2018/10/3
For
example, the simplified registration of the classic prescription
compound preparations is taken as an example. In order to implement the
relevant provisions of the Chinese Medicine Law, in October 2017, the
CFDA organized the drafting of the “Regulations on the Simplified
Registration and Approval of Traditional Chinese Medicine Classic
Compound Preparations (Draft for Comment)” and The
draft regulations on the two filing materials were open to the public
for comments, but no official documents have yet been released.
Although
the State Administration of Traditional Chinese Medicine has recently
published the "Ancient Classics Catalogue", the specific implementation
policy for the simplified registration of the traditional Chinese
medicine compound preparations has not yet reached the stage, and the
Chinese medicine enterprises are still waiting for an anxious wait.
Article
5 of the Chinese Medicine Law “The competent department of Chinese
medicine under the State Council is responsible for the management of
Chinese medicine in the country. Other relevant departments of the State
Council are responsible for the work related to the management of
Chinese medicine within their respective functions and
responsibilities.” Basically clarified the CFDA and the management of
Chinese medicine. The industry"s regulatory status of the bureau, while other relevant departments did not clearly state. With
the opening of a new round of institutional reforms by the State
Council, the institutional setup and functions related to the
pharmaceutical industry have also undergone major changes, reflecting
the transformation of the pharmaceutical industry"s regulatory thinking
at the national level. The Chinese medicine industry will also face new
challenges and development dilemmas. .
1. Who should take this responsibility for the supervision of the whole industry chain of Chinese medicine?
The
State Council’s new round of institutional reforms established the
“National Market Supervision and Administration Bureau”. Its main
responsibilities are: responsible for comprehensive market supervision
and management, organizing comprehensive market law enforcement,
standardizing and maintaining market order, and responsible for
industrial product quality and safety, food safety, and special
equipment. Safety supervision, etc. The
establishment of the "National Drug Administration", managed by the
General Administration of Market Supervision, is mainly responsible for
the registration and implementation of supervision and management of
drugs, cosmetics and medical devices. From
the description of the basic functions of the newly established market
regulators, we do not seem to see the affiliation of the departments
involved in the cultivation and distribution of Chinese herbal medicines
in the front end of the Chinese medicine industry chain, while the
functions of the SFDA are mainly the Chinese medicine decoction pieces
and preparations. Supervision,
the quality of Chinese herbal medicines will remain the regulatory
blank of the entire Chinese medicine industry chain.
1. The Chinese medicine industry chain is long and complicated, and the supervision is difficult.
Chinese
medicine is different from chemical medicines. Its industrial chain is
longer and the industry spans a lot. From Chinese medicine seedlings to
Chinese medicine decoction pieces and Chinese patent medicines used by
patients, it has to go through many aspects such as planting and
breeding, collection, storage, decoction processing, and preparation
production. In particular, it has to go through multiple logistics links. The
Chinese medicine industry chain spans a number of functional
departments such as agriculture, forestry, food, drug supervision,
Chinese medicine bureau, and the Ministry of Commerce. The supervision
of the Chinese medicine industry is much more difficult than chemical
drugs.
Chinese
herbal medicines have both the dual attributes of agricultural products
and medicinal materials, which poses severe challenges to the
management of traditional Chinese medicine. Poor supervision will
seriously threaten the healthy development of the entire Chinese
medicine industry. Although
the "Chinese Medicine Law" clearly stipulates the quality management of
further strengthening the cultivation, collection, storage and primary
processing of Chinese medicinal materials, and clearly sets out the
specific requirements for the protection of traditional intellectual
property rights of traditional Chinese medicine. However, there are still no operational implementation rules for actual implementation.
In
2009, the Ministry of Commerce began to build a nationwide circulation
system for the circulation of Chinese herbal medicines, but mainly
focused on the traceability of circulation information. There was a lack
of third-party quality inspection and control in the middle, and the
traceability of the medicines was open, and no closed loop was formed.
