Business Plan for WHO Prequalification Program: Key Findings for PSM Discussion document September 26, 2005 Summary Why a collaboration with the Clinton Foundation? CHAI works with countries and suppliers to ensure access to affordable ARVs. The de-listings in 2004 spurred CHAI to focus on QA and ask the WHO if and how it could help. PSM/QSM identified the need for a business plan to ensure a strong platform for the future of the program. Why are we concerned about 2006-07 needs of the Prequalification Program? The Prequalification Program offers distinctive value to WHO Member States, but its throughput is being challenged by limited resources and the quality of submissions. As demand increases, its ability to meet that demand will be based on its ability to define its needs now. How do we estimate the program’s needs? Models that quantify demand and cost have been built based on data from 2004-2005 and assumptions made with the program team. The resulting projections suggest substantially increased needs but also emphasize the need to maximize resource utilization. How can we contain costs and improve performance? The Prequalification Program can improve performance and reduce its resource needs by following through on non-technical recommendations to increase procedural efficiency and improve the quality of submissions. What do we do now to meet the need? The program faces a need of $12 million in 2006-07, up from $5 million in 2004-05. While it should continue to refine these estimates and evaluate other revenue sources, it should be primarily focused on aggressively pursuing donor governments with internal WHO endorsement. 1 Summary Why a collaboration with the Clinton Foundation? CHAI works with countries and suppliers to ensure access to affordable ARVs. The de-listings in 2004 spurred CHAI to focus on QA and ask the WHO if and how it could help. PSM/QSM identified the need for a business plan to ensure a strong platform for the future of the program. Why are we concerned about 2006-07 needs of the Prequalification Program? The Prequalification Program offers distinctive value to WHO Member States, but its throughput is being challenged by limited resources and the quality of submissions. As demand increases, its ability to meet that demand will be based on its ability to define its needs now. How do we estimate the program’s needs? Models that quantify demand and cost have been built based on data from 2004-2005 and assumptions made with the program team. The resulting projections suggest substantially increased needs but also emphasize the need to maximize resource utilization. How can we contain costs and improve performance? The Prequalification Program can improve performance and reduce its resource needs by following through on non-technical recommendations to increase procedural efficiency and improve the quality of submissions. What do we do now to meet the need? The program faces a need of $12 million in 2006-07, up from $5 million in 2004-05. While it should continue to refine these estimates and evaluate other revenue sources, it should be primarily focused on aggressively pursuing donor governments with internal WHO endorsement. 2 CHAI works with countries and suppliers to ensure access to affordable ARVs, and the de-listings spurred CHAI to focus on QA Operations Work with suppliers to lower ARV prices Reaction After De-Listings • Conducted audit • Mobilize TA to increase quality of production and submissions Prequalification is critical to ensure quality ?? Work with purchasers to access products • Communicate flexibilities from different policies and standards • Initiate QC project 3 After CHAI approached PSM/QSM to seek if and how it can help the Prequalification Program, the need for a business plan was conveyed Create a business plan for the WHO Prequalification Program which supports the ability of it and its partners to achieve the following critical near-term tasks: • Recruit additional human resources • Solicit additional financial resources • Complete the 06-07 planning process • Promote the program 4 A month of work between April and May produced the findings which were presented to WHO in June, as part of an ongoing collaboration Last progress review April - May • Three weeks of full-time work with the WHO • Interviews and document research • Developing and refining model of demand, cost • Testing hypotheses with program team June • Present final conclusions internally • Complete and hand over final products • Agree on modalities of working together on an ongoing basis July + • Program will incorporate needs and findings of plan into WHO competency review • Program will pursue its fundraising needs externally • CHAI will provide support as needed and as agreed with WHO 5 Summary Why a collaboration with the Clinton Foundation? CHAI works with countries and suppliers to ensure access to affordable ARVs. The de-listings in 2004 spurred CHAI to focus on QA and ask the WHO if and how it could help. PSM/QSM identified the need for a business plan to ensure a strong platform for the future of the program. Why are we concerned about 2006-07 needs of the Prequalification Program? The Prequalification Program offers distinctive value to WHO Member States, but its throughput is being challenged by limited resources and the quality of submissions. As demand increases, its ability to meet that demand will be based on its ability to define its needs now. How do we estimate the program’s needs? Models that quantify demand and cost have been built based on data from 2004-2005 and assumptions made with the program team. The resulting projections suggest substantially increased needs but also emphasize the need to maximize resource utilization. How can we contain costs and improve performance? The Prequalification Program can improve performance and reduce its resource needs by following through on non-technical recommendations to increase procedural efficiency and improve the quality of submissions. What do we do now to meet the need? The program faces a need of $12 million in 2006-07, up from $5 million in 2004-05. While it should continue to refine these estimates and evaluate other revenue sources, it should be primarily focused on aggressively pursuing donor governments with internal WHO endorsement. 