Good Practice Guidance Communication Public Medicines Availability Issues - en
Good Practice Guidance Communication Public Medicines Availability Issues - en
Good Practice Guidance Communication Public Medicines Availability Issues - en
EMA/632473/2018
1. Introduction
Medicine shortages or problems relating to the availability of medicines are a multifactorial problem
involving a wide range of stakeholders, from patients and animal owners to the pharmaceutical
industry. In addition to measures to improve reporting and management of availability problems,
measures aimed at improving communication of such issues to the public play an important role in
minimising their potential impact. There is also a need for more systematic involvement and
interaction with stakeholders, especially on issues with potential impact on patients. Timely and
comprehensive information is necessary to ensure planning, rationing of existing stocks and prevention
of stockpiling. Advice to healthcare professionals and patients on potential alternative medicinal
products is often needed. This approach to communicating shortages would also help to maintain and
improve trust in the regulatory system.
Most shortages and availability problems are managed at national level; some are managed at EU
level. Processes for communication to the public are already in place at EU and national level, however
communication practices vary amongst member states and there is a need to review and consolidate
existing practices into a single document providing clear and harmonised guidance to EU national
competent authorities and EMA, promoting good practices and improving EU coordination.
This document provides EU national competent authorities and EMA with key principles and examples
of good practices for communication to the public on shortages for human and veterinary medicines as
well as availability issues due to revocations or cessations of marketing authorisations. The document
is intended for guidance only. Implementation should be a matter for EMA and EU national competent
authorities taking into account available resources and the communication needs within their territory.
• Enhancing current communication to the public and ensuring a multidisciplinary approach within
regulatory authorities;
This document is based on the results of a survey of all EU member states carried out by the HMA-EMA
task force to collect information on how issues related to shortages and availability of medicines are
measured and communicated to the public.
• When to publish
• Internal collaboration
Shortages referred to in this guidance are to be understood in the context of the harmonised definition
agreed by EMA-HMA in the “Guidance on detection and notification of shortages of medicinal products
for Marketing Authorisation Holders (MAHs) in the Union (EEA)”:
‘A shortage of a medicinal product for human or veterinary use occurs when supply does not meet
demand at a national level’.
The definition applies to all shortages that are already affecting or that are expected to affect one or
more EU member states in the future.
The below recommendations have been drawn up based on the results of the survey on existing
practices in member states and take into account the outcome of the workshop held at EMA in
November 2018 where stakeholders raised transparency and visibility of availability issues as crucial
elements for good shortage management. The recommendations also draw on EMA’s experience in
publishing information, which has been well established for medicine shortages affecting more than
one member state where an assessment and recommendations are made at EU-wide level. 1
1
https://www.ema.europa.eu/en/human-regulatory/post-authorisation/medicine-shortages/shortages-catalogue
Criteria for EMA to • shortages of medicines (that are centrally or nationally authorised)
make information
where the shortage affects more than one member state and EMA’s
publicly available
scientific committees have given recommendations to healthcare
professionals (a DHPC).
Format and tools • EU national competent authorities and EMA should use a
systematic listing (usually in the form of a catalogue, one for human
medicines and one for veterinary medicines) to communicate on
shortages.
• MAH
Timing of publication • Publication should occur once the shortage has been confirmed by the
marketing authorisation holder for the affected medicine and, if
applicable, recommendations have been agreed. The exact timing may
be determined at national level taking into account national
requirements. However, early communication to the public is
encouraged and important to allow for adequate planning and to
ensure continuity of care.
• A record of supply problems that have been resolved should be kept for
a set period of time, i.e. at least 6 months.
Collaboration with • EU national competent authorities and EMA should consider involving
stakeholders relevant stakeholder groups (in particular patients’, consumer and
healthcare professional organisations) on availability issues, especially
in those with higher potential impact on patient care. Wholesale
distributors may also be involved for questions on sourcing of
medicines. Involvement should aim at obtaining advice and feed-back
on potential suitable alternatives and recommendations, if applicable,
as well as feedback on whether key messages are well communicated
and how to ensure adequate dissemination.
