A framework to support new product introduction in national health systems
Registration
Ensuring new products are registered for use in-country
In order for products to be used in national programs, they must comply with national or donor regulatory requirements. While suppliers take responsibility for submitting dossiers for product registration, processes can often be subject to bottlenecks that cause delays in access to new products. National treatment programs and partners may be able to assist with communication and addressing challenges in the regulatory process.
Registration Checklist
Ensure suppliers have filed dossiers with the National Drug Regulatory Authority (NDRA) to register new ARV products
Monitor registration status and progress with NDRAs
When appropriate, apply for a registration waiver or expedited review process while national registration is pending
Ensure the new product is included in the country’s essential medicines list and standard treatment guidelines, where applicable
Support Ministry of Health and NDRA collaboration to communicate public health priorities and address common registration bottlenecks (as outlined in the HIV New Product Introduction Guide)
Registration Tools and Resources
Ministries of Health and implementing partners should monitor product development timelines and dossier submissions for products required for use in the national program, stringent regulatory authority (SRA) approvals, and product registrations with National Drug Regulatory Authorities (NDRAs). Clear communication of national program priorities to NDRAs can help with prioritizing and accelerating review and registration of those products which offer the greatest public health benefits. In addition to NDRA registration, program implementers should also ensure that the product is included in the country's essential medicines list if that is a requirement for importation. This section outlines resources that can be useful in the product registration process.
Stringent Regulatory Authority Approval
A Stringent Regulatory Authority (SRA) is a medicines regulatory authority that enforces and ensures medicines developed by manufacturers and suppliers are up to international standards. Some donors require specific SRA approvals to be in place before products can be procured (e.g. Procurement from the U.S. President's Emergency Plan for AIDS Relief requires approval from the U.S. Food and Drug Administration). The CHAI ARV approvals database can be referenced for information on US FDA approved/tentatively approved products and products that have received WHO PQ or GF ERP.
WHO Prequalification Program
The WHO Prequalification of Medicines Programme (WHO PQ) helps ensure that medicines supplied by procurement agencies meet acceptable standards of quality, safety, and efficacy. WHO maintains a list of prequalified products on their website. Please note that while WHO PQ is not a Stringent Regulatory Authority, products with WHO PQ are also listed in the CHAI SRA approval database.
National Drug Regulatory Authorities
National Drug Regulatory Authorities (NDRAs) are mandated to ensure that all medicines and medical devices used in countries are safe, effective, and of high quality. It is important to ensure that the drug is registered in-country through an NDRA. It may be possible to obtain an import waiver to enable importation of SRA-approved products prior to NDRA review and approval to avoid delays in patient access to new products. This document outlines an illustrative process and requirements for national programs to request a waiver to make products accessible while national registration is underway.
Global Fund Sourcing and Management of Health Products
The Global Fund provides regular updates on ARVs found to be quality assured, including updates on quality assurance issues and changes to procurement guidance. These updates include products approved by the Expert Review Panel, an independent body of technical experts hosted by the WHO’s Quality and Safety of Medicines Department.
