European Cancer Organisation's Response to EU Pharmaceutical Strategy Roadmap Consultation

The European Cancer Organisation welcomes the commitment to producing a new EU Pharmaceutical Strategy, and the accompanying commitment to public consultation on its content.

This is an encouraging recognition of not only the range of concerns that exist in relation to such issues as access, affordability, availability, transparency, and the research, incentive and regulation frameworks in operation. It also acknowledges the opportunities being highlighted by new tools, approaches and proposed paradigms, such as better use of data tools and patient reported outcomes.

This response includes comment relating to the current research landscape for pharmaceutical (and other) treatment in Europe, noting opportunities to reduce burden and improve access to clinical trials. In responding to this consultation, we wish to strongly express that in respect of cancer, as in other disease conditions, treatment is multi-modal and best outcomes for the patient are achieved by a range of interventions, including multidisciplinary care.

So while welcoming attention to pressing policy needs for the pharmaceutical domain we encourage policy makers at both European and national level to be ever mindful of the need for attention to all components of care and treatment. Distortion of policy attention in this respect, should be avoided. Policy makers should always strive for an holistic and comprehensive approach to improving outcomes for patients.

Related to this, we emphasise the importance of the new EU Pharmaceutical Strategy not sitting in isolation. It should be considered and understood to be part of a broader need to re-orientate and improve health systems generally. This includes an overall need to improve the balance of incentives to ensure that access to improvements in ALL treatment modalities is achieved, and across the care continuum i.e. in respect to prevention, detection, diagnosis and follow up care. For this reason it is important that the Pharmaceutical Strategy seek coherence with other EU initiatives such as digital, research and industrial strategies, and of course, Europe’s Beating Cancer Plan. A common overall social purpose and vision should be pursued by these strategies, encompassing improved access of citizens and patients to improved treatments and care.

The European Cancer Organisation's response articulates seven (7) key recommendations:

  1. Ensure the new EU Pharmaceutical Strategy is ambitious and comprehensive

  2. Remodel the incentive structures further towards value and outcomes, and support innovation in all areas of treatment and care

  3. Resolve the current political impasse on the HTA cooperation proposal

  4. Leverage data and new tools in a more coherent and powerful way

  5. Reduce bureaucracy in the clinical trial landscape

  6. Urgently address the medicines shortages crisis

  7. Work with medical and healthcare professional societies and patient associations as equal partners in creating the best possible changes

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