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Medication Errors Why is it Important to Record, Assess, and Prevent Them

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Medication errors are an important concern in healthcare systems around the world. They can occur at any stage of the medication process, from prescribing to administration, and can have serious consequences in patients. Some examples of medication errors could include giving a medication to the wrong patient, giving the wrong dose of a medication, not prescribing a medication that was indicated, entering an order for the wrong patient, or forgetting to give a medication that was due. In this article, we will explore the definition of medication errors, the various stages where they can occur, the role of healthcare professionals in reporting and preventing these errors, and strategies for reducing their occurrence.

 

Defining Medication Errors

A medication error is a commonly used term and is defined as an unintended failure in the treatment process that leads to, or has the potential to lead to, harm to the patient (Ferner & Aronson, 2006; EMA Guidance 2015). These errors can take place at multiple stages of the medication-use system, such as during prescribing, entering data into computer system, preparing or dispensing the drug, or administering the drug to the patient.

 

Why are Medication Errors Important – Prevalence and Impact of Medication Errors

The FDA receives more than 100,000 US reports each year associated with a suspected medication error. Individual studies have reported hospital inpatient medication error rates of 4.8% to 5.3% and in another study, prescribing errors for inpatients occurred 12.3 times per 1,000 patient admissions. One study on the frequency of medication errors revealed that fewer than 1% of medication errors resulted in an adverse event.

These medication error reports come from various sources, including drug manufacturers, healthcare professionals, and consumers. These reports are reviewed by the FDA and are classified to determine the cause and type of the error. Medication errors can also result in serious consequences. In addition to the harmful impact on patients, medication errors can also impose significant costs on healthcare systems. Estimates suggest that these errors, in addition to decreasing the patients’ confidence in medical services, can cost between $6 billion and $29 billion per year in the United States alone.

 

Relationship between Medication Errors and Adverse Effects

The Figure below reflects the interplay between medication errors and harm (i.e. associated with adverse reaction and preventability).

Adverse reactions that result from medication errors are considered preventable, in contrast to generally non-preventable adverse reactions which are mentioned in the Product Label (e.g. in Prescribing Information, SmPC etc.) for which the chances of adverse event occurrence is usually known and accepted and will likely occur depending on the frequency of the adverse reaction and on other circumstances such as concomitant medication use, underlying disease condition etc.

There are medication errors which do not essentially result in adverse reaction, but which are important from their unwanted effects e.g. from an economic or environmental standpoint.

Figure 1: Figure: Correlation between medication errors, preventable and generally non-preventable adverse reactions and intercepted errors (modified according to Morimoto et al., Qual Saf Health Care 2004; 13:306-314). Ref: EMA Good Practice Guide on recording, reporting & assessment of medication errors; 23 Oct 2015.

 

Stages of Medication Errors

Medication errors can occur at various stages of the drug delivery process. These stages include:

  1. Prescribing

Errors during this phase can occur due to incorrect drug selection, dosage, or frequency, or by failing to consider the patient’s medical history or potential drug interaction.

  1. Transcribing

Errors can occur when entering prescription information into a computer system, such as incorrect drug selection, dosage, or frequency.

  1. Dispensing

Errors can happen during the preparation and distribution of the drug, such as dispensing the wrong medication, incorrect dosage, or improper labelling.

  1. Administration

Errors can occur when administering the drug to the patient, such as administering the wrong drug, dose, or route, or at the wrong time

  1. Monitoring

Errors can happen when healthcare professionals fail to monitor the patient’s response to the medication, leading to potential adverse reactions or failure to achieve therapeutic goals.

 

Recording and Reporting Medication Errors

Medication errors associated with drug use may be spontaneously reported as unsolicited reports by a consumer, healthcare professional or marketing authorization holder, or may be reported as solicited reports of suspected adverse reactions from data collection systems e.g. non-interventional studies or registries.

Suspected (serious and non-serious) adverse reactions associated with medication errors should be recorded, reported and assessed. The reports of medication errors not associated with adverse reaction should also be recorded; however, these cases are not reportable as valid ICSR.

The marketing authorization holders should summarize relevant information on medication errors, even when not associated with adverse outcomes, in the periodic safety update reports and the risk management plans. The figure below provides a summary of recording of medication errors from the perspective of pharmacovigilance and patient safety.

