ANTIRETROVIRAL PRICE REDUCTIONS - UNTANGLING THE WEB OF - Ärzte ohne Grenzen
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PREFACE In this report, we provide an update on the key facets of HIV treatment access. It includes the latest HIV treatment guidelines from World Health Organization (WHO), an overview on pricing for first-line, second-line, and salvage regimens, and a summary of the opportunities for – and threats to – expanding access to affordable antiretroviral therapy (ART). There is a table with information on ARVs, including quality assurance, manufacturers and pricing on pages 19 to 21. Detailed information on key antiretroviral drugs and fixed-dose combinations is available at: www.msfaccess.org/utw2016 THE MSF ACCESS CAMPAIGN In 1999, on the heels of Médecins Sans Frontières (MSF) being awarded the Nobel Peace Prize – and largely in response to the inequalities surrounding access to HIV/AIDS treatment between rich and poor countries – MSF launched the Campaign for Access to Essential Medicines. Its sole purpose has been to push for access to, and the development of, life-saving and life-prolonging medicines, diagnostics and vaccines for patients in MSF programmes and beyond. www.msfaccess.org MSF AND HIV Médecins Sans Frontières (MSF) began providing antiretroviral therapy to a small number of people living with HIV/AIDS in 2000 in projects in Thailand, South Africa and Cameroon. At the time, treatment for one person for one year cost more than US$10,000. With increased availability of low-cost, quality antiretroviral drugs (ARVs), MSF provides antiretroviral treatment to 247,000 people in 18 countries, implements treatment strategies to reach more people earlier in their disease progression, and places people living with HIV at the centre of their care. Over the past 16 years, the MSF Access Campaign has been monitoring the barriers to availability and affordability of life-saving ARVs and appropriate formulations, including patent monopolies, prices and lack of generic competition through Untangling the Web and pushing for the uptake of policies that promote access to affordable quality medicines. Due primarily to generic competition, the price of ARVs has dropped by more than 99% over the last 15 years, but the price of the newest drugs, already needed by some people in MSF projects, is prohibitive and a source of great concern both for MSF and national treatment programmes. PATENT OPPOSITION DATABASE The Patent Opposition Database was launched by the MSF Access Campaign in October 2012 as an online space where civil society can share the resources and tools needed to oppose patents on medicines. The database gathers contributions from around the world. It allows documents to be shared, arguments to be replicated, and new alliances to be forged, with the aim of successfully opposing patents and ultimately improving access to medicines in developing countries. To find out more about patents that block access to essential medicines and what you can do to challenge them, or to contribute by sharing resources, visit: www.patentoppositions.org Médecins Sans Frontières | July 2016
TABLE OF CONTENTS TABLE OF CONTENTS 2 STATE OF HIV TREATMENT ACCESS Speed up treatment scale-up in Western and Central Africa 4 OPTIMISING HIV TREATMENT 7 PRICING High antiretroviral prices in middle- and high-income countries 11 REGISTRATION Lack of access to dolutegravir in India 12 PATENT OPPOSITIONS AND PATENT LAW REFORM Patent oppositions for hepatitis C Evergreening 14 TRADE AGREEMENTS LDC exemption from pharmaceutical IP extended Colombia: Compulsory licence threat invites US pressure 16 STOCKOUTS Market shaping institutions – what needs to happen Update on the Medicines Patent Pool’s new licences 18 CONCLUSION 19 ANNEX: SUMMARY TABLE OF ALL PRICES 22 REFERENCES 24 GLOSSARY AND ABBREVIATIONS Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 1
STATE OF HIV STATE OF HIV TREATMENT ACCESS TREATMENT ACCESS In 2000, when the International AIDS Conference was last held in Durban, South Africa, a basic antiretroviral (ARV) regimen cost over US$10,000 per person per year (pppy), multilateral programmes funding the fight against HIV, TB, and malaria did not exist, and many donors – such as the US government – had yet to provide a single dollar for antiretroviral treatment in resource-limited countries. Now, in 2016, 17 million HIV-positive for 2020, referred to as ‘90-90-90’.3 people are receiving lifesaving To meet these targets, the number of THE 2020 UNAIDS antiretroviral therapy (ART),1 and the people on treatment will need to more lowest price for a generic, World Health than double again, since nearly 20 TARGET: 90-90-90 Organization (WHO)-recommended million HIV-positive people are newly By 2020, 90% of all first-line regimen is $100 pppy. eligible for ART under the new ‘treat- HIV-positive people will be all’ recommendation.1 aware of their status; 90% In 2015, the number of people starting HIV treatment surpassed the number At the UN High Level Meeting on of all people diagnosed of new infections in Africa for the HIV in June 2016, governments with HIV will have access to first time. Since 2010, the number of agreed on a global target: reaching sustained ART; and 90% of people receiving ART has more than 30 million people with treatment people on ART – or 73% of doubled.1,2 The push to continue by 2020. Reaching this goal will all HIV-positive people – will ARV scale-up has gained momentum require increased and sustained achieve viral suppression.3 around the UNAIDS global targets support from donors. © Isabel Corthier Tsandia receives her antiretroviral medicines at the HIV department of the Arua Regional hospital in Uganda. 2 Médecins Sans Frontières | July 2016
STATE OF HIV TREATMENT ACCESS GRAPH 1: GENERIC COMPETITION AS A CATALYST FOR PRICE REDUCTION FOR A FIRST-LINE REGIMEN Originator products Generic products 12000 10439 10000 US$ per person per year 8000 6000 4000 2767 2000 549 0 132 June 00 Sept 01 June 02 June 03 Dec 03 Apr 04 June 05 June 06 Since 2000, MSF has been providing HIV care and treatment to people in developing countries. Today, MSF provides HIV treatment for nearly 250,000 people. SPEED UP TREATMENT SCALE-UP IN WESTERN AND CENTRAL AFRICA Although HIV prevalence is lower in worsened by the Ebola outbreak - tests, drug stockouts, out-of-pocket Western and Central Africa than in add to barriers that include limited fees for healthcare, and lack of Southern Africa, over a quarter of access to diagnostic and monitoring decentralised treatment.4 all AIDS-related deaths occur in the region, including 40% of all deaths among children.4 In Central African Republic, HIV prevalence is 5%, but HIV accounts for 84% of hospital-based deaths where MSF works. In Democratic Republic of the Congo, three out of four HIV-positive people who present to the hospital where MSF works are too sick to save. In 2015, only 1.8 million © Sam Phelps people (28%) of the region’s 6.5 million HIV-positive people were accessing ART.1 Political instability, inadequate funding and Mohamed (left) is tested for HIV at an MSF mobile clinic in Conakry, Guinea. weak healthcare systems - some Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 3
