National Policy For Rare Diseases 2021 was drawn as rare diseases lack published data on long-term treatment outcomes and are often incompletely characterised. This makes it necessary to explore international and regional collaborations for research, collaborations with the physicians who work on any rare disease and with patient groups and families dealing with the consequences of these disorders.
Explained: National Policy For Rare Diseases 2021
New Delhi (ABC Live India): National Policy For Rare Diseases 2021: Background Ministry of Health and family Welfare, Government of India formulated a National Policy for Treatment of Rare Diseases (NPTRD) in July, 2017.
Implementation of the policy, however, faced
certain challenges. A limiting factor in its implementation was bringing States
on board and lack of clarity on how much Government could support in terms of
tertiary care.
Public Health and Hospitals is
primarily a State subject. Stakeholder consultation with the State Governments
at the draft stage of formulation of the policy could not be done in an
elaborate manner. When the policy was shared with State Governments, issues such
as cost effectiveness of interventions for rare disease visà-vis other health
priorities, the sharing of expenditure between Central and State Governments,
flexibility to State Governments to accept the policy or change it according to
their situation, were raised by some of the State Governments.
In the circumstances, though framed
with best intent, the policy had implementation challenges and gaps, including
the issue of cost effectiveness of supporting such health interventions for
limited resource situation, which made it not feasible to implement. Given the
challenges in implementing the policy, the need for wider consultation and
recommendations, a decision was taken to reframe the National Policy for
Treatment of Rare Diseases.
An Expert Committee was constituted by
Ministry of Health and Family Welfare in November, 2018 to review the NPTRD,
2017.
The Terms and References of the Expert
Committee are given below:
a. To review the national Policy for Treatment
of rare Diseases, 2017 and to suggest amendments/changes as may be required.
b. To define Rare diseases for India.
c. To draft National Policy for Rare
Diseases.
d. To suggest vision and strategy in
country’s context.
Pending reframing the policy, the
earlier policy has been kept in abeyance vide a non statutory Gazette
Notification dated 18-12-2018, till the revised policy is issued or till
further orders, whichever is earlier. Based on the report of the Expert
Committee and with the approval of the competent authority, the draft National
Policy for Rare Diseases, was finalized and placed in the public domain on
13.1.2020 inviting comments/views from all the stakeholders, general public,
organisations and States/UTs. Comments/suggestions received from general
public/organisations/stake holders/States/UTs were referred to DGHS for
examination and to submit recommendations. DGHS constituted an Expert Committee
to examine the comments/suggestions received. Based on the examination of the
comments/suggestions received and recommendations of the same Expert Committee
and after further deliberation, the National Policy for Rare Diseases has been
finalised.
Rare Diseases: Issues & Challenges
The field of rare diseases is complex
and heterogeneous. The landscape of rare diseases is constantly changing, as
there are new rare diseases and conditions being identified and reported
regularly in medical literature. Apart from a few rare diseases, where
significant progress has been made, the field is still at a nascent stage.
For a long time, doctors, researchers
and policy makers were unaware of rare diseases and until very recently there
was no real research or public health policy concerning issues related to the
field. This poses formidable challenges in development of a comprehensive
policy on rare diseases. Nevertheless, it is important to take steps, in the
short as well as long term, with the objective of tackling rare diseases in a
holistic and comprehensive manner.
The varying definitions of rare
diseases WHO defines rare disease as often debilitating lifelong disease or
disorder with a prevalence of 1 or less, per 1000 population. However,
different countries have their own definitions to suit their specific
requirements and in context of their own population, health care system and
resources. In the US, rare diseases are defined as a disease or condition that
affects fewer than 200,000 patients in the country (6.4 in 10,000 people). EU
defines rare diseases as a life-threatening or chronically debilitating
condition affecting no more than 5 in 10,000 people. Japan identifies rare
diseases as diseases with fewer than 50,000 prevalent cases (0.04%) in the
country. A summary of the prevalence based definitions of rare diseases used in
various countries is tabulated below:
The I.C. Verma Sub-Committee Report
‘Guidelines for Therapy and Management’ The use of varying definitions and
diverse terminology can result in confusion and inconsistencies and has
implications for access to treatment and for research and 6 development.
According to a study1, that reviewed
and analysed definitions across jurisdictions, most definitions, as discussed
above, appear to consider disease prevalence, but other criteria also apply
sometimes, such as - disease severity, whether the disease is life-threatening,
whether there are alternative treatment options available, and whether it is
heritable. The study found that relatively few definitions included qualifiers
relating to disease severity and/or a lack of existing treatments, whereas most
definitions included a prevalence threshold. The average prevalence thresholds
used to define rare diseases ranges among different jurisdictions from 1 to 6
cases/10,000 people, with WHO recommending a prevalence less than 10/10,000
population for defining rare diseases.
The study concluded that attempts at
harmonising the differing definitions, should focus on standardizing objective
criteria such as prevalence thresholds and avoid qualitative descriptors like
severity of the disease.
