Risk minimisation
Selecting, implementing, and evaluating activities
Vicky Dong
Risk Management Plan Evaluation Section, Pharmacovigilance & Special Access Branch
Medicines Regulation Division, TGA
Australian Pharmacovigilance regulatory Requirements and Risk Management Plans Summit
March 2019
How does risk minimisation work?
Risk
minimisation
activities
Reaching the
target
population
(implementation)
Clinical
knowledge Clinical actions
Ultimate Goal
Minimal
occurrence of
ADR
Select, implement, and evaluate risk minimisation activities
March 2019
1
Select additional risk minimisation activities
Select, implement, and evaluate risk minimisation activities
March 2019
2
How does risk minimisation work?
Risk
minimisation
activities
Reaching the
target
population
(implementation)
Clinical
knowledge
Clinical actions
Ultimate Goal
Minimal
occurrence of
ADR
Select, implement, and evaluate risk minimisation activities
March 2019
3
Implement risk additional minimisation activities: reaching
target population
What to consider How to plan
Target population Specific
Layout and content Measurable
Timing and frequency of distribution Attainable
Methods of distribution Relevant
Time-based
Select, implement, and evaluate risk minimisation activities
March 2019
4
Table 4: Australian implementation of additional risk minimisation activities (example)
Record your implementation plan in the ASA
Additional risk minimisation
activity
Target audience Implementation details,
including method (s) of
dissemination
Time-points for and
frequency of dissemination
e.g. health professional guide
and checklist
GPs
pharmacists
Paper copies posted to GPs
and pharmacists on sponsor-
held mailing list
At launch
Mailing list reviewed every 6
months and brochure mailed
to new additions
Repeat mail at 18 months
after launch
e.g. patient guide Patients Paper copies posted to GPs to
provide to patients (initial
mailing of 5 copies); GPs can
re order through sales reps
and medical information.
Electronic copies available
through patient support
program website
At launch
Mailing list reviewed every 6
months and brochure mailed
to new additions.
Repeat mail at 18 months
after launch
Select, implement, and evaluate risk
minimisation activities
March 2019
5
How does risk minimisation work?
Risk
minimisation
activities
Reaching the
target
population
(implementation)
Clinical
knowledge
Clinical actions
Ultimate Goal
Minimal
occurrence of
ADR
Process indicators Outcome indicators
Ultimate Goal
Minimal
occurrence of
ADR
Select, implement, and evaluate risk minimisation activities
March 2019
6
Evaluate additional risk minimisation activities
Select, implement, and evaluate risk minimisation activities
March 2019
7
You hope it works like this…
Risk
minimisation
activities
Reaching the target
population
(implementation)
Clinical
knowledge
Clinical actions
Ultimate Goal
Minimal
occurrence of
ADR
PASS, AE
reporting, PSUR,
other post-
market data
HCP education Material sent to
doctors by email
Survey to test knowledge and action 6
months after the product supply. Target:
to send 100 survey invitations, to receive
≥ 30 responses. Knowledge test: ≥ 90%
pass rate
Select, implement, and evaluate risk minimisation activities
March 2019
8
What if it doesn’t work out as expected…
20 doctors responded to the survey. 19
doctors knew the safety risk, but only 9
knew they needed to conduct regular
monitoring.
Reassess
Risk
minimisation
activities
Reaching the
target
population
(implementation)
Clinical
knowledge
Clinical actions
Ultimate Goal
Minimal
occurrence of
ADR
HCP education
Material sent to
doctors by
emails
Recommendation on regular monitoring
was on page 10 of the 15-page
educational material.
PASS, AE
reporting,
PSURs, other
post-market data
Cut educational
material down to
3 pages, move
monitoring
recommendation
to 1st page
Select, implement, and evaluate risk minimisation activities
March 2019
9
Standard clinical practice
Reassess and adjust
Eventually it works like this…
Risk
minimisation
↓ ADRs from AE
reporting,
PSURs, other
post-market data
Select, implement, and evaluate risk minimisation activities
March 2019
10
Resources
• TGA guidance: Risk management plans for
medicines and biologicals
• TGA guidance: Australian-Specific Annex
template
• TGA adopted EMA Guideline on good
pharmacovigilance practices Module XVI
11
Presentation: Risk Minimisation

Presentation: Risk Minimisation

  • 1.
