Global Health Security Summary Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance 2 October 2013 The views expressed in this document are the sole responsibility of the author(s) and do not necessarily reflect the view of Chatham House, its staff, associates or Council. Chatham House is independent and owes no allegiance to any government or to any political body. It does not take institutional positions on policy issues. This document is issued on the understanding that if any extract is used, the author(s)/ speaker(s) and Chatham House should be credited, preferably with the date of the publication or details of the event. Where this document refers to or reports statements made by speakers at an event every effort has been made to provide a fair representation of their views and opinions, but the ultimate responsibility for accuracy lies with this document’s author(s). The published text of speeches and presentations may differ from delivery. Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance INTRODUCTION This was the first of a series of meetings organized by the Centre on Global Health Security at Chatham House to address the problem of antimicrobial resistance. A series of roundtables and a conference are envisaged to address, in particular, the following key issues: What new efforts by governments and stakeholders in the developing and developed world are needed for global antimicrobial conservation? What obstacles constrain effective action? How can they be addressed? What are the most efficient ways of stimulating new drug development for long-term sustainability? What has been tried? What is most likely to work? What does this mean for government policies? How do we address antibiotic use in the food and agriculture sector (including fisheries)? How do we promote cross-sectoral collaboration? What are the obstacles? How can they be overcome? The underlying purpose of these consultations is to influence actions by governments and policymakers in global and multilateral fora such as the World Health Organization (WHO), the World Organization for Animal Health (OIE), the Food and Agriculture Organization (FAO) and the Transatlantic Taskforce on Antimicrobial Resistance (TATFAR), and in national governments (e.g. through policies to promote long-term sustainability). Possible outcomes include contributing to the content of agreements in the WHO, the OIE, the FAO and other organizations on global actions to combat resistance and recommendations to national governments on stewardship and incentives for drug development. This first roundtable was convened to address the second point above. It brought together a broad range of senior participants from industry, regulators, research organizations and civil society. The meeting was chaired by John-Arne Røttingen of the Norwegian Institute of Public Health and Harvard University. Participants are listed in Annex 1. CONTEXT As resistance to antibiotics continues to grow, there is a well-recognized misalignment between the incentives for the development of new antibiotics and the clinical need for them. The returns from investment in antibiotic research and development (R&D) are perceived as too small. The number of large multinational companies researching antibiotics has fallen drastically in the last 20 years and few new antibiotics have been developed. Apart from the poor economic return, there are particular scientific challenges in developing antibiotics. And companies complain that regulatory requirements are uncoordinated and disproportionate, and correspondingly costly, which compounds the problem of inadequate returns. In terms of use, there are various clinical issues that militate against using antibiotics in a rational way (i.e. to treat an identified bacterial disease with the right antibiotic at the right dose). The psychology of the patient-clinician relationship, inadequate access to speedy diagnostic tools, overthe-counter sales, inappropriate use of antibiotics for viral illnesses and sub-standard drugs with too little active ingredient are among the reasons why antibiotic resistance develops faster than it should. Moreover, the financial incentives for providers or payers often do not discourage inappropriate use and may in fact instead encourage misuse (such as salaries based on number of prescriptions filled). Higher prices have been suggested not just as a way to incentivize research but also to discourage unnecessary use. However, higher prices could put antibiotics out of reach of poorer populations and increase the costs to health systems in higher-income countries. This summary was compiled by Charles Clift, Senior Consulting Fellow at the Centre on Global Health Security at Chatham House www.chathamhouse.org 2 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance The purpose of the roundtable was to contribute to the drafting of a roadmap outlining the steps necessary to promote appropriate incentives for development and use in national and international policy circles. SESSION 1: INTRODUCTION AND BACKGROUND Kevin Outterson introduced his background paper: ‘Antibiotic Delinkage Models: New Business Models to Prevent an Antibiotic Apocalypse’. This paper describes the various proposals that have been made to stimulate new antibiotic development based on delinking the return to producers from the volume of their sales. This would mean that companies would not be incentivized