 

Category Medication Error with AR Medication Error without AR Intercepted Error Situations Capable of Causing Medication Error
Medication Error Yes Yes Yes No
Adverse Reaction (AR) Yes No Not Applicable Not Applicable
Recording of Medication Error Medication Error with AR Medication Error without AR Intercepted Medication Error Situations capable of causing Medication Error
Report Type / Relevance Record ICSR Report, if applicable PSUR, RMP PSUR, RMP PSUR, RMP PSUR, RMP

 

Strategies for Reducing Medication Errors

Various mechanisms can be employed to reduce the occurrence of medication errors.

The FDA is actively involved in efforts to prevent medication errors. Before approving drugs for marketing, FDA reviews the drug name, labelling, packaging, and product design to identify and revise information that may contribute to errors. FDA reviews the following to reduce the incidence of medication errors:

  • Proposed brand names to minimize confusion among drug names. Look-alike and sound-alike names are to be avoided.
  • Container labels to ensure healthcare providers and patients can select the correct drug and easily differentiate between different strengths of the same drug.
  • Prescribing and patient information to ensure clear and easy-to-read instructions for use.

After the drugs are approved for marketing, FDA continues to monitor and evaluate medication error reports.

  • FDA may require manufacturers to revise labels, packaging, product design, or proprietary names to prevent errors.
  • FDA may also issue communications to alert the public about medication error safety issues.
  • FDA collaborates with regulators, external stakeholders, standard-setting organizations, patient safety organizations, and researchers to understand the causes of medication errors and develop interventions to prevent them.

 

Implementing Barcodes on Drug Labels

The FDA has introduced rules requiring barcodes on certain drug and biological product labels. These barcodes allow healthcare professionals to use barcode scanning equipment to verify that the correct drug, dose, and route of administration are being given to the right patient at the right time, to reduce medication errors in hospitals and other healthcare settings.

 

Providing Guidance to Manufacturers

The FDA has published guidance documents to help manufacturers design drug labels, packaging, and select drug names in a way that reduces or eliminates hazards contributing to medication errors. These guidance documents offer recommendations on various aspects of drug design, such as imprint codes on tablets, appropriate dosing devices, and package design to protect consumers against incorrect use.

 

Importance of Consumers in Reducing Medication Errors

Consumers play a crucial role in reducing medication errors. Some tips for the consumers to minimize the risk of medication errors include the following:

  1. Be aware of the various causes and risks of medication errors.
  2. Know the name and purpose of the medications that is prescribed.
  3. Know how to take the medication and follow the directions properly including directions for storage.
  4. Check the container’s label every time the medication is taken.
  5. Keep medications stored in their original containers.
  6. Maintain an updated list of all medications, including over-the-counter drugs, supplements, and other substances and share this list with your healthcare provider.
  7. Be aware of the risk of drug-drug and drug-food interactions.
  8. Ask the pharmacist or healthcare provider in case of any questions about the medication.
  9. Report suspected medication errors.

 

Specific Consideration of Medication Errors in High-Risk Groups

Consumers play a crucial role in reducing medication errors. Some tips for the consumers to minimize the risk of medication errors include the following:

 

  1. Paediatric patients

Paediatric patients may be at especially high risk of medication errors, with dosing errors being the most common type of error. This may be due to the variation in age, size and weight, and body surface area in children. Overdose was the most commonly reported medication error (accounting for 21% of all reports) in a study of paediatric patients while underdosing was the most commonly reported medication error in certain paediatric specialties in another study. These conflicting findings suggests a more general risk of dosing errors (leading to either over- or underdosing) in paediatric patients.

Paediatric prescribing is often decided by the patient’s weight, yet weight is not measured before each prescription and can change over time. Further, mathematical miscalculations may also occur. Accidental ingestion or other unintended use of medicinal products by children should be prevented. A standard statement that drugs should be kept out of the sight and reach of all children is included on the labelling for all products and use of child-resistant packaging may also be considered.

 

  1. Elderly patients

Elderly patients are at a high risk of medication errors. These patients may have physical and cognitive impairment and therefore may have difficulties in taking medicines, e.g. swallowing tablets, opening packaging or reading user instruction. Moreover, elderly patients frequently use multiple drugs (polypharmacy) which in itself may cause compliance problems which may be partly overcome by the design of the drugs (e.g. a wider range of colours, sizes and tablet shapes is known to assist the recognition of medicines).