However, it has been contested that
disease prevalence alone may also not be an accurate basis for defining rare
diseases, as it does not take into account changes in population over time.
Hence, some have suggested that a more reliable approach to arriving at a
definition could be based on the factors of – a) location - a disease which is uncommon
in one country may be quite common in other parts of the world; b) levels of
rarity - some diseases may be much more rare than other diseases which are also
uncommon; and c) study-ability - whether the prevalence of a disease lends
itself to clinical trials and studies.
This underscores the need for further
research to better understand the extent of the existing diversity of
definitions for rare diseases and to examine the scope of arriving at a
definition, which is best suited to the conditions in India. It shall be done
on a priority basis as soon as sufficient data is available. Steps have already
been taken for creation of a hospital based National Registry for rare diseases
in India by ICMR.
Diagnosis of rare diseases
Early diagnosis of rare diseases is a challenge owing to multiple factors that include lack of awareness among primary care physicians, lack of adequate screening and diagnostic facilities. Traditional genetic testing includes tests that can only address a few diseases.As a result, physicians most often provide their best guess on which tests are to be done. If the test is negative, further testing will be required using next generation sequencing based tests, or chromosomal microarray which is applicable, but expensive and time consuming processes with interpretation and counselling issues at times.
There is a lack of awareness about
rare diseases in general public as well as in the medical fraternity. Many
doctors lack appropriate training and awareness to be able to correctly and
timely diagnose and treat these conditions.
According to a recent report , it
takes patients in United States (US) an average of 7.6 years and patients in
United Kingdom (UK) an average of 5.6 years to receive an accurate diagnosis,
typically involving as many as eight physicians (four primary care and four
specialists).
In addition, two to three misdiagnoses
are typical before arriving at a final diagnosis. Delay in diagnosis or a wrong
diagnosis increases the suffering of the patients exponentially. There is an
immediate need to create awareness amongst general public, patients & their
families and doctors, training of doctors for early and accurate diagnosis,
standardization of diagnostic modalities and development of newer diagnostic
and therapeutic tools.
Challenges in research and development
A fundamental challenge in research and development for the majority of rare
diseases is that there is relatively little known about the pathophysiology or
the natural history of these diseases.
Rare diseases are difficult to
research upon as the patient pool Rare Disease Impact Report: Insights from
patients and the medical community available at: https://globalgenes.org/wp-content/uploads/2013/04/ShireReport-1.pdf
is very small and it often results in
inadequate clinical experience.
Therefore, the clinical explanation of
rare diseases may be skewed or partial. The challenge becomes even greater as
rare diseases are chronic in nature, where long term follow-up is particularly
important.
As a result, rare diseases lack
published data on long-term treatment outcomes and are often incompletely
characterised. This makes it necessary to explore international and regional
collaborations for research, collaborations with the physicians who work on any
rare disease and with patient groups and families dealing with the consequences
of these disorders.
This will help gain a better
understanding of the pathophysiology of these diseases, and the therapeutic
effects that would have a meaningful impact on the lives of patients. There is
also a need to review and where possible modify, clinical trial norms keeping
in mind the particular challenges in rare diseases, without compromising on the
safety and quality of the drugs or diagnostic tools.
Challenges in treatment
Unavailability of treatment
Availability and access to medicines are important to reduce morbidity and
mortality associated with rare diseases. Despite progress in recent years,
effective or safe treatment is not available for most of the rare diseases.
Hence, even when a correct diagnosis is made, there may not be an available
therapy to treat the rare disease. There are between 7000 - 8000 rare diseases,
but less than 5% have therapies available to treat them. About 95% rare
diseases have no approved treatment3 and less than 1 in 10 patients receive
disease specific treatment. Where drugs are available, they are prohibitively
expensive, placing immense strain on resources. https://www.thelancet.com/journals/landia/article/PIIS2213-8587(19)30006-3/fulltext
Prohibitive cost of treatment
As the number of persons suffering
from individual rare diseases is small, they do not constitute a significant
market for drug manufacturers to develop and bring to market drugs for them.
For this reason, rare diseases are also called ‘orphan diseases’ and drugs to
treat them are called “orphan drugs”.
Where, they do make drugs to treat
rare diseases, the prices are extremely high apparently to recoup the cost of
research and development. At present very few pharmaceutical companies are
manufacturing drugs for rare diseases globally and there are no domestic
manufacturers in India except for Food for Special Medical Purposes(FSMP) for
small molecule inborn errors of metabolism.
Due to the high cost of most
therapies, the government has not been able to provide these for free. It is
estimated that for a child weighing 10 kg, the annual cost of treatment for some
rare diseases, may vary from Rupees 10 Lakhs to more than 1 crore per year with
treatment being lifelong and drug dose and cost increasing with age and weight.
