Health Canada’s Use of its Notice of Compliance With Conditions Drug Approval Policy: A Retrospective Cohort Analysis
Bibliographic record
Abstract
Health Canada has developed its Notice of Compliance with conditions (NOC/c) policy to get promising new drugs for serious diseases to market faster than would be possible through its standard approval process. Companies can receive an NOC/c for a new drug or a new indication based on incomplete evidence in return for agreeing to conduct post-market studies. This paper investigates the additional therapeutic gain from drugs approved under this policy, the percent of drugs that have fulfilled their conditions, and the length of time for fulfillment. From the inception of the policy in 1998 to the end of 2017, 89 new drugs and new indications for existing drugs received an NOC/c. Therapeutic evaluations were available for 78 of the drugs, and 54 offered only minimal or no gains over existing products. Fifty NOC/c were fulfilled, 31 were not fulfilled, and 8 were withdrawn. The median time to fulfillment was 1,040 days. Twelve NOC/c took more than 5 years to fulfill their conditions. The unfulfilled NOC/c had been issued for a median of 1,161 days, and 10 had been issued more than 5 years. The value of the NOC/c policy to patients is uncertain.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.007 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.002 | 0.000 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.001 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one teacher head, not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".