co., Ltd. helps to formulate detailed planning specifications in response to the development of disease needs and market strategies, including experts and their care settings, projects and personnel performance indicators, services, services Projects, etc., from the recruitment, interview evaluation, education and training, performance management, and the performance implementation progress and compliance management of the overall project.
【early stage】
1) Drawing of project specifications (SOW/SOP)
2) Project settings and standard documents and assistive material table designs
3) Related internal and external management system frame connection and settings
4) Recruitment, interview evaluation, education and training, etc.
【mid stage】
1) Instructions for the patients who have collected cases
2) Project execution progress and performance management
3) Regular staff education and training and performance management
4) Regular report delivery and comparison project implementation progress and performance
【Late stage】
1) Compliance retain and archiving of the data of the project document
2) Confirmation of related reconciliation and request information
Provide a installment plan for first treatment and then payment, and use compliance risk assessment methods to assist specific prescription patients at the same time as a medical and disease common decision -making treatment plan. At the same time, there may be other payment methods to facilitate the initiation of the drug purchase treatment.
Help patients face the sudden medicinal costs, which can extend the payment time and soothe the pressure of drug purchase. Therefore, it provides a "self -funded installment project". Through cooperation with the Special Pharmacy, the financial risk model evaluation is conducted for the purchase amount of specific drugs, and Patients with one more payment plan, through multiple periods of allocation, to strive for patients to raise drug costs and do not affect the start time of treatment.
The characteristic description is as follows:
1. Extend the payment period and strive to raise funds time: "Medicine Installation" is aimed at specific project -type drugs, providing the funds for the early stage of medical purchase, and the time for you to raise the cost of treatment. "Pharmaceutical" allows you to extend the payment of payment and reduce the pressure of one payment.
2. Easily handle, speed processing: special person service, online explanation, solve the problems you encountered in your application, and complete the "medicinal stage" application. Quickly review, let you know the results of the audit within three working days.
3. Apply before payment: There is no charge during the application period. After you obtain the drug through the review, pay the payment conditions and time.
4. Online entity, good service: North, Central and South has a special pharmacy bureau for cooperation, so that you can apply at ease and rest assured to buy medicine.
The PAPPAY installment service (PAP) provided by Medi-Loan Fintech, Ltd., in order to help the implementation of the vision of paying before treatment, helping patients plan medical funds, can also start treatment at the same time at the same time. In addition, the treatment of the original family life is kept at the same time. Therefore
【early stage】
1) Cooperation content negotiation
2) Related process design
3) Form file formulation
4) Disting and communication between the Special Pharmaceutical Bureau
【mid stage】
1) Project commentary
2) Credit review review of patients (applicants) who received the case
3) Resource subsidy execution and related connections and communication
【Late stage】
1) Compliance retain and archiving of the data approved case
2) Confirmation of related account information
Assist pharmaceutical factories to plan information with medical staff, establish the best platform for communication with medical staff, and use data to obtain ins -decision -making decisions to achieve business goals.
To meet the digital transformation, you need a smarter digital strategy -Medicine! Medical Communication Medi+KNOW service to establish a medical staff exclusive channel, diverse planning marketing contacts to communicate with medical staff, and comprehensively track digital footprints. Use data to understand users' attention information, formulate future trends and achieve business goals!
Establish an official channel, connect medical channels that are dedicated to the brand, and make various promotions (Tuka, Video, LANDINGPAGE, Customized Web Page ...) to transmit professional medical knowledge according to the marketing period. And the article archives system can divide all medical information in the same class to become a knowledge platform with away. Through the system recorded user digital footprint, comprehensively analyzes user habits, and uses data to formulate future trends and achieve business goals!
Provide traditional media or new media topics strategies to maintain a good interaction with government departments, media relations, medical and disease communities and market systems.
Assist public relations services such as online and offline pharmaceutical activities and public health publicity, and assist in consulting and suggestions for consulting and suggestions of providing demand, providing medical public relations consultants and strategic communication services, assisting in maintaining relationships with the media, and training special press issues.
Since 2006, Caifu integrated marketing specializes in medical media and public issues in pharmaceutical/biotechnology/science education. According to the news planning goals, formulate professional topic strategies and exposure channels, create sound volume, and improve topic exposure.