to maximize sales in ways that could accelerate the development of resistance. A summary of the various proposals is at Annex 2. In discussion the importance of improving diagnostics to foster appropriate use was emphasized by several participants. In addition, improved diagnostics could significantly lower the costs of clinical trials by allowing accurate targeting of patients for inclusion. Ways to stimulate diagnostic development, such as prizes for instance, therefore needed to be considered. Several participants took issue with the idea in the paper that only a few new ‘high quality’ antibiotics should be prioritized, rather than incentivizing a larger number of so-called ‘follow-on’ or ‘me too’ drugs. It was contended that this misunderstood the R&D process, which is difficult to focus in the way proposed; and that follow-on innovation was very important in improving the quality of ‘first in class’ drugs and for market competition. For example, there had been four generations of cephalosporins – with each generation addressing a new unmet need. Additionally, innovators face uncertainty until late stage clinical trials regarding the potential impact of a new antibiotic. There have also been instances where unsuccessful antibiotics (such as vancomycin) are later found to be more valuable due to new public health threats. By limiting the reward to only game-changing antibiotics, there was concern that this would limit the overall amount of R&D investment. But there was general agreement that rewards should be larger for those antibiotics that have the largest potential impact or add to the resistance profile of products available. SESSION 2: FOCUS ON INCENTIVES FOR DEVELOPMENT DELINKED FROM VOLUME OF SALES Initial presentations focused on three possible delinkage models. One idea was that, up to the end of Phase 2, the funding would be worked via a public/private partnership, not dissimilar from what often happens now (e.g. through the Innovative Medicines Initiative (IMI) or the US Biomedical Advanced Research and Development Authority (BARDA)). Then, at the Phase 3 start decision there would be a contract with the purchaser (usually a government). That would be a long-term contract of up to 20 years. Under that contract, the manufacturer would commit to supply as little or as much of that antibiotic as the purchaser required, based on public health considerations. The manufacturer would not be involved in the distribution of that antibiotic, its promotion or education about it. These would be entirely up to the purchaser. Purchasers could then utilize incentives to reward appropriate use by providers and prescribers, including where providers could pay a variable fee for antibiotics (or a class) depending on their record of appropriate use (or infection rates in hospitals). Another presentation focused on the Rewarding Antibiotic Development and Responsible Stewardship (RADARS) model. In this model (applicable to the US health care system), public and private payers reimburse hospitals for the incremental costs of qualified infectious disease products (for example as defined in the US Generating Antibiotic Incentives Now (GAIN) Act) above and beyond existing diagnosis-related group payments (DRGs). Payments would only be made if drugs are prescribed in accordance with a preapproved stewardship programme. Guaranteed minimum payments for a period of five years would be paid to the innovator pharmaceutical company irrespective of the volume sold. During this period, promotion by the pharmaceutical company would be prohibited. After five years the guaranteed minimum payments would cease but the www.chathamhouse.org 3 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance incremental payments would continue for an additional five years to further reward innovators who produce particularly innovative products and/or accurately address the most troubling resistance trends. Another participant set out a proposal for global model that treated new antibiotics as global public goods requiring special treatment (see Figure 1). Under this initiative a sizeable fund would be established at a global level that would manage the whole spectrum of activities from discovery to the market. The fund would offer a variety of incentives for innovation, from grants to prizes tied to development milestones or end products and contract manufacturing with the private sector on a cost-plus basis. But against this the intellectual property would be held either by a suitable body such as the WHO, the Medicines Patent Pool, or similar. This needs to happen at the UN, or in any case, global level because the intellectual property would need to extend to all countries of the world and require a licence in perpetuity. The idea would also be to fully harness the innovative capacity of middle income countries and to provide medicines of assured quality through a new regulatory mechanism. Figure 1. Proposed Initiative: New Antibiotics as Global Public Goods. Other participants outlined the model of public-private partnership utilized by the IMI with member companies of the European Federation of Pharmaceutical Industries and Associations (EFPIA), and emphasized the need for new incentive structures both in drug development and use. The role of small and medium enterprises (SMEs) as important innovators should not be ignored in this context. The use of the European Commission’s SME funding