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Policy
Orphan drugs introduced in Korea are 'increasing'
by
Lee, Tak-Sun
Oct 14, 2020 06:22am
As the orphan drug market has recently emerged as Blue Ocean, the introduction of Orphan Drugs by global pharmaceutical companies is increasing in Korea. In particular, as the MFDS has given a PMS of up to 11 years to Orphan Drugs through amendment of regulations, the market monopoly is expected to be prolonged. According to the MFDS on the 12th, two of the recently approved Orphan Drugs have been granted PMS for more than 10 years. PMS, which means re-examination of new drugs, is subject to investigation conditions after being marketed during the period, but it also has a data protection function, blocking entry of generic drugs, and thus gaining market monopoly. Since 2017, the MFDS has been granting PMS for 10 years, up to 11 years, in recognition of its contribution to the development of Orphan Drugs with fewer patients and no alternative drugs, and 11 years are granted for pediatric clinical trials. Until last year, only two drugs were given PMS for 10 years. The two drugs are 'NexoBrid', which removes the eschar without harming viable tissue by BL&H in 2018 and 'Raxone', a treatment for visual impairment caused by Leber Hereditary Optic Neuropathy by DKSH Korea in 2019. In August, Pfizer's PMS of 'Vyndamax (Amyloid Cardiomyopathy (ATTR-CM) treatment)' was given 10 years, and in September Kyowa Kirin's PMS of ‘Crysvita' was given 11 years. Crysvita is a treatment for hereditary hypophosphatemia (XLH), and PMS has been recognized for 10 to plus 1 year, up to 11 years because of the results of pediatric clinical trials. Accordingly, Crysvita is exclusive in the market, with data protected until September 16, 2031. An official from the MFDS said, "PMS is granted for 10 years, up to 11 years for orphan drugs that do not have alternative drugs. " In addition, he explained, "In order to support the development of orphan drugs with a small number of patients, we are operating the existing PMS grant period (6 years for new drugs and 4 years for improved drugs)."
Policy
Copayment unchanged for using reimbursed Dupixent
by
Lee, Hye-Kyung
Oct 14, 2020 06:22am
When processing atopic dermatitis patients visiting tertiary hospitals, the healthcare institutes should now be aware that the 100-percent outpatient copayment rate does not apply to the severe case patients. On Oct. 7, the Ministry of Health and Welfare (MOHW) and Health Insurance Review and Assessment Service (HIRA) provided information on the outpatient copayment rate billed to an atopic dermatitis patient at a tertiary hospital. The South Korean government is to enforce the revised regulation on healthcare reimbursement standard and methods from Oct. 8 that applies 100 percent of the healthcare reimbursement cost on patients visiting a tertiary hospital to treat cold and other mild cases. Previously, a mild case patient had to pay 60 percent of copayment rate for an outpatient treatment at a tertiary hospital, but it would be raised to 100 percent as the copayment rate ceiling system excludes the case from now on. Reflecting the change, the healthcare institute has to clearly distinguish between mild case and severe case of patients with atopic dermatitis. A mild case atopic dermatitis patient is to pay the entire copayment when visiting a general hospital, but a patient eligible to get prescribed with Dupixent (dupilumab) 300 mg prefilled injection would be applied with the previous 60-percent copayment rate. However, the issue is that hospitals may struggle to distinguish between the cases as they do not have an independent disease code for severe case atopic dermatitis, yet. The severe case disease code would be applied from Jan. 1 next year. MOHW official advised, “Even for severe case atopic dermatitis patients, their copayment rate may go up due to the revised regulation. The prescription of Dupixent from Oct. 8 through Dec. 31 to an atopic dermatitis patient would be calculated with premium rate by disease code and Healthcare Quality Evaluation Grant,” and “the hospitals should input general outpatient copayment rate instead of the unique code, ‘F025.'”
