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Digital
Therapeutics:
The Integral Cog
of Digital
Innovation in Drug
Development
Vivek Vikram Singh (PhD),
Associate Director,
Healthcare R&A, WNS
01
wns.com
It is well acknowledged that the traditional drug
development paradigm has been changing
rapidly in the 21st century, with greater focus
being placed on delivering personalized
medicine solutions. This has been fueled by the
development of social networks, smartphones,
wearable devices and cloud-based data
platforms, which have enabled the collection,
storage and analysis of ever-increasing amounts
of clinically relevant data. Furthermore, the
expansion of digital analytical tools and advances
in Machine Learning (ML) have empowered
researchers to transform data into knowledge
and aid clinical decision-making.
This new-age armamentarium permits a broad
range of activities in digital health, including in
mobile health (mHealth), Health Information
Technology (HIT), wearable devices, telehealth /
telemedicine and personalized Digital
Therapeutics (DTx).
Digital Therapeutics:
The Integral Cog of
Digital Innovation in
Drug Development
Vivek Vikram Singh (PhD), Associate Director, Healthcare R&A, WNS
The Field of Digital
Therapeutics
In simple terms, DTx are a health discipline and
treatment option that utilize digital and often
online health technologies to treat a medical
condition. It is however different from, say, a
wellness app in that a DTx must undergo clinical
ɨƊǶǞƮƊɈǞȌȁ‫ش‬ɈȲǞƊǶɈȌȯȲȌɨƵǞɈȺƵǏ˛ƧƊƧɯƊȺƊƦȌȁƊ
˛ƮƵɈǘƵȲƊȯƵɐɈǞƧ‫خ‬
DTx thus form an independent category of
evidence-based products within the broader
digital health landscape. It is distinguished
through its primary function of delivering
software-generated therapeutic interventions
directly to patients to prevent, manage or treat a
medical disorder or disease. The individual
treatment strategy is ‘optimized’ (for instance, by
applying ML techniques to the individual’s
observed data), thereby realizing the principle of
personalized medicine. DTx are validated by
regulatory bodies, as required, to support product
ƧǶƊǞǿȺȲƵǐƊȲƮǞȁǐȲǞȺDz‫ة‬ƵǏ˛ƧƊƧɯƊȁƮǞȁɈƵȁƮƵƮɐȺƵ‫خ‬
Megan Coder, executive director of the Digital
ÀǘƵȲƊȯƵɐɈǞƧȺǶǶǞƊȁƧƵ‫(ـ‬À‫ةف‬ƊȁȌȁٌȯȲȌ˛Ɉ
organization, which is responsible to set
standards and integrate DTx into healthcare,
says, “Digital therapeutics are part of the broader
digital health landscape, but in order to be called
one, a product has to be software driven and
evidence based, and make a claim to prevent,
manage, or treat a medical disease or disorder.
A digital therapy can be used alone, or with other
therapies to optimize outcomes.”
DTx are considered distinct from pure-play
adherence, diagnostic and telehealth products.
However, while their key focus is on delivering
direct therapeutic interventions, DTx products
possess the unique ability to incorporate
additional functionalities into its comprehensive
portfolio. Integration with mHealth platforms;
ability to provide complementary diagnostic or
adherence interventions; compatibility with
digital devices, sensors, or wearables; remote
delivery of intervention; and integration into
electronic prescribing, dispensing, and EMR
platforms, are the key additional features that
can be part of a DTx solution.