The quality of the medicines was difficult to guarantee. Some
experts have suggested that if the government can introduce the system
and build a platform, encourage enterprises to establish a traceability
system for the whole quality of medicinal materials, use information
technology to force the source of medicinal materials to be managed, and
through third-party testing and full-course traceability mechanism,
explore the establishment of a Chinese herbal medicine that can talk to
the world. The
industry chain standard system will eventually achieve "the source can
be checked, the destination can be traced, the responsibility can be
studied", and it is expected that this traceability mechanism can play
its due role.
2. The quality of Chinese herbal medicine directly affects the development of Chinese medicine
Chinese
herbal medicines are the source of the Chinese medicine industry, but
there have been loopholes such as unclear standards and lax supervision. Due
to the scattered planting of Chinese medicinal materials, the original
production methods, and the lack of uniform standards and testing
methods in various links, which are greatly affected by natural
conditions, the quality of collected medicinal materials is uneven.
In
recent years, Chinese herbal medicine dyeing, sub-filling, sulfur
fumigation, mildew and anti-corrosion, excessive pesticide residues and
other chaos have emerged endlessly, seriously restricting the
development of traditional Chinese medicine decoction pieces and
preparations based on this. Even the centuries-old enterprise
Tongrentang has been repeatedly exposed. The quality of the Chinese-style pieces caused by unqualified Chinese herbal medicines. Industry
experts say that "Chinese medicine will die in Chinese medicine" is not
sensational, and "Chinese medicine will be destroyed in medicine" is
not impossible!
The
rapid development of Kampo medicine in Japan in recent years is worthy
of reference based on its emphasis on the quality standard system. Tsumura
Co., Ltd. is a company mainly engaged in the production of Kampo
medicine. Its products account for 84% of the medical Chinese medicine
market, but its medicines are highly dependent on purchasing from China. In
order to control the quality of Chinese herbal medicines, Tsumura has
set up branches in China and established a quality control system for
raw materials. It can register and manage producers, and planting,
harvesting and processing of medicinal plants, all have standard
operating procedures, and can be traced throughout. It
guarantees the controllable quality of its Chinese preparations and
provides guarantees for the efficacy and safety of the drugs.
3. Industry chain supervision loopholes will torture the supervision ability of the SFDA
The
quality problems of Chinese herbal medicines that have occurred
frequently in recent years reflect the complexity and regulatory
difficulty of the Chinese herbal medicine industry on the one hand, and
the lack of supervision over Chinese herbal medicines on the other hand.
The
quality problems of Chinese herbal medicines directly lead to the
efficacy, safety and quality of traditional Chinese medicine decoction
pieces and proprietary Chinese medicines. The damage is the efficacy and
medication safety of the majority of
patients. In
the face of the regulatory difficulties of Chinese medicine caused by
the loopholes in the upstream industrial chain of Chinese medicine, the
drug regulatory department is also in an awkward position.
According
to the newly established medical supervision bureau, the main scope of
supervision is Chinese herbal medicines and traditional Chinese medicine
preparations. Although Chinese herbal medicines have pharmaceutical
properties, there is no clear departmental commitment to their
supervision, and the existing human resources and capabilities of the
Food and Drug Administration. It is obviously not enough to take up the supervision of the entire industrial chain of Chinese medicine.
If
the regulatory problems at the front end of the Chinese medicine
industry chain cannot be effectively solved, the quality of Chinese
medicine decoction pieces and preparations is difficult to guarantee,
and relevant departments must act as soon as possible to ensure the
sound development of the Chinese medicine industry.
Second, deepening the reform of the medical insurance system will further impact the Chinese medicine industry
The
State Council’s institutional reforms newly established the “National
Medical Insurance Bureau”, which opened the era of “big medical
insurance” in the pharmaceutical industry, perfected the basic medical
insurance system for urban and rural residents, ensured the rational use
of medical insurance funds, and controlled safety, and coordinated
medical and medical insurance. The
reform of the "three medical linkages" of medicines is of great
significance to ensure the medical needs of the majority of insured
personnel more efficiently. New changes will occur in the reform of basic medical insurance supervision and payment mechanisms.
First
of all, the Medical Insurance Bureau will attack the illegal behavior
of the medical insurance industry, severely crack down on various forms
of fraudulent medical insurance fund behavior, focus on the behavior of
doctors to induce patients" needs, and the phenomenon of medical
institutions providing excessive medical services.