Policy
'Adding CSO' to the target of rebate penalty
by
Lee, Jeong-Hwan
Oct 13, 2020 06:05am
A revision of the law is being promoted so that not only pharmaceutical companies that gave rebates to doctors and pharmacists, but also the Contract Sales Organization (CSO) that they delivered on their behalf, can be directly punished for violating the Pharmaceutical Affairs Law. It is to clarify the grounds for administrative disposition in case of illegal detection by including the pharmaceutical CSO in ‘Article 47 (Order in Distribution of Drugs, etc.) of the Pharmaceutical Affairs Act)’. On the 12th, Jung Choun-sook, a member of Democratic Party of Korea said in a phone call with Dailypharm that he plans to initiate a representative proposal next week as soon as possible on the revision of the Pharmaceutical Affairs Law. On the 8th, at the parliamentary inspection of the administration of the Ministry of Health and Welfare, she spoke to Minister Park Neung-hoo about the illegal rebates through CSOs of some pharmaceutical companies. Despite the fact that CSO is being abused as a place to provide new rebates, contrary to its basic purpose, it is criticized that the legal basis for punishment is insufficient due to the blind spot of Pharmaceutical Affairs Law. CSO was originally created to act as an agent for legal sales such as promotion of drug sales for pharmaceutical companies and to help pharmaceutical companies focus on new drug development. However, some pharmaceutical companies are exploiting CSOs by offering variant rebates because CSO is not considered a 'drug supplier' subject to a ban on rebates under the Pharmaceutical Affairs Act. According to the data submitted by the MOHW to her, it was unable to properly determine the current status of the number of CSO companies currently operating. In a survey of some pharmaceutical companies last year, only statistics were obtained that 27.8% of the 464 responding pharmaceutical companies were consigning sales. The MOHW said that there was only one illegal rebate through CSO, but this is also not an accurate statistics. Specifically, a pharmaceutical Company was prosecuted in 2018 on charges of providing rebates worth about ₩1.6 billion to a number of medical professionals with CSO and pharmaceutical wholesalers from 2013 to 2017. As a result, both executives and employees of pharmaceutical companies and CSO's CEO were notified of disposition for violating the Pharmaceutical Affairs Act. She is preparing an amendment to the Pharmaceutical Affairs Act that extends the provisions prohibiting the exchange of rebates so that CSO can't do anything related to rebates. This is a method of adding 'a person who has received drug business consignment from a pharmaceutical company or other business processing consignment' to the scope of drug suppliers in the Pharmaceutical Affairs Act. She said, "We will create a legal basis to directly punish those who act as pharmaceutical companies such as CSO through illegal rebates." In addition, she explained, "The scope of administrative disposition includes CSOs and wholesalers, thereby enhancing the eradication of illegality and the completion of the Pharmaceutical Affairs Act."
Policy
HIRA finally revises PE guideline after 9 years
by
Lee, Hye-Kyung
Oct 13, 2020 06:05am
Finally, the pharmacoeconomic evaluation (PE) guideline is to be revised after nine years. South Korea’s Health Insurance Review and Assessment Service (HIRA) is accepting public opinion until Dec. 6 for the unveiled draft of revised PE guideline that reflects most of the suggestions made in the 2019 research on PE guideline revision (Principle investigator: Professor Lee Tae-Jin of Seoul National University Graduate School of Public Health and Professor Bae Eun Young of Gyeongsang National University School of Pharmacy). HIRA has decided to partially amend the regulation on pharmaceutical reimbursement evaluation criteria and procedure to formulate detailed evaluation standards on projecting pharmaceutical efficacy and cost, to remove a clause on financial impact analysis and to bring down the discount rate from 5% to 4.5%. The new PE guideline is to remove the ‘financial impact analysis’ section. The financial impact analysis projects the total financial changes in National Health Insurance (NHI) caused by introducing the applicant drug, in which the analysis significantly affects the decision in drug pricing or listing decision. And HIRA means to include the part in the pharmaceutical decision application, but to completely omit it in the revised guideline. ◆Cost: In the consigned research report, the investigators pointed out there has been many cases where the guideline’s perspective did not match the cost scope the actual analysis included, because transportation cost, time cost, and nursing cost were omitted when analyzing from the limited social perspective. Therefore, the new guideline would rule out transportation cost, time cost, and nursing cost from the basic analysis as they are not caused within the healthcare system, although the patients and their families have to pay the cost. However, the applicant may separately elaborate on the items with increased or lowered cost, besides from the basic analysis, if the cost or benefit is substantial, such as for diseases with burdensome nursing cost or noticeable productivity loss. ◆Discount rate: HIRA also plans to lower the basic analysis discount rate from 5 percent to 4.5 percent. In South Korea, the Korea Development Institute’s (KDI) research in 2017 consigned by the Ministry of Economy and Finance (MOEF) estimated the social time preference to be 3.7 percent to 4.5 percent, and it lowered the social discount rate to 4.5 percent, generally considering the market interest rate and declining economic growth in last 10 years. HIRA evaluated reducing