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UCPMP 2024: Game Changer or False Dawn?

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On March 12, 2024, the Department of Pharmaceuticals (DoP) of the Government of India notified the new Uniform Code for Pharmaceutical Marketing Practices (UCPMP) 2024.

Having gone through the details, many construe that aiming to finally clean up pharmaceutical marketing practices in India, as demanded by many stakeholders – including the Supreme Court of India, the new one released by the DoP in March 2024 still appears to be a ‘work in progress.’ One therefore, wonders whether UCPMP 2024 is a step forward or status quo in establishing desirable standards for pharma business ethics in India.

In this article, let me dwell on this issue, highlighting examples of some key points in this regard.

Some key points to take note of:

There are several key points to take note of some examples, which will include:

  • Unlike its predecessor, the 2024 UCPMP removes the word “voluntary” but doesn’t explicitly make the code mandatory. It requests industry associations to implement the code.
  • The code doesn’t explicitly prescribe penalties for pharmaceutical companies beyond removal from industry associations (if they are members).
  • Doctors who violate ethical codes can face license suspension and fines under the National Medical Commission (NMC) guidelines. However, the NMC’s stricter 2023 code revisions were put on hold due to industry pressure.

Thus, several issues, including the following, need to be answered, beyond any ambiguity whatsoever. That said, let me start with how the UCPMP 2024 brings both opportunities and challenges for Indian drug companies, and then we will try to fathom whether the new code as it presents today will prove to be a game changer to improve the quality of ethical standards, especially, in Indian pharmaceutical marketing. 

UCPMP 2024 – some key challenges for drug companies:

A.  Marketing Revamp:  The new UCPMP demands a complete overhaul of marketing practices and strategies. Companies need to find new, compliant ways to educate doctors about their products, likely focusing on:

  • Scientific Data and Value Proposition: Stronger clinical trial data and highlighting a drug’s actual benefits will be crucial.
  • Transparency and Credibility: Building trust with doctors through clear, accurate information and high-quality educational materials is essential.

B.  Salesforce Transformation: Medical representatives, previously reliant on personal connections, now need expertise in:

  • Scientific Communication: Effectively engaging doctors with the science behind the drug.
  • Product Knowledge: Deep understanding of the drugs they are promoting.
  • Potential Sales Slump: Stricter marketing might lead to a decline in sales, particularly for established brands that rely heavily on promotion. Companies need to adapt their sales strategies to address this.

Effectively navigating these challenges requires significant investments in:

  • R&D: Stronger focus on research and development to create innovative drugs with a clear value proposition.
  • Data-Driven Marketing: Utilizing data science to understand doctor needs and target marketing efforts effectively.
  • Salesforce Training: Upskilling representatives in scientific communication and product knowledge.

By adapting their approach, Indian drug companies can leverage UCPMP as an opportunity to move towards a model focused on the quality and scientific merit of their products.

UCPMP 2024 – some key opportunities for drug companies:

The UCPMP 2024, while presenting challenges, also offers some key opportunities for Indian drug companies to thrive:

  • Level Playing Field: The ban on gifts and incentives removes an unfair advantage for larger companies. This allows smaller or generic drug companies to compete based on the merits and affordability of their products.
  • Focus on Innovation: With less emphasis on promotion, companies may be incentivized to invest more in R&D, leading to the development of new, innovative drugs with stronger scientific backing.
  • Building Brand Trust: Transparency and accurate information mandated by UCPMP can help companies build trust with doctors and patients alike. This strong reputation can be a valuable asset in the long run.
  • Data-Driven Marketing: The shift towards data-driven marketing allows for targeted communication based on doctor needs and preferences. This can be more cost-effective and lead to better engagement with healthcare professionals.
  • Focus on Patient Education: UCPMP encourages companies to provide clear information directly to patients. This can empower patients to make informed decisions about their healthcare and potentially increase the demand for effective medication.

By capitalizing on these opportunities, Indian drug companies can:

  • Differentiate themselves: By focusing on innovation and patient-centricity, they can carve out a niche in the market.
  • Building long-term value: Investing in R&D and building trust with doctors can lead to sustainable growth and brand loyalty.
  • Becoming more competitive globally: A focus on innovation and scientific merit can help Indian companies compete effectively in the international pharmaceutical market.