Countries have dealt with this unique problem of high cost through various
means that were suited to their local needs. Instruments like the Orphan Drug
Act (ODA) in US & Canada, provide incentives to drug manufacturers to
encourage them to manufacture drugs for rare diseases. The economic incentives
& safeguards offered under the Act ensure benefits to the local patients.
However, the exorbitant prices of drugs for rare diseases have led to concerns
even in the developed countries about maintaining sustainability of the rare
diseases funding/reimbursement programmes.
The exorbitant prices have led to
calls for transparency in setting prices of drugs and for price control and
have even prompted scrutiny and congressional inquiries.
The Indian Scenario Data on how many
people suffer from different diseases that are considered rare globally, is
lacking in India. The cases identified so far have been diagnosed at tertiary
hospitals. The lack of epidemiological data on incidence and prevalence of rare
diseases impedes understanding of the extent of the burden of rare diseases and
development of a 10 definition. It also hampers efforts to arrive at correct
estimation of the number of persons suffering from these diseases and describe
their associated morbidity and mortality. In such a scenario, the economic
burden of most rare diseases is unknown and cannot be adequately estimated from
the existing data sets. Although extremely challenging, considering the
complexity of various diseases and the difficulty in diagnosis, there is a
clear need to undertake systematic epidemiological studies to ascertain the number
of people suffering from rare diseases in India.
So far only limited number of diseases has been recorded in India from tertiary care hospitals that are globally considered as rare diseases though ambit may encompass from 7000 to 8000 disorders. The commonly reported diseases include Primary immunodeficiency disorders, Lysosomal storage disorders (Gaucher’s disease, Mucopolysaccharidoses, Pompe disease, fabry disease etc.) small molecule inborn errors of metabolism (Maple Syrup urine disease, organic acidemias, etc.), Cystic Fibrosis, osteogenesis imperfecta, certain forms of muscular dystrophies and spinal muscular atrophy, etc.
Experiences from other countries:
While preparing the policy for rare diseases in India, policies of other countries have been reviewed.
In United States of America, development of drugs for rare
disease is sought to be encouraged through the Orphan Drugs Act, which
incentivises industry by way of market exclusivity, grants to researchers and
tax incentives on expenditure incurred during evaluation of drugs for their
therapeutic potential. However, critics have pointed out that pharmaceutical
companies have taken advantage of this arrangement and ‘gamed the system’ to
maximise profits. The European Joint Programme on Rare Disease mostly focuses
on research.
National Health Service (NHS) England,
for example, provides that the treatment for Spinal Muscular Atrophy (SMA) will
be made available to the youngest and most severely-affected (SMA Type 1)
patients immediately by Biogen (The pharmaceutical company that manufactures
treatment for SMA), with NHS England offering funding on 11 National Institute
for Health and Care Excellence (NICE) publication of final guidance. In
Singapore, a fund - Rare Disease Fund – has been created to fund five medicines
to treat three rare disease conditions. In Malaysia and Australia subsidised
access for eligible patients is provided for expensive and lifesaving drugs.
Need to balance competing priorities
of public health in resource constrained settings Rare diseases place a major
economic burden on any Country and especially in resource-constrained settings.
The financial capacity to support exorbitant cost of treatment, is an important
consideration in public health policy development with reference to treatment
for rare diseases. In resource-constrained settings, it is pertinent to balance
competing interests of public health for achieving optimal outcome for the
resources allocated. As resources are limited and have multiple uses, the policy
makers have to make choice of prioritizing certain set of interventions over
others- the appropriate choice is then to support those interventions that
would provide more number of healthy life years for given sum of money while
simultaneously looking at the equity i.e., interventions that benefit poor who
cannot afford healthcare are prioritized.
Thus, interventions that address
health problems of a much larger number of persons by allocating a relatively
smaller amount are prioritized over others such as funding treatment of rare
diseases where much greater resources will be required for addressing health
problems of a far smaller number of persons. Hence, any policy on rare diseases
needs to be considered in the context of the available scarce resources and the
need for their utmost judicious utilization for maximizing the overall health
outcomes for the whole of society measured in terms of increase of healthy life
years.
Definition of Rare Diseases: There is no universal or standard definition
of rare disease. A disease that occurs infrequently is generally considered a
rare disease, and it has been defined by different countries in terms of
prevalence – either in absolute terms or in terms of prevalence per 10,000
population.
A country defines a rare disease most
appropriate in the context of its own population, health care system and
resources.
As mentioned above, India faces the
limitation of lack of epidemiological data to be able to define rare diseases
in terms of prevalence or prevalence rate, which has been used by other
countries.
To overcome this, a hospital based
National Registry for Rare Diseases has been initiated by ICMR by involving
centers across the Country that are involved in diagnosis and management of
Rare Diseases. This will yield much needed epidemiological data for rare
diseases. In the absence of epidemiological data on diseases considered as rare
in other countries, it is not possible to prescribe threshold prevalence rates
to define a disease condition as rare.
