Collaboration For Sustainable Excellence – The Name of The Game in The New Normal

The union minister of health and family welfare of India recently invited Japanese companies to collaborate with Indian companies on research and innovation in emerging therapies, like precision medicine, cell and gene therapy, biological products, and on the utilization of digital tools and technologies. This was reported on May 16, 2023.

Underscoring this objective, the minister articulated, “such collaboration on research and innovation would help enhance the domestic availability and affordability of these innovative therapeutic options.”

The area of research and drug innovation in emerging therapies and on the utilization of digital tools and technologies has emerged as one of the top focus areas of the country in the new normal. Currently, the Indian pharmaceutical industry is primarily focused on manufacturing generic medicines, exporting bulk drugs, and supplying active pharmaceutical ingredients.

Thus, this goal can be quickly achieved through global collaborations – at a time when India plays a pivotal role in improving health outcomes worldwide by serving as a dependable supplier of affordable and high-quality generic drugs. The country is currently providing approximately 60 per cent of the global vaccine supply, and 20-22 per cent of generic exports. Importantly, ‘In the battle against the Covid-19 pandemic, India has supplied essential drugs to around 185 countries,” he underscored.

Interestingly, after the Covid-19 pandemic, there has been a significant shift in the approach of both Indian and multinational drug companies towards business collaboration. This article will focus on this area with recent Indian examples, culled from available reports. However, before delving into this space, let me also point out that drug MNCs operating in India are also changing focus on their India operations, as reported in recent times.

Drug MNCs operating in India are also changing business focus: 

This was brought to the fore by several recent reports. For example, in February 2022, The Economic Times reported: 

  • In February, Novartis India passed on the sales and distribution rights of three of its established brands to Dr Reddy’s Labs and terminated the employment of 400 staffers.  
  • In October, US drugmaker Eli Lilly sold the marketing rights of its anti-diabetes drugs to Cipla and laid off 120 employees in India. 
  • Around the same time, Danish pharma company Lundbeck decided to exit India as part of its global strategy. 

However, their key goal remains - delivering new patient-perceived value – not just incremental, but in quantum measure for business growth.

The need for increased collaboration and shared resources:

Against the above backdrop, it appears to me that the pandemic has highlighted the need for accelerated cooperation and sharing resources to address global healthcare challenges, effectively. As a result of which, both Indian and MNC drug companies are recognizing the benefits of working together, and are actively seeking collaboration opportunities in the following areas. 

  • Access to Emerging Markets: Indian pharma companies have a strong presence in emerging markets due to their cost-effective generic drug manufacturing capabilities. Multinational companies recognize the potential of these markets and are looking to collaborate with Indian firms to gain access to these regions. By partnering with Indian companies, MNCs can tap into local expertise, distribution networks, and regulatory knowledge. 

- Example: In 2022, Cadila Healthcare entered into a collaboration with Novartis to develop and commercialize multiple oral solids and injectable generics for global markets, including emerging markets.

  • Research and Development: Collaboration in research and development (R&D) activities has become crucial for drug companies. MNCs bring advanced research capabilities, cutting-edge technologies, and substantial financial resources, while Indian companies offer a skilled workforce and a cost-effective environment for R&D. By joining forces, they can pool their strengths and accelerate the discovery and development of new drugs and therapies.

- Example: In 2021, Bharat Biotech collaborated with the Washington University School of Medicine in St. Louis and the International AIDS Vaccine Initiative (IAVI) to develop a novel vaccine candidate for HIV. This collaboration aims to combine the strengths of all three organizations to advance HIV vaccine research.

  • Manufacturing and Supply Chain: The pandemic exposed vulnerabilities in global supply chains, particularly in the pharmaceutical sector. Collaborations between Indian and MNC drug companies can help diversify manufacturing locations and strengthen supply chain resilience. Indian companies’ expertise in large-scale generic drug production can complement the specialized manufacturing capabilities of multinational firms.

- Example: In 2021, Hetero entered into a partnership with the Russian Direct Investment Fund (RDIF) to manufacture the Sputnik V Covid-19 vaccine in India. This collaboration aimed to increase the production capacity of the vaccine to meet global demand.

  • Regulatory Compliance: Regulatory compliance is a critical aspect of the pharmaceutical industry. Indian companies have been working closely with regulatory authorities to meet global standards and gain approvals for their products. Collaborating with Indian companies enables MNCs to leverage their understanding of regulatory processes, navigate local regulations efficiently, and ensure compliance with diverse international requirements.

- Example, in 2022, Biocon Biologics partnered with Adagio Therapeutics, a US-based biotechnology company, to develop and commercialize an antibody treatment for COVID-19. This collaboration involves regulatory support from both companies to navigate global regulatory processes.

  • Market Expansion: Collaborations provide an opportunity for both Indian and multinational companies to expand their market presence. Indian companies can benefit from the MNCs’ established marketing networks, while MNCs can leverage the Indian companies’ extensive distribution channels and market knowledge. Joint ventures and partnerships facilitate market entry, improve market penetration, and help companies capture a larger share of the global pharmaceutical market. 

- Example: In 2022, Torrent Pharmaceuticals collaborated with Swedish multinational company Handicare Group AB to distribute and market Handicare’s range of mobility solutions in India. This collaboration enables Torrent Pharmaceuticals to diversify its product portfolio and expand into the healthcare mobility market. 

  • Technology and Innovation Sharing: Collaborations foster knowledge exchange between Indian and multinational drug companies. MNCs can share their technological advancements and research findings, while Indian companies can contribute their insights and expertise in managing large-scale production. Such knowledge-sharing initiatives can drive innovation, improve manufacturing processes, and enhance overall operational efficiency. 

- Example: In 2022, Glenmark Pharmaceuticals entered into a collaboration with the Canadian multinational company SaNOtize Research and Development Corp. to develop a nitric oxide nasal spray for the treatment of COVID-19. This collaboration combines Glenmark’s expertise in drug development with SaNOtize’s innovative nitric oxide platform.

  • Intellectual Property and Licensing: Collaboration often involves the exchange of intellectual property (IP) rights and licensing agreements. Indian companies possess a vast pool of generic drug formulations and manufacturing capabilities. MNCs can license their patented drugs or technology to Indian partners for production and distribution in specific markets. These licensing arrangements benefit both parties by expanding the product portfolio and maximizing revenue potential. 