Interestingly, the UCPMP presents a chance for Indian drug companies to move away from an outdated marketing model and embrace a more ethical and sustainable approach. By focusing on innovation, data-driven marketing, and building trust, they can seize this opportunity to become leaders in the global pharmaceutical industry.

Is UCPMP 2024 a game changer or a false dawn?

Having said all this, the question still remains whether UCPMP 2024 is a game changer or a false dawn. I reckon, while aiming to curb unethical practices in the pharmaceutical industry, questions linger about its effectiveness. Let’s delve into both sides of the argument:

A Game Changer:

  • Stronger Stance: The removal of “voluntary” from the code suggests a stricter approach compared to its predecessor.
  • Focus on Transparency: Provisions like mandatory expenditure disclosure for conferences organized by pharma companies could increase transparency.
  • Addressing Travel & Hospitality: Discouraging pharma-funded travel and hospitality for doctors might reduce undue influence.
  • Potential for Improved Ethics: A well-enforced UCPMP could lead to a more ethical environment where marketing focuses on the merits of drugs rather than lavish incentives.

False Dawn:

  • Missing Teeth: The lack of clear penalties beyond industry association removal for pharma companies raises concerns about enforcement.
  • Rollback of NMC Code: The NMC’s stricter code for doctors with potential financial penalties was rolled back due to industry pressure. This weakens the overall impact.
  • Ambiguity on Non-Member Companies: The code’s effectiveness might be limited if pharmaceutical companies outside industry associations are not held accountable.
  • Uncertain Implementation: The success of UCPMP hinges on robust implementation and a clear mechanism to address violations.

Conclusion:

From the above perspective, the true impact of UCPMP 2024 remains to be seen. While it has positive intentions, its effectiveness depends on stricter enforcement mechanisms, penalizing violations, and ensuring all companies are held accountable. Only time will tell if UCPMP 2024 ushers in a new era of ethical practices or remains a symbolic but unenforced reform.

By: Tapan J. Ray

Disclaimer: The views/opinions expressed in this article are entirely my own, written in my individual and personal capacity. I do not represent any other person or organization for this opinion.

Cancer Care: Dawns A New Era Of Precision Medicine In India

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The concept of ‘Precision Medicine’ has started gaining increasing importance, in the treatment process of many serious diseases, such as cancer. It is now happening in many countries of the world, including India.

The National Institutes of Health (NIH) of the United States, describes ‘Precision Medicine’ as:

“An emerging approach for disease treatment and prevention that takes into account individual variability in genes, environment, and lifestyle for each person.”

This is quite in contrast to the widely practiced “one-size-fits-all” type of drug treatment approach, where disease treatment and prevention strategies are developed for the average person, with less consideration for the differences between individuals.

It continues, irrespective of the fact that the same drug doesn’t always work exactly the same way for everyone. It can be difficult for a physician to predict, which patient will benefit from a medication and who won’t, besides having any advance inkling on who will experience Adverse Drug Reactions (ADR) with it, and who will not.

Whereas, the treatment path of ‘Precision Medicine’ allows doctors to predict more accurately which treatment and prevention strategies will work most effectively for a particular disease, and in which groups of people. This is mainly because, ‘Precision Medicine’ looks at the root cause of the ailment for each patient.

For example, in cancer care, use of the term ‘Precision Medicine’ would mean a treatment process for patients with similar tumors, that has been immaculately worked out in accordance with their unique genetic, physical, psychosocial, environmental, and lifestyle factors. Thus, especially for the treatment of life-threatening diseases, a gradual shift from “one-size-fits-all” types of medicines to ‘Precision Medicines”, could bring a new hope of longer survival or remission, for many such patients.

For example, in precision cancer care, it is all about analyzing a patient’s tumor to determine with specificity what drug or combination of drugs will work best with least side effects for that particular individual.

In this article, I shall focus on the development, use and benefits of ‘Precision Medicine’ in cancer, especially in India.

Not a radically new concept:

Several examples of ‘Precision Medicine’ can be found in a few other areas of medicine, as well, though its use in everyday health care is not very widespread, as on date.

