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Global Health Econ Sustain                                               Fast-track drug approvals in Brazil



            data. Manufacturers are required to report any negative   current expedited approval processes may not consistently
            results of which they become aware, but there is no   align with the expected therapeutic benefits for patients
            requirement that they actively seek out negative results.   (Lexchin, 2015b).
            As clinical reporting will remain voluntary, it is likely that   These studies highlight the importance of critically
            adverse reactions to drugs with accelerated approval will   evaluating the therapeutic value of drugs approved through
            be significantly underreported, although through hospital   fast-track pathways. The discrepancy between expedited
            notification systems, adverse drug events for specialist-only   approvals and independent assessments of therapeutic value
            medications, such as immunotherapies, may be detected   raises concerns about the potential compromise in rigorous
            and reported at a higher rate (Linger & Martin, 2018).  evaluation during expedited review processes. Therefore, it
              Concerns about the safety of drugs registered through   is crucial for regulatory agencies to establish clear guidelines
            fast track have been raised after the provisional approval   and post-marketing surveillance to monitor the real-world
            process was implemented in Canada. When compared to   therapeutic value and long-term benefits of drugs approved
            drugs approved through a standard registration process,   through expedited pathways. By doing so, regulatory
            there is a statistically significant risk that these drugs will   agencies can ensure that expedited approvals truly deliver
            generate more serious adverse events or even be removed   meaningful clinical advances to patients in need.
            from the market (Lexchin, 2015a).                    Accelerated access to new drugs can represent a way of
              A study by Mostaghim et al. (2017) reported an increase   adapting the regulatory landscape as current regulations
            in safety-related changes in drug labels and highlights the   do not adequately deal with advanced therapies. Due to
            importance of active safety monitoring for all drugs after   a deeper understanding of the causes of diseases, these
            initial registration, particularly those approved through   drugs are generally tested in small clinical trials with
            accelerated routes. The FDA receives voluntary reports   patients whose genetic profiles are known. On the other
            of  adverse  events  related  to  drugs,  which  can  lead  to   hand, this approach can put patient at risk and increase
            changes in the market authorizations. Since 2007, the   financial risks for individuals and society. In addition, the
            FDA’s electronic monitoring of health data and other   process of accepting regulatory decisions made in other
            sources through the Sentinel system has provided a critical   countries is often complicated by variable evaluation
            mechanism to conduct active observational studies to   criteria and differences in clinical practices, which can
            complement the voluntary reporting system. Compared to   make the extrapolation of these decisions dangerous in
            non-accelerated drugs, accelerated drugs had a 48% higher   other countries (Kubler, 2018).
            rate of changes in warnings and contraindications on their   Managed entry agreements are a set of tools used to
            market authorization. A qualitative review of changes in   mitigate the impact of uncertainty and financial burden
            the warning section of the label revealed that < 5% were   when registering a new drug. They can be subdivided into
            changed to account for a reduction of risk to patients.  payments that are tied to health outcomes or financial
              The therapeutic value of drugs approved through fast-  considerations, where the price is defined based on
            track pathways has become a topic of interest and concern   quantitative measures such as estimated consumption of
            within the medical and regulatory communities. A 2020   the technology in question. These agreements can enable
            study examined drugs approved by the US FDA and EMA   health systems to reduce their expenditure on advanced
            between 2007 and 2017 and found that less than a third   therapies, especially where there is significant uncertainty
            of these drugs were rated as having high therapeutic value   around safety and efficacy, as well as around the value of a
            by independent organizations. The study also revealed that   new drug. Managed entry agreements can be potentially
            expedited drugs were more likely to receive high ratings,   important tools for improving scientific capability and
            but a significant number of expedited drugs approved by   knowledge within health systems, whether public or
            the FDA were considered to have low therapeutic value   private, while providing access to innovative and high-cost
            (Hwang et al., 2020). In the similar vein, a cohort study   new drugs and seeking to minimize the opportunity costs
            conducted on Health Canada’s priority review process for   of decisions (Zampirolli Dias et al., 2020).
            new drugs, published in 2014, found that the assignment
            of priority approval by Health Canada was only a fair   5. Conclusion
            predictor of a drug’s therapeutic value once it entered the   With the advancements in drug development, regulatory
            market. The study emphasized the need for Health Canada   agencies must reorganize to meet the increasing demands
            to review its criteria for using priority reviews to ensure   for registration, considering the questionable levels of
            accurate identification of drugs that represent significant   evidence, and ensuring the rapid access of the population
            therapeutic advancements. These findings indicate that the   to new safe and effective therapies. Considering the


            Volume 1 Issue 2 (2023)                         9                        https://doi.org/10.36922/ghes.0995
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