Elderly patients are more likely to experience impaired swallowing. This may result in accidental underdosing, which can be appropriately managed by the use of formulations which are easier to swallow. It is important that appropriate materials for elderly patients are developed, including use of large print text and Braille for patients with impaired eyesight. Older people may also more frequently require the assistance of caregivers. The caregiver, nurse and family can play an important role for the correct use of the medicines and should be proactively involved by the doctor or pharmacist.

 

Conclusion

Medication errors are a significant concern in healthcare systems worldwide and is an important cause of patient morbidity and mortality. Medication errors can occur due to varied factors such as medication factors (e.g. similar sounding names, low therapeutic index), patient factors (e.g. poor renal or hepatic function, impaired cognition, polypharmacy), and health care professional factors (e.g. use of abbreviations, cognitive biases) which can precipitate medication errors. With the combined efforts of the FDA, healthcare professionals, manufacturers, and consumers, it can be ensured that the medication-use process is safer and more effective for all involved.

Why you Should Incorporate Signal Detection Process in Early Phase Clinical Development Programs

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What is a Safety Signal in Pharmacovigilance?

Information arising from one or multiple sources, including observations and experiments, which suggests a new potentially causal association, or a new aspect of a known association between an intervention and an event or set of related events, either adverse or beneficial, that is judged to be of sufficient likelihood to justify verificatory action. New aspects of a known association may include changes in the frequency, distribution (e.g. gender, age and country), duration, severity or outcome of the adverse reaction. A signal often relates to all medicinal products containing the same active substance, including combination products. Certain signals may only be relevant for a particular medicinal product or in a specific indication, strength, pharmaceutical form or route of administration whereas some signals may apply to a whole class of medicinal products.

 

Signal Management – What it is:

A set of activities performed to determine whether, based on an examination of individual case safety reports (ICSRs), aggregated data from active surveillance systems or studies, scientific literature information or other data sources, there are new risks associated with an active substance or a medicinal product or whether known risks have changed, as well as any related recommendations, decisions, communications and tracking.

 

What do the regulators say:

  1. 21CFR312.32

Review of safety information:

The sponsor must promptly review all information relevant to the safety of the drug obtained or otherwise received by the sponsor from foreign or domestic sources, including

information derived from any clinical or epidemiological investigations, animal or in vitro studies, reports in the scientific literature, and unpublished scientific papers, as well as reports from foreign regulatory authorities and reports of foreign commercial marketing experience for drugs that are not marketed in the United States.

 

  1. USFDA draft guidance on sponsor responsibilities – safety reporting requirements and safety assessment for IND and Biovailability / Bioequivalence studies

Systematic Approach for Review of Safety Information (§ 312.32(b)):

Sponsors should have a systematic approach to safety surveillance to comply with the IND safety reporting requirements and to improve the overall quality of safety reporting. Such an approach should include a process for promptly reviewing, evaluating, and managing accumulating data on SAEs from the entire drug development program that are sent from domestic or foreign sources. During the course of drug development, investigators who conduct clinical trials generally report to the sponsor adverse event information; however, a sponsor may become aware of new safety information from a variety of sources, both domestic and foreign. Compliance with post marketing safety laws and regulations for human drugs and therapeutic biologics.

The sponsor must review and evaluate safety information from any source regardless of whether the data came from studies conducted under the IND (§ 312.32(c)(1)(ii) and (iii)) to determine if there is a newly identified significant risk to trial participants. Sources include but are not limited to:

  • Animal or in Vitro Studies
  • Clinical or epidemiological investigations
  • Reports in the scientific literature, including unpublished reports of which the sponsor becomes aware
  • Information presented at professional or scientific meetings (e.g. abstracts)
  • Reports from foreign regulatory authorities
  • Reports from commercial marketing experience, including outside the United States

 

  1. European Medicine Agency (EMA)

Safety surveillance: The sponsor along with the investigators is responsible for the ongoing safety

surveillance and risk minimization of the study subjects during the clinical study duration, taking, if required, appropriate urgent safety measures for protection of study subjects. The Member State Concerned will monitor the risks of investigational medicinal products considering the available information according to the procedures laid down in the implementing Regulation on rules and procedures for the cooperation of the Member States in safety assessment of clinical trials. Safety reporting with regard to authorised Auxiliary Medicinal Products shall be made in accordance with the normal safety reporting requirements

for authorised medicinal products.

