Transcript Written Drug Information: Now & into the Future
Written Drug Information: Now & into the Future
A look at where things now stand with the provision of useful written information to consumers, along with some conjecture as to how the future of drug information might evolve.
Ray Bullman Executive Vice President National Council on Patient Information and Education April 24, 2007
NCPIE, Copyright 2007
Written Drug Information: Now & into the Future
ABOUT NCPIE
• Produces messages & /materials to promote better consumer – patient – provider dialogue about medicines • Sample Activities: National Brown Bag Medicine Review, “Talk About Rx” Month, Be MedWise about OTCs, Consumer Medicine Information (CMI) Initiative NCPIE, Copyright 2007
Written Drug Information: Now and Into the Future
NCPIE’s Role = Catalyst & Convener – Encourage committed stakeholders to meet long-range CMI goals established in Public Law 104-180, outlined in Action Plan for Provision of Useful Prescription Medicine Information – CMI Initiative formed March 2003 NCPIE, Copyright 2007
Written Information: Recent Regulatory History
• 1995: FDA proposed MedGuide Rule • 1996: Public Law 104-180; private sector charged with developing criteria for “useful” written medicine information (CMI) • 1997: HHS Secretary accepts Action Plan
;
Targets set for 2000 & 2006; FDA = “judge” • FDA’s interim evaluation released June 2002 NCPIE, Copyright 2007
CMI Targets
• 95%
-
Distribution with new Rxs at retail pharmacies • 95% Medicine CMI leaflets that meet Agency’s interpretation of Action Plan criteria as delineated in FDA’s Guidance on Useful Written Consumer Information (July 2006) NCPIE, Copyright 2007
NCPIE Involvement in Written Medicine Information
1996: ‘97-’00: NCPIE represented on Keystone Action Plan Committee (“useful” CMI) NCPIE stakeholder conferences include Action Plan topics 2002: FDA encourages NCPIE to act as convener/catalyst to stimulate stakeholder activity to achieve Action Plan goals NCPIE, Copyright 2007
NCPIE Involvement in Written Medicine Information
July ‘02: NCPIE presents @ FDA mid course assessment public hearing March ‘03: 1 st meeting of NCPIE CMI Initiative stakeholders, FDA, & Svarstad team March ’04: NCPIE convenes “all-hands” stakeholder meeting w/FDA NCPIE, Copyright 2007
NCPIE Involvement in Written Medicine Information
June ‘04: NCPIE CMI Criteria Cmtee meets with FDA team & Svarstad Aug. ‘04: NCPIE Criteria Cmtee completes
Guide for Assessing Usefulness of CMI
Sept. ’04: NCPIE submits
Assessment Guide
(above) to FDA for input. Oct. ’04 – No Agency response on Assessment May ’05:
Guide
NCPIE, Copyright 2007
NCPIE Involvement in Written Medicine Information
April ’05: NCPIE organizes session on CMI, PhRMA Paperless Labeling Initiative & FDA’s Daily Med & Medication Guide programs @ FDLI annual mtg. May ‘05: FDA publishes draft guidance on CMI NCPIE, Copyright 2007
NCPIE Involvement in Written Medicine Information
July ’05: NCPIE submits comments to FDA docket on draft CMI guidance; re submits
CMI Assessment Guide
Aug. ’05: NCPIE submits comments to FDA docket on draft Guidance for Industry on FDA’s “Drug Watch” for Emerging Drug Safety Information NCPIE, Copyright 2007
NCPIE Involvement in Written Medicine Information
July ‘06: FDA releases final Guidance on Useful Written CMI (14 months after release of draft guidance) July ’06: NCPIE organizes telecon with FDA & three dozen stakeholder groups to provide opportunity for Q & A about final CMI guidance NCPIE, Copyright 2007
NCPIE Involvement in Written Medicine Information
MedGuides / e- MedGuides
Jan. ’05: FDA invites NCPIE to organize stakeholder discussions about Medication Guide dissemination; NCPIE helps organize 3 meetings: July ‘05 Oct. ‘05 Sept. ‘06 NCPIE, Copyright 2007
NCPIE: Catalyst for Stakeholder Meetings with FDA on MedGuides
Sept. 2006 Meeting with FDA: • Key issues / recommendations from pharmacy supply chain paper presented • Summary of NCPIE focus groups to assess consumers' views on CMI and MedGuides presented.