OPTIMISING HIV TREATMENT OPTIMISING HIV TREATMENT COUNTRIES SHOULD IMPLEMENT WHO GUIDELINES Immediate treatment and a steady WHO has recommended immediate of care that put the patient at the supply of affordable medicines are and lifelong ART for everyone with centre of their treatment.10 essential to curbing the HIV epidemic. HIV: all infants, children, adolescents, Countries should implement the WHO ART lowers the risk of serious illness and adults, including pregnant and recommendations, including ‘test and and death, reduces the risk of breastfeeding women, regardless of start’, routine viral load monitoring developing tuberculosis (TB) by CD4 cell count or disease stage.9 [see below], better drugs (new 65%, and reduces HIV transmission In June 2016, WHO issued new HIV ARVs and once-daily, fixed-dose by 96%.5,6,7,8 treatment guidelines, including combinations), adherence support, and In light of the individual and recommendations for new ARV differentiated models of care to facilitate community benefits of HIV treatment, regimens and differentiated models rapid scale-up and quality patient care.10 ROUTINE VIRAL LOAD MONITORING Access to viral load testing – the gold standard for HIV treatment monitoring – is essential to achieving the 90-90-90 targets. For infants, an early diagnosis can be life-saving – and requires viral load testing. In 2016, WHO recommended point-of-care viral load testing for HIV-exposed infants.10 Since 2013, WHO has recommended routine viral load monitoring for diagnosing HIV treatment failure; the 2015 guidelines recommend viral load monitoring – now with dried blood spot testing – at six and 12 months after starting ART. For stable patients, viral load monitoring is recommended once every year thereafter instead of CD4 cell count monitoring.9,10 As tests have become more affordable and rollout less complex, more countries have adopted routine viral load as part of national policy. However, implementation still lags far behind; a 2014 WHO study of 122 low- and middle-income countries found that only 22% of people on ART received viral load monitoring.11 MSF began implementing viral load testing in 2012. In Lesotho, Malawi, Mozambique, Swaziland, Uganda, and Zimbabwe, risk factors for having a detectable viral load have been © Isabel Corthier identified, leading to interventions including a child-friendly clinic, community ART groups, and enhanced adherence counselling. Routine viral load testing has triggered a switch to second-line treatment and enhanced People wait to have their blood tested to measure their viral load at the HIV department adherence counselling in 10% to 68% of Arua Regional Hospital in Uganda. of patients. 12 4 Médecins Sans Frontières | July 2016
OPTIMISING HIV TREATMENT IMPROVING FIRST-LINE TREATMENT The 2015 WHO HIV treatment guidelines added recommendations for two alternative first-line ARVs: dolutegravir (DTG), a well-tolerated integrase inhibitor that rapidly lowers HIV viral load and is robust, with very few documented cases of resistance,13 and a lower, equally effective dose of efavirenz (EFV; 400mg vs. 600mg)9 © Ron Haviv/VII Photo that is better tolerated than the higher dose.14 Before these ARVs become part of a preferred first-line regimen, additional clinical data on their safety and efficacy during TB treatment, pregnancy, and breast-feeding are An MSF outreach worker measures out antiretroviral medication during a home visit needed;9,15 these studies are planned in Dawei, in southeastern Myanmar. or underway. BETTER SECOND-LINE TREATMENT As access to viral load monitoring increases, more people in need of second-line treatment will be identified. The WHO treatment guidelines have added two alternative recommendations for second-line ART: a heat-stable, fixed-dose combination (FDC) of darunavir/ritonavir (DRV/r) and a two-drug regimen of raltegravir (RAL; an integrase inhibitor) with lopinavir/ritonavir (LPV/r).10 DRV is a boosted protease inhibitor (PI) with fewer side effects than the © Julie Remy other second-line protease inhibitors (although it cannot be used during rifampicin-based TB treatment).16,17,18 But access to DRV/r is limited; there is no quality-assured heat-stable Loved Mupandanana is HIV positive, and her first-line treatment for HIV seems to be FDC on the market, and the current failing. At Gombe clinic, in Manicaland Province in Zimbabwe, she is receiving counselling about the need to move on to second-line treatment. price of generic DRV alone is at least three times more than other protease inhibitors, making it costly for wide- spread use. In 2015, MSF provided second-line HIV treatment for 10,200 people. Continued overleaf Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 5
OPTIMISING HIV TREATMENT Optimising HIV treatment continued THE ARV PIPELINE FOR ADULTS The ARV pipeline includes new drug three TAF-based FDCs (in November improve adherence and significantly formulations and classes. Tenofovir 2015, March 2016 and April 2016). reduce the cost of HIV treatment; alafenamide (TAF), a new prodrug of Stand-alone TAF has been approved interim results from a trial of a long- tenofovir disoproxil fumarate (TDF), in Europe (and filed in the US) for acting injectable combination (rilpivirine is equally effective as the currently hepatitis B treatment only. If Gilead, and cabotegravir) are promising, available version, at one-tenth of the the company marketing TAF, does not although an interaction between dose. TAF is likely to be safer, and register the drug as a single ARV for cabotegravir and rifampicin requires should be significantly less expensive use in HIV, generic manufacturers may further study.20,21,22,23 to produce than TDF,19 but data on face complications and long delays New ARV classes include attachment drug interactions between TAF and TB in registering TAF-containing FDCs in and maturation inhibitors; there are also treatment are needed. other countries. new versions of integrase inhibitors and The United States Food and Drug Long-acting, injectable ARVs with non-nucleoside reverse transcriptase Administration (USFDA) has approved monthly or bi-monthly dosing could inhibitors (NNRTI) in development. THE ARV PIPELINE FOR CHILDREN Only 49% of the world’s HIV-positive children difficult. The price of the pellets children had access to treatment in needs to be reduced so it is at least In 2015, MSF 2015.24 Without treatment, over half on par with the syrup, to encourage of all HIV-positive children die before countries to adopt them. supported their second birthday;25 treating infants treatment for The Drugs for Neglected Diseases when they are less than 12 weeks old 6,800 HIV-positive initiative (DNDi) LIVING study is lowers mortality by 75%.26 looking at the safety, effectiveness pregnant women, Research and development of and acceptability of LPV/r pellet-based and post-exposure paediatric ARVs and FDCs has lagged therapy in infants (>four weeks old) treatment for far behind adult treatment, which has and children, with