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ARCS Reg Affairs Interest Session
March 2018
George Masri
Assistant Secretary
Regulatory Services & Improvement Branch
Overview
• MMDR Bill 2 – new fees and charges commencing in 2018
• 2018-19 possible changes in fees and charges
– Good Manufacturing Practice (GMP)
– Indexation
– Application fee for Class I medical devices
– Annual charges for complementary medicines
– Annual charges for provisional registration
1
MMDR Bill 2 - Key Features
• Establish a scheme for provisional approval of promising new medicines
• Changes to regulation of complementary medicines, including:
• A new pathway under which listed medicines can be assessed for efficacy
• Establishing a list of permitted indications for listed medicines
• Providing incentives to develop new ingredients
• Streamlining and simplifying the framework for advertising therapeutic goods to the public
• Allowing greater use of assessments by comparable international regulators for medical
devices
• Providing refinements to allow Australian organisations, designated by the TGA, to conduct
conformity assessments of medical devices
• Enhanced compliance and enforcement powers and graduated penalties for non-compliance
2
TG Bill 2 – Implementation timetable
• Bill 2 changes to the Therapeutic Goods Act:
– Passed by Senate and again House of Representatives on 15 February 2018
– Late passage of Bill 2 has caused delay to commencement of some reforms
which were planned to commence on 1 January 2018
– Bill 2 Regulations/reforms came into force on 20 March 2018
 Advertising complaints implementation 1 July 2018
 Removal of advertising pre-approvals will now begin from 1 July 2020
3
TG Bill 2 - New fees commencing in 2017-18
– Application and evaluation fees for prescription medicine provisional pathway
– The designation fee for Provisional Approval $12,300
– *indicative fees presented in September 2017 TIF
Application fee ($) Evaluation fee ($) Total ($)
Designation extension fee 4,440 – 4,440
4,300*
Pre-market registration process – New prescription medicine 47,000 245,500 292,500
271,500*
Pre-market registration process – Extension of Indication 28,100 161,900 190,000
168,000*
Extension of Provisional registration 16,900 – 16,900
16,000*
Transition to full registration 28,000 118,100 146,100
-*
4
Fees for listing pathways
• Pathway 1 – current listed complementary medicines pathway
– listing after choosing a permitted indication
– the current listing fee of $800 will continue to apply for pathway 1
• Pathway 2 – (new) listed assessed medicines pathway
– listing after efficacy assessment by TGA
Pathway 2 - New listed assessed medicines Application fee ($) Evaluation fee (S) Total fees ($)
L(A)1 - Evaluation of a clone of an existing product, where the only difference is the name and/or flavour,
fragrance, printing ink or colour
430 1,640 2,070
L(A)2 - Evaluation of efficacy based on international evaluation reports which meet the minimum data
requirements
1,760 13,400 15,160
L(A)3 - Full de novo evaluation of efficacy
An application for a new medicine not covered by NP1 or NP2, that is an extension to an existing approved
medicine, including: New therapeutic indications; New strength; New dosage form
1,760 13,400 15,160
5
Fees for registered complementary medicines pathways
• Pathway 3 – registered complementary medicines pathway
– the current page count fee structure will be replaced
– new notification fee of $780 for some minor variations
• Assessment fees
Pathway 3 - Registered complementary medicines Application fee
($)
Evaluation fee
($)
Total fees ($)
RCM1 - Evaluation of a clone of an existing product, where the only difference is the name and/or flavour, fragrance,
printing ink or colour
530 3,060 3,590
RCM2 - Evaluation of safety, quality and efficacy based on international evaluation reports and/or accepted monograph
which meet the minimum data requirements
1,910 20,500 22,410
RCM3 - Evaluation of quality and either safety or efficacy based on international evaluation reports and/or accepted
monograph which meet the minimum data requirements AND de novo evaluation of either safety or efficacy
1,910 20,500 22,410
RCM4 - Evaluation of one of either safety, quality or efficacy based on international evaluation reports and de novo
evaluation of the two remaining parameters
- an application for a new medicine not covered by RCM1 – RCM3
2,530 27,800 2,530
RCM5 - Full de novo evaluation of safety, quality and efficacy
- an application for a new medicine not covered by RCM1 – RCM4
2,770 35,500 38,270
6
Fees for registered complementary medicines pathways
(Variations)
• Pathway 3 – registered complementary medicines variation fees
Pathway 3 -Registered complementary medicines (Variations) Application fee
($)
Evaluation fee
($)
Total fees ($)
RCMC1 – Changes identified in the Changes Table as application level C1.