- Example: In 2021, Glenmark Pharmaceuticals signed a licensing agreement with Canadian biopharmaceutical company Xenon Pharmaceuticals to develop and commercialize a potential treatment for epilepsy. This collaboration involves the licensing of Xenon Pharmaceuticals’ proprietary technology for the development of a novel therapeutic product.

Conclusion:

Overall, as the recent trends indicate, the post-pandemic era has accelerated initiatives of strategic collaboration between Indian and multinational drug companies. By leveraging each other’s strengths and with shared value and resources, these collaborations aim to drive innovation, address global healthcare challenges, and deliver affordable and accessible healthcare solutions to patients worldwide. And thereby, will help deliver a unique patient experience.

Additionally, the examples, as available from published sources, highlight an increasing number of such recent collaborations, besides operational re-focusing by several MNC drug majors in India.  

These strategic steps clearly emphasize their joint efforts to drive innovation, expand their market presence, and address critical healthcare needs. From this angle, I believe, for sustainable business excellence and for staying relevant to customers in the new digital world, one of the top focus areas for Indian pharma players deserves to be strategic collaboration initiatives.

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.

Indian Pharma Leadership: A Glimpse of Changing Mindset Post Pandemic

A recent survey of physicians, published by the CMI Media Group, provides fresh evidence that Medical Representatives meetings with the physicians that have become trickier to arrange since COVID-19, still continue. This was also reported in the March 29, 2023, edition of Fierce Pharma 

The survey objective was to capture what are physicians’ preferences, when asked whether they want to meet with pharmaceutical reps in person more often, less often or in equal frequency as pre-pandemic. Some of the key findings of this recent study include the following: 

  • 25% of the doctors, reportedly said they are reducing face-to-face interactions.
  • With 10% of doctors responding never seeing reps, it could be challenging for many pharma players to call on these doctors via the traditional in-person route. 
  • However, another 51% of physicians replied that the frequency of their in-person interactions is unchanged from pre-pandemic and 14% seeing reps more frequently than before. 
  • It also found that digital channels have potential to compensate for the pullback from in-person meetings.  
  • Most of such doctors prefer receiving resources for talking to reps via video or phone. 
  • Interestingly, 70% and 78% of physicians said digital resources are more convenient, educational and valuable than remote rep visits. 

Let me hasten to add that the above study was carried out mostly in the European countries. Thus, in today’s deliberation, I would focus mainly on two areas:

1. How is this situation evolving in India and the way some of the Indian majors are gearing up to convert this challenge into opportunities to gain a competitive edge, and 

2. What, in my view, needs to be a pharma marketing leadership mindset change, alongside its traits for effective change management, to excel in the changing market dynamics. More importantly, whether or not this trend is also visible within some of the Indian pharma majors.

The comparable situation in India:

I find some interesting data on the Indian pharma industry in this regard, from several public domain. These indicate that while some physicians may be open to virtual interactions with medical representatives during and after the COVID pandemic, there are also examples of physicians who were not too keen to meet with pharma reps. These seem to be for several reasons. Some reported examples are as follows:

  • Delhi Medical Association (DMA), which represents more than 15,000 doctors in the Indian capital, has banned pharma med reps from entering hospitals or meeting with doctors in person. The DMA has cited concerns about the influence of pharma reps on prescribing practices, besides potential conflict of interest.
  • With over 3.5 lakh memberships, the Indian Medical Association (IMA) appears to have discouraged physicians from meeting with MRs. Instead, the association has urged them to rely on evidence-based information and guidelines while prescribing drugs to patients.
  • Some private hospital chains in India have also restricted or banned pharmaceutical sales representatives from interacting with physicians. This includes Fortis Healthcare, which has banned pharma reps from its hospitals in Delhi and Mumbai, and Max Healthcare, which has restricted interactions to virtual meetings only. 
  • The Indian Psychiatric Society (IPS) has issued guidelines for its members recommending that they avoid interactions with pharma med reps. The IPS has stated that interactions with pharma reps can create conflicts of interest and bias in prescribing practices and may not always provide accurate and reliable information.
  • Some physicians in India are increasingly turning to online platforms to access unbiased information about medications and treatments, rather than relying on information provided by reps. Online platforms such as Medscape and Docplexus provide physicians with access to up-to-date medical information and peer-reviewed research studies.

With a changing mindset, some Indian players are facing this challenge:

Evidence suggests that there is a growing awareness among several physicians in India about the potential biases and conflicts of interest that can arise from interactions with pharma representatives. While virtual interactions and non-promotional information may still be acceptable to some physicians, others may prefer to rely on more objective sources of information or avoid interactions with pharma reps altogether. 

There are several examples in this area highlighting how some Indian pharma majors are trying to stay ahead of the technology curve. As reported, some specific responses of Indian pharmaceutical companies to the restrictions on interactions with physicians

include, Cipla’s launch of a digital platform called CiplaMed to provide healthcare professionals with access to non-promotional medical information and education.

Post-pandemic changes in the mindset and outlook of marketing leadership:

As I see, the COVID pandemic experience has brought significant changes in the mindset and outlook, especially, in the marketing leadership of several Indian drug companies. One key reason could be the success requirements in contemporary pandemic market dynamics are going through a metamorphosis. Which is why the emerging situation demands new approaches and strategies for success.  

Many pharma marketing leaders are now trying for early identification of even the nuanced change requirements relevant to their respective organizations for sustainable business success in the current paradigm. Some of these requirements were identified as:

Agility and Adaptability: The pandemic has highlighted the importance of being agile and adaptable. Pharma marketing leaders must now be able to quickly pivot their strategies and tactics based on changing market conditions and consumer needs.

For example, Cipla adapted quickly to the changing market conditions during the pandemic by ramping up the production of essential medicines and medical supplies. The company also developed innovative product solutions, such as a portable mechanical ventilator, to address the critical shortage of medical equipment during the pandemic. 

Similarly, Lupin demonstrated agility by diversifying its product portfolio to include COVID-19 testing kits, PPE, and other pandemic-related products, besides helping to develop innovative solutions to address the pandemic, such as a telemedicine platform that enables patients to consult with doctors remotely. 

Digitalization: The pandemic has accelerated the shift towards digitalization in the pharma industry. Marketing leaders must be able to effectively leverage digital channels such as social media, online advertising, and telemedicine to reach and engage with consumers.