The types of interventions being delivered /
developed by DTx products across the industry
are as diverse as the disease states being
addressed. In September 2017, Pear Therapeutics’
lead product, reSET®
‫ة‬ɩƊȺɈǘƵ˛ȲȺɈ(ÀɮɈȌȲƵƧƵǞɨƵ
market authorization from the US FDA to work in
conjunction with conventional outpatient
clinician-delivered care (face-to-face therapy) for
Substance Use Disorder (SUD). It’s a mobile-based
medical application system for a patient use and
has a clinician dashboard interface. With reset®,
patients can get Cognitive Behavioral Therapy
(CBT), to teach them skills that aid in the
treatment of SUD. Its purpose is to increase
abstinence from substance abuse and retention
of prescribed behavior in an outpatient therapy
programs. Soon thereafter, Pear’s second product
candidate, reSET-O®, for the treatment of Opioid
Use Disorder (OUD) received Breakthrough
Designation (BTD) and was authorized by the US
FDA in December 2018.
With the burgeoning of DTx platforms and
applications, patients, providers and payers can
expect increasing comprehensive network of
therapy modalities for physical, mental and
behavioral disease states. As per a market report
analysis from ResearchAndMarkets, the global
DTx market is expected to grow at a CAGR of 31.4
percent, from USD 3.4 Billion in 2021 to USD 13.1
Billion by 2026. Theincreasing focus on preventive
healthcare, emerging RD trends, technological
advancements, importance of patient
convenience and user-friendliness, and launch of
ȁȌɨƵǶȯȲȌƮɐƧɈȺɩǞɈǘƵȁǘƊȁƧƵƮƵǏ˛ƧǞƵȁƧɯƊȲƵDzƵɯ
factors contributing to the high CAGR in the
forecast period.
02
wns.com
03
wns.com
Examples of DTx in the
market or currently
under development
AI-based digital diagnostics and
personalized therapeutics for
pediatric behavioral healthcare
Combined software and
hardware program to
improve asthma and COPD
control, and optimize
healthcare utilization
Digital therapeutic
used as an adjunct
to standard,
outpatient treatment
for Substance
Use Disorder (SUD)
Neurologic Music
Therapy to address
motor, speech and
cognitive dysfunction
caused by neurologic
disease or injury
Digital sleep
improvement program
featuring Cognitive
Behavioral Therapy
(CBT) techniques
Digital therapeutic
utilizing adaptive
sensory stimulus
software for the
treatment of ADHD
delivered through
an engaging video
game experience
Digital therapeutic engaging
individuals with Type 2 diabetes
and hypertension, and their care
providers, to improve
self-management and outcome
DTx
Primary Purpose of DTx Product
yȌƵǏ˛ƧƊƧɯ
claims
regarding a
medical
disorder or
disease
Clinical trials
required
Clinical trials
required
Clinical trials
required
Clinical trials
required
Low to medium
risk (e.g. reduce
rate of disease
progression)
Medium to
high risk
(e.g. improve
ƵǏ˛ƧƊƧɯȌǏ
adjunctive
therapies)
Medium to high
risk (e.g. direct
ƵǏ˛ƧƊƧɯƧǶƊǞǿȺ
on clinical
outcomes)
Level of
Product Claims
(Related to
Medical
Disorder or
Disease)
Clinical
Evidence
Requirement
Regulatory
enforcement
discretion
(without explicit
oversight)
Third-party
validation of
ƵǏ˛ƧƊƧɯ‫ش‬ȺƊǏƵɈɯ
claims by
regulatory or
equivalent
national body
Third-party
validation of
ƵǏ˛ƧƊƧɯ‫ش‬ȺƊǏƵɈɯ
claims by
regulatory or
equivalent
national body
Third-party
validation of
ƵǏ˛ƧƊƧɯ‫ش‬ȺƊǏƵɈɯ
claims by
regulatory or
equivalent
national body
Level of
Support for
Product Claims
Direct-to-consumer
(prescription not
required)
OTC or
prescription
required
OTC or
prescription
required
Prescription
required
Patient Access
to DTx
Works
independently
or indirectly
supports
another therapy
Monotherapy or
directly
supports a
concurrent
treatment
Directly
supports a
concurrent
treatment
Monotherapy
or directly
supports a
concurrent
treatment
Association to
Concurrent
Therapies
Address a
Medical
Condition
Manage or
Prevent a Medical
Condition / Disease
Optimize
Medication
Treat a Medical
Condition /
Disorder
04
wns.com
In essence, every DTx product corresponds to one of the four categories based on its intended use
ƊȁƮȌǏ˛ƧǞƊǶȯȲȌƮɐƧɈƧǶƊǞǿȺ‫ب‬
‫ۀ‬ ƮƮȲƵȺȺƊǿƵƮǞƧƊǶƧȌȁƮǞɈǞȌȁ
‫ۀ‬ Manage or prevent a medical condition / disease
‫ۀ‬ Optimize an individual medication
‫ۀ‬ Treat a medical condition or disorder
Each category of DTx displays varying degrees of product claims, requirements for regulatory
oversight, patient and provider access and integration with concurrent therapies.