C1 applications do not need safety, efficacy and/or quality data or a justification for not providing the data.
1,380 - 1,380
RCMC2 – Changes identified in the Changes Table as application level C2.
• may require assessment of quality data
• do not need safety and/or efficacy data or a justification for not providing the data
730 3,960 4,690
RCMC3 – Changes identified in the Changes Table as application level C3.
• include changes to the quality, safety and/or efficacy of a medicine
• include changes to the medicine name where the new name requires a higher level of assessment, such as where there
is an identified risk associated with an umbrella branding segment
• require assessment of supporting safety and/or efficacy data or a justification for not providing the data
780 6,190 6,970
RCMC4 – Changes identified in the Changes Table as application level C4.
• include changes to the safety and/or efficacy aspects of the medicine
• require assessment of safety and/or efficacy data (clinical and/or toxicological) to support the proposed changes or a
justification for not providing the data
790 9,160 9,950
7
Fees for new complementary medicine ingredients & permitted
indications
• New ingredients
• New permitted indications
– Application fee for new permitted indications $1,020
New ingredients Application fee
($)
Evaluation fee
($)
Total fees ($)
IN1 - Evaluation of safety and quality based on international evaluation reports which meet the minimum data
requirements
1,050 14,000 15,050
IN2 - Evaluation of safety based on international evaluation reports which meet the minimum data requirements
AND de novo evaluation of quality
1,050 14,000 15,050
IN3 - Evaluation of quality based on international evaluation reports which meet the minimum data requirements
or an accepted monograph AND de novo evaluation of safety
2,770 22,900 25,670
IN4 - Full de novo evaluation of safety and quality 2,770 22,900 25,670
8
Fees for designation of conformity assessment bodies
• Fees for designation - Conformity Assessment Bodies (CABs) to undertake conformity assessment
certifications of medical devices
* Indicative fees presented in December 2017
Application fee ($) Assessment fee ($)
Full designation conformity assessment body determination 4,440
5,000*
71,700
80,000 – 100,000*
Partial designation conformity assessment body determination (full QMS) 2,410
3,000*
51,500
60,000-70,000*
Partial designation conformity assessment body determination (partial QMS or partial
devices)
2,410
3,000*
51,500
60,000-70,000*
9
2018-19 – Potential changes in fees and charges
• Potential changes required to TGA fees and charges in 2018-19
– Revised fees and charges model for GMP to address under-
recovery of GMP costs
– Indexation increase
– Application fee for class I medical devices
– Annual charges for complementary medicines
– Annual charges for provisional registration
10
Good Manufacturing Practice
Proposed fees under Option 3 (recommended by Deloitte)
• Deloitte’s proposed changes
– Merge and reduce annual charges
 High level licence charge will reduce from $12,200 to $4,590
 Low level licence charge will reduce from $6,260 to $ 4,590
 No free audit hours from 1 July 2018
– Application fee of $770 for a licence variation
 This is a regulatory requirement
– New licence application fee will reduce from $1,000 to $770
– Domestic inspection fee $970 per hour (currently $660)
 Continue to apply to on-site hours only, not all inspection hours
 Includes travel and accommodation costs
– GMP clearance application fee to increase from $390 to $790
 This will also cover cost of MRA assessment without a need to introduce separate fee
• 3B Option
– GMP Clearance application fee increase to $640
– Compliance verification application assessment fee to increase by $400 to $2,430 11
Other proposed changes from 1 July 2018
• Indexation: CPI / WPI for the Sept to Sept quarters 1.8% and 2%,
50:50 composite index 1.9%
• $530 application fee for inclusion of Class 1 medical devices
• Annual charges for complementary medicines increase $80 per
ARTG entry
• Annual Charge for Provisional registration
– Provisional biological prescription medicine annual charge:
$16,200
– Provisional non-biological prescription medicine annual
charge:$13,100
12
QUESTIONS?