For instance, Dr. Reddy’s Laboratories leveraged digital technologies to enhance its customer engagement efforts. The company developed a mobile app called - Medznat.’ It is touted as a one-stop solution for physicians, medical students and other healthcare professionals to stay abreast with the latest medical knowledge. It offers an umbrella of offerings, such as news, scientific articles, case studies, regulatory updates, medical events, drug flashcards, and many more. The app offers some key features, such as: personalized quality content, any time, anywhere and patient education materials.

Customer-centricity: The pandemic has increased the need for customer-centricity in the pharma industry. Marketing leaders must now prioritize customer needs and preferences and tailor their marketing strategies accordingly.

Sun Pharma appears to be another leading example that, reportedly, demonstrated customer-centricity by developing patient assistance programs that provide financial support to patients who cannot afford their medications. The company also partnered with healthcare providers to develop disease management programs that improve patient outcomes and reduce healthcare costs.

Data AnalyticsThe pandemic has highlighted the importance of leveraging data science and data analytics in the pharma industry. Marketing leaders must be able to effectively analyze data to understand customer behavior and preferences and to measure the effectiveness of their marketing campaigns. 

The name of Glenmark Pharmaceuticals comes to the top of mind in this area. The Company is now using data analytics to analyze sales data and identify trends in the market. The company is also using analytics to track physician interactions and ensure compliance with government regulations.

Continuous Innovation: The pandemic has created new opportunities for innovation in the marketing domain. Thus, marketing leaders must be willing to experiment with new approaches and technologies to stay ahead of the competition and meet changing customer needs.

As is known to many, Zydus Cadila has developed a COVID-19 vaccine and has also been working on the development of a COVID-19 drug. The company has also been involved in the development of new drugs to treat various other diseases.

Collaboration: The pandemic has underscored the need for collaboration across the healthcare ecosystem. Pharma marketing leaders need to work closely with other stakeholders, including healthcare providers, payers, patient advocacy groups, and government agencies, to develop solutions that meet the needs of all stakeholders.

In this area, Biocon, for instance, collaborated with government agencies and NGOs to distribute COVID-19 vaccines and treatments to underserved communities. The company also worked with healthcare providers and patient advocacy groups to develop education and awareness campaigns that promote better health outcomes.

Similarly, Dr Reddy’s Laboratories partnered with IQVIA to rollout IQVIA’s OCE application to its entire field force and marketing users in India to drive more meaningful and impactful customer engagement.

 Conclusion: 

These are a few areas with examples from a few Indian pharma majors that would give a sense of how the mindset and outlook of their marketing leadership teams are changing. This is happening, as is widely believed, after having experienced the last two years’ unprecedented disruptions in business and customer behavior.

It’s equally interesting to note that our domestic drug industry, which was not traditionally well known for effecting significant proactive changes – is transforming itself while stepping into the post-pandemic world – in pursuit of excellence. 

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.

 

 

With More Patients Preferring Telehealth Pharma Marketing Needs Retooling

Even after six months of COVID-19 pandemic, the omnipresent chaos, general unease and apprehensions about a yet unpredictable future continues in all countries, including India. In absence of vaccines and proven medicines to address the disease, wearing face mask, maintaining social distancing and frequent hand sanitizing, remain the primary measures for all to combat this unprecedented health crisis.

The rapid spread of the lethal Coronavirus has not only impacted lives and livelihoods, besides changing the health care ecosystem – with a silver lining, though. The pandemic has instilled a sense of urgency – an accelerated speed – in the entire value chain of the health care systems, including the pharma industry.

To contain the rapid spread of the disease – many physicians, Governments and even patients themselves, are being encouraged to leverage technological platforms, for various non-Covid related medical needs. Realizing that there no other working alternatives in this situation, even most skeptical doctors and patients are now resorting to video consultations.

Consequently, ‘Telemedicine’, in different forms, has started growing in leaps and bounce. Its spin-off benefits favor the patients – better care at lower costs, sans any further strain on the existing health care systems. Along with many others, the Bloomberg article of April 10, 2020 – ‘Coronavirus Should Finally Smash the Barriers to Telemedicine,’ also expects it to grow, not just during the pandemic, but much beyond.

Echoing the World Health Organization (W.H.O) on the need to promote telemedicine in this health crisis, Niti Aayog of India also acknowledged, ‘‘Telemedicine: A Blessing In Disguise In Time Of COVID-19.’ It further added, ‘With the arrival of the COVID-19 pandemic, telemedicine has finally gained momentum. Telemedicine providers reported an overnight increase in demand, acceptance among doctors, paramedics, and consumers.’

As patient-doctor interactions are now expanding – from personal visits to physicians to remote telehealth, is there a need for recomposing notes of the pharma marketing playbook - to excel in the new world order?  This article would focus on this specific area of leveraging ‘The Break in The Clouds’.

Telemedicine and its key primary driver: 

Telemedicine’– often called telehealth or e-medicine, in simple term, involves the remote delivery of health care services, when both doctors and patients are not physically present at the same place. It includes, patient examination, doctor consultations, diagnosis, treatment and remote monitoring, over the technology enabled modern communication infrastructure.

Although, telemedicine is not a new concept, it was not very popular for various reasons, till Covid pandemic offered no other viable alternatives to non-Covid patients. The article – ‘COVID-19: The rise and rise of telemedicine,’ published in the MobileHealthNews on May 27, 2020, also vindicates this point. It reconfirmed: ‘Telemedicine has experienced a huge surge in adoption over the past few months, during the coronavirus pandemic.’

Even Frost & Sullivan’s recent analysis, ‘Telehealth – A Technology-Based Weapon in the War Against the Coronavirus’ of May 13, 2020, found the demand for telehealth technology rising dramatically, as the COVID-19 pandemic continues to disrupt the delivery of healthcare worldwide. Thus, ongoing stringent requirements of wearing face masks and maintaining social distancing to contain the virus spread, will continue to drive the growth telemedicine as the preferred way of accessing healthcare.