Provide pharmaceutical factories on health products, care products, medical materials management and e-commerce and marketing services, and provide professional medical channel sales solutions.
MEDIA-WIND HEALTH E-COMMERCE has licenses for sales of drug dealers and medical equipment dealers, and can distribute professional products of pharmaceutical factories. From brand strategy formulation, marketing image formulation, planning execution to online and offline channel layout integrity planning .
International Pharmaceutical Factory Professional Products Brand Management: Brand Marketing Strategy Drawing and Practice, Brand Official Website Management, Members Deepening Management, AE Definition Report; E-commerce marketing operations: advertising, data analysis, sales strategy formulation, multi -channel layout; and line lines; and lines Lower Tong Road layout: Professional medical care institutions, closed -type community operations, corporate group purchase development.
Assist all kinds of institutional units to put the patient welfare plan on the healthy supermarket platform,For patients, check the relevant patient support plan information in one stop.
The company has the well -being plan for the planning for specific patients, but does not know where to accurately put the plan information to the qualified patients? This plan helps the industry partners to quickly find out the disease that meets the indications that meet the indications that meet the indications that meet the indications that meet the indications that meet the indications. Patients, and accurately provide the plan information to the other party. In addition, through blockchain technology, in order to not expose the patient's personal capital, assist in the health and well -being designed for special patients. And through system settings, provide highly accurate marketing channels. Media and exposure provides the plan to provide relevant plan information to patients who meet the relevant indications, as follows: the following three steps:
1) The plan specifications are drafted, and the plan specifications include the plan name, the plan interval, the plan of the plan, the planning of the plan, the plan of the plan and the related icons and the addition, exit, review and the audit. Broadcast information and so on.
2) Receive relevant plan information in the project window will be checked with you (1) and assisted the plan on the shelves through the background.
3) After the patient's medical records obtained by the system assisted the background comparison, the promotion reminded the user to go to the meal and buy it.
"Medical and Diseases" uses blockchain technology to connect health insurance SDK, solve the problem of patient identity authentication, ensure the medical record information of the ownership of the ownership of the health passbook, and then quickly confirm the supporting plan and welfare resources that can be applied for. The service description is as follows:
1) "My Data" download medical record information: Online authorized series of health preservation, download medical record information, eliminates the hospital application time and cost
2) "My Data" creates a healthy passport: Cross -consultation is troublesome, sharing the medical records and medication details with one click.
3) "Health Plan" Welfare Resources: It is like a healthy supermarket and provides a series of health welfare plan information for members.
4) The application for "Health Plan" is simple: One -click censorship wants to apply for a health plan. Through "My Data", identity authentication is used to avoid repeatedly paying the administrative process of the identity document of patients.
Assist patients with blockchain technology media to jointly produce relevant adaptive ethnic groups to provide precise marketing exposure to health plans.
In addition to the health plan, there are focus marketing activities and precise push? Welcome to major brands or colleagues in the industry, such as banks and insurance operators to provide insurance or related marketing plans. And help provide relevant marketing activities to increase the proportion of accurate target groups to join the plan.
Precise marketing is a task that major operators hope to achieve. However, how to find the precise ethnic group has become the biggest dilemma in practice. This plan has been authorized by the blockchain technology to assist patients to help patients bring their relevant medical records information information. Authorized certification to mobile phones, and patients with background media -related adaptive ethnic groups provide precise marketing exposure to health plans.
Provide marketing activities to discuss and match professional marketing consultant strategies.
Whether it is marketing questionnaire filling in, product test drinking and public education publicity, provide you with a one -stop consultation plan to assist you with the local pharmacy and clinics to assist in negotiating the arrangements of media related activities to assist your marketing activities implement.
Sandaron cooperation marketing channel service provides you with the most direct and local marketing service needs, help brands go deep into local clinics and pharmacy, and assist the media to cooperate with various types of medical care, health education, marketing and other opportunities, including various questionnaires to fill in , Product promotion, health education publicity services, etc.