 

The notifications required from sponsor or investigator in relation to safety of the clinical study subjects include:

  1. Reporting of adverse events and serious adverse events
  2. Reporting of suspected unexpected serious adverse reactions (SUSARs)
  3. Other unexpected events relevant for the subject’s safety
  4. Annual safety report
  5. Reporting of serious breaches
  6. Urgent safety measures
  7. Temporary halt of the study due to safety reasons

 

  1. CIOMS Working Group VI

Identification and Evaluation of Risk from Clinical Trial Data – Ongoing Safety Evaluation: The purpose of ongoing safety evaluation during drug development is to ensure that important safety signals are detected early and to gain a better understanding of the benefit-risk profile of the study drug.

 

  • Clinical trial sponsors should develop a system to analyse, evaluate and take actions on the safety information received during drug development on a continuous basis. This is to ensure the earliest possible detection of safety concerns and allow suitable risk minimization, such as of ongoing study protocol revisions, to ensure that clinical trial participants are not exposed to undue risk.

 

  • Safety monitoring, evaluation and analysis should be performed in such a way so that the integrity of the individual studies or the overall development program is not compromised. Study sponsor should be totally aware of the potential risks of the investigational product and the morbidities characteristic of the study population at every stage of drug development.

 

How Soterius can help you in Setting Up Signal Detection Process:

  1. Team of Experienced Physicians and Product Specific Trained Resources

–  The signal management team adheres to a process involving a thorough review and medical evaluation of safety data.

 

  1. Safety Surveillance Plan

– The components of the safety surveillance plan include the following:

Data Collection from

Various Sources

Preparation of Detailed

Signal Evaluation Reports

Signal Report Discussion

in Safety Review Meeting

·         Safety database line listings, Clinical database line listings including laboratory investigations

·         Published literature

·         Aggregate reports/Risk management plans

·         Regulatory Websites depending on authorization of client’s products in various countries/regions e.g.

·         FDA website*

*(Potential Signals of Serious Risks/New Safety Information Identified from FAERS)

·         Sources of signal detection Identified drug-event pairs

·         Signal validation Other relevant safety issues

·         Discussion with key stakeholders prior to finalization on periodic basis

·         Further actions (Routine monitoring, Potential Signals Y/N, Additional data search)

 

Signal Management Process:

Signal detection, Signal validation, Signal analysis and prioritization, Signal assessment, and Recommendations for action.

In conclusion, signal management is a process that requires a high-level standard operating procedure (SOP) describing:

  • How signal prioritization and evaluation are approached (e.g. what does the signal prioritization imply?
  • How are the sources of safety data queried? Who performs the signal evaluation?).
  • How is the risk determination performed (e.g. what criteria have been considered and what data are available to qualify the risks?).
  • How is the best course of action determined?
  • How, when and to whom the potential or identified risks are communicated.

Once a signal is identified, the following steps are necessary:

  • Assess public health impact.
  • Validate and assess the strength of the signal.
  • Define data sources and limitations.
  • Compile safety data.
  • Compare data from different sources.
  • Evaluate characteristics and likelihood of the risk associated with the signal.
  • Determine appropriate actions for evaluation, communication, and risk reduction.

Remember…. if the information available suggests that there could be a risk that requires prevention or minimization in a timely manner

  • Always use clinical judgement and flexibility throughout the process.
  • Be prepared to take action at any stage before the formal signal assessment is completed.
  • Points for consideration: severity, seriousness, outcome, reversibility, exposure in vulnerable populations, expected extent of regulatory intervention, consequences of treatment discontinuation & availability of other therapeutic options etc.

This was a small start with a quick reference to importance of Signal detection in Early Phase Clinical Development Programs. I would be discussing various aspects of signal management process in the upcoming articles.

Overview of Regulatory Requirement for Post-Marketing Medical Device Reporting in the USA and the EU

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Overview of Regulatory Requirement for Post-Marketing Medical Device Reporting in the USA and the EU

Meteriovigilance is the term used in the context of surveillance of medical devices and its purpose is to improve the protection of health and safety of patients, healthcare professionals, and other users by reducing the likelihood of reoccurrence of incidents related to the use of a medical device.

Presented below in brief is the post-marketing regulatory landscape as exist for USFDA and EMA in terms of Medical Device Reporting.