Indian perspective of increased online access to health care:

Practo’s Insight Report of June 20, 2020, titled, ‘How India accessed health care in the last three months,’ has revealed some interesting India-specific data in this area. This study was based on transactions of 500 million Indians accessing health care online, during March 1, 2020 to May 31, 2020 period. It found, while COVID-19 continued to remain India’s topmost concern, ‘telemedicine has helped doctors – patients stay connected, as people practiced physical/social distancing.’ This resulted into a ‘500 percent increase in online doctor consultations,’ in that time frame. Other important findings of this report include:

  • 80 percent of all telemedicine users experienced it for the first time.
  • 44 percent of the teleconsultations were from non-metro cities.
  • In-person doctor visits dropped by 67 percent.
  • Indians consulted their doctors 2 times per month, using telemedicine.

The surge in teleconsultations in India, reportedly, follows the long-pending telemedicine guidelines which were finally issued by the Ministry of Health and Family Welfare, in collaboration with NITI Aayog and Board of Governors, Medical Council of India (MCI).

Could ‘Telehealth’ be a game changer even beyond Covid time?

Many experts in this area believe so. For example, the article – ‘Telehealth could be a game-changer in the fight against COVID-19. Here’s why,’ published the World Economic Forum on May 01, 2020, makes some important observations. It suggests: ‘Beyond the pandemic, governments, insurers and healthcare providers need to work together to ensure that the innovation sparked by this crisis endures and accelerates. Post-crisis, telehealth can still help alleviate the pressures posed by healthcare resource shortages, the growing elderly population and issues with healthcare accessibility.’

The article, published in the Invest in India website of the Government of India, on April 10, 2020, emphasized the relevance and benefits of ‘Telemedicine’ in India – even after Covid Time. Conceding, in-person health care delivery in the country is challenging, given the large geographical distances and limited resources, it enumerated all-time relevance and the key advantages of ‘Telemedicine,’ as hereunder:

  • Saves cost, effort and other related inconveniences, especially of rural patients, as they need not travel long distances for obtaining consultation and treatment, also limiting burden on the secondary hospitals.
  • Ensures higher likelihood of maintenance of records and documentation, minimizing the possibility of missing out advice from the doctor and other health care staff.
  • Provides safety to patients and health workers’, especially where there is a risk of contagious infections.
  • The doctor has an exact document of the advice provided via tele-consultation. Written documentation increases the legal protection of both the parties.
  • Enables the availability of vital parameters of the patient available to the physician with the help of medical devices such as blood pressure, blood glucose, managing.
  • Provides equal access to quality care to all, minimizing inequity and barriers to access.

The official guidelines for telemedicine practices in the country are aimed at allowing registered medical practitioners to providing remote consultation. Under this backdrop, Telemedicine is expected to remain in a growth trajectory, even in India. Accordingly, there arises a need for recomposing notes of the pharma marketing playbook - to excel in the new world order. 

Increasing telehealth preference prompts marketing strategy retooling:

As I wrote on July 10, 2020, pharma leaders need to leverage the art of turning challenges into opportunities, now – especially when telehealth is at the threshold of playing a pivotal role in the health care delivery systems. In this scenario, traditional pharma brand-demand generation strategies are unlikely to deliver expected business results, anymore. Pharma players would need to work out fresh and effective marketing models, in-sync with patients changing health care related needs. Conceiving, strategizing, and delivering changing patient-value based content, effectively, using modern omnichannel platforms, would be the new ballgame.

‘Telehealth is more than a channel for delivering care’:

As the ZS Insights article – ‘While telehealth continues to evolve, pharma needs to keep an eye on the future,’ published on August 03, 2020 reiterated: ‘Telehealth is more than a channel for delivering care, it reflects a fundamental shift in how brands reach patients and physicians.’ Following are some key points worth noting:

  • Until now, in-person delivery of care has anchored brand marketing in the sales territory-based geographic perspective. Whereas, telehealth platforms are free of sales territory-based geographic distinction.
  • Physicians now provide telehealth services to patients in two ways, having different implications for pharma players:
  1. Vertically integrated virtual practices, such as, PractoLybrate and others in India.
  2. Brick-and-mortar offices, where physicians provide telehealth visits through     FaceTime, WhatsApp, Zoom and other teleconference platforms.

It is envisaged, alongside patients avoiding the risk of contracting Covid, tangible benefits of lower treatment cost and escaping long waiting time to meet the doctors physically, will encourage people switching to Telemedicine, for an indefinite period.

Collaborative, not standalone pharma marketing may not work better:

In the era of telehealth or Telemedicine, the common ground where patients, doctors and drug companies can meet, would be the telemedicine platforms. These may well be some popular telemedicine apps for e-consultation, such as, Meddo, Practo, mFine and others in India. Besides, there lies an opportunity for pharma companies also to develop custom-made ones, for installation by doctors.

These platforms can be effectively leveraged with collaborative approaches – for content delivery to physicians, patients and other stakeholders, at the appropriate time and places. There are various innovative ways to prepare a grand strategy for this purpose – ‘tailor-made’ for each company. And astute pharma marketers should play the role of ‘master tailors.’

Conclusion:

Meanwhile, as on October 11, 2020 morning, India recorded a staggering figure of 7,051,413 of Coronavirus cases with 108,371 deaths. The daily number of new cases appeared to have slowed down during the last week.

Nonetheless, the unprecedented and savage onslaught of the new Coronavirus has unsettled the pharma industry, as it disrupted the old normal of the world. At the same time, many people have also demonstrated high resilience, grit and innovative mind to keep moving, in a relatively orderly manner – amid an omnipresent chaos, as it were. In the health care space, the need for responding to non-Covid related health emergencies, pushed people to experiment with not much used before – telehealth or  Telemedicine.

It worked and continues receiving support from all concerned. Its other major benefits also surfaced – as a breath of fresh air. It’s unlikely that people will let it go, in the foreseeable future, which has a great implication to pharma industry. With more patients and doctors increasingly preferringTelemedicine, in various ways, pharma marketing needs retooling its strategy kit – by expanding into collaborative approaches with Telemedicine providers.

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.

 

The Curious Conundrum of New Drugs Approval Process

Fathoming the details of just a short span of time, not going beyond the last 10 years, I find from the published data that many new drugs, such as, Alatrofloxacin, Aprotinin, Drotrecogin alfa, Lumiracoxib, Propoxyphene, Rofecoxib, Rosiglitazone, Sibutramine, Tegaserod, Tetrazepam, were withdrawn from a number of important global markets. Quite a few of those were withdrawn also from the world market.