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授權轉載:Pharmascan 藥廠觀察
美國食品與藥物管理局(FDA)在決定核准或是撤銷處方藥時,通常會仰賴於由專家組成的獨立諮詢委員會意見,輔助FDA決策,並藉由透明的審議過程建立與公眾信任的機會。今年七月,一篇JAMA研究統計了過去十年以來,FDA最終的決議結果與專家意見的一致性。
在2023年3月,美國FDA周邊和中樞神經系統藥物諮詢委員會就治療肌萎縮性脊髓側索硬化症(ALS)的藥物 torfersen 是否應獲得許可進行了投票。儘管在討論過程中,小組成員對於藥物是否能有效減輕患者症狀存在意見分歧,但過去的試驗顯示患者體內蛋白質神經絲呈現減少的趨勢。最終,小組成員一致投下贊成票。在一個月後,torfersen 成功取得了加速許可。
像這樣需要跨足多個專業領域才能確定的問題,美國 FDA 有時會向外部專家尋求諮詢,並將其意見視為最後裁定的參考。然而,FDA 究竟多大程度上會根據諮委專家提供的建議做出裁定?
FDA幾乎總是同意專家的意見,但並不是每個情境皆如此
根據 JAMA 期刊日前一篇研究顯示,FDA 在過去 12 年間,一共召開了 409 次諮詢委員會會議(人用藥品),在進一步分析有進行投票的會議之後,FDA 最終的決定有 88 %與諮詢委員會投票的結果一致。該研究一共統計了 2010 年至 2021 年 FDA 召開的所有會議,會議討論性質區分了新藥許可 (Initial approval)、補充適應症許可 (Supplemental Indication Approvals)、安全性 (safety actions)、是否撤回加速許可(accelerated approval withdrawls)。
第一作者 Joseph Ross Daval 博士與其他作者在該文中指出,這代表諮詢委員會在 FDA 決策的過程中扮演關鍵角色。研究作者們皆隸屬於波士頓布萊根婦女醫院和哈佛醫學院 (Brigham and Women’s Hospital and Harvard Medical School, Boston, Massachusetts)
諮委會投票結果與 FDA 最終決定之所以高度一致,推測除了有可能是因為 FDA 易被專家們說服之外,這些專家在投票的過程中早已能夠預測出 FDA 的決定,又或者是召開會議的方式,有利於 FDA 做出其希望做出的決定。此外。這項高度一致的成果並沒有隨著年代而有所有差異。
儘管將近 9 成的高度一致性,幾乎明示了諮委會的結果就等同於最後 FDA 的裁示。但是不論是從歷史案例還是統計數據卻還是告訴我們,FDA 還是具有其不可預測的部分。
歷史上最為有名的案例就屬於阿茲海默症藥物 Aduhelm (aducanumab)。當時,FDA周邊與中樞神經系統藥物諮詢委員會針對藥物的有效性進行表決,在討論「將單一一個效果正面的研究數據,作為 Aduhelm可以有效治療阿茲海默症早期症狀的主要證據是否合理」這個問題時,沒有任何一個委員投下贊成票,但卻出現 10 人反對, 1 人表示不確定的情境。最終,FDA 依然通過了該藥的加速許可,但需要進行另一個臨床試驗。消息一出,三位擔任諮委的專家不滿 FDA 放行該藥,除了對外質疑藥物療效之外,最後甚至遞出辭呈以表抗議。其中一名退出委員會的哈佛醫學院教授 Aaron S. Kesselheim 更是進一步表示這是「美國有史以來,最糟糕的藥物核准決定。」
事實上,這樣的案例並不只有一個,而且像這樣彼此不一致的情況最容易出現在諮委會投下負面票的時候。以新藥許可為例 (Initial approval),本篇研究統計,在 60 個諮委會投下負面票的情境中,有 40 個最後才是真正未獲得許可,換言之,當諮委會向 FDA 說「No」時,有三分之一 FDA 是不同意的,這個發現明顯與諮委會投下正面票的情境形成鮮明對比。同樣以新藥許可為例,在 147 個諮委會投下正面票的情境中,有 142 個最後獲得了許可,一致率將近 100 %,代表當諮委會向 FDA 說「Yes」時,FDA幾乎完全遵照這些專家的意見。
「FDA正在利用諮委會來找出許可障礙,同時藉此引導當局採用更簡便的審核途徑來核准藥物。」南加大公共政策學院副教授 Genevieve Kanter 博士針對該研究撰文表示。該評論亦刊登在 JAMA 期刊之中。
FDA向諮詢委員會提出的關鍵問題為何?