the discount rate is necessary for PE when the social discount rate is falling constantly due to the changes in social economic circumstances. When the PE guideline was first compiled, the social discount rate was as high as 7.5 percent. The discount rate of 5 percent has been applied so far considering it is a healthcare policy and the level of other countries’ discount rate. But for the revised guideline, HIRA adjusted it down to 4.5 percent to match the discount rate applied in preliminary feasibility evaluation. ◆Analysis techniques: The existing guideline recommended to conduct a ‘cost-minimization analysis,’ when the effects of applicant drug and reference drug can be proven to be equivalent, and to conduct ‘cost-effectiveness analysis’ or ‘cost-utility analysis,’ when the effects of applicant drug and reference drug differ. But the new revision clarified to conduct ‘cost-utility analysis as a basic analysis technique. A drug with evidence of unable to produce cost-utility analysis can conduct cost-effectiveness analysis instead, but in such case the indicator reflecting the outcomes of the drug should be used as endpoint. The endpoint for the cost-effectiveness analysis should use Quality-Adjusted Life Years (QALY). ◆Evaluation methodology: The revised guideline then presented a number of factors, other than market share rate, to be considered when selecting reference drug. The existing principle of selecting a reference drug with highest substitutability when listing a new drug would be maintained, but the guideline would now also accept alternative plans supported by decent quality evidence when the circumstances are limited. For instance, a new alternative reference subject along with the comparability-based reference subject can be considered when qualifying all following conditions; a reference drug is standard of care; it has no direct comparable grounds between a new drug and a reference drug with highest market share and the uncertainty is too big when indirectly comparing and the comparability becomes an issue; and it is used as a conventional therapy in South Korea regardless of the reference drug used in the clinical trial did not have the highest market share. When calculating the pharmaceutical expense, the unit price of the applicant drug has to be used. If other drug with same substance, content and formulation is not yet listed, then the price of the applicant drug would be used. And weighted average pricing would be applied to unit price of the reference drug, when multiple drugs with same substance, content and formulation are listed already.
Policy
Many companies apply for a patent challenge for Otezla
by
Lee, Tak-Sun
Oct 13, 2020 06:05am
Korean pharmaceutical companies' patent challenges are continuing on new psoriasis treatments that are not released in Korea due to the failure to apply insurance benefits. Otezla (Apremilast), which was approved in 2017 as a treatment for psoriasis and psoriatic arthritis in Korea, has recently received a patent challenge from domestic companies such as Daewoong. In particular, Otezla is not released in Korea, but is recognized for its marketability overseas. According to the industry on the 9th, Dongkoo Bio & Pharma filed a trial for a passive confirmation of the scope of rights for the patents of Otezla's use (expired on March 20, 2023) on the 8th and formulation (December 26, 2032) registered on the MFDS patent list. It started a procedure to evade a patent for generic drugs. Since Daewoong requested the first patent trial on the 29th of last month, four companies, including Dong-A ST, Chong Kun Dang, and Dongkoo Bio & Pharma, began to challenge the patent. Otezla is a drug that Celgene was approved in Korea in November 2017. As Amgen acquired the drug for $13.4 billion in August last year, it also acquired domestic copyright. Otezla is a prescription medicine approved for the treatment of adult patients with moderate to severe plaque psoriasis for whom phototherapy or systemic therapy is appropriate and for the treatment of adult patients with active psoriatic arthritis. In Korea, after approval, they tried to raise benefits, but the agreement failed due to differences of opinion between the company and the insurance authorities. Insurance authorities judged that Otezla was not cost-effective due to its high price compared to other drugs in psoriasis, and suggested less than the amount converted to the average price of alternative drugs, but importers and sellers did not accept this. It was not officially released in Korea after the reimbursement failure. However, in the global market, it is active as a blockbuster with annual sales of about ₩2 trillion. According to ESTEEM 1 and 2 studies in plate-shaped psoriasis patients (about 1250 patients), Otezla, a new family that specifically acts on intracellular cyclic AMP (cAMP) concentration, 33.1% of patients 16 weeks after taking the drug PASI 75 (75% decrease in PASI score) was reached, showing a significant improvement compared to the placebo group (5.3%). Moreover, it is evaluated as a drug that improves the life and quality of patients by improving symptoms of itchy nails, scalp, and itching, which are difficult to treat. Psoriasis treatments that were compared before insurance benefits as Enbrel records annual sales of over ₩10 billion (based on IQVIA), it is expected to guarantee high performance if reimbursement is carried out in Korea. Moreover, it is an oral medication unlike Enbrel. However, even if generic drugs have surpassed their patents, it is difficult to launch a product within a short period of time as new drugs still have reexamination. This is because Otezla's PMS remains on November 19, 2023, with about three more years left. It is expected that more domestic pharmaceutical companies will participate in the drug market.
