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1Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Minimizing Risk in
Pharmacovigilance
www.elsevier.com/pharmacovigilance
Key Challenges in
Pharmacovigilance
3Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Challenge
• Development of a common platform
across different geographic locations,
functional groups, product lines.
• Integration of data — a single database to
include data across the entire product life
cycle (pre and post-market). Challenge:
multiple databases may contain similar
information but are not linked/linkable to
each other.
• Implementation of work flow
management technology — identify and
distribute information to stakeholders
according to a predetermined set of rules.
Ensure only the appropriate employees
receive the data required to inform the
decisions they are authorized to make.
How to Standardize Processes and Data Management
“We don’t view drug safety from a postmarket or
premarket perspective but, rather, as a continuum
from the time the compound is identified and the time
of animal studies on through when companies are
hoping to get approval...”
Alan Goldhammer, Associate vice president of regulatory
affairs for the Pharmaceutical Research and
Manufacturers of America (PhRMA) (source: PWC report)
4Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Challenge
Implement Proactive Risk Management
• Development of a risk
management action plan
Establish risk scoring and
mitigation processes to
evaluate external risk
factors (regulatory,
reputation, product liability)
and internal (portfolio,
strategic and financial risk).
• Dashboard
Summarize safety
information across the
product portfolio in real
time. Identify the types
of data that should/should
not be used in drug safety
decision making.
• Implementation of data
mining techniques
Assess the patterns, time
trends and events
associated with drug-
drug interactions.
5Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Challenge: Run PV Operations Cost Effectively
• Growing amount of data
causes important safety
signals to be missed — how
to deal with the data storm?
Embase, October 2014
• Savings from outsourcing PV
operations can be negated with
costs from the manual review of
records. Tools that better target
relevant literature can prevent
this.
• Signal identification must not
be lost due to segmentation of
the analysis by different parties.
1975
1980
1985
1990
1995
2000
2005
2010
2011
2012
2013
0 5 10 15 20 25 30
Millions of Records
Increasing number of records added to Embase
6Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Once Articles Are Captured, the Review and Triage
Process Has Additional Challenges
Too much time is wasted
looking at the same article
multiple times
Challenges Needs
Some outsourced systems
are unable to meet the rigid
regulatory demands
Existing in-house systems are
becoming outdated, and
maintenance & replacement
costs are high
Need to be sure all articles are
captured and reviewed
A coordinated workflow to
manage the article pipeline
Capture metrics behind article
reviews in case of audits
7Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Elsevier Can Create a Unifying Structure that Can Be
Used to Promote Best Practices
Adapted from Zhengwu Lu, Information technology in pharmacovigilance: Benefits, challenges, and
future directions from industry perspectives, Drug Health Patient Saf. 2009; 1: 35–45.
Tested and Proven Cloud-Based Tools
Set up a
coordinated
workflow to
manage the
article pipeline
Be sure all
articles are
captured
and reviewed
Capture metrics
behind article
reviews in case
of audits
Ensure
accessibility
of safety
information
Organizational
Alignment
Operations
Management
Data
Management
Risk
Management
8Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Cloud Based
Solution
Pharma company was using a combination
of a cloud-based solution and SharePoint
to monitor literature for adverse events.
Pharma company reviewed captured
articles and submitted serious cases to
regulatory agencies
However, not all articles were appearing in
SharePoint, and important articles are missed,
resulting in a warning from the regulatory agency
Regulatory
Agency
Issues
Warning
Pharma
Company
What Can Go Wrong in Large Pharma
A Gap in Literature Monitoring
Published Literature
Literature
Monitoring
System
9Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Published Literature
Literature
Monitoring
System
Elsevier implemented a complex search
strategy into its biomedical literature
database [Embase] to ensure that relevant
information was captured.
Elsevier also provided a tool that alerted the
customer about unread articles to make
sure all materials were reviewed.
Seamless
Literature
Triage
Largest Journal
and Conference Coverage
+
Specialist-Developed
Search Strategy
Regulatory
Agency
ICSRs
Pharma
Company
What Can Go Wrong in Large Pharma
A Gap in Literature Monitoring
10Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Additional Sub-optimal Processes in Pharma Companies…
• Under-staffed literature screening teams
– Some global pharma companies have as few as one person screening literature for
adverse events.
– This is a tremendous workload that results in too much time being taken to discover
serious ADRs, or possibly missing them entirely.