enrolment having 4,400 babies. severely limited treatment options for begun in Kenya.30 HIV-positive infants and children. There is a new pellet formulation of LPV/r, which is part of the WHO- recommended first-line regimen for children under three years old.10 In May 2015, the USFDA granted tentative approval for LPV/r pellets for children who weigh >5 kg and are over 14 days old.27,28 This formulation of LPV/r is available to a limited group of low- and middle-income countries through a Medicines Patent Pool (MPP) voluntary licence (VL), although one © Sydelle WIllow Smith year after stringent regulatory authority (SRA) approval, it has not yet been made commercially available. Pellets could replace LPV/r syrup, which contains 40% alcohol and propylene glycol, requires refrigeration, and has been described as tasting “horrible”29 – Jennipher Mwamvera is a mother of four and a patient in the prevention-of-mother-to- child transmission of HIV (PMTCT) program in Thyolo, Malawi. all of which have made treating young 6 Médecins Sans Frontières | July 2016
PRICING PRICING Affordable generic ARVs have made HIV treatment scale-up possible in countries that can access them. Robust competition between multiple generics producers has dramatically lowered the price of first-line antiretroviral therapy over the last decade-and-a-half. FIRST-LINE REGIMENS Since 2014, there has been a 30% (TDF/FTC/EFV) can be as low as Aurobindo’s generic version of reduction in the price for generic $100 pppy, down from $143 pppy in dolutegravir will have a price of first-line treatment.* If countries are 2014. Prices for first-line treatment $44 pppy,32 which is on par with able to import and use generics, are unlikely to decrease further, since the price of efavirenz 600mg. the price for the fixed-dose of the they are now close to the minimum A fixed-dose combination of DTG WHO-recommended combination sustainable production price, with TDF/XTC should be available of tenofovir/emtricitabine/efavirenz according to experts.31 by the end of 2017. Continued overleaf GRAPH 2: THE PRICES OF DIFFERENT FIRST-LINE REGIMENS TODAY 1200 $1033 1000 US$ per person per year 800 $ 613 600 400 200 $164 $106 $100 $94 $124 $66 0 Lowest Lowest Lowest Lowest Lowest Lowest Originator Originator generic price generic price generic price generic price generic price generic price price for price for AZT/3TC/NVP TDF/3TC + NVP AZT/3TC + EFV TDF/3TC + EFV TDF/3TC/EFV TDF/FTC/EFV Cat.1 Cat.2 TDF/FTC/EFV TDF/FTC/EFV * Price reductions may be due in part to currency fluctuations. Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 7
PRICING Pricing continued GRAPH 3: THE EVOLUTION IN PRICE OF DIFFERENT FIRST-LINE REGIMENS TDF/FTC/EFV (1 pill/once a day) TDF/3TC/EFV (1 pill/once a day) AZT/3TC + EFV (1 pill/twice a day + 1 pill/once a day) 600 500 487 US$ per person per year 426 400 410 300 200 164 106 100 100 0 June 07 June 08 Dec 09 June 10 June 11 June 12 June 13 June 14 June 16 HIGH ANTIRETROVIRAL PRICES IN MIDDLE- AND HIGH-INCOME COUNTRIES According to UNAIDS, 70% of all not included in voluntary licensing High-income countries such as the HIV-positive people will be living in agreements, and/or have not used US are struggling with spiralling middle-income countries by 2020.33 TRIPS flexibilities such as compulsory costs of patented medicines, licences.* Instead, they must pay including ARVs. In the US, the Several ARVs are still on patent in high prices to originator companies combination of TDF/FTC/EFV (sold middle-income countries. Some for patented drugs on a case-by- under the brand name Atripla) costs lower- and upper-middle-income case basis or under ‘tiered pricing’ nearly $30,000 pppy35 versus $100 countries where patent barriers on schemes that are not based on a pppy for Indian generic versions. key ARVs remain cannot produce or buy generic ARVs, because they are realistic concept of affordability.34 * The World Trade Organization’s Trade-Related Aspects of Intellectual Property (TRIPS) Agreement can and should be interpreted in light of the goal “to promote access to medicines”. Legal safeguards include (but are not limited to) enabling networks of people living with HIV/AIDS to challenge patent claims before and/or after they are granted; the right to examine patent claims strictly and reject new use and/or new forms of known medicines; the right to register generic versions of patented medicines; the right to issue compulsory licences (CLs; these allow countries to import or locally produce generic versions of patented medicines without the patent holder’s consent); and the right to import and resell lower-priced medicines from other countries instead of paying higher prices for them – also without consent from the patent holder (called parallel importing). 8 Médecins Sans Frontières | July 2016
PRICING SECOND-LINE REGIMENS Boosted protease inhibitors are the Although LPV/r must be taken twice Prices for boosted protease inhibitors backbone of second-line regimens. a day, it can be dose-adjusted for use are especially high in middle-income The lowest-priced generic second- with rifampicin-based TB treatment. countries, since many of them have line regimen, zidovudine/lamivudine LPV/r is still more expensive than patent barriers and are excluded from (AZT/3TC) and atazanavir/r (ATV/r), is ATV/r, at $243 pppy versus $213 voluntary licensing agreements. In now priced at $286 pppy. Since 2014, its designated Category 2 countries,* pppy [see graph 4]. The price of the price has dropped by 11%, from AbbVie charges higher prices for LPV/r generic LPV/r is 5% higher than $322 pppy. than in least-developed countries the originator product, because the (LDCs): $740 pppy (which has not Switching to second-line therapy originator company, AbbVie, has been changed since 2012), compared to nearly triples the price of treatment consistently undercutting generic $231 pppy in LDCs [see graph 4]. In [see graph 5]. Currently, there competition with slightly lower prices. Malaysia, prices for LPV/r were quoted are two WHO-preferred boosted above $3,500 pppy in 2014.36 The protease inhibitors for second- For several of the newer second-line originator price from Bristol-Myers line regimens, ATV/r and LPV/r; options, current demand is low. The Squibb (BMS) for atazanavir– which one alternative boosted protease price of generic versions has not yet must be used with ritonavir (RTV) – is inhibitor, darunavir+r (DRV+r); and come down, and only a few $816 pppy; AbbVie’s originator price an alternative, twice-daily two-ARV producers have entered the market. for RTV is set on a “case-by-case” basis. regimen, the integrase inhibitor DRV is much more expensive than raltegravir (RAL) plus LPV/r.10 The lowest originator price for RAL is ATV/r or LVP/r, and it is not available $675 pppy; the lowest-price generic as a fixed-dose combination with A generic, fixed-dose, heat-stable version is $973 pppy [see graph 6]. ritonavir (RTV or r). Darunavir is formulation of ATV/r is available. It has Currently, RAL is taken twice daily, fewer side effects than LPV/r, although available from the originator