The key reason for almost all these withdrawals was serious safety concerns for the patients while using these medicines. Interestingly, some of these new molecules were withdrawn even after attaining the blockbuster status, such as Rofecoxib.

Tens of thousands of patients have died only because of this reason, according to reports.

It is widely believed by the experts in this area, if full public disclosure of the entire data of drug clinical trials was made, most of these new drugs would not have seen the light of the day and without putting many patients’ health safety in jeopardy.

All this is a part of a curious conundrum in the new drug approval process, across the world, for various reasons. In this article, I would try to dwell on this issue.

Voices against this ‘unethical practice’ getting louder:                                             

On December 22, 2015, ‘CBC News’ published an interesting article, titled “Researcher issues ‘call to action’ to force release of hidden drug safety data: Bringing drug industry data into the light of public scrutiny.”

The article echoed the same belief of other global experts and, in fact, went a step forward. It categorically reiterated, if full disclosure of the entire data of drug clinical trials is made public, medical practice might have been quite different.

To drive home this point, the article cited the example of the arthritis drug rofecoxib (Vioxx), which has been linked to tens of thousands of deaths related to heart attacks.

It highlighted, although this risk was very much known to the regulatory authority of the United States, the relevant data was not released to the public for an impartial scrutiny.

Quoting different sources, the paper observed, almost half of the drug trials remain secret and the studies that are published, overwhelmingly report results that make the drug in question look good.

Independent experts’ views differed from the innovator companies:

In some cases, when researchers were able to see what is hiding in the filing cabinets of the drug innovator companies, a different picture altogether emerged on the overall profile of those drugs.

One group looked at 12 antidepressants, comparing the published studies with the internal US FDA assessments. They found that 94 per cent of the published studies were positive, as compared to 51 per cent, when they included all of the studies assessed by the drug regulator.

Based on a detailed study, the authors concluded, without considering all the data, drug effectiveness can often be exaggerated, leading doctors and patients to assume that the medications work better than what they actually do. The ongoing practice of the drug players may help them to significantly diminish the risks, related to the benefits offered by these medicines.

A few months ago, another group analyzed the data from an unpublished drug company study about the effect of Paxil on teen depression and found that the drug did not work and was not safe for the patients. This result completely contradicted the original, unpublished study on this drug.

A crusader emerged in Canada:

Interestingly, the same article, as above, states that Mathew Herder , the health law associate professor at Dalhousie University in Halifax, Canada is now taking up the fight. He is now “calling on other doctors, researchers and journalists to bombard Ottawa with their own demands for drug industry data, using the new legislative lever called the ‘Protecting Canadians from Unsafe Drugs Act,’, which was passed late last year in Canada. 

He has also created a template to help doctors, researchers and journalists access drug safety data at Health Canada. Herder reportedly could even include biomedical researchers, doctors who prescribe medicine, investigative journalists pursuing questions about drug safety, and other activists and patient groups.

This example is worth imbibing elsewhere.

The Rule Books are in place, though with loopholes:

To curb such alleged patient unfriendly practices of the innovative drug manufacturers, while obtaining the marketing approval of new drugs, various rules and procedure were put in place, by various authorities.

I shall deliberate below a few of these rules, and enough loopholes therein, enabling the interested parties to hoodwink the external experts, at the cost of patients.

International Clinical Trials Registry Platform:

Much before Herder, following a ministerial summit on Health Research in 2004, a World Health Assembly Resolution passed in 2005 called for unambiguous identification of all interventional clinical trials. This resolution led to the establishment of the ‘World Health Organization (WHO) International Clinical Trials Registry Platform’. It collates information on trials that have been notified in a network of clinical trial registries.

According to W.H.O, “The registration of all interventional trials is a scientific, ethical and moral responsibility”.

In the latest version of the Declaration of Helsinki, it reiterates, “Every research study involving human subjects must be registered in a publicly accessible database before recruitment of the first subject.”

It unambiguously states, “Researchers have a duty to make publicly available the results of their research …. Negative and inconclusive as well as positive results must be published or otherwise made publicly available”.

Understandably, W.H.O statement underscores, “There is an ethical imperative to report the results of all clinical trials, including those of unreported trials conducted in the past.”

It is worth mentioning here that on January 1, 2015, by a new policy on publication of clinical data, ‘European Medicines Agency (EMA)’ also decided to proactively publish all clinical reports submitted as part of marketing-authorization applications for human medicines, by the by pharmaceutical companies.

Big Pharma's serious apprehensions on greater Public transparency:  

Before finalization of the above policy, EMA sought comments on its draft from various state holders. On September 5, 2013, in its remarks on the draft, ‘The European Federation of Pharmaceutical Industries and Associations, EFPIA’ expressed its apprehension about the public health safety oriented proactive move by the EMA as follows:

“We are worried by a move towards greater transparency of clinical trials data that appears to be putting transparency – at whatever cost – ahead of public health interests. Our detailed response to the EMA draft policy speaks to this concern. While EFPIA values other voices and opinion in the conversation surrounding clinical trials data, we believe there are better alternatives than what the EMA is presenting.” 

This is of course understandable. That said, it also gives satisfaction to note that EMA did not wilt under any pressure on this score, whatever the anecdotal might of the external force be. 

Gross non-compliance, endangering patients health safety:

Although, the standards and requirements of “Public Disclosure of Clinical Trial Results” have been well specified now, and even in most of the Big Pharma websites one can find disclosure norms of clinical trial data, their overall compliance on the ground, is still grossly inadequate, endangering patients’ health safety.

An article published in the BMJ Open on November 12, 2015 titled, “Clinical trial registration, reporting, publication and FDAAA compliance: a cross-sectional analysis and ranking of new drugs approved by the FDA in 2012”, well captured the magnitude of this issue. 

Nevertheless, the study analyzed just a subset of drugs approved in a single year, 2012. The researchers only examined whether clinical trials were registered and reported, not what that data suggested about how the drugs worked.

The paper reported the results as follows:

“In 2012, the US FDA approved 39 novel new medicines, known as NMEs, and 35 novel drugs. Combining these lists, the FDA approved a total of 48 new drug entities, 15 of which were sponsored by 10 large pharmaceutical or biotechnology companies with market capitalizations valued over US$19 billion. A total of 342 trials were conducted to gain regulatory approval of the 15 drugs, 24 of which were excluded from our analysis, leaving 318 trials involving 99 599 participants relevant to our study, a median of 17 trials per drug.”