6 The Prequalification Program adds distinctive value to WHO Member States and the global fight against the three diseases Distinctive Value • In addition to innovator products, program judges safety, efficacy and quality of products still on patents • Saves money by making more affordable products eligible for purchase (or, increases purchasing power of a given set of resources) • Few national regulatory authorities evaluate generics in this way • Fewer still are endorsed by major donors, e.g. Global Fund • WHO standard, in particular, has high visibility and is judged with trust by donors and recipients • Ensures high quality of products being used by WHO Member States • Improves clinical outcomes by making FDCs available • Makes possible otherwise unavailable treatments (malaria) and diagnostics (CD4 for resource-poor settings) – regulatory standard reinforces market opportunity and encourages R&D and competition 7 The financial value of the program – and its return on investment to donors – is substantial Price difference Impact at scale ROI to donors Average difference for most common ART firstline regimens* Hypothetical cost for ART scale-up of 350,000 in Africa between 2004-2005 Assuming 80% use of generics, savings compared to cost of PQ $560 $196 million Savings of $100 million compares to cost of prequalification for four drugs of $100-200k $190 Innovator Generic $67 million Innovator Return on investment: $100-200 to $1 Generic * AZT+3TC+NVP and d4T+3TC+NVP; difference between prices of generic FDCs and single pills is marginal 8 External and internal perception of the program is consistently strong; the principal concern is ensuring resources for more prequalifications Strengths • Acknowledgement of critical role to treatment scale-up • Technical competency and dedication of team • Strong reflection of WHO value add to Member States • Use of program – 500 dossiers, donor policies, and purchases by countries Weaknesses • “Remarkable job on a shoe string budget” • Common external perception that the process is slow • Need for more dialogue with suppliers and stakeholders 9 Resources to date have been adequate, but throughput is limited based on two factors, both external to the program 1 2 Resources are limited… Limited number of assessors relative to submissions has resulted in the need for extraordinary sessions, limited number of inspectors often causes months of lag time between readiness for and conducting of inspection Quality of submissions is inconsistent… One-half to two-thirds of products are not prequalified (of 500 submissions since inception, 120 products are prequalified and ~60 dossiers are active), and the average prequalification time and cost varies widely from what would be a perfect submission (24 vs. 4-5 months and $87-128k vs. $40k per prequalification) 10 The factors that limit throughput will be compounded by increasing demand on the program with new submissions across therapeutic areas HIV/AIDS • Expect increases in number of companies submitting and different variations on current products • Estimate increases in submittals for second line products as countries scale up treatment plans • Change in GFATM policy will lead to increased demand for prequalification due to elimination of “Option C” TB • Expect another 12 companies will be ready to submit within year MDR-TB • Half of eligible formulations have been submitted; rest are expected soon • Expect half of the 70 • Increase in overall manufacturers who have expressed initial interest to become serious enough to submit over the next several years demand of patients: MDR-TB patients approved for DOTS+ doubling every 18 months • Are reaching out to manufacturers (in China, India and Russia) to encourage new submissions Malaria • Will have at least three additional FDCs on next EOI invitation • Each formulation has at least two API suppliers, meaning higher demand per product than other therapeutic areas • Also expect increases in submissions of dossiers as they encourage more companies to submit Source: HTM Cluster; HIV/AIDS Department; STB Department; Stop TB Partnership; RBM Department; RBM Partnership 11 The likelihood of continued increases in demand is reflected by the number of formulations that still have one or less prequalified generic Formulations listed in the Invitation for EOIs 100% 56 38 12 12 10 80 60 0 PQ Products 0 PQ Products 0 PQ Products 0 PQ Products 40 20 0 0 PQ Products 1 PQ Product 1 PQ Product 1 PQ Product 2+ PQ Products HIV/AIDS 2+ PQ Products OIs/Anti-Cancer MDR TB 1 PQ Product 2+ PQ Products Malaria TB Note: Product refers to a unique formulation manufactured by a specific supplier; the number of total formulations reflects the current draft of the next EOI invitation and includes specific dosage forms when possible; prequalifications based on lists available on August 30, 2005 12 Relative to these challenges, the business planning exercise serves two roles to support the future of the Prequalification Program 1 To quantify resource requirements facing the program for 2H 2005 through 2007 based on likely demand 2 To make recommendations on how to maximize resource utilization vis-à-vis the goals of the program 13 Summary Why a collaboration with the Clinton Foundation? CHAI works with countries and suppliers to ensure access to affordable ARVs. The de-listings in 2004 spurred CHAI to focus on QA and ask the WHO if and how it could help. PSM/QSM identified the need for a