for however, Merck plans to submit it cannot be used during rifampicin- $663 pppy; generic versions are data to the USFDA and the European based TB treatment. Because of supply $1217 pppy, since the current low Medicines Agency (EMA) to seek problems with LPV/r, an increase demand prevents companies from approval for once-daily RAL.37 RAL in demand for ATV/r is expected, being motivated to commercialise it can be dose-adjusted for use during hopefully leading to lower prices. in low- and middle-income countries. rifampicin-based TB treatment.38 GRAPH 4: THE EVOLUTION IN PRICE OF BOOSTED PROTEASE INHIBITORS FOR SECOND-LINE REGIMENS Lowest generic ATV/r Originator price for Cat. 1 LPV/r Lowest generic LPV/r Originator Price for Cat. 2 LPV/r 1200 1034 1000 1000 US$ per person per year 800 740 600 500 400 304 243 231 200 213 0 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 * Albania, Armenia, Azerbaijan, Belarus, Bolivia, Bosnia and Herzegovina, China, Colombia, Dominican Republic, Ecuador, El Salvador, Fiji, Georgia, Guatemala, Guyana, Honduras, India, Indonesia, Jamaica, Jordan, Kazakhstan, Kyrgyzstan, Macedonia, Marshall Islands, Micronesia, Moldova, Mongolia, Montenegro, Nicaragua, Pakistan, Papua New Guinea, Paraguay, Peru, Philippines, Serbia, Sri Lanka, Suriname, Syria, Tajikistan, Thailand, Tonga, Turkmenistan, Ukraine, Uzbekistan, Viet Nam. Continued overleaf Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 9
PRICING Pricing continued SALVAGE REGIMENS There is an urgent need for more + ETV), in countries that fall into the $1,217; this does not include the ritonavir affordable third-line, or salvage regimens select group eligible for access pricing it must be used with. At the same time, for people that have acquired resistance from originators (but many countries the access price from the originator has to first- and second-line treatment. are paying much more). This represents dropped by 17%, from $810 to $675. Low volume and high prices from both nearly an 18-fold increase over the lowest A quality-assured generic RAL is priced at originator and generic companies keep first-line prices, and nearly a seven-fold $973 pppy, but it is still more expensive these medicines out of reach. increase over the most affordable than the originator version, which has second-line regimen [see graph 5]. The lowest price for a salvage regimen stayed at $675 since 2011. The originator today is $1,859 pppy, for darunavir+r, Since 2014, the price of generic DRV price for ETV has stayed at $438 since raltegravir and etravirine (DRV+ r + RAL has increased by 10%, from $1,095 to 2011 [see graph 6]. GRAPH 5: PRICE COMPARISONS OF FIRST-LINE, SECOND-LINE AND POSSIBLE THIRD-LINE TREATMENT REGIMENS 2000 $1,859 1500 x 17.4 US$ per person per year x 6.5 1000 x 2.7 500 $106 $286 0 Lowest generic price Lowest generic price RAL+DRV+r+ETV TDF/3TC/EFV AZT/3TC+ATV/r First-line regimen Second-line regimen Third-line regimen GRAPH 6: PRICES FOR THIRD-LINE ARVS DRV 600 mg originator price RAL 400 mg originator price DRV 600 mg generic price RAL 400 mg generic price ETV 100 mg originator price 2000 1750 1752 US$ per person per year 1500 1250 1217 1095 1000 973 913 810 750 675 675 663 500 438 250 0 June 11 June 12 June 13 June 14 June 15 June 16 10 Médecins Sans Frontières | July 2016
REGISTRATION REGISTRATION In many countries, marketing authorisation for promising new ARVs can take several years; this type of regulatory lag forces people living with HIV/AIDS to wait for life-saving medicines. National Drug Regulatory Authorities (NDRAs) do not always have the resources to ensure timely registration of more affordable generic versions of new ARVs, and/or fail to prioritise them.39 Pharmaceutical companies don’t Collaborative or regional registration new drugs for neglected diseases, ARVs often prioritise registration in low- processes have reduced the time to for paediatrics, and salvage regimens. and middle-income countries. Some registration for some products in In addition, the Indian NDRA should originator companies shift the some participating countries. These prioritise new ARVs, FDCs, and child- responsibility for filing registration collaborations should be considered friendly formulations, taking note of, dossiers in high-burden developing by national regulatory authorities to and relying on WHO guidelines and/or countries to generics companies that reduce the considerable workload Expression of Interest from the have signed voluntary licences. associated with reviewing registration WHO prequalification programme.* dossiers. For example, in East Africa, In some countries, generics companies Another delay is the WHO a pilot of the African Medicines are able to register generic versions prequalification programme, which has Registration Harmonisation Initiative of medicines, but in others, when been essential for reviewing the quality, has reduced the time to registration originators don’t register their ARVs safety, and efficacy of generic ARVs that by 50% in Burundi, Kenya, Rwanda, before generics companies do, it may aren’t always reviewed or approved by Uganda, and Zanzibar.39 cause significant delays, or become an a stringent regulatory authority (SRA). absolute barrier to treatment access. India’s lack of intellectual property In 2013, the median wait for WHO (IP) barriers and historically efficient prequalification was 15.1 months.39 Countries have different regulatory regulatory pathway made it possible pathways, priorities, rules, for generics companies to produce and requirements, legal frameworks, register more affordable medicines for capacities, and timelines, and some developing countries. But availability 97% of the do not have NDRAs. There is no of new quality-assured generic ARVs medicines MSF uses ‘essential documentation package’ to streamline the registration process and FDCs from India is starting to be to treat people with delayed. This is partly because India’s across all NDRAs in developing criteria to waive phase III clinical trials HIV are generics countries, and country-level are restrictive in certain cases. These made in India. bureaucracy can delay registration. criteria need to be expanded to include BARRIERS TO UNIVERSAL ACCESS TO GENERIC DOLUTEGRAVIR FROM INDIA The pharmaceutical company ViiV has granted voluntary for registration in India. As a result, the responsibility licences (VLs) for the integrase inhibitor dolutegravir for registration is now with Indian producers that have (DTG) to several Indian generic companies through developed generic dolutegravir. They will need to do the Medicines Patent Pool (MPP). The VLs will not local clinical trials, as per the Indian NDRA requirements result in universal access to the drug, since a number of for new drugs, which will lead to a significant delay high-burden countries are excluded from the territories in the availability of affordable generics across the that can import the generic version from India. developing world. In the meantime, patients in India In India, generic DTG will only be available on the who have exhausted other treatment options are