Based on the findings, the authors concluded asunder:

“Trial disclosures for new drugs remain below legal and ethical standards, with wide variation in practices among drugs and their sponsors. Best practices are emerging. 2 of our 10 reviewed companies disclosed all trials and complied with legal disclosure requirements for their 2012 approved drugs. Ranking new drugs on transparency criteria may improve compliance with legal and ethical standards and the quality of medical knowledge.”

Simultaneously, The Washington Post in an article of November 12, 2015, titled, “How pharma keeps a trove of drug trials out of public view”, summarized this report by highlighting to the general public that one third of the clinical trial results that US FDA reviewed to approve drugs made by large pharmaceutical companies in 2012, were never publicly reported. 

Unethical practices skewing medical science:

On July 25, 2015, ‘The Economist’ published an article titled, “Spilling the beans’. It highlighted again that the failure to publish the results of all clinical trials is skewing medical science. 

This article also brought to the public attention that half of the clinical trial results are never published over several decades. It broadened the discourse with the observation that this specific unwanted practice, distorts perceptions of the efficacy of not just drugs, but devices and even surgical procedures too, in a well planned and a systematic manner. What is most important to note is, it has seriously compromised with patients’ health interest, across the world. 

It keeps on happening, as there are no firm obligations on the part of drug companies for making public disclosure of all such data, both for and against, though all these data are required to be filed with the regulatory authorities. Hence, the overall assessment of the drugs, weighing all pros and cons, is just not possible for any outside expert agency.

For granting necessary marketing approval, the designated authorities, at least theoretically, ensure that the drugs are reasonably safe, and have, at least, ‘some beneficial effects’. However, the prescribing doctors would continue to remain ignorant of the untold facts, the article states. 

According to ‘The Economist’, although in the United States the relevant laws were modified, way back in 2007, to address this issue, it still remains as a theory, the actual practices in this regard are mostly not so.

Despite vindication no tangible outcome yet:

As I said earlier, this fact got vindicated through extensive research by the ‘BMJ Online’ article and many other contemporary medical publications. 

For example, the evidence released earlier on  April 10,  2014 by the Cochrane Collaboration of London, UK, also shows that a large part of negative data generated from the clinical trials of various drugs were not disclosed to the public. 

Again, like Vioxx, though the US FDA was aware of all such data, for a well known drug Tamiflu, unfortunately the prescribing doctors were not. As a result, the U.S. Centers for Disease Control and Prevention (CDC), which doesn’t have the same access to unpublished data as the regulators, recommended this medicine not being able to evaluate it holistically. 

However, as the findings from the unpublished clinical trials eventually surfaced, CDC expressed serious apprehension on the overall efficacy of Tamiflu, quite contrary to the assessment of the concerned big pharma player.

Hence, despite quite a large number of vindications by the experts, no tangible outcome has been noticed on this pressing issue, just yet.                                                               

Conclusion:

Based on all this discussion, the moot question that springs up: Why do the doctors still prescribe such drugs, even after being aware of the full facts?

In this regard, an article titled, “Big Pharma Plays Hide-The-Ball with Data”, published in the Newsweek on November 13, 2014 raised a very valid question. 

It commented, even if Tamiflu does nothing, and there is just a slight chance of life-threatening side effects, why was it approved by the US FDA, in the first place?

Even more intriguing is: Why do the doctors continue prescribing these, especially after the Cochrane Collaboration took the Tamiflu’s maker, Roche, to task about many of its claims, in April 2014.

Incidentally, the Cochrane Collaboration is widely regarded as one of the most rigorous reviewers of health science data. It takes results of multiple trials, looks for faults and draws conclusions. It doesn’t accept funding from businesses with a stake in its findings.

The answer to this question may perhaps be too obvious to merit any elaborate discussion here. 

Be that as it may, this curious conundrum of ‘New Drug Approval’ with ‘Partial Public Disclosure of Clinical Trial Data’ needs to effectively addressed, without further delay. If not, patients’ health interest would continue to get seriously compromised with the continuation of prevailing laxity in its implementation process by the drug regulators.

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.

R&D: Is Indian Pharma Moving Up the Value Chain?

It almost went unnoticed by many, when in the post product patent regime, Ranbaxy launched its first homegrown ‘New Drug’ of India, Synriam, on April 25, 2012, coinciding with the ‘World Malaria Day’. The drug is used in the treatment of plasmodium falciparum malaria affecting adult patients.  However, the company has also announced its plans to extend the benefits of Synriam to children in the malaria endemic zones of Asia and Africa.

The new drug is highly efficacious with a cure rate of over 95 percent offering advantages of “compliance and convenience” too. The full course of treatment is one tablet a day for three days costing less than US$ 2.0 to a patient.

Synriam was developed by Ranbaxy in collaboration with the Department of Science  and Technology of the Government of India. The project received support from the Indian Council of Medical Research (ICMR) and conforms to the recommendations of the World Health Organization (WHO). The R&D cost for this drug was reported to be around US$ 30 million. After its regulatory approval in India, Synriam is now being registered in many other countries of the world.

Close on the heels of the above launch, in June 2013 another pharmaceutical major of India, Zydus Cadilla announced that the company is ready for launch in India its first New Chemical Entity (NCE) for the treatment of diabetic dyslipidemia. The NCE called Lipaglyn has been discovered and developed in India and is getting ready for launch in the global markets too.

The key highlights of Lipaglyn are reportedly as follows:

  • The first Glitazar to be approved in the world.
  • The Drug Controller General of India (DCGI) has already approved the drug for launch in India.
  • Over 80% of all diabetic patients are estimated to be suffering from diabetic dyslipidemia. There are more than 350 million diabetics globally – so the people suffering from diabetic dyslipidemia could be around 300 million.

With 20 discovery research programs under various stages of clinical development, Zydus Cadilla reportedly invests over 7 percent of its turnover in R&D.  At the company’s state-of-the-art research facility, the Zydus Research Centre, over 400 research scientists are currently engaged in NCE research alone.