Till the time such data is available
and the Country arrives at a definition of a rare disease based on prevalence
data, the term rare diseases, for the purpose of this policy, shall construe
the following groups of disorders identified and categorized by experts based
on their clinical experience:
Group 1: Disorders amenable to
one-time curative treatment: a) Disorders amenable to treatment with
Hematopoietic Stem Cell Transplantation (HSCT) –
i. Such Lysosomal Storage Disorders
(LSDs) for which Enzyme Replacement Therapy (ERT) is presently not available
and severe form of Mucopolysaccharoidosis (MPS) type I within first 2 years of
age.
ii. Adrenoleukodystrophy (early stages),
before the onset of hard neurological signs.
iii. Immune deficiency disorders like
Severe Combined Immunodeficiency (SCID), Chronic Granulomatous disease, Wiskot
Aldrich Syndrome, etc. iv. Osteopetrosis v. Fanconi Anemia b) Disorders
amenable to organ transplantation i. Liver Transplantation -Metabolic Liver
diseases: a. Tyrosinemia, b. Glycogen storage disorders (GSD) I, III and IV due
to poor metabolic control, multiple liver adenomas, or high risk for
Hepatocellualr carcinoma or evidence of substantial cirrhosis or liver
dysfunction or progressive liver failure, c. MSUD (Maple Syrup Urine Disease),
d. Urea cycle disorders, e. Organic acidemias. ii. Renal Transplantationa.
Fabry disease b. Autosomal recessive Polycystic Kidney Disease (ARPKD), c.
Autosomal dominant Polycystic Kidney Disease (ADPKD) etc. iii. Patients
requiring combined liver and kidney transplants can also be considered if the
same ceiling of funds is maintained. (Rarely Methyl Malonic aciduria may
require combined liver & Kidney transplant) etc.
Group 2: Diseases requiring long term
/ lifelong treatment having relatively lower cost of treatment and benefit has
been documented in literature and annual or more frequent surveillance is
required: 14 a) Disorders managed with special dietary formulae or Food for
special medical purposes (FSMP) i) Phenylketonuria (PKU) ii) Non-PKU
hyperphenylalaninemia conditions iii) Maple Syrup Urine Disease (MSUD) iv)
Tyrosinemia type 1 and 2 v) Homocystinuria vi) Urea Cycle Enzyme defects vii)
Glutaric Aciduria type 1 and 2 viii) Methyl Malonic Acidemia ix) Propionic
Acidemia x) Isovaleric Acidemia xi) Leucine sensitive hypoglycemia xii)
Galactosemia xiii) Glucose galactose malabsorbtion xiv)Severe Food protein
allergy b) Disorders that are amenable to other forms of therapy (hormone/
specific drugs) i) NTBC for Tyrosinemia Type 1 ii) Osteogenesis Imperfecta –
Bisphosphonates therapy iii) Growth Hormone therapy for proven GH deficiency,
Prader Willi Syndrome and Turner syndrome, Noonan syndrome. iv) Cystic
Fibrosis- Pancreatic enzyme supplement v) Primary Immune deficiency disorders
-Intravenous immunoglobulin and sub cutaneous therapy (IVIG) replacement eg.
X-linked agammablobulinemia etc. 15 vi) Sodium Benzoate, arginine, citrulline
,phenylacetate (Urea Cycle disorders), carbaglu, Megavitamin therapy (Organic
acidemias, mitochondrial disorders) vii) Others - Hemin (Panhematin) for Acute
Intermittent Porphyria, High dose Hydroxocobalamin injections (30mg/ml
formulation – not available in India and hence expensive if imported) viii)
Large neutral aminoacids, mitochondrial cocktail therapy, Sapropterin and other
such molecules of proven clinical management in a subset of disorders
Group 3: Diseases for which definitive
treatment is available but challenges are to make optimal patient selection for
benefit, very high cost and lifelong therapy. 3a) Based on the literature
sufficient evidence for good long-term outcomes exists for the following
disorders 1. Gaucher Disease (Type I & III {without significant
neurological impairment}) 2. Hurler Syndrome [Mucopolysaccharisosis (MPS) Type
I] (attenuated forms) 3. Hunter syndrome (MPS II) (attenuated form) 4. Pompe
Disease (Both infantile & late onset diagnosed early before development of
complications) 5. Fabry Disease diagnosed before significant end organ damage.
6. MPS IVA before development of disease complications. 7. MPS VI before
development of disease complications. 8. DNAase for Cystic Fibrosis. 3b) For
the following disorders for which the cost of treatment is very high and either
long term follow up literature is awaited or has been done on small number of
patients 1. Cystic Fibrosis (Potentiators) 16 2. Duchenne Muscular Dystrophy
(Antesensce oligoneucletides, PTC) 3. Spinal Muscular Atrophy (Antisense
oligonucleotides both intravenous & oral & gene therapy) 4. Wolman
Disease 5. Hypophosphatasia 6. Neuronal ceroid lipofuschinosis
The list of diseases under Group 1,
Group 2 and Group 3 are not exhaustive and will be reviewed periodically based
on updated scientific data by the Technical Committee.