left public market or to non-governmental providers, without access to DTG, since ViiV has been dragging its leaving a number of patients with drug resistance feet to provide the medicine via compassionate use. who need immediate access without any source To ensure open generic competition in the future, from Indian pharmacies. a patent opposition for DTG has been filed in India, Although DTG has been registered in many other by and on behalf of people living with HIV, and countries, ViiV, the originator company, has not filed supported by MSF. * These include: dolutegravir (DTG) singles and FDCs, including tenofovir/lamivudine/dolutegravir; a low-dose (400mg) efavirenz FDC and heat-stable darunavir/ritonavir Priority pediatric formulations for HIV include: lopinavir/ritonavir pellets or sachets; abacavir/lamivudine/lopinavir/ritonavir (ABC/3TC/LPV/r) zidovudine/lamivudine/lopinavir/r (AZT/3TC/LPV/r) pellets or sachets for children over three years old and lamivudine/abacavir/efavirenz (3TC/ABC/EFV 75/150/150mg) dispersible tablets for children ages 3-10 years. Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 11
PATENT OPPOSITIONS PATENT OPPOSITIONS AND PATENT LAW REFORM AND PATENT LAW REFORM INDIA, THE ‘PHARMACY OF THE DEVELOPING WORLD’, IS UNDER PRESSURE TO DROP ITS PUBLIC HEALTH SAFEGUARDS Indian generics comprise 76% of of Intellectual Property Rights [TRIPS]). pressure – led by the multinational the ARVs used in low- and middle- India’s national patent laws include pharmaceutical lobby – to change its income countries and more than public health safeguards such as national intellectual property laws and 97% of those used by MSF in its stringent patentability criteria, and the policies, or sign free trade agreements treatment programmes.31,44 India opportunity to file legal challenges to that will dismantle them. Over the last encouraged generic competition for patents before and/or after they are two years, pharmaceutical industry- decades, since it did not introduce granted (called pre-and post-grant led pressure from the US has been patent oppositions). patents for pharmaceuticals until escalating. India must reject the 2005 (when it had to comply with India has fought off numerous demands to grant patents more easily, international trade rules under the challenges to its public health as well as TRIPS-plus rules that the World Trade Organization [WTO] safeguards, but it has been under United States is trying to force upon Agreement on Trade-related Aspects excessive external and domestic India’s Ministry of Commerce. PATENT OPPOSITIONS FOR HEPATITIS C Patent oppositions have been used when patent has applied for WHO prequalification for their generic claims do not meet national patentability criteria, version of the drug. and when a patent directly blocks or delays access In India, one critical sofosbuvir patent has been to essential medicines. recently granted, reversing its prior rejection in 2015. Worldwide, an estimated 150 million people This decision is now under appeal. If upheld, the have chronic hepatitis C virus infection; without patent will block additional competition from the treatment, they are at risk of developing liver Indian generics companies that do not want to sign failure and liver cancer.45 a voluntary licence with Gilead, leaving them unable Hepatitis C can be cured with a few months’ treatment to supply sofosbuvir to millions of people in India using oral drugs, called direct-acting antivirals (DAAs). and other middle-income countries. In addition, this In 2013, the price of the first DAA on the market, decision would allow Gilead to disrupt or stop exports sofosbuvir, sent shock waves throughout the world. of the raw materials from India that are used to make Although it can be mass-produced for less than sofosbuvir’s key active pharmaceutical ingredient (API). $1 per pill,46 sofosbuvir’s launch price was $1,000 This will make it difficult for the generics companies in per pill in the US. Egypt, Bangladesh, Pakistan and Latin America that are Gilead’s patent on sofosbuvir has been opposed – producing sofosbuvir without a patent in force – and and rejected – in some countries. The patent on the without a licence agreement with Gilead – to continue pro-drug form of sofosbuvir was rejected in China and production. More patent oppositions on sofosbuvir Ukraine. In Egypt, where the primary patent application have been filed in Argentina, Brazil, Russia, Thailand, for sofosbuvir was rejected, a company called Pharco France and India. 12 Médecins Sans Frontières | July 2016
PATENT OPPOSITIONS AND PATENT LAW REFORM PATENT LAW REFORM IN BRAZIL, SOUTH AFRICA AND ARGENTINA South Africa and Brazil are in the pharmaceutical companies involved that charge unaffordable prices. process of reforming their patent laws, in the ‘Pharmagate’ scandal (a In order to overcome IP barriers to in part to more effectively manage covert, $600,000 campaign funded generic competition, a coalition of prices for medicines, and to encourage by large pharmaceutical companies civil society groups has recently filed a competition (and local production). and medical device producers to patent opposition in Brazil on the main There is a lot at stake: South Africa has delay - and influence - South African patent related to TAF. In addition, in the largest number of people living with patent reforms). South African Health November 2015, GTPI (Working Group HIV in the world, and Brazil guarantees Minister Aaron Motsoaledi has accused on Intellectual Property), a civil society HIV treatment for all, with many people the multinational pharmaceutical coalition, filed a patent opposition to on salvage therapy, as well as first- and companies in South Africa of conspiring deny a patent to BMS (for atazanavir; second-line treatment. But delays in against the state and the people of ATV) that could extend the patent patent law reform will undermine access South Africa, and called on all South holder’s monopoly until 2024. Brazil to affordable medicines, including ARVs. Africans to fight back “…to the last currently pays $496.40 pppy for drop of their blood.”50 the 300mg version of ATV; a Health SOUTH AFRICA Ministry-approved licence between In 2015, 3.1 million people living BRAZIL BMS and the Brazilian government- with HIV were accessing antiretroviral Brazil is consistently excluded from linked pharmaceutical laboratory therapy through South Africa’s public voluntary licensing programmes, and Farmanguinhos forbids production of sector,47 and the government recently therefore forced into tiered pricing atazanavir in newer formulations and announced a ‘test and start’ policy.48 schemes from originator companies combinations, such as ATV/r.51 As more people are treated, the need for second-line and salvage regimens will increase. Many of these ARVs are patented and are too expensive for the government to procure for the public sector. But South Africa has not introduced or implemented key measures to safeguard public health, including fully adopting TRIPS flexibilities, and especially substantive examination of patent claims. In 2008 