On the specific areas highlighted in the Commission sponsored study which can be summarised as follows:
1. Data sources and safety issue detection
- Need to harmonize the different sources of safety information between member states (Individual Case Safety Reports, PSURs, registries, consumption data, safety studies).
- Develop & implement common set of statistical tools to be used by member states.
- Optimize national data bases.
- Make sure that Marketing Authorization Holders fulfill their role of first-line signal detection for both centrally and nationally authorized products.
- Make sure that safety reporting is easy, accessible to all stakeholders, not cumbersome or time consuming (public electronic terminals? – internet?).
- Facilitate involvement of healthcare professionals (doctors, nurses, pharmacists) and patients.
- Clarify type of safety issues to be reported (need to include known side effects?).
- Distinguish between safety & pharmacovigilance questions.
2. The legal framework and new legal tools
- Prioritize mandatory phase IV studies for innovative medicines.
- Implement no blame system on AE reporting.
- Regulate internet pharmacies.
- Harmonize legal framework and its implementation between Member States.
3. Decision making in pharmacovigilance
- Involve patient representatives in PSUR/CHMP decisions.
- Involve patients/representatives in reevaluation of risk/benefit ratio in approved medicines.
- Make adequate use of external expertise.
- Harmonize & streamline process within Community.
- Identify and remove disparities between Member States.
- Improve coordination with international partners.
4. Impact of communications and actions
- Harmonize & streamline mechanisms to inform doctors, pharmacists, patients and the general public in Member States.
- Improve impact on prescription behaviour.
- Consult patients/patient groups in decision making prior to communications and actions.
- Assess outcomes of regulatory actions.
5. Facilitation and monitoring of compliance with pharmacovigilance requirements
- Collaboration between Member States should be improved by implementation of multinational phase IV cohort studies (large number of patients needed to capture rare AE).
- Measure industry compliance.
- Establishment of confidentiality between patient organisations and pharmaceuticals to balance the need for timely information and commercial and legal concerns when sharing such information in advance of public announcements.