Policy Direction
The policy aims at lowering the
incidence and prevalence of rare diseases based on an integrated and
comprehensive preventive strategy encompassing awareness generation,
premarital, post-marital, pre-conception and post-conception screening and
counselling programmes to prevent births of children with rare diseases, and,
within the constraints on resources and competing health care priorities,
enable access to affordable health care to patients of rare diseases which are
amenable to one-time treatment or relatively low cost therapy.
Considering the limited data available
on rare diseases, and in the light of competing health priorities, the focus
would be on prevention of rare diseases as a priority for all the three groups
of rare diseases identified by Experts. Public Health and hospitals being a
State subject, the Central Government would encourage & support the States
in their endeavour towards screening and prevention of rare diseases through
Centres of Excellence under Rare Disease Policy and Nidan Kendras under
Department of Biotechnology.
Prevention & Control of Rare
Diseases:
Capacity building of health
professionals The Central Government will work with the State governments to
build capacity of health professionals at various levels. The content of such
capacity building would be based on the roles of various health professionals.
The Centres of Excellence would develop Standard Operating Protocols to be used
at various levels of care for patients with rare diseases to improve early
diagnosis, better care coordination and quality of life.
Prevention at different levels
Though in the last two decades, due to
advancement in technologies, understanding of the pathophysiological mechanisms
of rare genetic disorders has somewhat improved, yet the treatment modalities
are few and the available therapies may not lead to “cure’. More importantly
these are exorbitantly costly and not universally available &accessible.
Accordingly, prevention needs to be the focus for all genetic disorders. The
prevention of genetic disorders can be done at multiple levels. For application
of these strategies, the first step is to build the capacity of health
professionals and increase awareness in the population at large about the
prevalence of such diseases and prevention measures. Frontline workers will be
adequately capacitated for screening of rare diseases. Adequate IEC material
will be designed and made available across multiple levels of the health care
pyramid as this forms a basic pillar of tackling the issue of limited awareness.
Primary Prevention: This aims at preventing the
occurrence of the disease, i.e., preventing birth of an affected child. Though
not always feasible, this strategy yields the highest returns in terms of
decreasing the incidence & prevalence of rare disorders in the population
in the long run. Some of the strategies can be as follows: Examples include
avoidance of pregnancy in advanced age, or any other rare monogenic disorder by
not marrying a carrier, carrier couples not reproducing etc., but these are not
feasible options in the real world scenario. So in most situations the feasible
preventive 18 strategy is secondary prevention. However, a simple checklist
will be made available to primary health care providers in the health and
wellness clinics to identify a couple at risk based on disease in a previous
sib or family history of that disorder.
Secondary prevention: This strategy focuses on avoiding
the birth of affected fetus (prenatal screening and prenatal diagnosis), early
detection of the disorders, appropriate medical intervention to ameliorate or
minimize the manifestations (newborn screening). a) Prenatal screening:
The common screening methods presently
recommended for all pregnancies include biochemical screening and
ultrasonography for chromosomal disorders like Down syndrome etc. and
ultrasonography for other structural defects. In the context of rare diseases
objective of the prenatal screening and diagnosis is to identify the high risk
mothers for having an affected fetus with a rare disease.
These mothers can be identified based
on the family history (previous affected child or affected relative with a
known or suspected genetic disorder). Based on the suspected disease a targeted
screening of the affected child or couple for a specific disorder or a carrier
testing for monogenic disorders using next generation sequencing technique can
be offered, the later being presently expensive. b) Prenatal diagnosis by
invasive testing (e.g., by Chorionic villus sampling and amniocentesis): is
possible for any single-gene disorder if the disease causing variant in the
gene / enzyme defect is known and for any chromosomal abnormality.
Most common indications are known
single gene disorders or chromosomal abnormality in a previous affected child in
the family. These tests can also be offered if the married couple is found to
be carrier for any single gene disorder and mutations have been identified in
the couple. Now a day, prenatal diagnosis for above mentioned disorders are
widely available in India at many institutions. T
he invasive procedures are performed
by obstetricians and fetal 19 medicine experts. These procedures however carry
a small risk of fetal loss which is very low if done by experienced
specialists. This has to be explained to the family before the procedure.
Cost would primarily depend on the
type of the test to be performed on the sample. If the fetus is found to be
affected, the couple has the option for termination of pregnancy, the legal age
of which in India has been increased to 24 weeks of pregnancy. c) Newborn
screening (NBS): is the best example of secondary prevention in which the
babies are screened with in few days of birth before symptoms of the disease
manifest and treatment is initiated which prevents morbidity and mortality. In
the developed world NBS is being offered for many rare disorders particularly
the treatable ones (e.g., LSDs, SCID) apart from the common disorders. d) Early
postnatal diagnosis and treatment: before development of severe manifestations
/complications which are irreversible is also included in secondary prevention
for disorders amenable to therapy which would require increasing awareness and
better availability of diagnostics.