alone, South Africa granted 2,442 patents, while Brazil granted only 272 patents between 2003 and 2008.49 © Stefan Heunis In 2009, South Africa’s Department of Trade and Industry (DTI) initiated a process to reform the country’s IP law and policy. In 2011, TAC, Section 27 and MSF co-launched the ‘Fix the Patent Laws’ campaign, which now includes 18 MSF and the Treatment Action Campaign launched the ‘Fix the Patent Laws’ campaign other non-governmental organisations. to demand patient-focused reforms to South Africa’s patent laws. The campaign highlights how pharmaceutical companies have used evergreening tactics to exploit South Africa’s patent system. In September EVERGREENING 2013, the DTI released a draft policy Many countries often do not expired, but they are not because document for public comment. But the examine patent claims strictly, of evergreening. new policy is still not finalised, and is not leaving them vulnerable to In Ukraine, home to nearly expected until mid-2017. ‘evergreening’, whereby 265,000 people living with HIV,40 pharmaceutical companies make The longer DTI delays, the longer it GSK extended its abacavir (ABC) minor changes to medicines that will take for South Africa to introduce patent monopoly by eight years are already on the market to extend short- and long-term reforms that with its secondary patent on the their patents. Several ARVs should can accelerate and promote generic hemisulfate salt.41 Ukraine’s price now be free from patent barriers competition, and to drive down prices for originator ABC is $277.40 (including ABC, DRV, EFV and for patented drugs. The delay also raises pppy42 versus $123.42 pppy for RTV) since their basic patents have concern about undue political and the generic version.43 commercial pressure from multinational Continued overleaf Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 13
PATENT OPPOSITIONS AND PATENT LAW REFORM/ TRADE AGREEMENTS Patent oppositions and patent law reform continued At the same time, multinational In November 2014, a multinational Argentina adopted new patentability drug companies are using lawsuits group of pharmaceutical companies examination guidelines for the to challenge measures that promote (INTERFAMA, the Pharmaceutical pharmaceutical sector to prevent the generic competition in Brazil, including Research Industry Association) filed granting of numerous patents that the country’s patent examination a Collective Action against ANVISA, do not meet specific criteria such as process. Since 2001, ANVISA, Brazil’s questioning the legitimacy of ANVISA’s novelty, inventive step, and industrial national drug regulatory agency, has participation in the patent granting application. Since Argentina’s new participated in analysing pharmaceutical process. Local civil society groups have guidelines were enacted, 95% of patent applications, instead of leaving strongly reacted to these setbacks. ARV patent applications have been this task exclusively to patent office rejected, an increase from the 51% Patent law reform that would improve examiners, and ANVISA has rejected rejection rate in 2012.54 affordability of new medicines has more than 400 of them. ANVISA’s role been delayed for more than two years. In 2015, CAEME – the association in pharmaceutical patent examination In 2013, a ‘package’ of bills to amend of multinational pharmaceutical has been considered an important Brazil’s patent law was introduced. If companies in Argentina – filed a safeguard to public health and access to approved, it will ensure that Brazil has court case questioning the validity of medicines.52 Multinational companies clearer criteria for patent examination, the patent guidelines. In response, have frequently contested ANVISA’s and introduce important flexibilities civil society groups from Brazil rejections in court. In 2011, the Attorney into its national laws.53 and Argentina launched the ‘Big General’s Office (AGU) issued a legal opinion strengthening the position of Pharma Drop the Case’ campaign at pharmaceutical companies – although it ARGENTINA the 31st session of the UN Human proved unenforceable, the AGU has not Argentina has taken steps to Rights Council, to push CAEME and formally withdrawn its legal opinion. improve its patent laws. In 2012, INTERFARMA to abandon their actions. TRADE AGREEMENTS Governments, civil society and generics producers should use TRIPS flexibilities to improve affordability of, and access to, needed medicines. But TRIPS flexibilities are endangered by free trade agreements (FTAs) that pose serious threats to access to affordable medicines. These FTAs include intellectual property provisions – so-called ‘TRIPS-plus’ provisions – that exceed countries’ obligations under World Trade Organization (WTO) trade rules. EU-INDIA FTA TRANS PACIFIC access to generic medicines due to the proposed inclusion of TPP-like Negotiations on the EU-India FTA PARTNERSHIP intellectual property rules by Japan began in 2007. They have been stalled AGREEMENT (TPP) and South Korea. since 2012, in part due to public The TPP is a far-reaching trade agreement across the Asia-Pacific region. If ratified, Countries that did not join the TPP – pressure, but may resume this year. the TPP will be the worst-ever trade particularly India and key members The EU-India FTA could jeopardise agreement for access to medicines: it will of the Association of Southeast access to India’s affordable generic Asian Nations – will be pushed to lengthen, deepen and expand intellectual medicines for millions of people, by property and patent monopolies, and adopt similar standards in the RCEP limiting production, sale and export of prevent or delay access to affordable, negotiations, which would represent a medicines in the future. life-saving generic medicines for millions rollback of protections against extended of people.56 While the TPP agreement has patent terms and data exclusivity that In the past, the EU has demanded been signed by governments, it has yet to are part of past agreements. a range of intellectual property be ratified by any country. provisions that exceed India’s The RCEP negotiations will have REGIONAL serious repercussions globally, since obligations under TRIPS, including both India, the ‘pharmacy of the measures that would allow companies COMPREHENSIVE developing world’, and China, the to prevent legitimate export of ECONOMIC world’s largest producer of the active medicines to developing countries or PARTNERSHIP (RCEP) pharmaceutical ingredients (API) used bring legal action against people who The RCEP trade negotiations among to make medicines, are among the 16 buy or distribute generics.55 16 Asia-Pacific countries could threaten countries included in the negotiations. 14 Médecins Sans Frontières | July 2016