• Use of Reference Management tools to manage literature
– Reference Management tools do not allow searching of full text articles.
– This results in a highly manual process that requires additional time to read the
article for mentions of adverse events.
Addressing the Challenges in
Pharmacovigilance
12Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Our Mission in Pharmacovigilance
Elsevier provides the capabilities necessary for
Pharmacovigilance and Drug Safety groups to be:
more efficient
stay compliant
and mitigate risk
13Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
1. Avoid missing critical
information
2. Save time with better
article pipeline
management
3. Connect literature
to broader ecosystem
4. Manage risk of
late-stage failure
Output
Analysis
Regulatory Data for
Risk Mitigation
Strategies
Case
Input
Automated
Literature
Monitoring
Case
Processing
Automated
Literature
Triage
Case
Output
Integration with case
reporting systems
and audit trails
Our Framework
14Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Case Input: Literature Monitoring
Key Challenges
Output
Analysis
Regulatory Data for
Risk Mitigation
Strategies
Case
Input
Automated
Literature
Monitoring
Case
Processing
Automated
Literature
Triage
Case
Output
Integration with case
reporting systems
and audit trails
• How thorough is your existing
literature monitoring process?
Are you at risk of missing
articles that report AEs?
• Are you wasting valuable
time sifting through
duplicate articles?
• Are you increasing cost by
purchasing the full-text articles
multiple times?
15Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Centralized
Document
Repository for
Drug Safety
Published
Literature
Avoid missing critical information
Case Input: Literature Monitoring
More confidently
find adverse
events in the
literature
Find information
not available in
other tools
Increase the
likelihood of early
signal detection
Save time reviewing,
reduce the risk of
double-counting
Most
comprehensive
journal coverage
and indexing
available
Most
comprehensive
coverage of
conference
proceedings
Custom
development of
complex
searches
Automatic
deduplication of
articles
16Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Case Processing: Literature Triage
• Are the appropriate employees
receiving the required data to inform
the decisions they are authorized
to make?
• Are you working with multiple
databases that contain similar
information but are not linked/linkable
to each other?
• Are you wasting valuable time sifting
through duplicate articles?
• Are you increasing cost by purchasing
the full-text articles multiple times?
Key Challenges
Output
Analysis
Regulatory Data for
Risk Mitigation
Strategies
Case
Input
Automated
Literature
Monitoring
Case
Processing
Automated
Literature
Triage
Case
Output
Integration with case
reporting systems
and audit trails
17Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Case Processing: Literature Triage
Regulatory
Reports
Centralized
Document
Repository
Save time with better article pipeline management
Seamless
centralized
triage tool
Text mining of
articles
Alerts about
unread articles
Triage articles
faster
Find AEs faster by
reviewing the most
relevant articles
Be more confident
that information
isn’t missed
18Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Case Output: Integration With Case Reporting System
• Can you effortlessly export your
data to existing
analysis/reporting tools?
• Are you wasting valuable
resources on manual
processing of data?
• In the event of an audit, will you
be able to clearly demonstrate
that the review process was
done correctly?
Key Challenges
Output
Analysis
Regulatory Data for
Risk Mitigation
Strategies
Case
Input
Automated
Literature
Monitoring
Case
Processing
Automated
Literature
Triage
Case
Output
Integration with case
reporting systems
and audit trails
19Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Case Output: Integration With Case Reporting System
Connect literature process to the broader ecosystem
Pharmacovigil
ance Signal
Detection and
Reporting
Ecosystem
Centralized
Document
Repository
Review process
tracked for
reporting
Literature
pre-formatted
for case reports
Automated
exporting of
data to case
management
systems
Be better prepared
for audits
Save time and effort
Reduce manual steps
when integrating
triage results
20Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Output Analysis: Risk Mitigation
Key Challenges
Output
Analysis
Regulatory Data for
Risk Mitigation
Strategies
Case
Input
Automated
Literature
Monitoring
Case
Processing
Automated
Literature
Triage
Case
Output
Integration with case
reporting systems
and audit trails
• How can we better manage risk?
• Are we gathering all available
safety/AE data about a drug/
class of drugs?
• Are we leveraging best practices
from precedent preclinical/
clinical studies?
• Have all the potential and
unanticipated risks been captured?
21Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Output Analysis: Risk Mitigation
Make better informed risk management and mitigation decisions
Reduce
regulatory
cycling
Improve REMS
planning and
approval
processes
Detect emerging
risks not observed
in the clinic
Identify key areas of
surveillance
Understand how to tailor
standards to specific risks
Find best practices in
designing and
implementing REMS
intervention
Comparative drug
safety data across
preclinical, clinical
and post market
Precedent REMS
plans and
regulatory context
Precedent
standards and
regulatory context
for patient and
HCP
communication
plans
Post market
data from
regulatory
documents and
literature
Searchable
FDA/EMA drug
approval
documents,
biomedical
literature and
FDA AERS
22Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
The Elsevier Life Science Solutions (ELSS) Portfolio
• Workflow specific decision tools that
support key use cases and
research outcomes in Life
Sciences
• Working as a portfolio — Evolving
from ‘point solutions’ to tools that
work together to support integrated,
cross-domain workflows
• Using our capabilities to provide
services that address ‘custom’ use
cases, changing how organizations
manage R&D data
Text Mining &
Data Integration
23Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
Embase & Pharmapendium
A single drug search in Embase seamlessly
links to PharmaPendium to deliver:
• Comprehensive information that better
informs a risk management /
pharmacovigilance strategy
• Drug safety information reported
in the literature
• FDA/EMA approval and drug review
reports that provides insights into
historical regulatory precedents
• A direct link to preclinical and clinical
observations and reported adverse
events (AERs) to better monitor and
anticipate safety risks
23
Improving biomedical literature search and risk monitoring
24Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
QUOSA
A combination of software and services that
allows customers to reduce risk, remain
compliant and ensure that workgroups have
the latest scientific literature
•Pharmacovigilance — Monitor literature for
adverse drug events
•Medical Affairs — Collect and share the
latest information for Key Opinion Leaders
and healthcare providers
•Medical Devices — Conduct post-market
surveillance for adverse events reporting and
pre-market approval
•Information Management — Collect,
organize and share key documents for your
stakeholders
24
Improving biomedical literature search and risk monitoring
25Minimizing Risk in Pharmacovigilance |
www.elsevier.com/pharmacovigilance
To Summarize…
• Key trends in Pharmacovigilance include:
–greater standardization of processes and data management
–implementation of proactive risk management
–reduction/management of costs
• Elsevier provides the capabilities necessary for Pharmacovigilance and Drug
Safety groups to be more efficient, stay compliant and mitigate risk
–Automated literature monitoring — avoid missing critical information
–Fast and effective literature triage — save time with better article
pipeline management
–Seamless integration with existing case reporting systems — connect
literature to a broader ecosystem
–Unique access to regulatory data — manage the risk of late stage failure
by making more informed risk management/mitigation decisions
Thank you!
www.elsevier.com/pharmacovigilance

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Minimizing Risk in Pharmacovigilance

  • 1. 1Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Minimizing Risk in Pharmacovigilance www.elsevier.com/pharmacovigilance
  • 3. 3Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Challenge • Development of a common platform across different geographic locations, functional groups, product lines. • Integration of data — a single database to include data across the entire product life cycle (pre and post-market). Challenge: multiple databases may contain similar information but are not linked/linkable to each other. • Implementation of work flow management technology — identify and distribute information to stakeholders according to a predetermined set of rules. Ensure only the appropriate employees receive the data required to inform the decisions they are authorized to make. How to Standardize Processes and Data Management “We don’t view drug safety from a postmarket or premarket perspective but, rather, as a continuum from the time the compound is identified and the time of animal studies on through when companies are hoping to get approval...” Alan Goldhammer, Associate vice president of regulatory affairs for the Pharmaceutical Research and Manufacturers of America (PhRMA) (source: PWC report)
  • 4. 4Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Challenge Implement Proactive Risk Management • Development of a risk management action plan Establish risk scoring and mitigation processes to evaluate external risk factors (regulatory, reputation, product liability) and internal (portfolio, strategic and financial risk). • Dashboard Summarize safety information across the product portfolio in real time. Identify the types of data that should/should not be used in drug safety decision making. • Implementation of data mining techniques Assess the patterns, time trends and events associated with drug- drug interactions.