instruments has demonstrated that it is possible to mobilize SMEs in this area of research. Issues raised in discussion included the following. Delinkage could provide a promising means to increase R&D in antibiotics by removing the disincentives inherent in the limited market prospects for new antibiotics. But there was also a realization that to implement delinkage models will require significant stakeholder input and effort, ensuring long-term coordination. From the innovator perspective common characteristics that were important for any delinkage model were the magnitude of the reward for innovation (which needed to be in line with other therapeutic areas) and its predictability. Delinkage was not just a new way of rewarding www.chathamhouse.org 4 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance R&D but needed to offer returns sufficient to offset the risks inherent in the R&D process. Offering a generous return might be a good investment in terms of costs saved down the line, akin to an insurance policy against having no effective antibiotics in a health crisis. Application of delinkage to promote appropriate use raised a number of issues. A key one was price. In developed countries it might be possible to charge a very high price to deter inappropriate use without burdening the patient but this would not, in most participants’ opinion, be appropriate in developing country settings where most people met costs from their own pocket. At the same time price as a barrier is probably less important in a developed country where use can be more properly regulated and enforced, whereas price as barrier was seen by some as a potential mechanism to avoid inappropriate use in private sector providers and from over the counter sales. Ensuring access in low-and-middle-income countries (LMICs) to both existing and new antibiotics required special attention. It seemed likely that far more people died in developing countries through lack of access to antibiotics than as a result of resistance. The cost of goods for novel hospital intravenous antibiotics might be as much as $50–100 per day, which was not affordable in LMICs. LMICs might benefit from the spill-over effects, meaning that some or many high income economies will be willing to finance the development of novel antibiotics and LMICs will benefit from the novel antibiotics at accessible prices. The use of public-private partnerships on the lines of the IMI or BARDA, which enable risk-sharing between private and public sectors, should be considered as one model. The experience from the IMI so far had demonstrated the ability to attract cofunding from companies, including the engagement of new companies. It was noted by some that these should not be considered as subsidies if they involved significant investment by companies that they otherwise would not have made. The possibility of models similar to orphan drug legislation in the United States and EU, which had been successful in attracting company attention to drugs for smaller patient populations, was discussed. But it was questioned by some whether this model, often involving (very) high prices for the specified indication, was cost-effective and appropriate in the case of antibiotics. Drug company pay-for-performance incentives (where innovators are reimbursed for the actual impact of the new antibiotic or diminished resistance) were deemed too risky since innovators are often uncertain until late stage trials of the real potential of a new antibiotic. By contrast, pay-for-performance between payers and providers/prescribers is a more viable approach. Surveillance of hospital or community behaviour and resistance levels was deemed to be a task of the payers and the public health system and should be independent of the company innovation process. www.chathamhouse.org 5 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance SESSION 3: INTEGRATING INCENTIVES FOR DEVELOPMENT WITH INCENTIVES FOR CONSERVATION One presenter suggested a number of feasible performance measures that could aid conservation. For instance whether or not antibiotics were prescribed using an algorithm rather than guesswork, or what percentage of prescriptions was based on a diagnostic test. Encouraging more diversity in antibiotic use would also be positive – gonorrhoea has become very difficult to treat because the same drug was used repeatedly. The notion could also be applied to encouraging diversity in R&D programmes. There could also be rewards to producers, for example for working with diagnostic developers on combination products. A second presenter argued that delinkage should not be seen as a cure-all. The causes of inappropriate use were many and setting clear rules and guidelines on company behaviour in respect of information and marketing was important but only part of the picture. There needed to be a clear set of rules for all the players, both producers and providers. The presenter also emphasized that developers need ‘good prices, accelerated access and support from regulators’. He saw health technology assessment practices emphasizing cost-effectiveness and value for money (particularly in Europe) as a threat to development, given that drugs were approved simply on the principle of non-inferiority. A third presenter noted that there was already a lot of money going into push funding. The issue was therefore the right mix of push and pull funding to develop new