05
wns.com
The US Food and Drug Administration (FDA) and
regulatory agencies of other regions have been
undertaking considerable effort to streamline
their respective regulatory frameworks to
support the development, evaluation and,
when warranted, clearance of novel DTx. As
digital treatments proliferate, scrutiny of the
various medical claims being made becomes
more important. DTx come under the purview of
the Software as a Medical Device (SaMD)
framework, developed by the International
Medical Device Regulators Forum (IMDRF),
though not everything reviewed by the SaMD is
a digital therapeutic.
The IMDRF, conceived in February 2011 as a
medium to deliberate directions in medical
device regulatory harmonization. It is a voluntary
group of medical device regulators from around
the world, to build on the robust foundational
work of the Global Harmonization Task Force
(GHTF) to fast-track international medical device
regulatory harmonization. In 2013, IMDRF
formed the Software as a Medical
Device-Working Group (WG) to provide
guidance for supporting global innovation and
quick access to safe and effective SaMD. Chaired
by the FDA, the SaMD-WG outlined the key
ƮƵ˛ȁǞɈǞȌȁȺ‫ة‬ǏȲƊǿƵɩȌȲDzǏȌȲȲǞȺDzƧƊɈƵǐȌȲǞɹƊɈǞȌȁǏȌȲ
SaMD, quality management for SaMD and
guidance for the clinical evaluation of SaMD for
the industry and FDA.
The precise path prescribed in the SaMD
framework that DTx must take, and the level of
clinical evidence its maker must provide, is
dependent on the novelty of the product and
how great a risk it poses should it malfunction.
Pear’s reSET®
, for instance, had to submit results
of a randomized controlled trial through the
FDA’s De Novo approval pathway. The FDA
approved it as a prescription-only product, a
designation that is independent of the level of
regulatory control DTx require. Nonetheless,
regardless of the type of claim being made, the
FDA can exercise ‘enforcement discretion’
waiving regulatory oversight if it decides a
product is low risk.
In 2017, the FDA outlined a pilot scheme for a
ٙȯȲƵٌƧƵȲɈǞ˛ƧƊɈǞȌȁٚȯȲȌǐȲƊǿɈȌƊȺȺƵȺȺƧȌǿȯƊȁǞƵȺ
ȲƊɈǘƵȲɈǘƊȁȯȲȌƮɐƧɈȺ‫§خ‬ȲƵٌƧƵȲɈǞ˛ƵƮƧȌǿȯƊȁǞƵȺ‫ة‬
deemed to have demonstrated excellence in
software development and validation, could
market lower-risk devices without further
oversight or through a more streamlined
process. Real-world performance data, which is
generally much easier to collect for DTx than for
ȯǘƊȲǿƊƧƵɐɈǞƧƊǶȺ‫ة‬ƧȌɐǶƮɈǘƵȁƦƵɐȺƵƮɈȌƊǏ˛ȲǿƊ
product’s regulatory status as well as support its
evolution. The idea is being tested in a pilot
scheme involving nine companies that are
undergoing the new process alongside
conventional review, to check that they produce
the same decision.
Regulatory Perspectives
on Digital Therapeutics
05
wns.com
03
wns.com
Conceptually, DTx can be prescribed with or
without combinations with a pharmacotherapy.