Policy
Drugs exempt from economic evaluation are applied to RSA
by
Kim, Jung-Ju
Oct 13, 2020 06:05am
From today (8th), generic drugs under risk-sharing agreements (RSA), drugs exempt from economic evaluation, and drugs released with early permission under the condition of Phase III are also covered by RSA between insurers and pharmaceutical companies. A new legal basis for adjusting the limit upper price will be established in the case of drugs whose license requirements are changed. The MOHW revised and issued the 'Pharmaceutical Determination and Adjustment Criteria' on the 8th in accordance with Article 14 of the 'Rules on Standards for National Health Insurance Medical Care Benefits'. The biggest point among the revisions is to expand the scope of RSA application. Usually, RSA is applied in Korea as follows. ▲In case of being used for serious diseases that threaten survival as an anticancer drug or rare disease treatment that does not have an alternative or equivalent therapeutic range or treatment ▲The Pharmaceutical Benefits Advisory Committee's impact on disease severity, social impact, and other health care when it is evaluated that consensus on additional conditions is necessary in consideration of the impact, etc. ▲In the case of a drug that has the same therapeutic scope as the drug applied according to the preceding two criteria and is a cost-effective drug. According to the revised adjustment criteria, drugs judged to be cost-effective as a result of the adequacy evaluation of the benefits of the Pharmaceutical Benefits Advisory Committee, and drugs that were judged to be exempted from economic evaluation, and drugs with a conditional approval for phase III are included in the RSA. A new standard for price adjustment of drugs with changed licenses has been established. This includes drugs that the MOHW deems necessary to adjust the upper limit price. The decision was requested at the time of announcement, and the upper limit price is recalculated according to the reporting standards. However, the Pharmaceutical Benefits Advisory Committee can adjust it if deemed necessary.
Policy
Pharmaceutical reimbursement standards should be updated
by
Lee, Hye-Kyung
Oct 12, 2020 06:13am
It has been argued that the government should be active from screening for osteoporosis to creating a continuous treatment environment and establishing an integrated treatment system for preventing fractures in stages. On the 7th, Bong-min Jeon, a member of People Power Party (Health and Welfare Committe, Suyeong-gu, Busan), published a national audit policy booklet with The Korean Society for Bone and Mineral Research and the 'the Osteoporosis Policy Task for Establishing a Virtuous Cycle of Health in Ultra-aged Societies', pointed out the low recognition rate for osteoporosis and urged social interest and national investment. According to the policy databook as a problem in the management of osteoporosis in Korea, there is a lack of an integrated management system that does not prevent the cascade of osteoporosis worsening, such as ▲low disease awareness and low treatment rate, and ▲limited drug reimbursement standards that make continuous treatment difficult. Currently, only patients with a T-score of -2.5 or less when measuring bone density can receive insurance benefits for one year as the subject of treatment. He said, “If the T-score exceeds -2.5, even though there is still a risk of fracture, it is excluded from the benefit.” He added, “It is necessary to create a continuous treatment environment by spreading awareness of demand, establishing a reimbursement standard that fits clinical evidence, and establishing a system for preventing fractures in stages within the health insurance system.” Meanwhile, according to the policy materials, the prevalence of osteoporosis is gradually increasing with the aging of the population, and the number of osteoporosis patients exceeded 1 million in 2020. Since the health problems of the elderly population are directly connected to the problem of participation in economic activities and the ability to live independently, he pointed out that diseases such as osteoporotic fractures that deprive the elderly population of mobility can be a primer to increase the burden of support for the entire society. He said, "If the osteoporosis is intensifying and the fracture is stored, it is serious if the probability of death is 17%, but if 66 out of 100 patients with osteoporosis stop treatment within one year, continuous management is not performed." He stressed that the work to improve the reimbursement standards, which are pointed as the main cause of the disruption, will be corrected by discussing with the government and academia.