Internal collaboration • For the assessment and communication of shortages, advice and
within the network consultation may be sought where needed from the Single Point of
Contact (SPOC) network. 2
2
Single Point of Contacts (SPOC) are contact points at each human and veterinary medicines regulatory agency in the
EU/EEA responsible for sharing information with other SPOCs and coordinating subsequent actions in relation to shortages
and availability of authorised medicines. They have been nominated by the Task Force on Medicines Availability with the
aim to facilitate better prevention, identification, management and communication of shortages and availability issues.
Format and tools • EU national competent authorities and EMA should use a
systematic listing (usually in the form of a catalogue, one for human
medicines and one for veterinary medicines) to communicate on other
availability issues.
• MAH
In May 2018, EMA and HMA carried out a survey to map public communication on shortages and
availability of human medicines 3 by EU regulators. The purpose was to assess, qualitatively and
quantitatively, how EU regulators communicate to the public on shortages and supply issues.
The results of the survey build on existing knowledge on communication practices gained from
previous work which led to the development of EMA’s public catalogue on shortages.
The survey comprised a questionnaire with 7 questions on the public communication practices in
individual EU member States.
The questionnaire focused on public communication activities to the general public, mainly in relation
to shortages.
The survey was sent to the Single Point of Contact (SPOC) nominated for human and veterinary
medicines at the relevant regulatory authority for each Member state.
For human medicines, the survey was sent to 33 SPOCs (28 EU Member states, including 2 SPOCs for
Germany to cover the two regulatory agencies (BfArM and PEI), including EMA and 3 for EEA). Of
these, 30 responded. The response rate was 90%.
For veterinary medicines, the survey was sent to 30 SPOCs and 27 responded. The response rate was
90%.
• Amongst the authorities that publish information, a majority (69%) do not have set criteria for
publication and publish on any shortage that is reported. Only selected member states have criteria
for publication based on the duration of the shortage and the criticality of the medicine.
• Most authorities also communicate on other issues such as revocation or suspension of medicines
(50%) or withdrawals of medicines due to commercial reasons (70%). However this information is
not necessarily reflected in the listing of shortages and various other communication tools may be
used (such as press releases for individual availability issues).
• Globally, a similar picture for human medicines can be seen as in the EU. In the USA, the
Association of Health System Pharmacists and the Food and Drug Administration publish a web
listing of medicine shortages.4,5 Both listings include information on current and resolved shortages
as well as other information for patients and consumers. The websites contain concise information
on products affected by the shortage, the reason for the shortage, suitable alternatives and the
expected resolution date. The information on the FDA website covers ‘medically necessary’
medicines as well as those considered non-medically necessary for which the FDA has received
multiple requests for information. However it does not include information on shortages of brief
duration.
• For veterinary medicines, the picture is similar with fewer EU regulatory authorities publishing
information with only 52% publishing information on shortages on their website.
3
This guidance applies only to human medicines at present, however a similar approach will be taken to address veterinary
medicines.
4
http://www.ashp.org/menu/DrugShortages/CurrentShortages.aspx
5
https://www.fda.gov/drugs/drug-safety-and-availability/drug-shortages
Key recommendations
• any shortage of a medicine that affects the whole country (nationwide issues rather than local
issues).
The survey found the following results for the formats and tools used by regulatory authorities:
• For human medicines, 88% of authorities who already publish information on availability issues,
usually do this in the form of a systematic listing, i.e. a catalogue format. The majority of
authorities (69%) do not have set criteria for publication and publish all reported shortages. Only
selected member states have criteria for publication related to the duration of the shortage and the
criticality of the medicine.
• In addition to the shortage catalogue EU regulatory authorities (national competent authorities and
EMA) use a variety of communication tools to inform on availability issues: Press releases (57%),
newsletters (30%) and social media (23%).
• For veterinary medicines, the proportion of authorities that use a catalogue listing is 64%. Most of
those (64%) do not use any selection criteria when publishing information. Communication tools
used by veterinary regulatory authorities are press releases professional organisations and
professional journals.
A catalogue listing is ideal for providing information on shortages as it allows quick one-stop
referencing and is ideal for stakeholders looking for specific information. Presentation of information
can be in summarised in bullet-point format and colour coded to highlight new and more relevant
shortages.
It is envisaged that in the future a single portal will give access to all information on availability issues
from EU regulatory authorities. While the single portal is being built, as an interim solution, both the
HMA webpage (https://www.hma.eu/598.html) and the EMA Webpage
(https://www.ema.europa.eu/en/human-regulatory/post-authorisation/medicine-shortages/shortages-
catalogue) provide a listing of links to national shortage catalogues.
• shortages of medicines affecting the country. In some instances this communication complements
information issued centrally by EMA. Ideally regulatory authorities should not apply selection
criteria for publication and should communicate on any nationwide shortage (as per the agreed
EMA-HMA definition).
EMA should use a systematic listing in a catalogue to communicate on the following issues:
• shortages of medicines (centrally or nationally authorised) where the shortage affects more than
one member state and EMA’s scientific committee has given recommendations (a DHPC).
• For availability issues with a high impact on patients or animals, EU national competent authorities
and EMA should consider using additional communication tools (press releases, newsletter or social
media) and reflect the information on the homepage. High-patient impact is usually associated
with safety-related issues or unavailability of a critical medicine.
• Regardless of the tools used, all availability issues should be accessible on a single webpage.
When the decision to publish a shortage in a catalogue has been made, the information to publish
should be brief, concise but sufficient for healthcare professionals and patients or veterinarians and
animal owners to identify the medicine involved and take the required actions. The information is
based on information published by those member states who already publish (see annex I) and is
summarised in the table below:
• MAH
Communication to the public needs to be timely and up-to-date to ensure effective planning. The
survey found that:
• EU national competent authorities and EMA always update their published information on shortages,
as new information becomes available and when the shortage is resolved.
• In addition, some member states (35%) review their information at set time intervals (ranging
from daily to monthly).
• Once a shortage is resolved, most authorities remove the information (62%) and only 38% keep
this information on their website.
• For veterinary medicines, 71% of EU regulatory authorities also update their information as new
information becomes available. 27% review the information at set time intervals. Once a shortage
is resolved 57% of authorities remove the information from the website.
Key recommendations
• For shortages: publication should occur once the shortage has been confirmed by the MAH and
recommendations have been agreed (if applicable). The exact timing may be determined at
national level taking into account national requirements. Updates should be issued to reflect any
potential change in the recommendations. For supply situations that have been resolved this needs
to be reflected as soon as notification is received that the shortage is resolved. This could be by
updating the catalogue listing to mark the medicine as available again. It is good practice to keep a
record of supply problems that have been resolved for a set period of time, i.e. at least 6 months.
• For human medicines most EU national competent authorities and EMA mainly target healthcare
professionals (100%) and patients (92%) in communication. Industry and other regulators are also
targeted in 60% of the cases.
• Healthcare professionals and patients, veterinarians and animal owners are the key audience who
require timely accurate and up-to-date information from public health authorities on availability
issues. This is particularly important as information from other sources on availability issues is
sparse and early knowledge is important to allow for early planning and adjustment of clinical
practice. Other regulators and industry (including wholesale distributors) are less often targeted
but would also benefit from early information.
Key recommendations
• Public communication by EU national competent authorities and EMA should primarily target
patients and healthcare professionals for human medicines and veterinarians and animal owners
for veterinary medicines.
• Other regulators and industry (including wholesale distributors) should also be targeted.
• To address this wide audience the language of any communication should be public friendly,
concise and using lay terms.
• For human medicines 54% of authorities who communicate on availability issues overall also
engage with their target audience in their communication. For veterinary medicines it is only 26%
who engage with their target audience. In both cases, it is not clear whether this is seeking active
advice or rather for dissemination only.