One such example can be drawn from the blood transfusion area. A person requiring it, is not given blood from a randomly selected donor. To minimize the risk of any possible post-transfusion related complications, the blood for transfusion is selected only after scientific confirmation that the donor’s blood type matches to the recipient.

Difference between ‘Precision’ and ‘Personalized’ Medicines:

There is a significant overlap between these two terminologies. According to the National Research Council (NRC) of the United States, ‘Personalized Medicine’ is an older term having a meaning similar to ‘Precision medicine’, but may not always be exactly the same.

This change was necessitated as the term ‘Personalized’ could be interpreted to imply that treatments and preventions are being developed uniquely for each individual. Whereas, in ‘Precision Medicine’, the focus is on identifying which approaches will be effective for which patients based on genetic, environmental, and lifestyle factors, as stated above. The NRC, therefore, preferred the term ‘Precision Medicine’ to ‘Personalized Medicine’ to avoid such confusions or misunderstandings. Nevertheless, these two terms are still being used interchangeably.

Another terminology – ‘Pharmacogenomics’ is also used by some, in the same context, which is, in fact, a part of ‘Precision Medicine’. According to National Library of Medicine, United States, Pharmacogenomics is the study of how genes affect a person’s response to particular drugs. This relatively new field combines pharmacology (the science of drugs) and genomics (the study of genes and their functions) to develop effective, safe medications and doses that will be tailored to variations in a person’s genes.

Global initiatives taking off:

Currently, in various parts of the world, there are many initiatives in this area. However, one singular state sponsored initiative, I reckon, is exemplary and stands out.

According to NIH, in early 2015, President Obama announced a research effort focusing on bringing ‘Precision Medicine’ to many aspects of health care. The President’s budget for fiscal year 2016 included US$216 million in funding for the initiative for the NIH, the National Cancer Institute (NCI) – the NIH institute focused on cancer research, and the Food and Drug Administration (FDA).

‘The Precision Medicine Initiative’ has both short-term and long-term goals:

  • The short-term goals involve expanding precision medicine in the area of cancer research. Researchers at the NCI hope to use this approach to find new, more effective treatments for various kinds of cancer based on increased knowledge of the genetics and biology of the disease.
  • The long-term goals focus on bringing ‘Precision Medicine’ to all areas of health and healthcare on a large scale.

The market:

According to a July 2016 research report by Global Market Insights, Inc., the ‘Precision Medicine’ market size was over US$39 billion in 2015, and has been estimated to grow at 10.5 percent CAGR from 2016 to 2023, expanding the market to US$ 87.79 billion by end 2023.

The demand for ‘Precision Medicine’ is expected to significantly increase, specifically in cancer treatments, and also would be driven by advancements in new healthcare technologies, and favorable government regulations, in this area.

Faster US regulatory approval:

According to an August 15, 2016 article, published in the ‘MedCity News’ – a leading online news source for the business of innovation in health care, companion diagnostics, this trend is gaining currency as novel drugs are being paired up with tests that determine which patients will have a higher chance of responding to that drug.

This is vindicated by an expert analysis of a recent study, which found that the probability of a drug approval jumped three-times to 25.9 percent of those drugs that were approved with a predictive biomarker, from 8.4 percent for drugs without one.  This means a threefold increase in success, as determined by FDA registration, if any pharma or biologic drug company had a predictive marker in its new product development strategy. This indication would expectedly encourage more drugs to come with companion diagnostics than without, as the analysis underscored.

The National Institutes of Health (NIH) of the United States defines ‘Biomarkers’ or ‘Biological Markers’ as, “a characteristic that is objectively measured and evaluated as an indicator of normal biological processes, pathogenic processes, or pharmacological responses to a therapeutic intervention.”

‘Precision Medicine’ in India:

In the Indian health care space, ‘Precision Medicine’ is still in its nascent stage. This is despite its need in the country being high, especially while treating life threatening ailments, such as cancer, with greater precision, predictability and, therefore, more effectively than at present.

In several focus group studies too, the local medical specialists have also concurred with the global estimation of the inherent potential of ‘Precision Medicine’, as it rapidly evolves in India, particularly for use in oncology.

Local research:

Studies related to ‘Precision Medicine’ have already commenced, though in a modest scale, in a number of Government research centers, such as, Centre for Cellular and Molecular Biology (CCMB), Indian Council of Medical Research (ICMR), National Institute of Biomedical Genomics (NIBMG) and Institute of Genomics & Integrative Biology (IGIB).

