Table. Summary of the Methodologies and Recommendations Informing the Development of the New Regulatory Model Based on the Principles of the WHO GBT .
Study Number | Aim | Method | Key Recommendations From the Study | Corresponding Elements Within the New Regulatory Model (Figure 2) | Corresponding GBT Parameters Endorsing the Elements of the Model |
Study 17 | Examine the regulatory review process applied by the MCC | A questionnaire was completed by the MCC to describe the organisation of the authority, record key milestones and timelines in the review process and to identify GRevPs |
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The following 5 areas for improvement were identified to be common amongst the recommendations from the 6 studies conducted. These 5 elements encompass all the recommendations from each study and were deemed to be critical in informing the development of the new regulatory model | The GBT is used to evaluate each of the nine component regulatory functions of the regulatory system against a series of sub-indicators For the purpose of this study reference was made specifically to the sub-indicators of the regulatory functions of the national regulatory systems and marketing authorisation |
Study 210 | Provide the historical context supporting the new regulatory environment in South Africa and the transition from the MCC to SAHPRA | A review was conducted of the history of the enabling legislation supporting the establishment of SAHPRA and the similarities and differences between the MCC and SAHPRA were compared |
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Quality Measures
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RS05.01: Top management intervention is required to demonstrate commitment and leadership to develop and implement a QMS |
RS05.02: The quality policy, objectives, scope and action plans for the establishment of the QMS must be in place and be communicated to all levels | |||||
RS05.04: Enough competent staff must be assigned to develop, implement and maintain the QMS | |||||
RS03.05: The NRA is required to promote GRPs | |||||
MA04.10: The formal implementation of GRevPs is required | |||||
Study 38 | Evaluate the timelines of the milestones of the South African review process and the overall approval process for NASs | Data identifying the milestones and overall approval times for NASs registered by the South African Agency during 2015–2018 were collected and analysed |
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Monitoring and Evaluating
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MA04.06: The establishment of timelines for the assessment of applications and an internal tracking system are required to follow the targeted timeframes |
MA06: The use of a mechanism to monitor regulatory performance and output is required | |||||
MA06.02: The establishment and implementation of performance indicators for registration and/or market authorisation activities is required | |||||
RS10.01: The monitoring, supervision and review of the performance of the NRA is required using key performance indicators | |||||
Study 417 | Compare the registration process and the regulatory review model of the MCC to that of 4 other similar-sized regulatory authorities | A questionnaire was used to describe the structure, the registration process, good review and decision-making practices of the MCC Similar questionnaires were also completed and validated by Australia’s TGA, Canada’s Health Canada, Singapore’s HSA and Switzerland’s Swissmedic |
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Apply a Risk-Based Approach to Review
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RS03.04: Reliance on the decisions of other mature NRAs through documented policy, procedures and/or mechanisms must be formalised |
RS09.01: NRAs are encouraged to participate in a regional and/or global network in order to promote convergence and harmonisation efforts | |||||
Study 518 | Review the PARs available in the public domain against the UMBRA BR Template using a case study approach Evaluate the approach initiated by SAHPRA to document and communicate the BR decision |
PARs for 3 NASs published by NRAs in Australia, Europe, Canada, and the United States were compared with the validated UMBRA BR Template to evaluate the BR decision documentation A focus group discussed the use of PARs as potential knowledge management tools for stakeholder understanding of regulatory decision-making The SAHPRA approach to document and communicate the BR decisions was evaluated |
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Transparency and Communication
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MA05: NRAs must ensure that mechanisms exist to promote transparency, accountability and communication |
MA05.01: NRAs are required to ensure the availability of a website or other official publication that is regularly updated | |||||
MA05.02: NRAs are required to publish an updated list of all medicines granted market authorisation | |||||
RS09.04: NRAs are required to publish information on marketed medical products, authorised companies and licensed facilities | |||||
MA05.03: NRAs are required to publish the summary technical evaluation reports for approved applications of marketing authorisation in the public domain | |||||
RS09.03: NRAs are required to publish the NRA decisions related to regulatory activities in the public domain | |||||
Study619 | Identify criteria and current practices for implementing an abridged review process and understanding barriers and enablers in utilising reliance models | A questionnaire was completed by 6 NRAs to determine criteria and current practices for implementing an abridged review process Two focus group discussions were conducted on the practical implementation of an abridged review process based on GRelP |
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Training and Education
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MA03.01: Sufficient competent staff (education training skills and experience) should be assigned to perform marketing authorisation |
MA03.03: The development, implementation and annual updating of the training plan is required | |||||
MA03.04: Performing and maintaining records of staff training activities is required | |||||
RS05.14: The establishment of a mechanism to evaluate and demonstrate the effectiveness of training activities is required |
Abbreviations: WHO GBT, World Health Organization Global Benchmarking Tool; BR, Benefit-Risk; FRPs, facilitated regulatory pathways; GRPs, good regulatory practices; GRelPs, good reliance practices; GRevPs, good review practices; SOPs, standard operating procedures; HSA, health science authority; ICT, information and communications technology; MCC, Medicines Control Council; NASs, new active substances; NRA, national regulatory authority; PARs, public assessment reports; QMS, quality management system; SAHPRA, South African Health Product Regulatory Authority; TGA, therapeutic goods administration; UMBRA, Universal Model for Benefit Risk Assessment; ZAPAR, South African Public Assessment Report; ODMPs, quality decision-making practices.