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Global Health Econ Sustain                                               Fast-track drug approvals in Brazil


































            Figure 4. Queue length of time (in days) for drug registrations by prioritization (RDC 204/2017) and/or rare diseases (RDC 205/107).

            the average registration time, although caution should be   Phase III studies, expose patients to large uncertainties in
            exercised due to the small sample size.            efficacy and safety. The eligible population receiving the
              Fast track is a process created to accelerate the market   medication, which is still under research prospection, is
            availability of drugs to treat rare conditions and unmet   subject to high risk of bias; the medication costs are usually
            medical needs. The goal is to provide patients with early   borne  by  the health-care  system  or  the patients  (and
            access  to  new drugs  with clinically  relevant  results.  Fast   their  family).  Furthermore,  these  drugs  are  usually  very
            track applies to a wide range of severe illnesses, mostly   costly, and given that Phase II studies are conducted in a
            chronic diseases. According to a regulatory specialist and   limited population, there are concerns about the external
            former General Manager of Medicines and Biological   validation about efficacy and safety.
            Products at Anvisa, the fast-track process brought Brazil to   A study by Wong  et al. (2019) evaluated medication
            the first wave of submission worldwide (Line, 2021). Before   records from 2000 to 2015 registered by the FDA. The
            these regulatory movements, most pharma companies   authors found an average of 13.8% of success rate for drugs
            only decided to call for registry in Brazil after approval in   – success is defined as the registration of a molecule that
            the United States or Europe. The criteria for judging the   passed through all phases of the study showing consistent
            severity of a disease are varied, including whether the drug   efficacy and low-risk profile. Approximately 21% of Phase
            will affect the patient’s daily routine, survival, or the risk   II  studies  presented  satisfactory results  and received
            that, without treatment, the condition may evolve to a   registration. When evaluating medications for rare
            more severe state (Commissioner, 2018).            diseases, 12.7% of Phase II studies reached approval. For

              The data presented in this study show that since   oncologic drugs, < 40% progressed from Phase II to Phase
            2017, when accelerated registration mechanisms were   III, and 2.8% received approval.
            implemented by Anvisa in Brazil, there has been a large   Bypassing the traditional drug approval process is
            annual increase in numbers of registration requests using   equivalent to  transferring important stages  of clinical
            this process, with a mean response time much lower than   studies to the real world. Medications will be used in clinical
            standard registration. It is noteworthy to point out that   practice before their safety and efficacy are fully known and
            the length of drug registration, covering all process, had   without the rigorous monitoring and protection provided
            significantly reduced in terms of the average response time.  by clinical trials (Linger & Martin, 2018).
              Many fast-track registrations had only Phase II studies   The transfer of responsibility for monitoring outcomes
            available to support their decision. Treatments that are   of drugs registered through accelerated routes to the real
            registered based on Phase II trials, or preliminary data from   world will make pharmacovigilance the main source of


            Volume 1 Issue 2 (2023)                         8                        https://doi.org/10.36922/ghes.0995
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