business plan to ensure a strong platform for the future of the program. Why are we concerned about 2006-07 needs of the Prequalification Program? The Prequalification Program offers distinctive value to WHO Member States, but its throughput is being challenged by limited resources and the quality of submissions. As demand increases, its ability to meet that demand will be based on its ability to define its needs now. How do we estimate the program’s needs? Models that quantify demand and cost have been built based on data from 2004-2005 and assumptions made with the program team. The resulting projections suggest substantially increased needs but also emphasize the need to maximize resource utilization. How can we contain costs and improve performance? The Prequalification Program can improve performance and reduce its resource needs by following through on non-technical recommendations to increase procedural efficiency and improve the quality of submissions. What do we do now to meet the need? The program faces a need of $12 million in 2006-07, up from $5 million in 2004-05. While it should continue to refine these estimates and evaluate other revenue sources, it should be primarily focused on aggressively pursuing donor governments with internal WHO endorsement. 14 Methodology for demand model HIV/AIDS Works backward from assumption about number of products which will be prequalified for every HIV/AIDS formulation by roughly 2007 • Four for 1st line ARVs (25% of 56 formulations) • Two for 2nd line and pediatric ARVs and medicines to treat OIs • One for anti-cancer medicines and formulations with little therapeutic use Assumes 1 in 3 submissions will be prequalified Net demand is less existing prequalifications and existing dossiers under review which are likely to be prequalified Others Direct assumptions about number of submissions based on inputs from program teams and partnerships at WHO • TB: 22 in 2005, 39 in 2006 and again in 2007 • Malaria: 7 products, with 2.5 companies per product – 18 in 2005-2007 • Reproductive Health: 7 products, 3 suppliers per product – 21 in 2006-2007 Note: Model also accounts for re-qualifications after three years and variations of products already prequalified by the program 15 Output of demand estimate: Demand is projected to double in 2006 Actual and Estimated New Product Submissions 200 172 RH 150 Malaria TB 132 RH Malaria TB Malaria 100 158 TB 90 Malaria TB HIV/AIDS 50 HIV/AIDS 45 Malaria TB 0 HIV/AIDS HIV/AIDS HIV/AIDS 2003* 2004 2005E** 2006E 2007E * 2003 figures annualize data on submissions from April-December ** 2005 figures include actual submissions made through March 16 Methodology of costing model Unit Costs Known based on current expenses • Salaries for P and G staff time needed for assessments and inspections • Travel for each assessment session ($37k) and inspection ($6k) • External compensation for each session ($34k) and inspection ($4k) Number Of Units Assumed based on historical experience and guidance from program team • Staff time: Based on allocation of time for March 2004 through February 2005 and volume of assessments and inspections conducted in that time • Assessments: Assumes average prequalification requires 6 quality assessment reports and 3 efficacy assessment reports • Inspections: Assumes any submission progressing to inspections requires 2 formulation, 1 CRO and 0.5 API (3 API for malaria) visits Note: Model uses current prequalification process as a template, e.g. bi-monthly assessments, number of weeks assessors and inspectors have typically been available per year, current rates of compensation to external experts, etc. 17 Outputs of costing model… lead to conclusion that to contain costs and improve performance, the program should maximize resource utilization …vs. baseline Resource needs… Total 2006-07 budget $15.1m $4.7m (04-05) P staff members in 2006 14 3 (2005) Assessors in 2006 82 20 (2005) Inspectors in 2006 78 15 (2005) Resource utilization can be increased by: • Higher quality of submissions • More efficient review procedures 18 Summary Why a collaboration with the Clinton Foundation? CHAI works with countries and suppliers to ensure access to affordable ARVs. The de-listings in 2004 spurred CHAI to focus on QA and ask the WHO if and how it could help. PSM/QSM identified the need for a business plan to ensure a strong platform for the future of the program. Why are we concerned about 2006-07 needs of the Prequalification Program? The Prequalification Program offers distinctive value to WHO Member States, but its throughput is being challenged by limited resources and the quality of submissions. As demand increases, its ability to meet that demand will be based on its ability to define its needs now. How do we estimate the program’s needs? Models that quantify demand and cost have been built based on data from 2004-2005 and assumptions made with the program team. The resulting projections suggest substantially increased needs but also emphasize the need to maximize resource utilization. How can we contain costs and improve performance? The Prequalification Program can improve performance and reduce its resource needs by following through on non-technical recommendations to increase procedural efficiency and improve the quality of submissions. What do we do now to meet the need? The program faces a need of $12 million in 2006-07, up from $5 million in 2004-05. While it should continue to refine these estimates and evaluate other revenue sources, it should be primarily focused on aggressively pursuing donor governments with internal WHO endorsement. 