  1. Regulations that Govern Medical Device Reporting

  • USFDA
  • 21 CFR PART 803
  • 21 CFR PART 806
  • EMA
  • Regulation (EU) 2017/745
  1. Type of Report and Reporting Timelines

  • USFDA
  • 5-day report: No later than 5 workdays after becoming aware of a reportable event that requires
  • Remedial action to prevent an unreasonable risk substantial harm to the public health.
  • A reportable event for which FDA made a written request.
  • 30-Day report: No later than 30 calendar days after becoming aware of a reportable death, serious injury, or malfunction
  • EMA
  • Serious public health threat: Immediately, but not later than

days after the manufacturer becomes aware of that threat.

  • Death or an unanticipated serious deterioration in a person’s state of health: Immediately, but not later than 10 days after the date on which the manufacturer becomes aware of the serious incident.
  • Other serious incident: Immediately, but no later than 15 days after manufacturer become aware of the incident.
  1. Method to submit Reportable Medical Device Reports

  • USFDA
    • Electronic Submissions Gateway (Web Trader)
    • Gateway to Gateway
  • EMA
    • Submission of Manufacturer’s Incident Report (MIR) form via email to the approving Competent Authority.
    • Under development: EUDAMED
  1. Requirement for submission of Periodic Report

  • USFDA
    • Not mentioned*
    • Guidance for Combination product has specific requirements; will be detailed in subsequent posting.
  • EMA
    • Class IIb and class III devices: Annual PSUR Submission
    • Class IIa devices: PSUR to be submitted at least every two years
  1. Requirement for Trend reporting

  • USFDA
  • Not mentioned
  • EMA
  • Manufacturers shall electronically report any statistically significant increase in the frequency or severity of incidents that are not serious incidents or that are expected undesirable side effects that could have a significant impact on the benefit-risk analysis, and which have led or may lead to risks to the health or safety of patients, users or other persons that are unacceptable when weighed against the intended benefits

Navigating the Unique Challenges of AI and Automation in Pharmacovigilance: The Vital Role of Computer System Validation (CSV)

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Artificial Intelligence, Machine Learning, Automation, Cost Reduction: all the buzzwords in pharmacovigilance! Everyone seems to be implementing Automation and AI in pharmacovigilance to reduce manual work and reduce costs of safety monitoring. However, compared to all other fields where Automation and AI is being implemented, pharma as an industry is facing a unique set of challenges in implementing these systems.

 

Regulators such the USFDA and EMA require that computerized systems should be fit for intended use and meet current regulatory requirements. ‘Fit for intended use’ is a broad term that encompasses detailed testing, documentation, qualification and validation activities to demonstrate that the ‘use’ and ‘fitness for such use’ of a system is demonstrated effectively and is available for review during audits and inspections.

 

The method for achieving this is Computer System Validation, which is rooted in the principles of Good Automated Manufacturing Practice (GAMP), Title 21 CFR Part 11, and EU Annex 11. In the pharma space, the requirements become all the more critical, since it is no longer just about compliance; it’s about safeguarding lives.

 

The Indispensable role of CSV in Pharmacovigilance

End Point Regulation Requirement How CSV Helps to Achieve the Requirement
Patient Safety EU Annex 11 Patient Safety Aids in the timely detection, management, and mitigation of risks associated with pharmaceutical products
Data Precision GAMP Precise Reporting Ensures data accuracy, reducing the risk of errors that could significantly impact patient safety.
Regulatory Compliance Title 21 CFR Part 11, EU Annex 11 Robust compliance standards for

electronic records and signatures in

FDA-regulated industries, guidelines

For computerized systems in the

European Union

Adherence to these regulations, ensuring that you consistently meet the stringent requirements of regulatory authorities
Operational Efficiency GAMP, Title 21 CFR, and EU Annex 11 Importance of efficient systems Streamlined processes not only improve productivity but also lead to faster responses, an invaluable asset in pharmacovigilance where time can mean the difference between life and death

 

In the next few parts of this series, I will be discussing some approaches that we have followed in implementing CSV procedures for software systems developed for the pharmacovigilance space, what we have learned in the process, how CSV can be applied by harmonizing international regulatory requirements and how it can

be applied to the agile development. Stay tuned for more updates and reach out to me if you would like to see any other topics covered as part of the series.