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.
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