Although DTx as a monotherapy has been the
pivotal approach in its development, the use of a
digital therapeutic prescribed along with a
pharmacotherapy is potentially a more
interesting strategy. Such interaction is not only
limited to digital and pharmacological
treatments targeting the same indication, but
could also pertain to co-indications.
For instance, anxiety co-occurs with a number
ȌǏƧǘȲȌȁǞƧƧȌȁƮǞɈǞȌȁȺ‫ة‬ǞȁƧǶɐƮǞȁǐǞȁ˜ƊǿǿƊɈȌȲɯ‫ة‬
respiratory and oncological disorders. Whereas a
lot of pharmacological therapies exist for the
ɈȲƵƊɈǿƵȁɈȌǏǞȁ˜ƊǿǿƊɈǞȌȁ‫ة‬ȲƵȺȯǞȲƊɈȌȲɯƮǞȺɈȲƵȺȺ
and cancers, and while behavioral therapies
have proven to be greatly effective in the
treatment of anxiety, much less is understood
about the synergistic effect of treating both at
the same time.
Arguably, when compared with the development
of new molecular entities, the development of
a DTx monotherapy as well as the combination
of a DTx with a known pharmacotherapy have
faster and more cost-effective paths to patients
and medical value creation. Therefore, it could
be an interesting opportunity for the
biopharmaceutical industry to explore capabilities
of these novel DTx technologies to enhance
overall outcomes of pharmacological treatment.
On a more protracted level, one could also
imagine the development of a new molecular
entity combined with a DTx technology, planned
from the onset as part of a combined
‘drug-device’ therapy. This could potentially create
more medical value for patients than bringing the
new molecule to the market by itself.
However, the current market dynamics of new
drug development may not be conducive to
assuming such additional risk in the
development of the new molecule, even if the
addition of the innovative technology could
create incremental medical value. It may be for
future visionaries to explore how DTx
technologies may be incorporated into core drug
ƮƵɨƵǶȌȯǿƵȁɈɩǞɈǘȌɐɈȺǞǐȁǞ˛ƧƊȁɈǶɯƊƮǯɐȺɈǞȁǐɈǘƵ
classical pharma business model, which focuses
primarily on new molecular entities.
Novel Business Models
for Digital Therapeutics
07
wns.com
Digital therapeutics provide a new approach to
treatment and disease management, wherein
digital systems help patients manage their own
health and disease conditions. DTx utilize the
infrastructure of the Internet, mobile phone and
the novel gains in AI, ML and big data analytics
to optimize treatment for a given individual,
thereby echoing true principles of personalized
medicine. As the distribution of the global
population shifts towards older age groups,
prevention and effective management of
chronic diseases is more relevant than ever. DTx
may provide safer and less expensive options
than traditional treatment, which, in turn, may
save hundreds of billions of dollars in healthcare.
Similar to pharmaceuticals, DTx necessitate
rigorous investigation in randomized controlled
clinical trials to provide reliable evidence of
safety and effectiveness. However, unlike regular
drug development, the timelines can be
substantially reduced because some steps, such
as toxicity studies, are not applicable. Although,
clinical trials to assess digital interventions pose
new logistical, statistical and ethical challenges,
DTx provide unique opportunities for
implementing innovative research designs and
big data analytical techniques. Novel models of
unison between bio / pharma and tech
companies is bound to expedite development of
innovative digital medicinal products.