    Risk minimisation Selecting, implementing,and evaluating activities Vicky Dong Risk Management Plan Evaluation Section, Pharmacovigilance & Special Access Branch Medicines Regulation Division, TGA Australian Pharmacovigilance regulatory Requirements and Risk Management Plans Summit March 2019
  • 2.
    How does riskminimisation work? Risk minimisation activities Reaching the target population (implementation) Clinical knowledge Clinical actions Ultimate Goal Minimal occurrence of ADR Select, implement, and evaluate risk minimisation activities March 2019 1
  • 3.
    Select additional riskminimisation activities Select, implement, and evaluate risk minimisation activities March 2019 2
  • 4.
    How does riskminimisation work? Risk minimisation activities Reaching the target population (implementation) Clinical knowledge Clinical actions Ultimate Goal Minimal occurrence of ADR Select, implement, and evaluate risk minimisation activities March 2019 3
  • 5.
    Implement risk additionalminimisation activities: reaching target population What to consider How to plan Target population Specific Layout and content Measurable Timing and frequency of distribution Attainable Methods of distribution Relevant Time-based Select, implement, and evaluate risk minimisation activities March 2019 4
  • 6.
    Table 4: Australianimplementation of additional risk minimisation activities (example) Record your implementation plan in the ASA Additional risk minimisation activity Target audience Implementation details, including method (s) of dissemination Time-points for and frequency of dissemination e.g. health professional guide and checklist GPs pharmacists Paper copies posted to GPs and pharmacists on sponsor- held mailing list At launch Mailing list reviewed every 6 months and brochure mailed to new additions Repeat mail at 18 months after launch e.g. patient guide Patients Paper copies posted to GPs to provide to patients (initial mailing of 5 copies); GPs can re order through sales reps and medical information. Electronic copies available through patient support program website At launch Mailing list reviewed every 6 months and brochure mailed to new additions. Repeat mail at 18 months after launch Select, implement, and evaluate risk minimisation activities March 2019 5
  • 7.
    How does riskminimisation work? Risk minimisation activities Reaching the target population (implementation) Clinical knowledge Clinical actions Ultimate Goal Minimal occurrence of ADR Process indicators Outcome indicators Ultimate Goal Minimal occurrence of ADR Select, implement, and evaluate risk minimisation activities March 2019 6
  • 8.
    Evaluate additional riskminimisation activities Select, implement, and evaluate risk minimisation activities March 2019 7
  • 9.
    You hope itworks like this… Risk minimisation activities Reaching the target population (implementation) Clinical knowledge Clinical actions Ultimate Goal Minimal occurrence of ADR PASS, AE reporting, PSUR, other post- market data HCP education Material sent to doctors by email Survey to test knowledge and action 6 months after the product supply. Target: to send 100 survey invitations, to receive ≥ 30 responses. Knowledge test: ≥ 90% pass rate Select, implement, and evaluate risk minimisation activities March 2019 8
  • 10.
    What if itdoesn’t work out as expected… 20 doctors responded to the survey. 19 doctors knew the safety risk, but only 9 knew they needed to conduct regular monitoring. Reassess Risk minimisation activities Reaching the target population (implementation) Clinical knowledge Clinical actions Ultimate Goal Minimal occurrence of ADR HCP education Material sent to doctors by emails Recommendation on regular monitoring was on page 10 of the 15-page educational material. PASS, AE reporting, PSURs, other post-market data Cut educational material down to 3 pages, move monitoring recommendation to 1st page Select, implement, and evaluate risk minimisation activities March 2019 9
  • 11.
    Standard clinical practice Reassessand adjust Eventually it works like this… Risk minimisation ↓ ADRs from AE reporting, PSURs, other post-market data Select, implement, and evaluate risk minimisation activities March 2019 10
  • 12.
    Resources • TGA guidance:Risk management plans for medicines and biologicals • TGA guidance: Australian-Specific Annex template • TGA adopted EMA Guideline on good pharmacovigilance practices Module XVI 11