Some large Government Hospitals too, like, All India Institute of Medical Sciences (AIIMS), National Institute of Mental Health and Neurosciences (NIMHANS), and even in Tata Memorial Hospital are making good progress in this area.

Local potential and market impact:

In March 2016, a leading daily of India had reported with examples that oncologists have started using ‘Precision Medicine’, in the country.

In this report, a molecular geneticist was quoted saying, “We see patients with blood, breast, lung, and colon cancer being referred for genetic testing on a routine basis. This testing is either for predictive purposes or for precision medicine guidance, where genetic tests are increasingly being used to determine which drug may be used for treatment.”

“We have had more than a few cases where patients respond well after being put on a new drug based on the results of these tests,” the expert said.

According to a May 2016 report of the Indian Council of Medical Research (ICMR), in the year 2016, the total number of new cancer cases is expected to be around 14.5 lakh (1.5 million), and the figure is likely to reach nearly 17.3 lakh (1.7 million) of new cases in 2020.

Over 7.36 lakh (736,000) people are expected to succumb to this disease in 2016 while the figure is estimated to shoot up to 8.8 lakh (880,000) by 2020. The data also revealed that only 12.5 percent of patients come for treatment in early stages of the disease.

Taking note of this fast ascending trend, it would be quite reasonable to expect that treatment with ‘Precision Medicine’, using advanced genetic profiling, would catch up, and grow proportionally in some section of the population, sooner than later. This trend is expected to keep pace with the commensurate increase in the anti-cancer drug market of India.

In tandem, the demand for preventive measures, especially, for cancer, cardiovascular, psychosomatic and many chronic metabolic diseases at the onset or prior to even onset stages, based on genome-based diagnostics, are also expected to go north. This would primarily be driven by increasing health awareness of the younger generation of India.

The spin-off commercial benefits for the pharma and diagnostic players in India, competing in these segments, could well be a significant boost even in the market potential of the older generic drugs in new patient groups, prompted by many out-of- box diagnostic and disease treatment strategies.

Another interesting article on genomic diagnostics for ‘Precision Medicine’, published on March 15, 2016 by ‘Pistoia Alliance’ – a global, not-for-profit alliance in life science that aims at lowering barriers to innovation in R&D, also expressed similar views regarding the future potential of ‘Precision Medicine’ in India.

Some key strategic steps:

Taking proactively some key strategic steps for business planning and development by the domestic pharma and diagnostic players, is now more important than ever before. This may call for developing some critical studies that would accelerate working out novel strategies for ‘Precision Medicine’ in India, besides obtaining required regulatory approvals in the coming years. The studies may include, among others:

  • Detailed analysis of target patient populations
  • Their genetic makeup for different types, or sub-types of diseases
  • Addressable sub populations
  • Their current treatment strategies, costs, affordability and differentiated value offerings of each, if any.

Conclusion:

Genomic research in India is now mainly directed towards routine genome-based diagnostics for a number of conditions, mostly for cancer. The country needs to encourage taking rapid strides to first sharpen and then gradually broaden this area, in various ways, for more effective and predictable treatment outcomes with ‘Precision Medicine’. As on date, most of such studies are carried out in the United States and Europe.

Alongside, a robust regulatory framework is required to be put in place, for wider usage of ‘Precision Medicine’ in India, without causing any concern to stakeholders. Government should also explore the need of clearly defining, and putting in place transparent, patient-friendly and robust Intellectual Property (IP) policies in the ‘Precision Medicine’ related areas to encourage innovation.

Healthcare expenditure being out-of-pocket for a vast majority of the population in India, the additional cost to be incurred for genomic sequencing tests, still remains a huge concern for many. Nevertheless, the good news is, many players have now gradually started entering into this area, spurring a healthy competition. This process would also gain accelerated momentum, as we move on.

This is just a dawn of a new era of ‘Precision Medicine’ in India. Its rapid development, is expected to be driven by a large number of startups, equipped with state-of-art technology, and hopefully, with greater health insurance penetration and the support from the Government. All this would bring the ‘Precision Medicine’ treatment cost affordable to a sizeable section of the population in the country, particularly for the treatment of cancer. The evolving scenario appears to be a win-win one, both for the patients, as well as the pharma and diagnostic players in India.