Policy
'Abortion' within 14 weeks of pregnancy is allowed
by
Lee, Tak-Sun
Oct 12, 2020 06:13am
As the government allowed abortions in early pregnancy in accordance with the Constitutional Court's ruling against the constitution of abortion, it also decided to permit spontaneous abortion inducing medicines. Accordingly, it is noteworthy whether 'Mifegyne', which is widely used overseas, will be officially introduced in Korea. The government announced on the 7th that it will improve the crime of abortion according to the order of the Constitutional Court through an advance notice of revisions to the Criminal Code, the Mother and Child Health Law, and the Pharmaceutical Affairs Law. This revision of the law creates a safe operating environment, prevents unwanted pregnancies, and reduces abortions within the legally permitted range, while providing social and institutional conditions. It explains that the focus was on the protection of the right to life of the fetus and the right to self-determination of women. The procedure for collecting opinions on the amendment will continue until December 31 of this year. In particular, through the revision of the Pharmaceutical Affairs Law, it is planned to allow the use of abortion suggestive phrases or designs for drugs permitted by the Criminal Act and the Maternal and Child Health Law. The MFDS is planning to take necessary measures preemptively, such as establishing a system for safe use of the drug and preventing illegal use. The policy is to apply for spontaneous abortion inducing medicines license and, if necessary, advance consultation for the application for permission is also promoted. There is no officially licensed spontaneous abortion inducing medicines in Korea so far. Overseas, the abortion pill called 'Mifegyne' is widely used to induce natural abortion. It is based on steroidal antiprogesterone that can be used within 50 days of pregnancy or up to 8 weeks. Mifegyne is used in 75 countries, and women and civic groups have strongly requested domestic introduction. Through the revision of the Criminal Law, the government decided to set the allowable period for determining pregnancy maintenance and childbirth for pregnant women to be 'within 24 weeks of pregnancy', and then divide it into 14 weeks and 24 weeks of pregnancy to differentially regulate the requirements. The current Maternal and Child Health Act allows abortion within 24 weeks of pregnancy only if there is a certain reason, but the amendment fully reflects the purpose of the decision of the Constitutional Court. An abortion can be decided according to the decision of the pregnant woman herself without certain reasons or counseling within 14 weeks of pregnancy. In addition, an abortion is allowed if there are reasons under the existing Maternal and Child Health Act and social and economic reasons specified in the Constitutional Court decision within 15 to 24 weeks of pregnancy. For safe abortion, it is limited to those that are performed by doctors as in the current practice, and abortions can be performed using medically recognized methods. Through the revision of the Maternal and Child Health Act, it was decided to expand the options by specifying treatment methods. In order to ensure access to medical information on induced abortion and to prevent repeated induced abortion, the written consent of the doctor has been established with the obligation to explain the procedure, sequelae, and compliance before and after the procedure. Rejection of induced abortion treatment according to the doctor's personal belief can be admitted. If the doctor refuses to request a procedure, he or she should immediately inform a pregnancy/birth counseling institution that provides information on whether to maintain pregnancy. The government announced on the 7th that it will do its best to complete the revision of the law within this year by promptly submitting the government legislation to the National Assembly through a legislative notice, review of the Legislative Office, and a cabinet meeting.