Second, strengthen medical insurance control fees, cost accounting will provide reference for medical insurance cost control. With
the advancement of the medical insurance system for the single-patient
payment and the DRG payment system, the implementation of the clinical
path docking accounting standard cost will make the drugs with
evidence-based medical research evidence and pharmacoeconomic advantages
more clinical advantages. The
so-called "magic drugs" and some drugs with a wide range of treatments,
ineffective or even ineffective, and large clinical doses will be
further monitored.
Third,
the Medical Insurance Bureau has become a large purchaser of the
pharmaceutical market, undertaking the formulation and adjustment of
drugs, medical service prices and charging standards, formulating
bidding procurement policies for drugs and medical consumables, and
supervising implementation, etc., and is strong in drug pricing and
bargaining. The status has been improved. With
the speeding up of the reform of the medical insurance payment system,
the method of closely binding the price of the drug to the standard of
medical insurance will definitely reduce the price of the drug.
In
summary, the pharmaceutical industry will be affected in the “big
medical insurance” environment, and the first to be the traditional
Chinese medicine sub-industry.
1. Traditional Chinese medicine generally lacks evidence-based medical research data.
The
concept of evidence-based medicine was put forward in the 1990s, which
has had a tremendous impact on the development of world medicine. It has
become an important method for medical science decision-making in many
countries and an inevitable trend in the development of modern medicine. Western
medicine is evidence-based medicine. In recent years, with the advanced
diagnosis and treatment equipment and drugs continuously applied to
domestic clinical, the development of western medicine in China has
basically achieved synchronization with developed countries, and
evidence-based medical research results have become more and more
clinically used. An important reference basis has gradually become one of the elements of medical cost accounting.
Traditional
Chinese medicine is an empirical medicine accumulated over thousands of
years. It emphasizes dialectical treatment and attention to overall
treatment. Although
many traditional Chinese medicine varieties have been clinically
applied for decades or even hundreds of years, their efficacy can be
generally recognized by doctors and patients. However, due to the lack
of large-scale evidence-based medical research, there is a certain
degree of limitation in clinical use. Under
the theoretical system of traditional Chinese medicine, the efficacy of
traditional Chinese medicine is often difficult to judge with clear
indicators, which is one of the difficulties in the implementation of
evidence-based medicine research.
Traditional Chinese medicine, which lacks evidence-based medical evidence, has become a shortcoming in clinical use. With
the implementation of a more stringent medical insurance control
system, the promotion of disease-based payment and DGR payment system,
Western medicine with evidence-based medicine support will have a more
obvious advantage, while Chinese medicine may face further restrictions
and be weakened. The trend of being marginalized.
2. Most of the ingredients of traditional Chinese medicine have complex functions and mechanisms are unknown.
Traditional
Chinese medicine compound generally has problems such as inaccurate
active ingredients, unclear path of action, and unclear mechanism of
action. This not only brings difficulties to the choice of doctors who
are accustomed to the characteristics of targeted drug delivery in
Western medicine, but also becomes a huge obstacle for Chinese medicine
to go abroad. Due to the
inaccurate composition, the toxic side effects of Chinese medicines have
been tortured to Chinese medicine companies. A
doctor from the First Affiliated Hospital of Guiyang Hospital said in
his article "Accurately Understanding the Hepatotoxicity of Traditional
Chinese Medicine" that although the research on hepatotoxicity of
traditional Chinese medicine has received more and more attention, 90%
of the toxicity of traditional Chinese medicine has not yet been
mastered, and there is a lack of systematic research.
3. Traditional Chinese medicine has not yet established a complete clinical drug guidance system.
After
years of accumulation, Western Medicine has already established a
relatively complete system for the diagnosis and treatment of diseases.