Timely referral of the suspected
patients & their families to appropriate facilities that are equipped to
make a correct diagnosis and where indicated, initiate treatment is the key.
Genetic testing will also be augmented by laboratories under the National
Genomics Core funded by the Department of Biotechnology and Institute of
Genomics and Integrative Biology (IGIB) & Centre for Cellular and Molecular
Biology (CCMB) under CSIR.
Tertiary prevention refers to
provision of better care and medical rehabilitation to those rare disease
patients who present at an advanced stage of the disease. It encompasses
providing best supportive care to the affected patients with various rare
disorders including the ones for which no specific treatment is available. This
would improve quality of life of affected individuals and families. Supportive
care includes developmental assessment and intervention including early
stimulation and behavioural 20 intervention, physical therapy and
rehabilitation, provision of visual and hearing aids and above all emotional
and psychological support to affected individuals and families.
Optimal screening and diagnosis
strategy:
Considering the competing priorities
within available resources, universal screening of all pregnancies and/or all
newborns in the country for all rare disorders is not feasible. The policy
recommends a screening and diagnostic strategy wherein those pregnant women in
whom there is a history of a child born with a rare disease and that rare
disease diagnosis has been confirmed, would be offered prenatal screening
test(s) through amniocentesis and / or chorionic villi sampling. This strategy
is in sync with the policy direction of reducing the incidence of rare diseases
in the population. In cases where, the diagnosis could not be established
during the prenatal period, it would be imperative to offer to the newborn or
the infant as the case may be and would include newborn screening for (a) small
molecule Inborn Errors of Metabolism by liquid chromatography – tandem mass
spectrometry (LC-MS/MS), (b) diagnosis of SCID by T cell receptor excision
circles (TREC) and (c) diagnosis of lysosomal storage disorders (LSDs) by
microfluids / LC-MS/ MS. (d) diagnosis of disorders by newer but economical
molecular diagnostic platforms. 9. Centres of Excellence (COE) and Nidan
Kendras
The Government will notify selected
Centres of Excellence, which will be premier Government tertiary hospitals with
facilities for diagnosis, prevention and treatment of rare diseases.
To begin with the following institutes
would be notified as Centers of Excellence for Rare Diseases: a) All India
Institute of Medical Sciences, New Delhi b) Maulana Azad Medical College, New
Delhi c) Sanjay Gandhi Post Graduate Institute of Medical Sciences, Lucknow d)
Post Graduate Institute of Medical Education and Research, Chandigarh e) Centre
for DNA Fingerprinting & Diagnostics, Hyderabad f) King Edward Medical
Hospital, Mumbai 21 g) Institute of Post-Graduate Medical Education and
Research, Kolkata h) Center for Human Genetics (CHG) with Indira Gandhi
Hospital, Bengaluru However, more Centres of Excellence can be added for
regional outreach if they are found to be suitable in terms of infrastructure
and human resources based on recommendations of technical committee.
The responsibilities and activities of
the COEs would be as follows:
• Education & Training at all
levels • Screening – Antenatal, neonatal (specified disorders), High risk
screening (both antenatal & in newborns and children)
• Diagnostics- Cytogenetic, molecular,
Metabolic
• Prevention by prenatal screening
& diagnosis • Research in the area of low cost diagnostics &
therapeutics.
• Treatment of rare diseases.
The proposed COEs shall be given
one-time financial support upto a ceiling of Rs 5 crore for procurement of
equipment as per individual centers need for strengthening patient care
services for screening, diagnosis and prevention (prenatal diagnosis) of rare
diseases based on a gap analysis. The list of equipments which are likely to be
useful for these activities is annexed.
These Centre of Excellence will take
the required decision for treatment and fund allocation on rare diseases cases
within 02 weeks of receiving the fresh application.
Nidan Kendras: Nidan Kendras have been
set up by Department of Biotechnology (DBT) under Unique Methods of Management
and treatment of Inherited Disorders (UMMID) project for genetic testing and
counseling services. These Nidan Kendras will be performing screening, genetic
testing and counseling for rare diseases. Nidan Kendras possessing the facility
for treatment may do so under the guidance and supervision of a CoE.
22 List of Nidan Kendras is given
below:
• Lady Hardinge Medical College
(LHMC), Delhi
• Nizam’s Institute of Medical
Sciences (NIMS), Hyderabad, Telangana
• All India Institute of Medical
Sciences (AIIMS), Jodhpur • Army Hospital Research & Referral, Delhi
• Nil Ratan Sircar (NRS) Medical
College and Hospital, Kolkata Currently Nidan Kendras / Mentor Institutes are
supporting aspirational districts for screening of rare diseases.