13
Arcs presentation-reg-affairs-interest-session

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Arcs presentation-reg-affairs-interest-session

  • 1. ARCS Reg Affairs Interest Session March 2018 George Masri Assistant Secretary Regulatory Services & Improvement Branch
  • 2. Overview • MMDR Bill 2 – new fees and charges commencing in 2018 • 2018-19 possible changes in fees and charges – Good Manufacturing Practice (GMP) – Indexation – Application fee for Class I medical devices – Annual charges for complementary medicines – Annual charges for provisional registration 1
  • 3. MMDR Bill 2 - Key Features • Establish a scheme for provisional approval of promising new medicines • Changes to regulation of complementary medicines, including: • A new pathway under which listed medicines can be assessed for efficacy • Establishing a list of permitted indications for listed medicines • Providing incentives to develop new ingredients • Streamlining and simplifying the framework for advertising therapeutic goods to the public • Allowing greater use of assessments by comparable international regulators for medical devices • Providing refinements to allow Australian organisations, designated by the TGA, to conduct conformity assessments of medical devices • Enhanced compliance and enforcement powers and graduated penalties for non-compliance 2
  • 4. TG Bill 2 – Implementation timetable • Bill 2 changes to the Therapeutic Goods Act: – Passed by Senate and again House of Representatives on 15 February 2018 – Late passage of Bill 2 has caused delay to commencement of some reforms which were planned to commence on 1 January 2018 – Bill 2 Regulations/reforms came into force on 20 March 2018  Advertising complaints implementation 1 July 2018  Removal of advertising pre-approvals will now begin from 1 July 2020 3
  • 5. TG Bill 2 - New fees commencing in 2017-18 – Application and evaluation fees for prescription medicine provisional pathway – The designation fee for Provisional Approval $12,300 – *indicative fees presented in September 2017 TIF Application fee ($) Evaluation fee ($) Total ($) Designation extension fee 4,440 – 4,440 4,300* Pre-market registration process – New prescription medicine 47,000 245,500 292,500 271,500* Pre-market registration process – Extension of Indication 28,100 161,900 190,000 168,000* Extension of Provisional registration 16,900 – 16,900 16,000* Transition to full registration 28,000 118,100 146,100 -* 4
  • 6. Fees for listing pathways • Pathway 1 – current listed complementary medicines pathway – listing after choosing a permitted indication – the current listing fee of $800 will continue to apply for pathway 1 • Pathway 2 – (new) listed assessed medicines pathway – listing after efficacy assessment by TGA Pathway 2 - New listed assessed medicines Application fee ($) Evaluation fee (S) Total fees ($) L(A)1 - Evaluation of a clone of an existing product, where the only difference is the name and/or flavour, fragrance, printing ink or colour 430 1,640 2,070 L(A)2 - Evaluation of efficacy based on international evaluation reports which meet the minimum data requirements 1,760 13,400 15,160 L(A)3 - Full de novo evaluation of efficacy An application for a new medicine not covered by NP1 or NP2, that is an extension to an existing approved medicine, including: New therapeutic indications; New strength; New dosage form 1,760 13,400 15,160 5
  • 7. Fees for registered complementary medicines pathways • Pathway 3 – registered complementary medicines pathway – the current page count fee structure will be replaced – new notification fee of $780 for some minor variations • Assessment fees Pathway 3 - Registered complementary medicines Application fee ($) Evaluation fee ($) Total fees ($) RCM1 - Evaluation of a clone of an existing product, where the only difference is the name and/or flavour, fragrance, printing ink or colour 530 3,060 3,590 RCM2 - Evaluation of safety, quality and efficacy based on international evaluation reports and/or accepted monograph which meet the minimum data requirements 1,910 20,500 22,410 RCM3 - Evaluation of quality and either safety or efficacy based on international evaluation reports and/or accepted monograph which meet the minimum data requirements AND de novo evaluation of either safety or efficacy 1,910 20,500 22,410 RCM4 - Evaluation of one of either safety, quality or efficacy based on international evaluation reports and de novo evaluation of the two remaining parameters - an application for a new medicine not covered by RCM1 – RCM3 2,530 27,800 2,530 RCM5 - Full de novo evaluation of safety, quality and efficacy - an application for a new medicine not covered by RCM1 – RCM4 2,770 35,500 38,270 6