NCPIE, Copyright 2007
NCPIE Focus Groups -- Medication Guides --
- Focus group members appreciated formatted MedGuide more than unformatted CMI - MedGuide information should be provided by prescriber: * Best time for questions; too late at the pharmacy; * Can ask for alternative medicine NCPIE, Copyright 2007
Key Issues
• Paper distribution = poor distribution process • Pharmacists don’t know about MedGuides • Compliance with regulation (model pharmacy act) • Content of MedGuides: variability; confusion due to quantity of information • Integration of MG content into CMI • Cost shift to pharmacy ?
NCPIE, Copyright 2007
Written Information: Questions to Ponder
What impact will introduction of FDA’s
Patient Information Sheets
(PIS) have: On stakeholders: publishers, systems vendors, printers, packagers, pharmacies, pharmacists, prescribers? On patients and caregivers? NCPIE, Copyright 2007
Written Information: Questions to Ponder
• What impact will introduction of more and more
Medication Guides
have on CMI?
- On stakeholders (publishers, systems vendors, pharmacies, pharmacists)?
- On patients and caregivers?
NCPIE, Copyright 2007
Written Information: Questions to Ponder
• What do we know about consumers’: – Reaction to CMI? (apart from what FDA says) – Use of CMI?
– Expectations about or preferences for CMI? NCPIE, Copyright 2007
Consumer Medicine Information (circa March 2004) NCPIE, Copyright 2007
NCPIE, Copyright 2007
NCPIE, Copyright 2007
Action Plan Compliant CMI (circa 2006) NCPIE, Copyright 2007
NCPIE, Copyright 2007
NCPIE, Copyright 2007
2007 CMI Assessment
Goal # 1 95% Distribution • Very obtainable • “
Low hanging fruit”
-- 11% of pharmacies that did not provide CMI @ mid-point have had ample notification of deficiency • Preference: include other dispensing sites as well as community pharmacies (e.g., mail order) NCPIE, Copyright 2007
2007 CMI Assessment
Goal # 2 (per Action Plan 95% “Useful” CMI
and
FDA’s interpretive Final Guidance on criteria for content, design, layout, and readability) • Full goal attainment much more challenging; • At retail level – requires universal systems changes by 60,000+ community pharmacies in collaboration with 3rd party system vendors (from large chains to single pharmacy) NCPIE, Copyright 2007
2007 CMI Assessment
Goal # 2
(per Action Plan
and 95% “Useful” CMI
FDA’s interpretive Final Guidance on criteria for content, design, layout, and readability) • Publishers -
content is compliant
(self report); • Publishers – content available in multiple formats (text, xml) • Publishers - encouraging FDA to review / comment on monographs prior to dissemination (
What role might state pharmacy boards play in CMI feedback / oversight?)
NCPIE, Copyright 2007
2007 CMI Assessment
Goal # 2 (per Action Plan 95% “Useful” CMI
and
FDA’s interpretive Final Guidance on criteria for content, design, layout, and readability) • At the retail level –requires universal systems changes by 60,000+ pharmacies in collaboration with 3rd party system vendors (from large chains to single pharmacy) •
If
publishers’ content revisions are indeed Action Plan compliant, challenge becomes roll-out / implementation, populating marketplace with “new” CMI NCPIE, Copyright 2007
State of Flux /
What’s in Play
Goal # 2 (per Action Plan 95% “Useful” CMI
and
FDA’s interpretive Final Guidance on criteria for content, design, layout, and readability) • Reluctance to commit $ / change in part due to state of flux related to dissemination of medicine information.
What’s in play:
– CMI (as we now know it) – Medication Guides (as we now know them) NCPIE, Copyright 2007
What’s in Play?
– Medication Guides( pdf format, capacity to produce e version, in conjunction with CMI or stand-alone) – Package Insert (PI) - paper – e-Package Insert ( PhRMA Paperless Labeling ) – Patient Package Insert (PPI) - paper – DailyMed (FDA & Library of Medicine) NCPIE, Copyright 2007
What’s In Play?
ALL OF THE ABOVE ?
NCPIE, Copyright 2007
What’s In Play?
VARIATIONS OF THE ABOVE?
NCPIE, Copyright 2007
Are We Overlooking Something?