List of aspiration districts covered under the
programme is given below: Name of the Mentor Institute
Aspirational District State LHMC, New
Delhi Mewat Haryana CDFD, Hyderabad Yadgir Karanataka AIIMS, New Delhi Haridwar
Uttarakhand CMC, Vellore Washim Maharashtra MAMC, New Delhi Ranchi / Bokaro
Jharkhand SGPGIMS, Lucknow Shrawasti Uttar Pradesh NIIH (KEM hospital campus),
Mumbai Nandurbar Maharashtra More aspirational districts will be covered in
future either by setting up of more Nidan Kendras or by adopting more than one
aspirational districts by existing Nidan Kendras.
Government of India support in
treatment
The following initiatives shall be
taken for patients of Rare Diseases:
i. Financial support upto Rs. 20 lakh under
the Umbrella Scheme of Rashtriya Arogaya Nidhi shall be provided by the Central
Government for treatment, of those rare diseases that require a one-time
treatment (diseases listed under Group 1).
Beneficiaries for such financial
assistance would not be limited to BPL families, but extended to about 40% of
the population, who are eligible as per 23 norms of Pradhan Mantri Jan Arogya
Yojana, for their treatment in Government tertiary hospitals only.
ii. State Governments can consider
supporting patients of such rare diseases that can be managed with special
diets or hormonal supplements or other relatively low cost interventions
(Diseases listed under Group 2).
iii. Keeping in view the resource
constraints, and a compelling need to prioritize the available resources to get
maximum health gains for the community/population, the Government will
endeavour to create alternate funding mechanism through setting up a digital
platform for voluntary individual and corporate donors to contribute to the
treatment cost of patients of rare diseases.
iv. Voluntary crowd-funding for
treatment Keeping in view the resource constraint and competing health
priorities, it will be difficult for the Government to fully finance treatment
of high cost rare diseases. The gap can however be filled by creating a digital
platform for bringing together notified hospitals where such patients are
receiving treatment or come for treatment, on the one hand, and prospective
individual or corporate donors willing to support treatment of such patients.
The notified hospitals will share
information relating to the patients, diseases from which they are suffering,
estimated cost of treatment and details of bank accounts for donation/
contribution through online system. Donors will be able to view the details of
patients and donate funds to a particular hospital. This will enable donors
from various sections of the society to donate funds, which will be utilized
for treatment of patients suffering from rare diseases, especially those under
Group 3.
Conferences will be organised with corporate
sector companies to motivate them to donate generously through digital
platform. Ministry of Corporate Affairs will be requested to encourage PSUs and
corporate houses to contribute as per the Companies Act as well as the
provisions of the Companies (Corporate Social Responsibility Policy) Rules,
2014 (CSR Rules). Promoting health 24 care including preventive health care is
included in the list in the Schedule for CSR activities.
Treatment cost of the patient will be
first charge on this fund. Any leftover fund after meeting treatment cost can
be utilized for research purpose also.
Development of manpower Following
initiatives will be taken for strengthening of manpower: • State Governments
will be requested to create Department of Medical Genetics at least in one
medical colleges in the State for imparting education and increasing awareness
amongst health care professionals.
• Services of Nidan Kendras set up
under Department of Biotechnology will also be utilised for training of medical
practitioners and staff for screening for rare diseases.
Constitution of Consortium
(a) Consortium of Centres of
Excellence so created will synchronize prevention and treatment efforts. AIIMS,
Delhi will be the nodal hospital to coordinate with other Centres of Excellence
for various activities relating to prevention and treatment of rare disease.
(b) National Consortium for Research
and Development on therapeutics for Rare Diseases: National Consortium can be
provided with an expanded mandate to include research & development,
technology transfer and indigenization of therapeutics for rare diseases. It
will be convened by Department of Health Research (DHR) with ICMR as a member.
Increasing affordability of drug
related to rare diseases
(a) Research & Development
activities on rare diseases Indian Council of Medical Research (ICMR),
Department of Biotechnology, Department of Pharmaceuticals, Department of
science and Technology and Council for Scientific Education & Research will
be requested to promote research and development in the field of rare diseases
for diagnosis and treatment of rare diseases. Creation of an integrated
research pipeline to start the development of new drugs, for which
pharmaceutical companies would be encouraged and research organizations as well
as funding agencies would be involved in this important endeavour. Research for
repurposing the drugs and use of biosimilar would be encouraged. Approval for
new drugs and decision related to trials will continue to be provided by Drugs
Controller General of India under the New Drugs and Clinical Trial Rules, 2019.
(b) Ministry of Finance will be
requested for reduction in custom duties on import of medicines related to rare
diseases.
(c) Ministry of Chemicals and
Fertilizers, Department of Pharmaceutical (DoP), National Pharmaceutical
Pricing Authority (NPPA) shall take measures to document and make publicly
available the prices of drugs for rare diseases and work towards affordability
of drugs for rare diseases, in consultation with the Ministry of Health and
Family Welfare.