19 Three non-technical changes to review procedures are recommended to reduce cost and decrease average time to prequalification 1 Hold monthly rather than bi-monthly assessments, and schedule assessor capacity based on demand through the presence of a staff person in Copenhagen 2 Increase inspector availability, and reorient inspection scheduling to pre-set inspector availability (rather than seeking out inspectors based on need for inspection) 3 Begin scheduling inspections earlier in the review process, based on factors like previous experience with the supplier, stage of assessments, etc. 20 Changes – and investment – to improve the quality of submissions under review by the program are recommended to improve capacity building and reduce time to prequalification 1 2 Hire staff to focus on supplier relations… 1-2 staff members, independent of review process, can hold supplier workshops, conduct trainings, and proactively engage suppliers to improve quality of production and submission to WHO – provides capacitybuilding support and leads to higher throughput Create a minimum standard for initial dossier review… Rather than begin review of any dossier with complete documentation, create consistent and transparent criteria that filter out dossiers that do not meet a minimum standard of quality and invite applicants submitting these dossiers to re-submit 21 The result of these recommendations are refined projections of resource requirements that reflect more manageable needs Resource needs… Assuming no changes to the current process Accepting recs to + Accepting recs increase efficiency to increase quality of process of submissions Total 2006-07 budget $15.1m $11.3m $11.7m P staff members in 2006 14 10 11 Assessors in 2006 82 63 45 Inspectors in 2006 78 20 20 Months to prequalification 22 13 11 22 In addition, the following potential technical changes in review procedures are noted as areas which may justify further consideration 1 Prioritize the products program is reviewing (including which dossiers are reviewed and which inspections are scheduled first) based on programmatic needs 2 Introduce a separate approval standard for APIs and CROs to accelerate the review of multiple formulations which rely on identical APIs and CROs 3 Consider adopting an expedited process for generic products that have received regulatory approval by the FDA or other stringent regulatory authorities 23 Summary Why a collaboration with the Clinton Foundation? CHAI works with countries and suppliers to ensure access to affordable ARVs. The de-listings in 2004 spurred CHAI to focus on QA and ask the WHO if and how it could help. PSM/QSM identified the need for a business plan to ensure a strong platform for the future of the program. Why are we concerned about 2006-07 needs of the Prequalification Program? The Prequalification Program offers distinctive value to WHO Member States, but its throughput is being challenged by limited resources and the quality of submissions. As demand increases, its ability to meet that demand will be based on its ability to define its needs now. How do we estimate the program’s needs? Models that quantify demand and cost have been built based on data from 2004-2005 and assumptions made with the program team. The resulting projections suggest substantially increased needs but also emphasize the need to maximize resource utilization. How can we contain costs and improve performance? The Prequalification Program can improve performance and reduce its resource needs by following through on non-technical recommendations to increase procedural efficiency and improve the quality of submissions. What do we do now to meet the need? The program faces a need of $12 million in 2006-07, up from $5 million in 2004-05. While it should continue to refine these estimates and evaluate other revenue sources, it should be primarily focused on aggressively pursuing donor governments with internal WHO endorsement. 24 Ongoing and systematic data collection will help refine the program’s resource requirement projections over time – and better report to donors Internal metrics Oriented to donors • Length of time between • Percentage of dossiers different points in the process requiring review that get reviewed • Number of assessments • Average time from for a prequalified product submission to prequalification for a prequalified product For external consumption • Total number of assessments • Total number of inspections • Number of dossiers received • Number of prequalified products These metrics should be calculated regularly as a means to manage performance and allocate resources accordingly 25 An initial evaluation of alternative fundraising options suggests that donor governments should remain the source of ongoing financial support Option Conclusion Practicality? Revenues? Benchmarks? Sustainable? Diversify donor base Medium Medium N/A Low Charge per initial submission Medium High Low Medium No others charge generic suppliers of essential medicines Low Medium Low Medium Administration may not be practical, and rxn of suppliers is unclear Medium Low Low Medium See above, also low potential for revenues Fee per year charged to suppliers Low High Low Medium No other benchmarks and would likely not be regarded as acceptable Fee per year charged to “users” – formally, procuring UN agencies Low High Low Charge per initial submission, with recovery if prequalified Charge per re-qualification Low Short-term solution to meet resource gap but not sustainable Would not be regarded as acceptable 26 Following internal endorsement of future role and needs of the Prequalification Program, it faces three short-term needs Maximize use of existing resources by implementing management improvements Milestone: Hire non-technical manager Confirm financial resources required for 2006-2007 by successfully applying for new grants Milestone: More than 50% 2006-07 need confirmed by end of Q4 Confirm human resources required for 2006-2007 through confirmed secondees and assessors/inspectors from NDRAs Milestone: 3-4 technical officers hired and 50% of 2006-07 need for assessors and inspectors confirmed by end of Q4 27