  • 5. 5Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Challenge: Run PV Operations Cost Effectively • Growing amount of data causes important safety signals to be missed — how to deal with the data storm? Embase, October 2014 • Savings from outsourcing PV operations can be negated with costs from the manual review of records. Tools that better target relevant literature can prevent this. • Signal identification must not be lost due to segmentation of the analysis by different parties. 1975 1980 1985 1990 1995 2000 2005 2010 2011 2012 2013 0 5 10 15 20 25 30 Millions of Records Increasing number of records added to Embase
  • 6. 6Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Once Articles Are Captured, the Review and Triage Process Has Additional Challenges Too much time is wasted looking at the same article multiple times Challenges Needs Some outsourced systems are unable to meet the rigid regulatory demands Existing in-house systems are becoming outdated, and maintenance & replacement costs are high Need to be sure all articles are captured and reviewed A coordinated workflow to manage the article pipeline Capture metrics behind article reviews in case of audits
  • 7. 7Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Elsevier Can Create a Unifying Structure that Can Be Used to Promote Best Practices Adapted from Zhengwu Lu, Information technology in pharmacovigilance: Benefits, challenges, and future directions from industry perspectives, Drug Health Patient Saf. 2009; 1: 35–45. Tested and Proven Cloud-Based Tools Set up a coordinated workflow to manage the article pipeline Be sure all articles are captured and reviewed Capture metrics behind article reviews in case of audits Ensure accessibility of safety information Organizational Alignment Operations Management Data Management Risk Management
  • 8. 8Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Cloud Based Solution Pharma company was using a combination of a cloud-based solution and SharePoint to monitor literature for adverse events. Pharma company reviewed captured articles and submitted serious cases to regulatory agencies However, not all articles were appearing in SharePoint, and important articles are missed, resulting in a warning from the regulatory agency Regulatory Agency Issues Warning Pharma Company What Can Go Wrong in Large Pharma A Gap in Literature Monitoring Published Literature Literature Monitoring System
  • 9. 9Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Published Literature Literature Monitoring System Elsevier implemented a complex search strategy into its biomedical literature database [Embase] to ensure that relevant information was captured. Elsevier also provided a tool that alerted the customer about unread articles to make sure all materials were reviewed. Seamless Literature Triage Largest Journal and Conference Coverage + Specialist-Developed Search Strategy Regulatory Agency ICSRs Pharma Company What Can Go Wrong in Large Pharma A Gap in Literature Monitoring
  • 10. 10Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Additional Sub-optimal Processes in Pharma Companies… • Under-staffed literature screening teams – Some global pharma companies have as few as one person screening literature for adverse events. – This is a tremendous workload that results in too much time being taken to discover serious ADRs, or possibly missing them entirely. • Use of Reference Management tools to manage literature – Reference Management tools do not allow searching of full text articles. – This results in a highly manual process that requires additional time to read the article for mentions of adverse events.
  • 11. Addressing the Challenges in Pharmacovigilance
  • 12. 12Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Our Mission in Pharmacovigilance Elsevier provides the capabilities necessary for Pharmacovigilance and Drug Safety groups to be: more efficient stay compliant and mitigate risk
  • 13. 13Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance 1. Avoid missing critical information 2. Save time with better article pipeline management 3. Connect literature to broader ecosystem 4. Manage risk of late-stage failure Output Analysis Regulatory Data for Risk Mitigation Strategies Case Input Automated Literature Monitoring Case Processing Automated Literature Triage Case Output Integration with case reporting systems and audit trails Our Framework
  • 14. 14Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Case Input: Literature Monitoring Key Challenges Output Analysis Regulatory Data for Risk Mitigation Strategies Case Input Automated Literature Monitoring Case Processing Automated Literature Triage Case Output Integration with case reporting systems and audit trails • How thorough is your existing literature monitoring process? Are you at risk of missing articles that report AEs? • Are you wasting valuable time sifting through duplicate articles? • Are you increasing cost by purchasing the full-text articles multiple times?