products and also ensure the right conditions for both conservation and access. In addition the effectiveness of R&D could be enhanced by greater cooperation in terms of shared platforms and more collaborative working. In discussion the following issues were raised. The extent to which incentives for conservation and development could be integrated. Could the rewards to companies be determined by the extent of appropriate use of their products, rather as rewards to companies in some current schemes (‘managed entry’) were predicated on the demonstrated effectiveness of their products in use? Probably not but delinkage removed the incentive for aggressive marketing of products. In the same vein using pricing to incentivize appropriate use thought by many not to be the right approach, particularly in developing countries. Universal solutions, applicable across diverse countries, would be difficult. In a delinked scheme, at what point in the development cycle would a contract with a company be made, e.g. before or after marketing approval? The return needed to be attractive to attract private investment in development, but that needed to be on the basis that investors shared the scientific and market risk equitably. Similarly the rewards on offer needed to be related to the likely overall health impact. Marketing and promotion was very costly so a system that removed that cost for a product was in itself an incentive for R&D as well as a contribution to decreasing inappropriate use. The only reliable data on direct health impact was generated in Phase 3 – once on the market the randomness of the data was lost. And a new antibiotic would almost certainly look bad if principally used with very sick patients as a last resort. It was noted that the discussion focused on hospital use, but it was also contended that in reality most consumption and the development of resistance probably occurred elsewhere. This included also use in the food and agriculture sector. There was much that was not fully understood about what was driving resistance. The possibility of companies providing sales data free to public health authorities was raised. By this means any suspected overconsumption could be monitored. The potential value of combinations of antibiotics in combating the development of resistance was considered. There were particularly difficult issues in their development www.chathamhouse.org 6 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance for antibiotics, including demonstrating their impact on the development of resistance. On the other hand experimenting with different combinations of existing drugs could be a means to extend their useful life, as well as potentially increasing efficacy. But the regulatory system was predicated on demonstrating safety and efficacy, not the potential impact on resistance development. The latter regulatory approach has not been fully explored and could present some challenges. The need for regulatory harmonisation was re-emphasized as a means of reducing the cost of obtaining marketing approval in multiple territories with differing requirements for approval. SESSION 4: ELEMENTS OF A ROADMAP The first presenter attempted to summarize the key issues raised. Use in food and agriculture had been very briefly alluded to but the implications of antibiotics being used far more widely than that needed to be taken into account. Solutions in high- and low-income countries were likely to be very different with respect to the priorities for maintaining access and conservation. The importance of diagnostic development in conjunction with new antibiotic development had been emphasized. Perhaps a separate but linked roadmap was required for diagnostics. The diversity of antibiotic use policies, even from hospital to hospital in the same country, had been highlighted – so global guidelines on use would be hugely challenging, but international guidelines that can be nationally and locally adapted may be appropriate. The focus in the discussion had been on incentives for the private sector but incentives for academic and public sector researchers were also important. The diversity of the different actors and their different motivations needed to be considered. The view of antibiotics as global public goods and a possible global fund was brought up as an interesting possibility. It was also imperative to engage emerging economies. For that reason a UN initiative might be appropriate. As regards incentives for conservation and use, key issues would be measurability and what can be incentivized. Rules needed to be devised governing both the behaviour of companies as well as users of the product. The second presenter, focusing on LMICs, noted, first, that antibiotics were introduced in highincome countries when infectious disease levels had already declined as a result of improvements in living conditions. By contrast, in LMICs antibiotics were currently being used as a stop-gap measure in the absence of sustained improvements in living conditions and general hygiene and infection control. The fact that antibiotics were being used to the extent they were arose from multiple failures in prevention. Reducing the demand for antibiotics therefore required attention to improvements in water, sanitation and the other determinants of high levels of infection, as well as more use of vaccination. Second, there were huge disparities in access in developing