Conclusion and Outlook
§ȲƵȺɐǿƵƮ0Ǐ˛ƧƊƧɯ
Clinical Development Timelines
Figure: A model depicting various ‘drug-digital’
combinations that can be brought to the market
at varying time, cost and value points
Digital Monotherapy
Marketed separately and in parallel with
drug therapy (lies) in same indication
Digital + approved drug (branded or generic)
Markets as branded combination therapy, with
claims around drug-digital interaction
New Drug
Digital + New Drug
COPYRIGHT © 2022 WNS GLOBAL SERVICES
About WNS
To know more, write to us at marketing@wns.com
or visit us at www.wns.com
with WNS
Co-create to
outperform
WNS (Holdings) Limited (NYSE: WNS) is a leading Business
Process Management (BPM) company. WNS combines deep
industry knowledge with technology, analytics, and process
expertise to co-create innovative, digitally led transformational
solutions with over 400 clients across various industries. WNS
delivers an entire spectrum of BPM solutions including
industry-specific offerings, customer experience services, finance
and accounting, human resources, procurement, and research
and analytics to re-imagine the digital future of businesses. As of
June 30, 2022, WNS had 55,146 professionals across 53 delivery
centers worldwide including facilities in China, Costa Rica, India,
the Philippines, Poland, Romania, South Africa, Spain, Sri Lanka,
Turkey, the United Kingdom, and the United States.

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Healthcare Payer Services | Healthcare Payer BPO| BPM

  • 1. Digital Therapeutics: The Integral Cog of Digital Innovation in Drug Development Vivek Vikram Singh (PhD), Associate Director, Healthcare R&A, WNS
  • 2. 01 wns.com It is well acknowledged that the traditional drug development paradigm has been changing rapidly in the 21st century, with greater focus being placed on delivering personalized medicine solutions. This has been fueled by the development of social networks, smartphones, wearable devices and cloud-based data platforms, which have enabled the collection, storage and analysis of ever-increasing amounts of clinically relevant data. Furthermore, the expansion of digital analytical tools and advances in Machine Learning (ML) have empowered researchers to transform data into knowledge and aid clinical decision-making. This new-age armamentarium permits a broad range of activities in digital health, including in mobile health (mHealth), Health Information Technology (HIT), wearable devices, telehealth / telemedicine and personalized Digital Therapeutics (DTx). Digital Therapeutics: The Integral Cog of Digital Innovation in Drug Development Vivek Vikram Singh (PhD), Associate Director, Healthcare R&A, WNS
  • 3. The Field of Digital Therapeutics In simple terms, DTx are a health discipline and treatment option that utilize digital and often online health technologies to treat a medical condition. It is however different from, say, a wellness app in that a DTx must undergo clinical ɨƊǶǞƮƊɈǞȌȁ‫ش‬ɈȲǞƊǶɈȌȯȲȌɨƵǞɈȺƵǏ˛ƧƊƧɯƊȺƊƦȌȁƊ ˛ƮƵɈǘƵȲƊȯƵɐɈǞƧ‫خ‬ DTx thus form an independent category of evidence-based products within the broader digital health landscape. It is distinguished through its primary function of delivering software-generated therapeutic interventions directly to patients to prevent, manage or treat a medical disorder or disease. The individual treatment strategy is ‘optimized’ (for instance, by applying ML techniques to the individual’s observed data), thereby realizing the principle of personalized medicine. DTx are validated by regulatory bodies, as required, to support product ƧǶƊǞǿȺȲƵǐƊȲƮǞȁǐȲǞȺDz‫ة‬ƵǏ˛ƧƊƧɯƊȁƮǞȁɈƵȁƮƵƮɐȺƵ‫خ‬ Megan Coder, executive director of the Digital ÀǘƵȲƊȯƵɐɈǞƧȺǶǶǞƊȁƧƵ‫(ـ‬À‫ةف‬ƊȁȌȁٌȯȲȌ˛Ɉ organization, which is responsible to set standards and integrate DTx into healthcare, says, “Digital therapeutics are part of the broader digital health landscape, but in order to be called one, a product has to be software driven and evidence based, and make a claim to prevent, manage, or treat a medical disease or disorder. A digital therapy can be used alone, or with other therapies to optimize outcomes.” DTx are considered distinct from pure-play adherence, diagnostic and telehealth products. However, while their key focus is on delivering direct therapeutic interventions, DTx products possess the unique ability to incorporate additional functionalities into its comprehensive portfolio. Integration with mHealth platforms; ability to provide complementary diagnostic or adherence interventions; compatibility with digital