By: Tapan J. Ray  

Disclaimer: The views/opinions expressed in this article are entirely my own, written in my individual and personal capacity. I do not represent any other person or organization for this opinion. 

Pfizer and Biocon deal – heralds dawn of a new era for the Biopharmaceuticals Industry of India

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On October 19, 2010, home grown Biotech Company Biocon, based in the IT heartland – Bangalore created a stir in Industry by inking an interesting international corporate business deal with the largest global pharmaceutical company – Pfizer. The deal will bring to Biocon a total sum of US $350 million and enable Pfizer to globally commercialize Biocon’s biosimilar (generic versions of biotechnology medicines) human recombinant insulin and three insulin analogues.

Before this deal, Sanofi-Pasteur, the vaccine business unit of the global major Sanofi-aventis had acquired Shantha Biotech, located at Hyderabad for a sum of Rs 3,750 Crore, in July 2009.

Just a year before the above acquisition in india, on December 11, 2008, Reuters reported, just two days after Merck announced a major push into biosimilar medicines; Eli Lilly signaled similar aspirations. This report, at that time, raised many eyebrows in the global pharmaceutical industry, as it was in the midst of a raging scientific debate on the appropriate regulatory pathways for biosimilar drugs. Be that as it may, many felt that this announcement ushered in the beginning of a new era. An era of intense future competition with biosimilar drugs in the global market, with immense commercial interest. On October 19, 2010 the biosimilar deal between Biocon and Pfizer vindicated this point.

Increasing global interest on biosimilar drugs:

Globally, the scenario for biosimilars started heating up when Merck announced that the company expects to have at least 5 biosimilars in the late stage development by 2012. The announcement of both Merck and Eli Lilly surprised many, as the largest pharmaceutical market of the world – the U.S.A, at that time, was yet to approve the regulatory pathway for biosimilar medicines. However, along with the recent healthcare reform by the Obama administration, the regulatory pathway for biosimilar drugs has now been clearly charted by the US FDA. In the developed world, European Union (EU) had taken a lead towards this direction by putting a robust system in place, way back in 2003.

What then prompts the research based global pharmaceutical companies like Pfizer, Sanofi-aventis, Merck and Eli Lilly to step into the arena of Biosimilar medicines? Is it gradual drying up research pipeline together with skyrocketing cost of global R&D initiatives?

The future global business potential of Biosimilar medicines:

Currently, over 150 different biologic medicines are available in the global pharmaceutical market. However, the low cost biosimilar drugs are available in just around 11 countries of the world, India being one of them. Supporters of biosimilar medicines are indeed swelling as time passes by. At present, the key global players are Sandoz (Novartis), Teva, BioPartners, BioGenerix (Ratiopharm) and Bioceuticals (Stada). With the entry of pharmaceutical majors like, Pfizer, Sanofi-aventis, Merck and Eli Lilly, the global biosimilar market is expected to develop at a much faster pace than ever before. Removal of regulatory hurdles for the marketing approval of such drugs in the US – the largest pharmaceutical market of the world, will be the key growth driver.

Recently, the EU has approved Sandoz’s (Novartis) Filgrastim (Neupogen brand of Amgen), which is prescribed for the treatment of Neutropenia. With Filgrastim, Sandoz will now have 3 Biosimilar products in its portfolio.

Global Market Potential of Biosimilar Drugs:

The biosimilar drug market in the world is estimated to be around U.S. $ 16 billion by 2011. Currently, off-patent biologic blockbusters including Erythropoietin offer an excellent commercial opportunity in this category. By 2013, about 10 branded biologics with a total turnover of around U.S. $ 15 billion will go off-patent, throwing open greater opportunity for the growth of biosimilar drugs internationally.

Biosimilar Drugs in India:

Sales of biosimilar drugs in India are estimated to be around U.S. $ 4 billion by 2011 with scorching pace of growth driven by both local and global demands.