  • 8. Fees for registered complementary medicines pathways (Variations) • Pathway 3 – registered complementary medicines variation fees Pathway 3 -Registered complementary medicines (Variations) Application fee ($) Evaluation fee ($) Total fees ($) RCMC1 – Changes identified in the Changes Table as application level C1. C1 applications do not need safety, efficacy and/or quality data or a justification for not providing the data. 1,380 - 1,380 RCMC2 – Changes identified in the Changes Table as application level C2. • may require assessment of quality data • do not need safety and/or efficacy data or a justification for not providing the data 730 3,960 4,690 RCMC3 – Changes identified in the Changes Table as application level C3. • include changes to the quality, safety and/or efficacy of a medicine • include changes to the medicine name where the new name requires a higher level of assessment, such as where there is an identified risk associated with an umbrella branding segment • require assessment of supporting safety and/or efficacy data or a justification for not providing the data 780 6,190 6,970 RCMC4 – Changes identified in the Changes Table as application level C4. • include changes to the safety and/or efficacy aspects of the medicine • require assessment of safety and/or efficacy data (clinical and/or toxicological) to support the proposed changes or a justification for not providing the data 790 9,160 9,950 7
  • 9. Fees for new complementary medicine ingredients & permitted indications • New ingredients • New permitted indications – Application fee for new permitted indications $1,020 New ingredients Application fee ($) Evaluation fee ($) Total fees ($) IN1 - Evaluation of safety and quality based on international evaluation reports which meet the minimum data requirements 1,050 14,000 15,050 IN2 - Evaluation of safety based on international evaluation reports which meet the minimum data requirements AND de novo evaluation of quality 1,050 14,000 15,050 IN3 - Evaluation of quality based on international evaluation reports which meet the minimum data requirements or an accepted monograph AND de novo evaluation of safety 2,770 22,900 25,670 IN4 - Full de novo evaluation of safety and quality 2,770 22,900 25,670 8
  • 10. Fees for designation of conformity assessment bodies • Fees for designation - Conformity Assessment Bodies (CABs) to undertake conformity assessment certifications of medical devices * Indicative fees presented in December 2017 Application fee ($) Assessment fee ($) Full designation conformity assessment body determination 4,440 5,000* 71,700 80,000 – 100,000* Partial designation conformity assessment body determination (full QMS) 2,410 3,000* 51,500 60,000-70,000* Partial designation conformity assessment body determination (partial QMS or partial devices) 2,410 3,000* 51,500 60,000-70,000* 9
  • 11. 2018-19 – Potential changes in fees and charges • Potential changes required to TGA fees and charges in 2018-19 – Revised fees and charges model for GMP to address under- recovery of GMP costs – Indexation increase – Application fee for class I medical devices – Annual charges for complementary medicines – Annual charges for provisional registration 10
  • 12. Good Manufacturing Practice Proposed fees under Option 3 (recommended by Deloitte) • Deloitte’s proposed changes – Merge and reduce annual charges  High level licence charge will reduce from $12,200 to $4,590  Low level licence charge will reduce from $6,260 to $ 4,590  No free audit hours from 1 July 2018 – Application fee of $770 for a licence variation  This is a regulatory requirement – New licence application fee will reduce from $1,000 to $770 – Domestic inspection fee $970 per hour (currently $660)  Continue to apply to on-site hours only, not all inspection hours  Includes travel and accommodation costs – GMP clearance application fee to increase from $390 to $790  This will also cover cost of MRA assessment without a need to introduce separate fee • 3B Option – GMP Clearance application fee increase to $640 – Compliance verification application assessment fee to increase by $400 to $2,430 11
  • 13. Other proposed changes from 1 July 2018 • Indexation: CPI / WPI for the Sept to Sept quarters 1.8% and 2%, 50:50 composite index 1.9% • $530 application fee for inclusion of Class 1 medical devices • Annual charges for complementary medicines increase $80 per ARTG entry • Annual Charge for Provisional registration – Provisional biological prescription medicine annual charge: $16,200 – Provisional non-biological prescription medicine annual charge:$13,100 12