countries, which had implications for pricing. The presenter argued that there should be affordable access to the most commonly used antibiotics, but other antibiotics (e.g. daptomycin) could be rationed through price outside hospital settings. Third, the issue of agricultural use and the development of cross-resistance was particularly important in developing countries. Fourth, the innovative potential of emerging economies should be mobilized. The public and private sectors in developing countries needed to be brought into a global strategy to tackle resistance. Fifth, in countries associated with the Global Antibiotic Resistance Project (GARP), there was now much greater interest in tackling resistance. The time was ripe to involve them in the global effort. The third presenter, focusing on developed countries, thought that new models should be applied in the first instance in the United States and Europe. Note needed to be taken of successful models such as for orphan drugs and product development partnerships for neglected diseases, and the measures taken to accelerate adoption in developing countries (e.g. through GAVI and the AMC mechanism). Was more push-type funding (e.g. beyond BARDA and the IMI) required? As regards delinkage models, a five-year guaranteed payment might be long enough to provide an additional incentive for companies, but short enough for the payer not to be locked into an arrangement that turned out to have little value. A paying model could be similar to the Patient-Centred Outcome Research Institute (PCORI) in the United States, which is funded by a levy on each insured person. The possible relevance of orphan www.chathamhouse.org 7 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance drug-type exclusivities in a delinkage model needed further exploration. The outcome of the previous session seemed to confirm that companies had limited ability to directly affect stewardship other than through restrained marketing. These issues should be considered as part of a wider structure centred on the payer-provider relationship. In discussion some themes were reiterated. The issue of the huge variation of practices and guidance on antibiotic use between prescribers was reiterated. Even so, Sweden, for instance, had succeeded in reducing antibiotic use in children by 60 per cent. The other issue was the unrealism of pursuing an R&D strategy that would result in just a few ‘high quality’ drugs. It was asserted that drug development did not work like this. Discussion centred on preparing a summary of general principles that might govern new business models for conservation and use. These included the desirability of an integrated approach, encouraging delinkage and better conservation models, taking account of the marked differences in what might be required in low and high income countries (see Annex 3). These provoked much debate and it was clear that focusing on the details of particular schemes elicited a variety of responses that reflected differences in the interests and ideology of stakeholders, as well as the complexity of the issues that were being addressed. However, a majority of participants agreed on the need to move forward with designing and assessing ‘Delinkage Plus’ models where innovators/pharmaceutical companies are rewarded for the innovation and R&D investments through predictable mechanisms and not incentivized by price levels and volumes, and where purchasers/payers are responsible for suitable conservation strategies and appropriate regulations, guidance and incentives for providers and prescribers. www.chathamhouse.org 8 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance ANNEX 1: PARTICIPANTS Christine Årdal Norwegian Institute of Public Health Brendan Barnes EFPIA Esteban Burrone Medicines Patent Pool Daniel Burgess Rempex Pharma Otto Cars ReAct Marco Cavaleri EMA Charles Clift Centre on Global Health Security Stefan Elbe Sussex University Ed Godber H-Labs David Heymann, Centre on Global Health Security Andrew Jack Financial Times Marie-Paule Kieny WHO Ramanan Laxminarayan Public Health Foundation of India Rohit Malpani MSF Line Matthiessen European Commission Kevin Outterson Boston University David Payne GSK Laura Piddock Antibiotic Action, University of Birmingham Sadie Regmi University of Manchester John Rex AstraZeneca John-Arne Røttingen Norwegian Institute of Public Health Adrian Towse Office of Health Economics Patrick Vink Cubist Pharmaceuticals Anna Zorzet ReAct www.chathamhouse.org 9 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance ANNEX 2: DIFFERENT DELINKAGE MODELS Delinkage Models Model Description Advantages Problems Patents Owned By Payer Licenses Payers buy an annual license to have access to the antibiotic; actual antibiotics are delivered at marginal cost; companies retain the patent Full delinkage possible; competitive pricing if multiple payers are in the market; government participation not required Higher transaction costs (annual contracts required between each payer and each manufacturer); private payers will not want to increase overall antibiotic reimbursement; coordination will be difficult Private RADARS Payers top-up the hospital DRG for innovative antibiotic; government pays company significant prizes, reduced by company sales receipts; net effect could be full delinkage if the guaranteed payment is large Increased certainty for companies (existing reimbursement is