  • 15. 15Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Centralized Document Repository for Drug Safety Published Literature Avoid missing critical information Case Input: Literature Monitoring More confidently find adverse events in the literature Find information not available in other tools Increase the likelihood of early signal detection Save time reviewing, reduce the risk of double-counting Most comprehensive journal coverage and indexing available Most comprehensive coverage of conference proceedings Custom development of complex searches Automatic deduplication of articles
  • 16. 16Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Case Processing: Literature Triage • Are the appropriate employees receiving the required data to inform the decisions they are authorized to make? • Are you working with multiple databases that contain similar information but are not linked/linkable to each other? • Are you wasting valuable time sifting through duplicate articles? • Are you increasing cost by purchasing the full-text articles multiple times? Key Challenges Output Analysis Regulatory Data for Risk Mitigation Strategies Case Input Automated Literature Monitoring Case Processing Automated Literature Triage Case Output Integration with case reporting systems and audit trails
  • 17. 17Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Case Processing: Literature Triage Regulatory Reports Centralized Document Repository Save time with better article pipeline management Seamless centralized triage tool Text mining of articles Alerts about unread articles Triage articles faster Find AEs faster by reviewing the most relevant articles Be more confident that information isn’t missed
  • 18. 18Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Case Output: Integration With Case Reporting System • Can you effortlessly export your data to existing analysis/reporting tools? • Are you wasting valuable resources on manual processing of data? • In the event of an audit, will you be able to clearly demonstrate that the review process was done correctly? Key Challenges Output Analysis Regulatory Data for Risk Mitigation Strategies Case Input Automated Literature Monitoring Case Processing Automated Literature Triage Case Output Integration with case reporting systems and audit trails
  • 19. 19Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Case Output: Integration With Case Reporting System Connect literature process to the broader ecosystem Pharmacovigil ance Signal Detection and Reporting Ecosystem Centralized Document Repository Review process tracked for reporting Literature pre-formatted for case reports Automated exporting of data to case management systems Be better prepared for audits Save time and effort Reduce manual steps when integrating triage results
  • 20. 20Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Output Analysis: Risk Mitigation Key Challenges Output Analysis Regulatory Data for Risk Mitigation Strategies Case Input Automated Literature Monitoring Case Processing Automated Literature Triage Case Output Integration with case reporting systems and audit trails • How can we better manage risk? • Are we gathering all available safety/AE data about a drug/ class of drugs? • Are we leveraging best practices from precedent preclinical/ clinical studies? • Have all the potential and unanticipated risks been captured?
  • 21. 21Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Output Analysis: Risk Mitigation Make better informed risk management and mitigation decisions Reduce regulatory cycling Improve REMS planning and approval processes Detect emerging risks not observed in the clinic Identify key areas of surveillance Understand how to tailor standards to specific risks Find best practices in designing and implementing REMS intervention Comparative drug safety data across preclinical, clinical and post market Precedent REMS plans and regulatory context Precedent standards and regulatory context for patient and HCP communication plans Post market data from regulatory documents and literature Searchable FDA/EMA drug approval documents, biomedical literature and FDA AERS
  • 22. 22Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance The Elsevier Life Science Solutions (ELSS) Portfolio • Workflow specific decision tools that support key use cases and research outcomes in Life Sciences • Working as a portfolio — Evolving from ‘point solutions’ to tools that work together to support integrated, cross-domain workflows • Using our capabilities to provide services that address ‘custom’ use cases, changing how organizations manage R&D data Text Mining & Data Integration
  • 23. 23Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance Embase & Pharmapendium A single drug search in Embase seamlessly links to PharmaPendium to deliver: • Comprehensive information that better informs a risk management / pharmacovigilance strategy • Drug safety information reported in the literature • FDA/EMA approval and drug review reports that provides insights into historical regulatory precedents • A direct link to preclinical and clinical observations and reported adverse events (AERs) to better monitor and anticipate safety risks 23 Improving biomedical literature search and risk monitoring
  • 24. 24Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance QUOSA A combination of software and services that allows customers to reduce risk, remain compliant and ensure that workgroups have the latest scientific literature •Pharmacovigilance — Monitor literature for adverse drug events •Medical Affairs — Collect and share the latest information for Key Opinion Leaders and healthcare providers •Medical Devices — Conduct post-market surveillance for adverse events reporting and pre-market approval •Information Management — Collect, organize and share key documents for your stakeholders 24 Improving biomedical literature search and risk monitoring
  • 25. 25Minimizing Risk in Pharmacovigilance | www.elsevier.com/pharmacovigilance To Summarize… • Key trends in Pharmacovigilance include: –greater standardization of processes and data management –implementation of proactive risk management –reduction/management of costs • Elsevier provides the capabilities necessary for Pharmacovigilance and Drug Safety groups to be more efficient, stay compliant and mitigate risk –Automated literature monitoring — avoid missing critical information –Fast and effective literature triage — save time with better article pipeline management –Seamless integration with existing case reporting systems — connect literature to a broader ecosystem –Unique access to regulatory data — manage the risk of late stage failure by making more informed risk management/mitigation decisions