Prior to this in May 14, 2013, the Government of India’s Department of Biotechnology (DBT) and Indian vaccine company Bharat Biotech jointly announced positive results, having excellent safety and efficacy profile in Phase III clinical trials, of an indigenously developed rotavirus vaccine.

The vaccine name Rotavac is considered to be an important scientific breakthrough against rotavirus infections, the most severe and lethal cause of childhood diarrhea, responsible for approximately 100,000 deaths of small children in India each year.

Bharat Biotech has announced a price of US$ 1.00/dose for Rotavac. When approved by the Drug Controller General of India, Rotavac will be a more affordable alternative to the rotavirus vaccines currently available in the Indian market. 

It is indeed interesting to note, a number of local Indian companies have started investing in pharmaceutical R&D to move up the industry value chain and are making rapid strides in this direction.

Indian Pharma poised to move-up the value-chain:

Over the past decade or so, India has acquired capabilities and honed skills in several important areas of pharma R&D, like for example:

  • Cost effective process development
  • Custom synthesis
  • Physical and chemical characterization of molecules
  • Genomics
  • Bio-pharmaceutics
  • Toxicology studies
  • Execution of phase 2 and phase 3 studies

According to a paper titled, “The R&D Scenario in Indian Pharmaceutical Industry” published by Research and Information System for Developing Countries, over 50 NCEs/NMEs of the Indian Companies are currently at different stages of development, as follows:

Company Compounds Therapy Areas Status
Biocon 7 Oncology, Inflammation, Diabetes Pre-clinical, phase II, III
Wockhardt 2 Anti-infective Phase I, II
Piramal Healthcare 21 Oncology, Inflammation, Diabetes Lead selection, Pre-clinical, Phase I, II
Lupin 6 Migraine, TB, Psoriasis, Diabetes, Rheumatoid Arthritis Pre-clinical, Phase I, II, III
Torrent 1 Diabetic heart failure Phase I
Dr. Reddy’s Lab 6 Metabolic/Cardiovascular disorders, Psoriasis, migraine On going, Phase I, II
Glenmark 8 Metabolic/Cardiovascular /Respiratory/Inflammatory /Skin disorders, Anti-platelet, Adjunct to PCI/Acute Coronary Syndrome, Anti-diarrheal, Neuropathic Pain, Skin Disorders, Multiple Sclerosis, Ongoing, Pre-clinical, Phase I, II, III

R&D collaboration and partnership:

Some of these domestic companies are also entering into licensing agreements with the global players in the R&D space. Some examples are reportedly as follows:

  • Glenmark has inked licensing deals with Sanofi of France and Forest Laboratories of the United States to develop three of its own patented molecules.
  • Domestic drug major Biocon has signed an agreement with Bristol Myers Squibb (BMS) for new drug candidates.
  • Piramal Life Sciences too entered into two risk-reward sharing deals in 2007 with Merck and Eli Lilly, to enrich its research pipeline of drugs.
  • Jubilant Group partnered with Janssen Pharma of Belgium and AstraZeneca of the United Kingdom for pharma R&D in India, last year.

All these are just indicative collaborative R&D initiatives in the Indian pharmaceutical industry towards harnessing immense growth potential of this area for a win-win business outcome.

The critical mass:

An international study estimated that out of 10,000 molecules synthesized, only 20 reach the preclinical stage, 10 the clinical trials stage and ultimately only one gets regulatory approval for marketing. If one takes this estimate into consideration, the research pipeline of the Indian companies would require to have at least 20 molecules at the pre-clinical stage to be able to launch one innovative product in the market.

Though pharmaceutical R&D investments in India are increasing, still these are not good enough. The Annual Report for 2011-12 of the Department of Pharmaceuticals indicates that investments made by the domestic pharmaceutical companies in R&D registered an increase from 1.34 per cent of sales in 1995 to 4.5 percent in 2010. Similarly, the R&D expenditure for the MNCs in India has increased from 0.77 percent of their net sales in 1995 to 4.01 percent in 2010.

Thus, it is quite clear, both the domestic companies and the MNCs are not spending enough on R&D in India. As a result, at the individual company level, India is yet to garner the critical mass in this important area.

No major R&D investments in India by large MNCs:

According to a report, major foreign players with noteworthy commercial operations in India have spent either nothing or very small amount towards pharmaceutical R&D in the country. The report also mentions that Swiss multinational Novartis, which spent $ 9 billion on R&D in 2012 globally, does not do any R&D in India.

Analogue R&D strategy could throw greater challenges:

For adopting the analogue research strategy, by and large, the Indian pharma players appear to run the additional challenge of proving enhanced clinical efficacy over the known substance to pass the acid test of the Section 3(d) of the Patents Act of India.

Public sector R&D:

In addition to the private sector, research laboratories in the public sector under the Council for Scientific and Industrial Research (CSIR) like, Central Drug Research Institute (CDRI), Indian Institute of Chemical Technology (IICT) and National Chemical Laboratory (NCL) have also started contributing to the growth of the Indian pharmaceutical industry.

As McKinsey & company estimated, given adequate thrust, the R&D costs in India could be much lower, only 40 to 60 per cent of the costs incurred in the US. However, in reality R&D investments of the largest global pharma R&D spenders in India are still insignificant, although they have been expressing keenness for Foreign Direct Investments (FDI) mostly in the brownfield pharma sector.

Cost-arbitrage:

Based on available information, global pharma R&D spending is estimated to be over US$ 60 billion. Taking the cost arbitrage of India into account, the global R&D spend at Indian prices comes to around US$ 24 billion. To achieve even 5 percent of this total expenditure, India should have invested by now around US$ 1.2 billion on the pharmaceutical R&D alone. Unfortunately that has not been achieved just yet, as discussed above.

Areas of cost-arbitrage:

A survey done by the Boston Consulting Group (BCG) in 2011 with the senior executives from the American and European pharmaceutical companies, highlights the following areas of perceived R&D cost arbitrage in India:

Areas % Respondents
Low overall cost 73
Access to patient pool 70
Data management/Informatics 55
Infrastructure set up 52
Talent 48
Capabilities in new TA 15

That said, India should realize that the current cost arbitrage of the country is not sustainable on a longer-term basis. Thus, to ‘make hay while the sun shines’ and harness its competitive edge in this part of the world, the country should take proactive steps to attract both domestic as well as Foreign Direct Investments (FDI) in R&D with appropriate policy measures and fiscal incentives.