retained should the prize fail to materialize); conditions increased reimbursement on effective stewardship Hospital-based and US-centric Private GSK Fully delinked; predictable revenue stream. Long term contract with purchaser at Phase 3 start. Incentivizes new antibiotic innovation with appropriate use. Manufacturer not involved in distribution /promotion and will provide as little or as much as purchaser needs. Requires risk and significant financial commitment by purchaser Private Patent Buy-out Prize Funds Purchase of national patent rights by a government; actual antibiotics are provided by the government; could also be voluntary Full delinkage; one transaction per molecule per country; government can manage the molecule for long-term public health Difficult to negotiate appropriate price; political risk Public Strategic Antibiotic Reserve (SAR)1 For particularly important molecules that are not needed yet, a patent buyout or multi-year license to keep the drug off the market until needed clinically Saves very important molecules for a rainy day; will be rarely used Akin to paying farmers not to farm (Conservation Reserve Programme); pricing will be large and difficult to negotiate Public Antibiotic Health Impact Fund (AHIF)2 Governments create a fund that will pay for the actual health impact of the antibiotic including stewardship; company participation is entirely voluntary Pays for human health impact on a global basis; companies retain their patents; AHIF provides a nexus for coordination Requires significant up-front financial commitment from governments; measurement of the relative health impact will have significant financial impact for the companies Private 1 Kesselheim, A.S. and Outterson, K., ‘Fighting Antibiotic Resistance: Marrying New Financial Incentives to Meeting Public Health Goals’, Health Affairs, 29 (9), 2010; Kesselheim, A.S. and Outterson, K., ‘Improving Antibiotic Markets for Long Term Sustainability’, Yale Journal of Health Policy, Law and Ethics, 11 (1), 2011. 2 Outterson, K., Pogge, T. and Hollis, A., ‘Combatting Antibiotic Resistance Through the Health Impact Fund’, in Cohen, G.I. (ed.), The Globalization of Health Care: Legal and Ethical Issues (Oxford University Press, 2013). www.chathamhouse.org 10 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance Hybrid Models Model Description Advantages Problems Patents Owned By P4P Keeps existing reimbursement system intact; company receives a very significant top-up payment for achieving defined quality goals relating to appropriate use and resistance Easier startup; can be contractual or by statute; extension of existing ‘pay for performance’ initiatives; can directly support hospital infection control Not delinkage, but linkage with a quality payment that may fail to address underlying problems; will need to be an order of magnitude larger than existing quality incentives in order to attract new capital to the sector; companies may not want stewardship responsibilities Private Conditional Grants Push funding provides non-dilutive capital, conditioned on advance agreement to meet stewardship goals Piggybacks stewardship on government grants (IMI, NIH, BARDA) Increases company uncertainly about revenue stream unless the financial terms and commitments are clear at time of grant Private LPAD Plus LPAD with stewardship commitments, marginal cost sales & a significant prize Similar to prize funds Similar problems to conditional grants and prizes Private The various models can also be arranged based on the ownership of the intellectual property rights (IPRs). IPR Ownership in Antibiotic Delinkage and Hybrid Models Delinkage Hybrid Private IPR RADARS; Payer Licenses; GSK; AHIF P4P; Conditional Grants; LPAD Plus Buy-out by governments/payers Patent Buy-out Prize Funds; SAR www.chathamhouse.org 11 Aligning Incentives for Antibiotic Development and Use with Public Health Needs: First Roundtable on Antimicrobial Resistance ANNEX 3 1. General principles Goal – lowest achievable clinical failure rate To do this we need an integrated approach: Health-needs (including BOD) driven innovation Stewardship balanced with access Infection control and surveillance Public awareness (visibility of ABR and usefulness of diagnostics) Greater stimulation for innovation (in antibiotics, diagnostics, vaccines, delivery, etc.) with delinkage 2. Delinkage components Delink revenues from sales volumes Improve total innovation incentives, including predictability, for antibiotics Encourage long-term co-ordination by stakeholders Preserve access without regard to ability to pay 3. Conservation models Business models for diagnostics (including companion) Improved and measurable practices for use Public awareness Delinkage models for industry (where there is no promotion) Payer/provider incentive systems for improved use (taking account of differing national health systems) Business models for combination therapies, conservation and infection control 4. Models for high-income countries Delinkage Plus (business models coupled with conservation strategies, including follow-ons) Reluctance to require: Payment for health outcomes/institutional behavior Payment for diminishing resistance 5. Models for LMICs Positive spillovers (from HIC R&D) Products should be priced for accessibility but how to regulate use of new antibiotics? Access provisions built into delinkage models More work is needed here www.chathamhouse.org 12