Policy
Dupixent targeting atopic dermatitis was launched
by
Lee, Tak-Sun
Oct 08, 2020 06:25am
Dupixent Since the first biological drug Dupixent targeting atopic dermatitis was launched in Korea, other foreign-funded pharmaceutical companies are also developing new drugs. There are four clinical trials approved in Korea this year. On the 6th, the MFDS approved the phase III clinical trial protocol of Lebrikizumab. It is evaluated for efficacy and safety in patients with moderate to severe atopic dermatitis in this clinical trial. The multinational clinical trial will involve 400 patients around the world, and 55 people will be recruited in Korea. Lebrikizumab is a candidate material for the treatment of atopic dermatitis, which Lilly acquired earlier this year through the acquisition of biotechnology company Dermira. Originally developed by Roche as a treatment for asthma, Dermira took over and changed its use as a treatment for atopic dermatitis and commercialized it. In December of last year, the Food and Drug Administration (FDA) designated the drug for expedited screening. Currently, Sanofi's Dupixent (Dupilumab) is the only biological agent that can be used by patients with moderate or severe atopic dermatitis. Prior to this, in June, Pfizer’s Abrocitinib was approved for a domestic phase III clinical trial. This is a clinical trial to evaluate the efficacy and safety compared to Dupilumab in adult patients receiving background topical therapy for moderate to severe atopic dermatitis. Commercially, Abrocitinib seems to be ahead of Lebrikizumab. Pfizer aims to approve Abrocitinib in the US within the year. In May, Pfizer’s Crisaborole was approved for a phase III clinical trial in Korea, an ointment for atopic dermatitis. Crisaborole was approved by the U.S. FDA in 2016, but has not yet obtained official approval in Korea. In this clinical trial, Pfizer will verify the efficacy and safety of 2% of Crisaborole ointment in Asian pediatric and adult subjects (2 years of age or older) with mild to moderate atopic dermatitis. Nemolizumab developed by Chugai in Japan is also undergoing phase III clinical trial in Korea. It was approved for phase III clinical trial in June, and Galderma is known to have marketing and development rights excluding Japan and Taiwan. In this clinical trial, the efficacy and safety of Nemolizumab will be evaluated in patients with moderate to severe atopic dermatitis. The last four new drug candidates approved for phase III clinical trial are all biologics like Dupixent . It was approved in Korea in 2018 and can be used for atopic dermatitis and asthma. In the case of atopic dermatitis, it is used for the treatment of moderate to severe atopic dermatitis, for which topical treatments are not adequately controlled or these treatments are not recommended. Atopic dermatitis is a disease whose exact pathogenesis is not yet known. There are about 950,000 patients in Korea, and it is increasing every year. Mainly non-steroidal topical treatments are used, but they only help relieve symptoms. Even long-term treatment is not likely to be cured. Accordingly, Medical staff are hoping for Dupixent. Dupixent was listed in this year, and sales in the first half of IQVIA recorded ₩8.5 billion, and it is clear that it will exceed ₩10 billion per year, which is the standard for domestic drug blockbusters.
Policy
The bioequivalence test of Lixiana's generic has begun
by
Lee, Tak-Sun
Oct 08, 2020 06:23am
The development of a generic for Lixiana (Edoxaban, Daiichi Sankyo Korea), which was released as the latest among new oral anticoagulants (NOAC), has begun. Lixiana was approved six years later than the country's first NOAC drug, Xarelto (Rivaroxaban, Bayer Korea), but it is currently recording the highest sales performance in the market. With the expiration of PMS in August of next year, bioequivalence testing for generic commercialization began. On the 29th of last month, the MFDS approved the bioequivalence test plan for 'SIL1107' of Sinil. SIL1107 is same as generic for Lixiana. Lixiana will end PMS on August 24 next year. After the end of the PMS, it is possible to apply for permission for generics. Sinil is expected to submit an application for permission for generic drugs based on the results of the bioequivalence test. All of the domestically released NOAC drugs will be released. In the case of Xarelto, PMS expired in April 2015, and currently 22 generics for Xarelto have received permission. In addition, PMS of Pradaxa (Dadabigatran, Boehringer Ingelheim Korea) expired in February 2017, and 10 generics received permission. Eliquis (Apixaban, BMS Korea Pharmaceutical) expired in November 2017, and 50 generics received permission. From May of last year, the drugs was launched on the market. It is analyzed that the market release of generics for Pradaxa will continue in July of next year, and the release of generics for Xarelto will continue in October. However, in the case of Lixiana, the material patent will be terminated only in November 2026, so it is necessary to wait another 6 years for generics to be released. In the current market, Lixiana ranks first among NOACs. Looking at the outpatient prescriptions for the first quarter based on UBIST, Lixiana recorded ₩15.8 billion, Xarelto and Eliquis, ₩11.2 billion and Pradaxa, ₩3.8 billion. Generics for Eliquis, launched last year, recorded a total of ₩1.4 billion in outpatient prescriptions from 14 companies. The domestic generics that are operating mainly in clinics have limitations because NOAC has grown mainly in general hospitals. Therefore, the influence of the original drug is expected to be great even if generics for Pradaxa and Xarelto are released next year.
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