devices, sensors, or wearables; remote delivery of intervention; and integration into electronic prescribing, dispensing, and EMR platforms, are the key additional features that can be part of a DTx solution. The types of interventions being delivered / developed by DTx products across the industry are as diverse as the disease states being addressed. In September 2017, Pear Therapeutics’ lead product, reSET® ‫ة‬ɩƊȺɈǘƵ˛ȲȺɈ(ÀɮɈȌȲƵƧƵǞɨƵ market authorization from the US FDA to work in conjunction with conventional outpatient clinician-delivered care (face-to-face therapy) for Substance Use Disorder (SUD). It’s a mobile-based medical application system for a patient use and has a clinician dashboard interface. With reset®, patients can get Cognitive Behavioral Therapy (CBT), to teach them skills that aid in the treatment of SUD. Its purpose is to increase abstinence from substance abuse and retention of prescribed behavior in an outpatient therapy programs. Soon thereafter, Pear’s second product candidate, reSET-O®, for the treatment of Opioid Use Disorder (OUD) received Breakthrough Designation (BTD) and was authorized by the US FDA in December 2018. With the burgeoning of DTx platforms and applications, patients, providers and payers can expect increasing comprehensive network of therapy modalities for physical, mental and behavioral disease states. As per a market report analysis from ResearchAndMarkets, the global DTx market is expected to grow at a CAGR of 31.4 percent, from USD 3.4 Billion in 2021 to USD 13.1 Billion by 2026. Theincreasing focus on preventive healthcare, emerging RD trends, technological advancements, importance of patient convenience and user-friendliness, and launch of ȁȌɨƵǶȯȲȌƮɐƧɈȺɩǞɈǘƵȁǘƊȁƧƵƮƵǏ˛ƧǞƵȁƧɯƊȲƵDzƵɯ factors contributing to the high CAGR in the forecast period. 02 wns.com
  • 4. 03 wns.com Examples of DTx in the market or currently under development AI-based digital diagnostics and personalized therapeutics for pediatric behavioral healthcare Combined software and hardware program to improve asthma and COPD control, and optimize healthcare utilization Digital therapeutic used as an adjunct to standard, outpatient treatment for Substance Use Disorder (SUD) Neurologic Music Therapy to address motor, speech and cognitive dysfunction caused by neurologic disease or injury Digital sleep improvement program featuring Cognitive Behavioral Therapy (CBT) techniques Digital therapeutic utilizing adaptive sensory stimulus software for the treatment of ADHD delivered through an engaging video game experience Digital therapeutic engaging individuals with Type 2 diabetes and hypertension, and their care providers, to improve self-management and outcome DTx
  • 5. Primary Purpose of DTx Product yȌƵǏ˛ƧƊƧɯ claims regarding a medical disorder or disease Clinical trials required Clinical trials required Clinical trials required Clinical trials required Low to medium risk (e.g. reduce rate of disease progression) Medium to high risk (e.g. improve ƵǏ˛ƧƊƧɯȌǏ adjunctive therapies) Medium to high risk (e.g. direct ƵǏ˛ƧƊƧɯƧǶƊǞǿȺ on clinical outcomes) Level of Product Claims (Related to Medical Disorder or Disease) Clinical Evidence Requirement Regulatory enforcement discretion (without explicit oversight) Third-party validation of ƵǏ˛ƧƊƧɯ‫ش‬ȺƊǏƵɈɯ claims by regulatory or equivalent national body Third-party validation of ƵǏ˛ƧƊƧɯ‫ش‬ȺƊǏƵɈɯ claims by regulatory or equivalent national body Third-party validation of ƵǏ˛ƧƊƧɯ‫ش‬ȺƊǏƵɈɯ claims by regulatory or equivalent national body Level of Support for Product Claims Direct-to-consumer (prescription not required) OTC or prescription required OTC or prescription required Prescription required Patient Access to DTx Works independently or indirectly supports another therapy Monotherapy or directly supports a concurrent treatment Directly supports a concurrent treatment Monotherapy or directly supports a concurrent treatment Association to Concurrent Therapies Address a Medical Condition Manage or Prevent a Medical Condition / Disease Optimize Medication Treat a Medical Condition / Disorder 04 wns.com In essence, every DTx product corresponds to one of the four categories based on its intended use ƊȁƮȌǏ˛ƧǞƊǶȯȲȌƮɐƧɈƧǶƊǞǿȺ‫ب‬ ‫ۀ‬ ƮƮȲƵȺȺƊǿƵƮǞƧƊǶƧȌȁƮǞɈǞȌȁ ‫ۀ‬ Manage or prevent a medical condition / disease ‫ۀ‬ Optimize an individual medication ‫ۀ‬ Treat a medical condition or disorder Each category of DTx displays varying degrees of product claims, requirements for regulatory oversight, patient and provider access and integration with concurrent therapies.