• EU national competent authorities and EMA use a variety of communication tools to disseminate
information on availability issues: Communication through relevant organisations’ channels
(patients, consumers, healthcare professionals or learned societies) (63% for human medicines
and 48 % for veterinary medicines), press releases (57% and 48% for veterinary medicines),
professional/medical journals (57% for human medicines and 48% for veterinary medicines),
media (press, TV) (33% for human medicines and 30% for veterinary medicines), newsletters
(30% for human medicines and 20% for veterinary medicines), social media (23% for human
medicines and 26% for veterinary medicines).
Some EU authorities feed information about shortages into the national electronic patient health
systems (EMR) and electronic prescribing systems (7% for human medicines and 11% for
veterinary medicines). Thus, healthcare professionals and veterinarians will get instant alerts
about shortages when prescribing or dispensing the medicine in question.
• EU national competent authorities and EMA should consider involving relevant stakeholder groups
(patients, consumers and healthcare professional organisations) on availability issues especially in
those with higher potential impact on patient care.
• Wholesale distributors may also be involved for questions on sourcing of medicines. Involvement
should aim at obtaining advice and feed-back on potential suitable alternatives and
recommendations when applicable as well as for ensuring that the key messages are well
communicated and ensuring adequate dissemination.
• EU national competent authorities and EMA should consider sharing the final public communication
for information with marketing authorisation holders for information.
• EU national competent authorities and EMA should explore ways to multiply their communication
through relevant organisations’ channels (patients, consumers, animal owners, veterinarians,
healthcare professionals or learned societies), professional/medical journals, media (press, TV),
newsletters, and potentially electronic prescribing systems. Other means to explore to interlink
shortage information could be electronic product information.
The survey found that most communication materials are prepared by the departments involved in the
assessment of the availability issue (i.e. inspection) but often also involve communication colleagues
(57% for human medicines, 30% for veterinary medicines).
In addition during the assessment and communication of a shortage member states should seek advice
and consultation where needed using the the Single Point of Contact (SPOC) network.
Based on the survey feedback, the following initiatives were identified in selected EU member states as
examples of public communication and collaboration which could potentially be implemented in other
member states:
• Alerts (pop-ups) on shortages in electronic patient records and electronic prescription systems to
alert doctors and pharmacists at the point of prescribing or dispensing the medicine in question.
• Collaboration with the most commonly used sources of medicinal product information among
healthcare professionals (i.e. electronic pharmaceutical compendiums). In some countries
compendiums publish real-time alerts on important safety issues, shortage situations etc.,
providing instant information for the patient or physician.
It is proposed that public communication practices in EU member states on availability issues will be
reviewed regularly and this guidance will be updated accordingly and as needed.
Table 1: Information provided in shortage catalogues for human medicines by individual EU authorities
Austria X X X X X X X X X
Belgium X X X X X X X X
Bulgaria X X X X X X X
Croatia X X X X X X X X X
Czech Republic X X X X X
Denmark X X X X X X X
Estonia X X X X X X
Finland X X X X X X X
Germany (PEI) X X X X X X X X X
Germany (BfArM) X X X X X X X X X X X
Greece X X X X X X X X
Hungary X X X X X X X X X
Iceland X X X X X X
Italy X X X X X X X X X X
Latvia X X X X X X X
Lithuania X X X X X X X X X X
Netherlands X
Norway X X X X X X X X X X
Romania X X X X X X X X
Slovak Republic X X X X X X X
Slovenia X X X X X
Spain X X X X X X X X
Sweden X X X X X X X X X
EMA X X X X X X X X
Austria X X X X X X X
Belgium X X X X X X X X X
Denmark X X X X X X X
Estonia X X X X X X
Finland X X X X X X
Germany
X X X X
(PEI)
Greece X X X X X X X
Liechtenstein X X X
Norway X X X X X X X X X X
Slovenia X X X X X
Spain X X
Sweden X X X X X X X
UK X X X X X X