The guidelines on the first-line medication, second-line medication,
combined medication, clinical efficacy criteria, and treatment standards
are clearly defined, and have high clinical drug guidance. significance. Traditional
Chinese medicine is relatively backward in this respect. In recent
years, the Chinese Society of Chinese Medicine, the Chinese Pharmacy
Association and the Chinese Association of Integrative Medicine have
done a lot of work, and published some guidelines for the diagnosis and
treatment of traditional Chinese medicine combined with traditional
Chinese medicine, but adopted in clinical practice. Limited, the current stage of clinical drug guidance is not significant.
4. The results of re-evaluation of traditional Chinese medicine cannot be certified by relevant departments in time.
Some
excellent Chinese medicine companies have been making unremitting
efforts for many problems in the Chinese medicine industry. The
re-evaluation of traditional Chinese medicine injections started in
2009 has received positive response from many pharmaceutical companies
such as Buchang Pharmaceutical, Jiuzhitang, Kang Enbei, Tasly, Shanghai
Kaibao, Shanxi Vibration and Shenwei Pharmaceutical. However,
the results of the work done by the enterprise to invest a lot of
manpower and financial resources have been shelved due to the lack of
top-level design of the relevant management departments. So far, no
variety has been reviewed and approved.
Faced
with the difficulties in the research of evidence-based medicine in
traditional Chinese medicine, some Chinese medicine companies have also
actively tried and done a lot of research work, and some research
results are enough to support the further optimization of product
specifications. At
the same time, with the continuous upgrading of Chinese medicine
extraction and preparation technology, a large number of Chinese patent
medicine preparation processes have also been greatly improved, but the
registration of changes should be made to the regulatory authorities
according to law. It
is reported that many companies have applied for revision of the
specifications and process optimization changes for five years without
fruit, seriously damaging the enthusiasm of enterprises to carry out
re-evaluation research.
Third, related recommendations
First,
in order to ensure the implementation of the "Chinese Medicine Law"
truly achieves the legislative purpose, it strongly urges the State
Council to promulgate the "Regulations on the Implementation of the
Chinese Medicine Law" as soon as possible, further refine the relevant
legal provisions in the "Chinese Medicine Law", and clarify the relevant
ministries and commissions in Rights and responsibilities in the implementation of the Medical Law. The
State Council takes the lead in urging relevant government departments
and local government departments to clearly implement the objectives and
tasks of the Chinese Medicine Law to ensure that the Chinese Medicine
Law is implemented.
Second,
it is recommended that the State Council urge the State Administration
of Market Supervision to take the lead in the supervision departments of
agriculture, forestry, food and medicine, and jointly carry out the
supervision and quality standard system construction of the whole
industry chain of Chinese medicine to ensure the sound development of
the Chinese medicine industry from the source. For
the re-evaluation of the efficacy and safety of traditional Chinese
medicine, the agenda of the relevant departments should be mentioned. In
particular, the re-evaluation of traditional Chinese medicine
injections should establish a quality evaluation system and an
evaluation expert system as soon as possible. For enterprises and
varieties that have passed the review first, the medicines and prices
are used in medical insurance. The government should be biased towards policy.
Third,
it is recommended that the State Council urge the State Drug
Administration, the State Administration of Traditional Chinese
Medicine, the State Health and Health Commission, and the Ministry of
Science and Technology and other relevant departments to attach great
importance to the many difficulties faced by the development of Chinese
medicine at this stage, and to implement the Chinese Medicine Law. Inheriting
and developing good Chinese medicine, aiming at improving the clinical
value of traditional Chinese medicine, constructing research strategies
and technical methods that conform to the overall concept of Chinese
medicine and the characteristics of traditional Chinese medicine
compound, establish and improve the clinical diagnosis and treatment
guidelines system for Chinese medicine diseases, in order to cope with
the new medical insurance supervision The
impact of the Chinese medicine industry under the system may truly play
a role in the prevention and treatment of Chinese medicine.
Fourth,
it is recommended that the NPC initiate the legislative procedure of
the Pharmacist Law as soon as possible to clarify the functions of
clinical pharmacists in prescribing, regulating and guiding the use of
prescription drugs, so that pharmacists can become janitor of rational
drug use and safe drug use. The
pharmacist system is also the best choice to resolve the practical
problems of 80% of Chinese medicine prescription drugs prescribed by
Western medicine doctors.