  • 6. 05 wns.com The US Food and Drug Administration (FDA) and regulatory agencies of other regions have been undertaking considerable effort to streamline their respective regulatory frameworks to support the development, evaluation and, when warranted, clearance of novel DTx. As digital treatments proliferate, scrutiny of the various medical claims being made becomes more important. DTx come under the purview of the Software as a Medical Device (SaMD) framework, developed by the International Medical Device Regulators Forum (IMDRF), though not everything reviewed by the SaMD is a digital therapeutic. The IMDRF, conceived in February 2011 as a medium to deliberate directions in medical device regulatory harmonization. It is a voluntary group of medical device regulators from around the world, to build on the robust foundational work of the Global Harmonization Task Force (GHTF) to fast-track international medical device regulatory harmonization. In 2013, IMDRF formed the Software as a Medical Device-Working Group (WG) to provide guidance for supporting global innovation and quick access to safe and effective SaMD. Chaired by the FDA, the SaMD-WG outlined the key ƮƵ˛ȁǞɈǞȌȁȺ‫ة‬ǏȲƊǿƵɩȌȲDzǏȌȲȲǞȺDzƧƊɈƵǐȌȲǞɹƊɈǞȌȁǏȌȲ SaMD, quality management for SaMD and guidance for the clinical evaluation of SaMD for the industry and FDA. The precise path prescribed in the SaMD framework that DTx must take, and the level of clinical evidence its maker must provide, is dependent on the novelty of the product and how great a risk it poses should it malfunction. Pear’s reSET® , for instance, had to submit results of a randomized controlled trial through the FDA’s De Novo approval pathway. The FDA approved it as a prescription-only product, a designation that is independent of the level of regulatory control DTx require. Nonetheless, regardless of the type of claim being made, the FDA can exercise ‘enforcement discretion’ waiving regulatory oversight if it decides a product is low risk. In 2017, the FDA outlined a pilot scheme for a ٙȯȲƵٌƧƵȲɈǞ˛ƧƊɈǞȌȁٚȯȲȌǐȲƊǿɈȌƊȺȺƵȺȺƧȌǿȯƊȁǞƵȺ ȲƊɈǘƵȲɈǘƊȁȯȲȌƮɐƧɈȺ‫§خ‬ȲƵٌƧƵȲɈǞ˛ƵƮƧȌǿȯƊȁǞƵȺ‫ة‬ deemed to have demonstrated excellence in software development and validation, could market lower-risk devices without further oversight or through a more streamlined process. Real-world performance data, which is generally much easier to collect for DTx than for ȯǘƊȲǿƊƧƵɐɈǞƧƊǶȺ‫ة‬ƧȌɐǶƮɈǘƵȁƦƵɐȺƵƮɈȌƊǏ˛ȲǿƊ product’s regulatory status as well as support its evolution. The idea is being tested in a pilot scheme involving nine companies that are undergoing the new process alongside conventional review, to check that they produce the same decision. Regulatory Perspectives on Digital Therapeutics
  • 7. 05 wns.com 03 wns.com Conceptually, DTx can be prescribed with or without combinations with a pharmacotherapy. Although DTx as a monotherapy has been the pivotal approach in its development, the use of a digital therapeutic prescribed along with a pharmacotherapy is potentially a more interesting strategy. Such interaction is not only limited to digital and pharmacological treatments targeting the same indication, but could also pertain to co-indications. For instance, anxiety co-occurs with a number ȌǏƧǘȲȌȁǞƧƧȌȁƮǞɈǞȌȁȺ‫ة‬ǞȁƧǶɐƮǞȁǐǞȁ˜ƊǿǿƊɈȌȲɯ‫ة‬ respiratory and oncological disorders. Whereas a lot of pharmacological therapies exist for the ɈȲƵƊɈǿƵȁɈȌǏǞȁ˜ƊǿǿƊɈǞȌȁ‫ة‬ȲƵȺȯǞȲƊɈȌȲɯƮǞȺɈȲƵȺȺ and cancers, and while behavioral therapies have proven to be greatly effective in the treatment of anxiety, much less is understood about the synergistic effect of treating both at the same time. Arguably, when compared with the development of new molecular entities, the development of a DTx monotherapy as well as the combination of a DTx with a known pharmacotherapy have faster and more cost-effective paths to patients and medical value creation. Therefore, it could be an interesting opportunity for the biopharmaceutical industry to explore capabilities of these novel DTx technologies to enhance overall outcomes of pharmacological treatment. On a more protracted level, one could also imagine the development of a new molecular entity combined with a DTx technology, planned from the onset as part of a combined ‘drug-device’ therapy. This could potentially create more medical value for patients than bringing the new molecule to the market by itself. However, the current market dynamics of new drug development may not be conducive to assuming such additional risk in the development of the new molecule, even if the addition of the innovative technology could create incremental medical value. It may be for future visionaries to explore how DTx technologies may be incorporated into core drug ƮƵɨƵǶȌȯǿƵȁɈɩǞɈǘȌɐɈȺǞǐȁǞ˛ƧƊȁɈǶɯƊƮǯɐȺɈǞȁǐɈǘƵ classical pharma business model, which focuses primarily on new molecular entities. Novel Business Models for Digital Therapeutics
  • 8. 07 wns.com Digital therapeutics provide a new approach to treatment and disease management, wherein digital systems help patients manage their own health and disease conditions. DTx utilize the infrastructure of the Internet, mobile phone and the novel gains in AI, ML and big data analytics to optimize treatment for a given individual, thereby echoing true principles of personalized medicine. As the distribution of the global population shifts towards older age groups, prevention and effective management of chronic diseases is more relevant than ever. DTx may provide safer and less expensive options than traditional treatment, which, in turn, may save hundreds of billions of dollars in healthcare. Similar to pharmaceuticals, DTx necessitate rigorous investigation in randomized controlled clinical trials to provide reliable evidence of safety and effectiveness. However, unlike regular drug development, the timelines can be substantially reduced because some steps, such as toxicity studies, are not applicable. Although, clinical trials to assess digital interventions pose new logistical, statistical and ethical challenges, DTx provide unique opportunities for implementing innovative research designs and big data analytical techniques. Novel models of unison between bio / pharma and tech companies is bound to expedite development of innovative digital medicinal products. Conclusion and Outlook §ȲƵȺɐǿƵƮ0Ǐ˛ƧƊƧɯ Clinical Development Timelines Figure: A model depicting various ‘drug-digital’ combinations that can be brought to the market at varying time, cost and value points Digital Monotherapy Marketed separately and in parallel with drug therapy (lies) in same indication Digital + approved drug (branded or generic) Markets as branded combination therapy, with claims around drug-digital interaction New Drug Digital + New Drug
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