(d) Measures for creating conducive
environment for indigenous manufacturing of drugs for rare diseases would be
taken. Department of Pharmaceuticals, , Department for Promotion of Industry
and Internal Trade (DPIIT) will be requested to promote local development and
manufacture of drugs for rare diseases at affordable prices and take
legal/legislative measures for creating conducive environment for indigenous
manufacturing of drugs for rare diseases at affordable prices. PSUs would be
encouraged for local manufacturing of drugs for rare diseases.
Implementation strategy
Keeping in view lack of availability
of epidemiological data on rare diseases, constraints on resources and
competing health priorities, the focus of the Government will be on the
following:
i. The Government will have a hospital
based National Registry for Rare Diseases at ICMR with the objective of
creating a database of various rare diseases. Steps have already been taken in
this direction by ICMR. Over a period of time, the registry is expected to
yield information on hospital based data and disease burden.
ii. The Government shall take steps to create
awareness amongst all the levels of health care personnel as well as general
public towards the rare diseases.
This will encourage people to seek
pre-marital genetic counselling, identification of highrisk couples &
families and also result in prevention of births as well as early detection of
cases of rare diseases. Simple standard protocols/algorithms would be developed
for screening and diagnosis in order to avoid missing cases and provide best
possible management
iii. Public Health and hospitals being
a State subject, the Central Government shall encourage and support the State
Governments in implementation of a targeted preventive strategy.
iv. The Government shall provide
financial assistance upto Rs. 20.00 lakh (under the Umbrella Scheme of
Rashtriya Arogya Nidhi) to the entitled population, as per PMJAY norms, for
their treatment in Government tertiary hospital, for rare diseases amenable to
one-time treatment (identified under Group 1).
v. The State Governments may undertake
treatment of disorders managed with special dietary formulae or food for
special medical purposes (FSMP) and Disorders that are amenable to other forms
of therapy (hormone/ specific drugs)- diseases covered under Group 2.
vi. The Government shall notify
selected Centres of Excellence at premier government hospitals for
comprehensive management of rare diseases. The Centres of Excellence will be
provided one time grant subject to maximum of Rs. 5 crore 27 each for
infrastructure development for screening, tests, treatment, if such
infrastructure is not available.
vii. The Government shall create a
digital platform for bringing together notified Centres of Excellence where
patients of rare diseases can receive treatment or come for treatment, on the
one hand and prospective voluntary individual or corporate donors willing to
support treatment of such patients. Funds received through this mechanism will
be utilized for treatment of patients suffering from rare diseases.
viii. In order to maintain
transparency of transactions in provision of funding under RAN/ crowd funding
etc., the Centres of Excellence receiving the funds should have linkages with
the ICMR registry.
ix. The Government shall facilitate the
creation of an enabling environment that promotes research & development of
diagnostic and therapeutic modalities within the Country. Consortium of Centres
of Excellence shall be created so that research efforts are synchronized.
AIIMS, Delhi will be nodal hospital to coordinate with other Centres of
Excellence for various activities.
x. State Governments will be requested
to create Department of Medical Genetics at least in one medical college in the
State for imparting education and increasing awareness amongst health care
professionals. This will strengthen manpower base in the country for managing
Rare Diseases.
xi. Department of Pharmaceuticals, Department
for Promotion of Industry and Internal Trade (DPIIT) will be requested to
promote local development and manufacture of drugs for rare diseases by public
and private sector pharmaceutical companies at affordable prices and take
legal/legislative measures for creating conducive environment for indigenous
manufacturing of drugs for rare diseases at affordable prices. PSUs could also
be encouraged for local manufacturing of drugs for rare diseases.
xii. Ministry of Finance will be
requested for reduction in custom duties on import of medicines related to rare
diseases.
28 Annexure Suggestive List of
Equipment, which may be required for strengthening of patient services at
Centres of Excellence for screening, diagnosis and preventive (prenatal
diagnosis) of rare disease. • Cytogenetic workstation with software with
Fluorescent in situ hybridization • Multimode readers for both ELISA and
fluorescent enzyme assays • DNA Sequencer with 8 capillary sequencer • Mi Seq
next generation sequencer • Next Seq next generation sequencer • Liquid
chromatography Mass Spectroscopy (Tandem Mass Spectrometry) • HPLC (quarternery
pump high Performance Liquid Chromatography) • GCMS (gas chromatography Mass
Spectrometry) • Microfluidics platform • Real Time PCR (96 well format) for
real time polymerase chain reaction • High throughput rNA and DNA extraction
systems • Quality Check stations and microtips station • Chromosomal Micro
array platform • Newborn Screening platfrom for fluroimmunoassay • Antenatal
screening equipment (one stop screening for pre-ecclampsia and chromosomal
aneuploidies) • Bio-informatics set up for Nest generation data analysis using
High End desktop • Eonis tm system for DNA based newborn screening for rare
disorders • Capillary Electrophoresis system for newborn screening of
hemoglobinopathies • Upgradation of existing equipment’s may also be considered
to save costs benefiting a larger section • Any other with permission of the
MOHFW with proper justification and as decided by a technical committee of
experts set up by MoHFW.