「從表面上看,FDA向諮詢委員會提出的主要問題似乎是:我們是否應該批准這種藥物?」Genevieve Kanter 博士在文中提及道。「但這些發現告訴我們從表面上看, FDA向諮詢委員會提出的主要問題似乎是:是什麼阻礙了藥物獲得批准?或者是:我們有什麼不同的方法可以讓這種藥物獲得批准?」
Genevieve Kanter 博士進一步在文中闡述表示,以阿茲海默症藥物 Aduhelm 為例,儘管諮詢委員會一致認為,該藥物對最為關鍵的臨床終點沒有影響,但是 FDA 最後還是以替代終點做為該藥加速許可的途徑,而且沒有再次召集諮詢委員會會議。他認為,像這樣:「我們有什麼不同的方法可以讓這種藥物獲得批准?」的出發點可能是 FDA 受到了病友團體壓力,或是和藥業利益團體有關。
Genevieve Kanter 博士也表示這些諮委會上未通過的的藥物最終卻獲得了核准,也有可能是藥商回應了會議中提出的意見,並進一步克服了這些問題。雖然這種狀況並不常見,目前也無法得知這種情況發生的頻率和原因為何。
在這類不一致的結果中,有投下反對票的專家曾提出可以等待前瞻性結果出爐再予以決定,因而建議延遲批准某些藥物的適應症或許可,例如 pembrolizumab 用於三陰性乳癌的補充適應症,FDA 在獲得試驗結果後就核准了該適應症,而且並未重新召開另一次的會議。相較之下之下, selinexor 與 olaparib 都是在試驗結果出來之前就獲得了初步批准。
通常情況下,舉行諮委會議是為了在出現與試驗資料有關的問題或困難時協助審查部門詮釋數據或成果。對 FDA 而言,從政府以外的專家取得意見,藉由鼓勵病人、醫療保健提供者和其他有關人士在公開聽證會上分享他們的觀點,可以彰顯機構努力建設一個公開透明政府的印象。而諮委會議可以在審查過程的任何階段召開,也可以在產品獲得核准並上市後召開,以協助審查部門詮釋數據或成果。
「但這種支持核可的偏誤同時代表的是透明度的降低和政治干預的跡象。」Genevieve Kanter 博士批評道。
FDA 召開諮詢委員會的數字正在下降
從 2010 年至 2021 年,FDA 召開的 409 次會議中,開會次數在 2012 年達到最高峰為 50 次,接著到了 2020 和 2021 年則減少成 18 次。其中減少幅度最大的項目是新藥申請,雖然這可能是因為 COVID-19 疫情影響了這兩年數字,但整體而言還是有看到下降的趨勢。
Genevieve Kanter 博士指出,FDA 的局長 Robert Califf 曾建議不要在諮委會議投票,因為他認為投票並不重要,而且結果並不具有約束力。對此,Genevieve Kanter 博士則認為投票廣泛討論了複雜的醫療議題,而且摘要有助於 FDA 官員和公眾利益。她指出,要改正的反而是確認投票真正想問的「問題」是什麼? 博士進一步提出建議,並認為可以廢除最後那種「過」與「不過」的投票,保留針對「有效性」和「安全性」這類具有建設意見的投票。
「只要這類的 (支持許可) 的偏誤是反映了公眾對快速獲得新療法及其(對應)承受高風險的能力,就不會有問題。反之,如果它反應的是製藥公司的影響,這種偏誤就令人深感憂慮,尤其是考慮到政治介入後,諮詢委員會會議頻率的減少以及投票制度的廢除。」Genevieve Kanter 博士談道。
究竟 FDA 召開諮委會的頻率下降的原因為何,目前仍不得而知,然而可以確認地是,鑒於 FDA 近十年來新藥許可數字並未明顯下降,加上在這些會議之中,有執行投票的比例逆勢上升,顯示 FDA 雖然的確越來越少公開地諮詢專家意見,但是一旦召開會議,通常都會進行投票,而且 FDA最終的決議多數還是會遵循專家意見。
「這項研究表明,委員會在 FDA 決策過程中具有關鍵作用,但隨著時間的推移, FDA 徵求獨立專家意見的次數減少,即便它依然遵循這些意見。然而,諮詢委員會在目前的監管框架下,仍應有更清晰、公開的界定。」 Joseph Ross Daval 作者群最後在 JAMA 研究中總結道。
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