Recombinant vaccines, erythropoietin, recombinant insulin, monoclonal antibody, interferon alpha, granulocyte cell stimulating factor like products are now manufactured by a number of domestic biotech companies like Biocon, Panacea Biotech, Wockhardt, Emcure, Shantha Biotech, Bharat Biotech, Serum Institute of India, Dr. Reddy’s, Ranbaxy, etc. The ultimate objective of all these Indian companies will be to get regulatory approval of these products in the US and the EU either on their own or through collaborative initiatives.

It is worth mentioning here that to give a fillip to the Biotech Industry in India; the National Biotechnology Board was set up by the Government of India under the Ministry of Science and Technology way back in 1982. The Department of Biotechnology (DBT) came into existence in 1986. The DBT now spends around US$ 200 million annually to develop biotech resources in the country and have been making reasonably good progress. The DBT is reported to have undertaken an initiative for quite some time to prepare regulatory guidelines for Biosimilar Drugs, which is expected to conform to international quality and patients’ safety standards.

Steps taken by the Indian pharmaceutical companies:

Biosimilar version of Rituxan (Rituximab) of Roche used in the treatment of Non-Hodgkin’s lymphoma has already been developed by DRL in India. Last year Rituxan clocked a turnover of over US$ 2 billion. DRL also has developed filgastrim of Amgen, which enhances production of white blood-cell by the body, and markets the product as Grafeel in India. Similarly Ranbaxy has collaborated with Zenotech Laboratories to manufacture G-CSF.

On the other hand Glenmark is planning to come out with its first biotech product by 2011 from its biological research establishment located in Switzerland.

The focus is on Oncology:

Many domestic Indian pharmaceutical companies are targeting Oncology disease area for developing biosimilar drugs, which is estimated to be the largest segment with a value turnover of over US$ 55 billion by the end of 2010 growing over 17%. As per recent reports about 8 million deaths take place all over the world per year due to cancer. May be for this reason the research pipeline of NMEs is dominated by oncology with global pharmaceutical majors’ sharp R&D focus and research spend on this particular therapy area. About 50 NMEs for the treatment of cancer are expected to be launched globally by 2015.

Current size of the Indian oncology market is around US$ 18.6 million, which is expected to be over US$ 50 million by the end of 2010; the main reason being all these are and will be quite expensive products.

A trigger point for more collaborative initiatives:

It is expected that the recent Pfizer – Biocon deal will trigger many other collaborative initiatives between the global and the local pharmaceutical companies.

Among India biotech companies, Reliance Life Sciences has already marketed Recombinant Erythropoietin, Recombinant Granulocyte Colony Stimulating Factor, Recombinant Interferon Alpha and Recombinant tissue plasminogen activator. This company has been reported to have the richest pipeline of biosimilar drugs in India. Companies like Wockhardt, Lupin, DRL and Intas Biopharmaceuticals are also in the process of developing an interesting portfolio of biosimilar drugs in India to fully encash the fast growing global opportunities.

Biosimilar global business model will fast gain ground:

Many large research-based global pharmaceutical companies, after having encountered the ‘patent cliff’, are now looking at the generic and biosimilar businesses, in a mega scale, in the emerging markets of the world, like India. Our country has witnessed major acquisitions like, Ranabaxy, Shantha Biotech and Piramal Healthcare by Daiichi Sankyo of Japan, Sanofi-aventis of France and Abbott of USA, respectively. We have also seen collaborative initiatives of large global companies like, GSK, AstraZeneca, and Pfizer with Indian companies like DRL, Aurobindo, Claris, Torrent, Zydus Cadilla, Strides Arcolab and now Biocon to reach out to the fast growing global generic and biosimilar drugs markets.

This trend further gained momentum when immediately after Biocon deal early this week, on October 21, 2010, Pfizer strengthened its footprints in the global generics market with yet another acquisition of 40% stake in Laboratorio Teuto Brasilieiro of Brazil with US $240 million to develop and globally commercialize their generic portfolio.

Conclusion:

All said and done, the recent international deal of Pfizer and Biocon to globally commercialize four biosimilar insulin and analogues, developed by the later in India, does signal a new global status for the Indian biosimilar drugs to the pharma MNCs, who were vocal critics of such drugs developed in India, until recently.

Disclaimer: The views/opinions expressed in this article are entirely my own, written in my individual and personal capacity. I do not represent any other person or organization for this opinion.