Are We Overlooking mething?
Are WeOverlookingSomething?
Are We OverlookingSomething?
Are We Overlooking Something? (Code: Webdings, Wingdings, Bookshelf Symbol 7, Arial)
NCPIE, Copyright 2007
Are We Overlooking Something?
Telling consumers to “read it & heed it” and to ask questions ensures communication of useful medicine information … What if you can’t read, or can’t read with understanding or don’t speak the language of your health care provider?
Right?
NCPIE, Copyright 2007
Low Health Literacy
• “Half of all adults are unable to understand much of what they need to know to take care of themselves and to follow their doctor’s instructions.” (Dr. Harvey V. Fineberg, President, IOM) • 90 million adults (1 in 3) may lack the functional reading and math skills to effectively use the U.S. health system; most are native born, English speakers. (Health Literacy: A Prescription to End Confusion, IOM) NCPIE, Copyright 2007
Low Health Literacy
• Most likely to face limited health literacy: – Elderly; – Poor; – New Immigrants.
• System problem
not
a patient characteristic. NCPIE, Copyright 2007
Three Approaches Showing Promise 1. Culturally appropriate health education 2. Patient advocacy 3. Medical education recognizing the critical importance of patient communication in the training of hcps at all levels.
(IOM: Health Literacy: A Prescription to End Confusion, 2004) NCPIE, Copyright 2007
Healthy People 2010 – Chapter 17 Federal goals for ensuring better (more useful) medicine communication: FDA is lead agency for monitoring progress to meet objectives in Chapter 17: Medical Product Safety. Objectives 17.3 17.5 of relevance here: NCPIE, Copyright 2007
Healthy People 2010 – Chapter 17
17-3.
Increase the proportion of primary care providers, pharmacists, and other hcps who routinely review with their patients aged 65 years & older and patients with chronic illnesses or disabilities all new prescribed & OTC medicines.
DELETED from HP 2010 @ mid-course review!
NCPIE, Copyright 2007
Healthy People 2010 - Chapter17
17.4: Increase the proportion of patients receiving, at the time their new prescriptions are dispensed, written information that conforms to the
“Action Plan for the Provision of Prescription Medicine Information.”
NCPIE, Copyright 2007
Healthy People 2010 – Chapter 17
17.5: Increase the proportion of patients receiving from prescribers, pharmacists, and other hcps oral counseling information that conveys directions for use and risk information (precautions and warnings).
NCPIE, Copyright 2007
Important – but Under-spoken - Aspect of Medicine Communication Medication counseling by: • Prescribers and • Pharmacists NCPIE, Copyright 2007
Consumers’ Reported Receipt of Rx Information
@ the Physician’s Office
(told selected info) How much to take: How often to take: Refills: Precautions: Side Effects: Any information: All information:
1992 2000 2004
55% 62% 56% 64% 32% 37% 64% 66% 37% 33% 36% 29% 35% 61% 68% n/a 24% 37% 35% 70% 26% (source: FDA; Dec. 2006) NCPIE, Copyright 2007
Consumers’ Reported Receipt of Rx Information
@ the Pharmacy
(told selected info) How much to take: How often to take: Refills: Precautions: Side Effects: Any information: All information:
1992 2000 2004
28% 34% 27% 34% 29% 31% 16% 17% 18% 24% 11% 20% 37% 37% n/a 12% 16% 21% 17% 38% 6% (source: FDA; Dec. 2006) NCPIE, Copyright 2007
What’s Likely to Change
The Status Quo
NCPIE, Copyright 2007
In the (very) Near Future
• FDA Public Hearings: – Electronic dissemination of Package Insert (PI) April 27 in DC – Medication Guides (electronic dissemination, integration of content with CMI, etc) – June 12-13 in DC NCPIE, Copyright 2007
What We’re All Seeking
• Provision of the most useful information for all consumers to promote safe and appropriate medicine use. NCPIE, Copyright 2007
Questions
NCPIE, Copyright 2007
Contact Information
Wm. Ray Bullman Executive Vice President National Council on Patient Information and Education 4915 Saint Elmo Ave., Suite 505 Bethesda, MD 20814-6082 [email protected] – email (301) 656-8565 – phone (301) 656-4464 – fax www.talkaboutrx.org
www.bemedwise.org
NCPIE, Copyright 2007