TRADE AGREEMENTS COLOMBIA: COMPULSORY LICENCE THREAT INVITES US PRESSURE In April 2016, a leaked letter Thailand, Ecuador), which has As of mid-June 2016, the Colombian from the Colombian Embassy discouraged other governments Minister of Health announced that described how the US Senate from issuing compulsory licences they had issued a ‘public interest Finance Committee and the to ensure affordable medicines. declaration’ regarding imatinib, United States Trade Representative As WHO states in its letter to without public information about were pressuring the Colombian Colombia’s Minister of Health, whether the government will issue government not to issue a “unaffordable high prices of a compulsory licence to allow compulsory licence* for the anti- essential medicines, including for manufacturing and import of price- cancer cancer drug imatinib.58 non-communicable diseases, are lowering generic versions of the A number of countries have also a legitimate reason for issuing a drug, or simply reduce the price of faced similar pressure (Brazil, compulsory licence”.59 the Novartis product.60 LDC EXEMPTION FROM PHARMACEUTICAL IP EXTENDED Least-developed countries section 7) for pharmaceutical protect their TRIPS flexibilities in (LDCs) have been granted an products until 1 January 2033. 57 complex FTA negotiations. exemption from certain obligations But the free-trade agreements LDCs in Asia, including Laos, under TRIPS, in recognition of that are being negotiated in many Bangladesh, Cambodia and Myanmar, their economic, financial and countries across the Asia-Pacific as well as countries in sub-Saharan administrative constraints and region, in particular RCEP [see Africa, should continue to use the their need to make or procure low Trade Agreements, page 14], waiver to the fullest extent possible cost generic medicines. Under this could undermine the LDC transition to improve access to medicines transition period, LDCs do not have period, unless UN agencies and and should resist any pressure to to apply or enforce TRIPS provisions civil society provide technical and prematurely introduce intellectual concerning patents (TRIPS section political support to negotiating property rules that would undermine 5) or test data protection (TRIPS countries, particularly LDCs, to access to generic medicines. © Aye Pyae Sone Regular check-up session for HIV positive patients at Muse clinic in Myanmar. * A compulsory licence (CL) is an effective option for increasing access to ARVs and other medicines in countries where they are patented. It is a legal mechanism to allow producers other than the originator company to make the drug or to import generic versions into a given country. Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 15
STOCKOUTS STOCKOUTS For years, many countries have faced shortages and stockouts of essential medicines. Stockouts can be caused by logistical and administrative challenges in procurement, supply chain management, or ‘last mile delivery’, and by medicines having only a single source (which may lead to shortages: these are generally those under patent, without compulsory or voluntary licences that allow generic manufacturers to supply them). Because of stockouts, people may governments should make plans needed to ensure sufficient availability, receive smaller amounts of the for treatment transitions, ensure while achieving economies of scale. medicine they need, which means appropriate buffer stocks and give extra time-consuming trips to the clear clinical guidance on making In South Africa, the Stop Stockouts clinic. They may also be switched switches correctly. Project has empowered patients and to different, less-optimal doses or pushed for accountability in the supply regimens, or be told to buy the Generic manufacturers must work of medicines. The Project receives and medicines they need from the quickly to avoid shortages and publishes daily reports about drug private market with the promise of stockouts, using information about stockouts from people living with HIV reimbursement (which is usually not current and pipeline ARVs, dose and health care workers, conducts fulfilled), or go without medicine optimisation, changes in treatment comprehensive national surveys to altogether - which can lead to drug guidelines and eligibility, national and monitor the locations and extent of resistance and illness. global targets for treatment scale-up, stockouts, and works with National As countries upgrade their protocols and HIV epidemiology to anticipate and Provincial Departments of Health to reflect WHO’s new ARV guidelines, the quantity of API and final product to identify and implement solutions.61 © Mariska Van den Brink In South Africa, the Stop Stockouts Project – a consortium bringing together six civil society organisations – is pushing for more accountability on stockouts of medicines that impact people’s access to regular treatment. 16 Médecins Sans Frontières | July 2016
STOCKOUTS MARKET SHAPING INSTITUTIONS – WHAT NEEDS TO HAPPEN The Global Fund to Fight AIDS, the GFATM and other donors. to overcome any access barriers to Tuberculosis and Malaria (GFATM), The GFATM may not be able to affordable medicines. UNITAID and the Medicines Patent guarantee that these countries will Recent GFATM correspondence Pool have played a central role in be able to access the lowest prices indicates that it may seek to optimise the provision of affordable ARVs for new medicines, including those tiered pricing policies from drug around the world, including use of under patent, and it may even companies, instead of overcoming quality-assured generic drugs by the facilitate problematic tiered commercial pricing strategies. The GFATM, PEPFAR and other funders. pricing strategies used by drug e-marketplace has been recently companies in lieu of promoting The GFATM’s market-shaping criticised by the GFATM’s Office of robust generic competition. actions go beyond its ability to the Inspector General for failing provide treatment for millions of There are clear warning signs that to implement competitive bidding people, and have an important the GFATM is unwilling or unable to processes for the first products impact on worldwide ARV access. defend generic competition for the offered over the website.62 countries it supports. The GFATM After years of contributing towards did not signal support for the LDC At best, if the e-marketplace can collective efforts to reduce medicine extension, and has been silent overcome the challenges it is facing, prices, the scope and remit of the about the Trans-Pacific Partnership it could provide minimal technical GFATM is increasingly less ambitious trade agreement. It has not fixes as to how governments and potentially counter-productive. explicitly supported the use of TRIPS purchase medicines, without Progress has stalled, especially for flexibilities, although this principle dealing with the underlying barriers middle-income countries, where has been endorsed since the GFATM that make them unaffordable in the pharmaceutical companies seek started. Instead, the GFATM has been first place. At worst, prices offered to charge high prices. Some of championing an ‘e-marketplace’ under the e-marketplace will be these countries have a high disease (currently known as wambo.org) to insulated from the demands of burden, limited ability to pay for make procurement more efficient. government and civil society if such ARVs, and decreasing support