Archive | September 2017

Is Regulatory Platform as a Service (RPaaS) close to becoming a reality?

For as long as I have known the regulatory tools market space, it has been much more fragmented that it’s peer business functions such as Clinical and Safety. If you take the Regulatory Affairs value chain from Strategy / Submission Planning all the way through Archival, many sponsors use different products / platforms / tools for different functions. Typically you would see a mix of Excel/Spreadsheets to established tools for regulatory document & content management as well as publishing, submissions and archival. This is in contrast with Clinical and Regulatory space where you would typically find 2, if not 3 platforms that can cater to a major portion of the value chain. More than Clinical I would say Safety is probably a better in example to highlight this situation where you’d most likely find 2 products ruling the roost in Oracle Argus and Aris Global’s ARISg (LifeSphere Safety).

This situation in Safety platforms space was not achieved overnight but rather over 5 – 7 years through market consolidation. Oracle essentially bought off all the other reputable and competing tools in the market leaving only ARISg to compete with. Off late there has been a similar trend in the regulatory market with some of the niche tool providers like Octagon, ISI etc. being acquired by larger players like PAREXEL, Accenture, and CSC. While this has resulted in consolidation of the tools/platforms under a smaller set of vendors, these tools still need lot of integration to make them work together. There are vendors like Veeva (Veeva Vault RIM) that have taken a different approach to this problem and have reached a point where they can claim more cohesive platform that integrates out-of-the-box, and as is the case with Safety platforms, caters to majority of the functions in Regulatory Affairs value chain. However the jury is still out whether some of these platforms deliver the value they are expected to since the adoption has just begun and long term use is still not proven.

With the advent of Cloud solutions and adoption becoming a reality in Life Sciences R&D, even though it is much slower as opposed to other industries and even departments within Life Sciences for regulatory reasons, platforms on the cloud with coverage across the Regulatory Affairs value chain can get us closer to RPaaS. The reality of budget challenges across many Life Sciences companies is going to force the issue. For Platform vendors like Veeva and Aris Global the key is interest and willingness to invest by their clients. It will not be a win-win proposition unless each party can look forward to cost reduction, productivity improvement, technology currency and regulatory compliance through these platforms.

 

 

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REMS Journey from Inception to Latest FDA Guidance

In lieu of the recent draft guidance issued by FDA on “Providing Regulatory Submissions in Electronic Format — Content of the Risk Evaluation and Mitigation Strategies document Using Structured Product Labeling” earlier this month, I thought of taking a trip down the memory lane to revisit how we got here on REMS.

The following diagram provides a snapshot of the timeline: REMS-Journey

For those keen to understand how REMS documents get converted to SPL elements, you can refer to this presentation on “REMS Standardization via Structured Product Labeling (SPL)” by Adam Kroetsch, Policy and Informatics Advisor, Office of Program and Strategic Analysis,  Center for Drug Evaluation and Research from October 5, 2015.

I have talked about REMS in my past blog posts, specifically about “Implementing FDA REMS ETASU Requirements using a BPM Suite“. Feel free to check it out. I will have more to say on this topic in my future blog posts in relation to impact of the new guidance and how to prepare for it.

Three reasons you should upgrade to Oracle Argus Safety 8.1.x

Oracle Argus Safety is a leading Safety & Pharmacovigilance platform in the market. Oracle has been able to successfully move many sponsors from diverse drug safety platforms it built (Oracle AERS) or acquired (PhaseForwards’ Clintrace and Relsys’ Argus) to Argus Safety, making it their strategic safety platform of the future.

Upgrade to latest version of the platform has always been a challenging task for many sponsors, given the complex nature of configurations, customizations and integration with various clinical, regulatory and safety applications in the R&D ecosystem. Typically it takes anywhere between 1 to 3 years for customers to get onto the new release after the version is available. Of course this time line will change with the amount of changes the new version brings to the table. The impact of change will also determine the duration of the upgrade project/program. This has been the root cause for many customers delaying the upgrades in the past. Not to mention the cost associated with these upgrades.

The latest release, Argus 8.1 addresses new regulatory compliance requirements, functional enhancements and biggest of them all technology platform currency. In my opinion,these three things are key drivers to upgrade to Argus 8.1.x .

Regulatory Compliance Requirements: The new E2B (R3) reporting guidance for transmission of Individual Case Safety Reports based on Health Level-7 (HL7) messaging protocol provides an advantage to capture more data with increased granularity and frequency. ICH E2B(R3) is a mandatory regulatory requirement that all safety organizations need to be compliant with, in future. Different Health Authorities have different milestones / timelines for compliance. At this time it appears that PMDA (Japan) deadline of April 1st 2019 as the most impending one. Also many sponsors have implemented interim solutions to process EMA’s Eudravigilance ICSRs that are available in E2B (R3) format. The interim solutions have to be done away with and what better than meeting this requirement through the core platform. Also, electronic Vaccine Adverse Event Reporting System (eVAERS) and electronic Medical Device Reporting (eMDR) requirements, connected with E2B (R3) and important initiatives for Vaccines and Med Device sponsors are key requirements to be complied with.

Bug Fixes and Functional Enhancements: As with any of the past releases, Oracle has also addressed a lot of requirements pouring in from sponsors to fix some of the existing issues and enhance the platform to meet some new requirements. In 8.x there are over 350 Issues fixed. New Expedited Report Updates adhering regulations are added. There are also various Case Management Updates. There are a bunch of changes specifically targeting Argus J (i.e. Japan). Japan Development Safety Update Report (JDSUR) is enhanced replacement for ‘Clinical Study Periodic Safety Report’ (CSPSR). Also, ability to convert existing CSPSR report to JDSUR on Copying the Existing Report has been added. There are updates to PSR, ReSD, Global Lock and local data locks and local case data locks specifically for Japan.

Technology Platform Currency: Many existing technology platforms that support Argus platform have become outdated in the last few years. This has led to Oracle adopting newer versions of Windows, Oracle Database, OBIEE, Axway Interchange, Oracle B2B (new) etc. Also, some of the legacy technology platforms like Windows 2008/R2 are going out of support, not to mention premium support for Argus 7.x as well. The Technology platform changes themselves should be a big reason for sponsors to consider upgrade to 8.1.x.

More specific details around the bugs/enhancements as well as specific software versions in the technology platform currency can be found in Oracle Argus Safety 8.1 Release Notes.

As always, your feedback and comments are welcome. I would be very interested to hear from consultants and technologists in the trenches, driving the upgrades. Also from sponsors who are considering upgrades in near future (or not) .

P.S: This is my first post after a very long hiatus. But I plan to share my thoughts and opinions more often going forward. Thanks for your support and feedback.

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