When is an Early Access Program not the right option?

Early access programs (expanded access, compassionate use, named patient supply) are becoming a standard part of the development and launch process for medicines. This change, apparent over the last 5-6 years, has been driven by a greater awareness of such pre-license supply pathways by both physicians and patients, and a recognition by industry that such programs offer wider benefits than the ethical and social responsibility aspects that have largely driven them in the past.

Typically, the regulations state that early access should be for serious, debilitating or life-threatening illnesses, and that there should be no licensed alternative available in the country of intended use. However, these restrictions aren’t usually enforced by the regulators, who are more concerned with the safety profile of a medicine, and are generally happy to allow a physician to use their clinical judgement as to why an unlicensed medicine might be suitable for a patient.

Early access programs offer a wide range of benefits for patients, physicians and pharma companies alike. The opportunity to enter a market early, gain experience outside of the trial population, generate data and potentially generate revenue are all seen as attractive features of early access. They certainly can be attractive, but is opening an early access program always the right thing to do?

 

Situations where an access program may not be the appropriate option would include;

  • Where there have been no requests from physicians for access ahead of approval
  • Where the underlying driver is focused on revenue generation
  • Where the primary intention is data collection
  • Where the data suggests marginal improvement over available therapies
  • Where your manufacturing/supply chain is not at full capacity

If any one of these aspects is apparent, it would be advisable to work through a detailed Early Access Feasibility Analysis to gain a deeper understanding of the asset-specific environment before implementing a program.

 

Factors which lend themselves to successful early access programs include;

  • Where you are already receiving requests for early access to the product
  • There is no therapy available at all for the indication in question
  • Or, data suggests dramatic improvement over existing options
  • Well-established and active patient groups

 

There is no guarantee that these factors will result in an early access program that meets expectations, but they certainly increase the likelihood. There are a lot of intangibles in early access, not least awareness and physician perception of product, but being aware of some of the ‘red flag’ situations will increase your chances of a successful program.

Stuart Bell, Vice President, Inceptua Early Access

Stuart Bell, VP,  Inceptua Early Access

Stuart Bell has more than 20 years of healthcare consulting experience, with the last 10 years focused on early access. Stuart has been involved in over 100 early access programs. Stuart is responsible for Inceptua’s consulting activities, including: strategy and policy, feasibility analyses, real-world evidence development and communications. He pioneered the development of global corporate strategies on early access, the concept of detailed Feasibility Analyses for early access, and developed the first early access-specific EDC for real-world data collection.

Contact: stuart.bell@inceptua.com + 0044 7387 265 293

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CEO and Board Member

Stefan Fraenkel

Stefan Fraenkel is the CEO of the Inceptua Group and is also on the Inceptua Board. He has extensive experience in the pharmaceutical industry. Before joining Inceptua, he held senior management positions at Sobi (Swedish Orphan Biovitrum), Sweden’s largest publicly listed specialty pharmaceutical company, leading Marketing & Sales and serving as Head of Corporate Development and Strategy.

Previously, Stefan worked at Pfizer and Wyeth in international commercial leadership roles across Europe and the USA, gaining deep insights into global pharmaceutical markets and strategies. Stefan has also spent part of his career in management consulting. Stefan holds a PhD in International Economics, an MBA, and a BSc in Engineering.

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Chris Hasslinger is a Partner of Vesey Street Capital Partners and serves as a member of the Firm’s Investment Committee. He joined VSCP in 2023 and is responsible for sourcing and evaluating new investment opportunities and general portfolio company management. Mr. Hasslinger has nearly three decades of experience in healthcare and technology strategy and deal-making within the industry as well as in investment banking and private equity. He has extensive M&A experience, having closed over $20 billion in transaction value, and has established and structured a number of large commercial partnerships.

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Alan Raffensperger

Alan Raffensperger has a robust leadership background in the pharmaceutical industry, having served as CEO of Inceptua and COO of Sobi (Swedish Orphan Biovitrum), along with significant international executive roles at Amgen, Roche, and Pharmacia.

He has also been CEO for venture capital-owned medical device companies, showcasing his versatility in healthcare leadership. Alan’s early career as an advanced life support paramedic provided a strong foundation in emergency healthcare.

He holds an MBA and a BA in Emergency Health Care Management.

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Blake Goodner is a founder member of the investment firm Bridger Capital. He previously worked as a healthcare analyst at Tiger Management and a healthcare investment banker at Morgan Stanley. He currently serves as an advisor and board member for a range of healthcare companies. Mr. Goodner has been a member of the Trinity College Board of Visitors and the Duke Annual Fund Executive Committee. He is a current advisory board member with The Duke Margolis-Center for Health Policy.

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Adam Feinstein

Adam Feinstein is the Managing Partner of Vesey Street Capital Partners. Mr. Feinstein has 30 years of investment experience exclusively in the healthcare services sector. Prior to founding Vesey Street Capital Partners in 2014, he was a Managing Director on Wall Street and a healthcare industry executive. He held the position of Senior Vice President of Corporate Development, Strategic Investments, and Office of the Chief Executive Officer at LabCorp. Before his tenure at LabCorp, he spent 14 years as the Managing Director in Equity Research at Lehman Brothers/Barclays Capital. Mr. Feinstein is the Chairman of VSCP’s investment committee. He is also actively involved in working with portfolio company executives and sourcing new investment opportunities. At the same time, he oversees all of the firm’s investment activities and employees.

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Larry Marsh

Larry is a General Partner of Vesey Street Capital Partners and serves as a member of the Firm’s Investment Committee. He joined VSCP in 2016, and currently sits on the Board of QualityMetric, Safecor Health, and HRGi. He is responsible for portfolio company management and for evaluating new investment opportunities. Prior to VSCP, Larry was EVP, New Market Development & Chief Strategy Officer at Fortune 10 AmerisourceBergen. Prior to that, Larry was the #1 ranked Healthcare Technology & Distribution analyst on Wall Street for over a decade, at Barclays, Lehman Brothers, Salomon Smith Barney, and Wheat First Butcher & Singer. Larry worked with Adam, Bryan, Dan, and Joe at Barclays and Lehman. Larry received a B.S. in Economics & Management as well as an M.B.A. from the University of Richmond, and an M.P.H. from Columbia University.

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Heyward Donigan

Heyward Donigan is a seasoned healthcare CEO, Board Member, and Private Equity Advisor with broad industry experience and a track record of profitable growth. From 2019 to 2023, Ms. Donigan served as Rite Aid’s president and chief executive officer, making her one of the few women CEOs of a Fortune 500 company. While at Rite Aid, Ms. Donigan led the company to through a major brand, merchandise and technology transformation, debt reduction/refinancing, while also leading the company through a pandemic. Ms.Donigan is currently a strategic advisor to Vesey Street Capital Partners, Arima Health, and a board member of OnMed.

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Doug Cook

Doug Cook is the Executive Chairman at Inceptua. Mr. Cook began his career driving the early success of Livingston Healthcare, leading to the purchase by UPS to become what is today UPS’s Global Healthcare business. After Livingston Healthcare, Mr. Cook moved to AmerisourceBergen (now called Cencora/COR) in 1998 and had an impressive career overseeing most of Cencora’s high growth, manufacturer-facing business. Mr. Cook ultimately served as the Executive Vice President, President Commercialization and Animal Health for COR.

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