from But the e-marketplace is not expected products remain unaffordable. UPDATE ON THE MEDICINES PATENT POOL’S NEW LICENCES The MPP voluntary licences The VL for tenofovir now includes Some MPP licences have been (VLs) offer some countries the tenofovir alafenamide (TAF) and disappointing. AbbVie’s new MPP opportunity to gain access to has an expanded geographic scope adult licence for LPV/r has a limited affordable generic versions of new that allows generic producers from geographic scope and may force ARVs, although many middle- South Africa and China to join. specific generics companies that sign income and upper-middle-income The VL for elvitegravir (EVT) was the licence agreement to forego the countries, such as China and Brazil, amended to include production in right to supply specific countries continue to be left out of these VLs China and South Africa, provided that they currently have the right and are therefore prevented from that products are made from to supply. Furthermore, a new MPP buying the generic drugs produced Gilead-licenced producers of active licence with Bristol-Myers Squibb for through manufacturers based in pharmaceutical ingredients (API). daclatasvir, a hepatitis C medicine, their countries. In March 2016, GlaxoSmithKline (with introduces a worrying precedent: On one hand, the MPP has added ViiV) announced that it would increase it allows BMS to sign sub-licence new VLs, and increased the the geographic scope of its voluntary agreements with generics companies geographic scope or added new licensing agreements to include all together with the MPP (the normal formulations to other licences. In lower-middle-income countries. The practice is to not allow branded 2014, the MPP announced a new MPP’s VL for DTG has been expanded companies to be involved in signing agreement with AbbVie, for two to include Ukraine, Morocco, a sub-licence agreement). MSF specific paediatric formulations Moldova, Armenia and 14 other is concerned that such a practice of LPV/r covering 102 low- and low- and middle-income countries. could allow branded companies to middle-income countries.63 influence the practices of generics Although this is a welcome first step, In late 2015, a separate agreement excluded upper-middle-income companies, including for unrelated was signed between MPP and AbbVie countries will still be forced into tiered products, and undermine the on the adult formulation of LPV/r pricing schemes, and price-lowering neutrality of the MPP in managing which only covers African countries.64 competition will be prevented. the sub-licence agreements. Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 17
CONCLUSION CONCLUSION The global response to HIV/AIDS has reached a turning point. Ensuring sustainable access to affordable generic ARVs will save millions of lives. Scaling up to 90-90-90 is projected to save over 1.1 million lives and prevent 873,000 new HIV infections in the next five years; keeping up the pace for 10 years will save more than 2.4 million lives (including the mothers of 1.7 million children), and prevent over 2 million new infections.65 To accomplish this, governments Market-shaping institutions must All governments and donors must must commit to scaling-up, keep their focus on securing and do their part to accelerate the global optimising, and maintaining access to ensuring a sustainable supply of HIV response and meet the challenge affordable generic ARVs in the long diagnostics and adult and paediatric of the 90-90-90 goals, including run, as HIV is a disease that requires ARVs in low- and middle-income fully implementing the latest WHO people to have constant access to a countries, and the pharmaceutical guidelines, putting in place effective range of treatment options. This will industry should commit to registering policies at the national level, and require governments to use TRIPS ARVs in all countries, and expanding ensuring all people living with HIV flexibilities, reform patent laws, and the scope of their voluntary licensing have access to the most effective reject harmful TRIPS-plus provisions agreements to include all low- and drugs, diagnostics, and models of care. proposed in various FTA negotiations. middle-income countries. © N’gadi Ikram 18 Médecins Sans Frontières | July 2016
ANNEX: SUMMARY ANNEX: SUMMARY TABLE OF ALL PRICES TABLE OF ALL PRICES Developing country prices in US$ per patient per year, as quoted by companies. This table contains comprehensive information about ARV pricing in developing countries. It includes adult and paediatric formulations and doses, suppliers and WHO pre-qualification status/ US FDA SRA approval. The prices for developing countries are in US $, per person, per year, based on WHO dosing recommendations, as quoted by companies. Currency conversions were made when the pricing information was received, using the currency converter from www.oanda.com. Each originator company applies its own eligibility criteria for discounting ARVs. Countries that are eligible for a discount from one company may not be eligible for discounts from other companies. Usually, companies create two groups of discount-eligible countries, often called ‘Category 1’ (countries that are eligible for the deepest discounts) and ‘Category 2’ (countries that are offered a lesser discount). Paediatric formulations are highlighted in pink. Prices for paediatric products are estimated, based on WHO-recommended dosing, for the 10 to 10.9 kg weight band. When it was not possible to calculate dosing for the 10 kg weight band, the unit price was used. The ARVs that are included in the WHO list of Prequalified Medicinal Products or that have tentative or full US FDA approval (as of May 2016) are in bold. ARVs in Daily Originator company Generic companies alphabetical order dose Abacavir (ABC) ViiV Aspen Aurobindo Cipla Hetero 20mg/ml oral 289 249 228 123 12 ml solution (0.066) (0.057) (0.052) (0.028) 97 60mg tablet 4 (0.067) BMS Atazanavir (ATV) Aspen Cipla Emcure Category 1 Category 2 countries countries 100mg capsule xx (0.267) 412 412 380 207 150mg capsule 2 (0.564) (0.564) (0.520) (0.283) 200mg capsule xx (0.677) (0.677) (0.670) (0.433) 170 219 300mg capsule 1 (0.467) (0.600) Atazanavir/ Cipla Emcure Hetero ritonavir (ATV/r) 213 213 219 300/100mg tablet 1 (0.583) (0.583) (0.600) Darunavir (DRV) Janssen Aspen Hetero 75mg tablet xx (0.114) 150mg tablet xx (0.227) 438 973 400mg tablet 2 (0.600) (1.333) 663 658 1,217 600mg tablet 2 (0.908) (0.901) (1.667) Merck Quality Sun Efavirenz (EFV) Aspen Aurobindo Cipla Emcure Hetero Macleods Microlabs Strides Category 1 Category 2 Chemicals Pharma countries countries Case-by- 30mg/ml suspension xx (0.094) case 50mg capsule xx (0.058) (0.057) Case-by- 50mg tablet xx (0.114) case 81 57 200mg capsule 3 (0.074) (0.052) 394 Case-by- 113 200mg tablet 3 (0.360) case (0.103) 237 Case-by- 84 37 20 47 45 38 35 70 38 38 600mg tablet 1 (0.650) case (0.231) (0.100) (0.055) (0.129) (0.123) (0.105) (0.095) (0.192) (0.105) (0.103) Untangling the Web of ARV Price Reductions | msfaccess.org/utw2016 19
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