Simultaneously, aggressive capacity building initiatives in the R&D space, regulatory reforms based on the longer term need of the country and intensive scientific education and training would play critical role to establish India as an attractive global hub in this part of the world to discover and develop newer medicines for all.

Funding:

Accessing the world markets is the greatest opportunity in the entire process of globalization and the funds available abroad could play an important role to boost R&D in India. Inadequacy of funds in the Indian pharmaceutical R&D space is now one of the greatest concerns for the country.

The various ways of funding R&D could be considered as follows:

  • Self-financing Research: This is based on:
  1. “CSIR Model”: Recover research costs through commercialization/ collaboration with industries to fund research projects.
  2. “Dr Reddy’s Lab / Glenmark Model”: Recover research costs by selling lead compounds without taking through to development.
  • Overseas Funding:  By way of joint R&D ventures with overseas collaborators, seeking grants from overseas health foundations, earnings from contract research as also from clinical development and transfer of aborted leads and collaborative projects on ‘Orphan Drugs’.
  • Venture Capital & Equity Market:  This could be both via ‘Private Venture Capital Funds’ and ‘Special Government Institutions’.  If regulations permit, foreign venture funds may also wish to participate in such initiatives. Venture Capital and Equity Financing could emerge as important sources of finance once track record is demonstrated and ‘early wins’ are recorded.
  • Fiscal & Non-Fiscal Support: Should also be valuable in early stages of R&D, for which a variety of schemes are possible as follows:
  1. Customs Duty Concessions: For Imports of specialized equipment, e.g. high throughput screening equipment, equipment for combinatorial chemistry, special analytical tools, specialized pilot plants, etc.
  2. Income tax concessions (weighted tax deductibility): For both in-house and sponsored research programs.
  3. Soft loans: For financing approved R&D projects from the Government financial institutions / banks.
  4. Tax holidays: Deferrals, loans on earnings from R&D.
  5. Government funding: Government grants though available, tend to be small and typically targeted to government institutions or research bodies. There is very little government support for private sector R&D as on date.

All these schemes need to be simple and hassle free and the eligibility criteria must be stringent to prevent any possible misuse.

Patent infrastructure:

Overall Indian patent infrastructure needs to be strengthened, among others, in the following areas:

  • Enhancement of patent literacy both in legal and scientific communities, who must be taught how to read, write and file a probe.
  • Making available appropriate ‘Search Engines’ to Indian scientists to facilitate worldwide patent searches.
  • Creating world class Indian Patent Offices (IPOs) where the examination skills and resources will need considerable enhancement.
  • ‘Advisory Services’ on patents to Indian scientists to help filing patents in other countries could play an important role.

Creating R&D ecosystem:

  • Knowledge and learning need to be upgraded through the universities and specialist centers of learning within India.
  • Science and Technological achievements should be recognized and rewarded through financial grants and future funding should be linked to scientific achievements.
  • Indian scientists working abroad are now inclined to return to India or network with laboratories in India. This trend should be effectively leveraged.

Universities to play a critical role:

Most of Indian raw scientific talents go abroad to pursue higher studies.  International Schools of Science like Stanford or Rutgers should be encouraged to set up schools in India, just like Kellogg’s and Wharton who have set up Business Schools. It has, however, been reported that the Government of India is actively looking into this matter.

‘Open Innovation’ Model:

As the name suggest, ‘Open Innovation’ or the ‘Open Source Drug Discovery (OSDD)’ is an open source code model of discovering a New Chemical Entity (NCE) or a New Molecular Entity (NME). In this model all data generated related to the discovery research will be available in the open for collaborative inputs. In ‘Open Innovation’, the key component is the supportive pathway of its information network, which is driven by three key parameters of open development, open access and open source.

Council of Scientific and Industrial Research (CSIR) of India has adopted OSDD to discover more effective anti-tubercular medicines.

Insignificant R&D investment in Asia-Pacific Region:

Available data indicate that 85 percent of the medicines produced by the global pharmaceutical industry originate from North America, Europe, Japan and some from Latin America and the developed nations hold 97 percent of the total pharmaceutical patents worldwide.

MedTRACK reveals that just 15 percent of all new drug development is taking place in Asia-Pacific region, including China, despite the largest global growth potential of the region.

This situation is not expected to change significantly in the near future for obvious reasons. The head start that the western world and Japan enjoy in this space of the global pharmaceutical industry would continue to benefit those countries for some more time.

Some points to ponder:

  • It is essential to have balanced laws and policies, offering equitable advantage for innovation to all stakeholders, including patients.
  • Trade policy is another important ingredient, any imbalance of which can either reinforce or retard R&D efforts.
  • Empirical evidence across the globe has demonstrated that a well-balanced patent regime would encourage the inflow of technology, stimulate R&D, benefit both the national and the global pharmaceutical sectors and most importantly improve the healthcare system, in the long run.
  • The Government, academia, scientific fraternity and the pharmaceutical Industry need to get engaged in various relevant Public Private Partnership (PPP) arrangements for R&D to ensure wider access to newer and better medicines in the country, providing much needed stimulus to the public health interest of the nation.

Conclusion:

R&D initiatives, though very important for most of the industries, are the lifeblood for the pharmaceutical sector, across the globe, to meet the unmet needs of the patients. Thus, quite rightly, the pharmaceutical Industry is considered to be the ‘lifeline’ for any nation in the battle against diseases of all types.

While the common man expects newer and better medicines at affordable prices, the pharmaceutical industry has to battle with burgeoning R&D costs, high risks and increasingly long period of time to take a drug from the ‘mind to market’, mainly due to stringent regulatory requirements. There is an urgent need to strike a right balance between the two.

In this context, it is indeed a proud moment for India, when with the launch of its home grown new products, Synriam of Ranbaxy and Lipaglyn of Zydus Cadilla or Rotavac Vaccine of Bharat Biotech translate a common man’s dream of affordable new medicines into reality and set examples for others to emulate.

Thus, just within seven years from the beginning of the new product patent regime in India, stories like Synriam, Lipaglyn, Rotavac or the R&D pipeline of over 50 NCEs/NMEs prompt resurfacing the key unavoidable query yet again:

Has Indian pharma started catching-up with the process of new drug discovery, after decades of hibernation, to move up the industry ‘Value Chain’?

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.