Quality-Planning
Quality-Planning
2016
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Contents
Acknowledgments 3
1. Introduction 4
1.1 Purpose of the document 4
1.2 Definitions and abbreviations 4
1.3 Background 6
1.4 Context and scope of the toolkit item 7
3. Case studies 22
3.1 Agency for Medicinal Products and Medical Devices (HALMED), Croatia 23
3.2 Medicines Evaluation Board (MEB), Netherlands 28
3.3 National Authority of Medicines and Health Products (INFARMED), Portugal 35
3.4 Medicines and Healthcare Products Regulatory Agency (MHRA),
United Kingdom 39
5. Additional information 46
5.1 Effectiveness versus Efficiency 46
5.2 SWOT analysis (Strengths, Weaknesses, Opportunities and Threats) 46
5.3 OGSM method (Objectives, Goals, Strategies and Measures) 47
5.4 BSC (Balanced Scorecard) 47
2
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Acknowledgments
Author
Melinda Pálfi
This document has been developed and approved by all WP7 active partners (BG, ES, HU, IT,
PT and UK).
The author would like to thank all colleagues who participated in the online survey of WP7 and
thus, contributed to the identification of areas of quality management that needed further
explanation, and provided good practices to share across EU MSs. Furthermore, the author
would like to express special thanks to colleagues from the HALMED (HR), MEB (NL), INFARMED
(PT) and MHRA (UK) who participated in the follow-up activities and were willing to provide
detailed explanation and share their extensive experience on the topic of this document.
3
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
1. Introduction
The purpose is to share experience with and disseminate good practice across Member States
(MS) and to increase the level of awareness of PV assessors and interested staff on specific areas
of quality management instead of providing exhaustive guidance. Practices described in this
document may not cover all relevant issues and may not be suitable for every NCA. It is at the
discretion of each NCA whether to consider any practices presented in this document relevant
to their work, and there is no obligation to adopt any practices.
4
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Terminology Description
5
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
1.3 Background
The effective and efficient operation of any organisation, organisational unit, management system
or subsystem is primarily dependent on a consistent planning process. Goals relevant for the
strategic direction of the organisation have to be carefully planned together with measurable
indicators to check for the realisation of targets within a defined timeframe, and results have to
be fed back to the system for correction and improvement. Furthermore, planning ensures that
available resources that are usually limited or restricted in nature are used in the most effective
and efficient manner. Although NCAs are operating in the public sector, which makes them dif-
ferent from the private sector in many ways, a key sense of direction, good strategy and effective
implementation of strategic plans is essential to achieve success.
Quality management adds a further dimension by ensuring that the organisation works in com-
pliance with statutory and internal requirements, makes every effort to satisfy the needs and
expectations of its customers, aims at continuous improvement of its services and maximises its
performance. Introduction of quality management is the decision of the top management of an
organisation and an effective PV quality system cannot function in isolation, but rather as an
integral part of the global organisational quality system.
In public organisations, quality is often defined as the minimum that a supervisory body (e.g.
government) demands, and cost reduction is usually more important than quality improvements
which may not lead to an increase in customer demand.1 Nevertheless, based on the results of
the online survey conducted by WP7, some NCAs who decided to follow available international
quality standards (i.e. ISO 9001 and others) to assist them in the development of their quality
systems, benefited from such an approach considering both the global organisational and the
PV quality systems.2 Furthermore, GVP Module I is consistent with the general principles of the
ISO 9000 Standards on good quality management practices, specifically the ISO 9001:2008
Standard3 on quality management systems, issued by the ISO.
1
Pejovic G, Filipovic J, Tasic L, Marinkovic V. Int J Health Plann Mgmt (2014) DOI: 10.1002/hpm.2265
2
Pálfi M, Cserjés Zs. SCOPE Work Package 7 – Survey Report (2015)
3
Please note that from 15 September 2015, ISO 9001:2008 has been cancelled and replaced by the newest edition
ISO 9001:2015.
6
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Results of the online survey4 conducted by WP7 specific to the topic of this document pointed
out that although planning activities are in place at several NCAs as regards PV, it seems to be
ad hoc in a number of cases. Additionally, some discrepancies have been observed in the un-
derstanding of certain quality concepts related to the planning process (e.g. quality objectives,
performance and compliance indicators) which highlights the need for clear definitions and ex-
planation via practical examples. Specifically, the relationship between business and quality plan-
ning, the place of PV planning in the planning activity of the organisation, and the relationship of
PV quality objectives to indicators, especially that of compliance and performance management
were identified as requiring further explanation.
This document constitutes an item of the quality toolkit that outlines the importance and features
of the quality planning process as an integral part of a well-functioning QMS. The document
discusses the relationship of business and quality planning and its various levels (strategic and
operational). It will be explained how quality objectives – the primary foci of quality plans – may
be derived from and related to the quality policy of the NCA and the business planning process.
Practical examples and case studies will be provided to demonstrate how PV activities are rep-
resented at various levels of the planning process, including the selection and management of
objectives related to the quality and business management cycle.
In line with the information presented in the previous section (1.3 Background), quality planning
and quality objectives will be interpreted and discussed with reference to relevant international
standards, where applicable, so that organisations may see the added value of organising work
along with recognised quality principles, but without any obligation to follow such principles.
This document will not go into details of business management systems, and the methodology
of strategic or operational business planning. It will focus only on the place and added value of
quality management in the overall panning process and will handle PV quality system as part of
the organisation’s QMS.
The information sources of this document are data provided by NCAs during the online survey,
conducted by WP7 among SCOPE active partners; site visits, face-to-face and written follow-up
activities at some NCAs, websites of NCAs and the scientific literature.
4
Pálfi M, Cserjés Zs. SCOPE Work Package 7 – Survey Report (2015)
7
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
1.4.1 Objectives
This document will cover specific subtopics supported by practical examples coming from the
practice of NCAs that are summarised as follows:
The concept of planning and the relationship of quality and business planning
The concept of quality objectives, factors to be taken into account during their selection and
their documentation
Communication of strategies, the quality policy and objectives to staff and their feedback and
involvement in the planning process.
When presenting examples, the ‘golden thread’ will be followed that connects top management
with individual employees, i.e. how strategic objectives of the organisation are cascaded down
to the work of each and every individual employee with specific focus on PV activities and the
contributory role of PV staff.
1.4.2 Limitations
Participation in SCOPE was voluntary for MSs, and the type of information and level of details
provided during the online survey or follow-up activities was at the discretion of each participat-
ing NCA. Good practices and case studies chosen by the author to be presented in this docu-
ment are based on the information provided by MSs and the willingness to share experience and
practices, and are therefore not representative of all EU NCAs. Further to the examples de-
scribed, most probably there are other NCAs where the planning process as a whole or any sub-
processes are robust and functioning well. Additionally, good practices presented in this docu-
ment may not be suitable for every NCA, as operation of a QMS should respect a variety of local
or internal factors, and should be adapted to the needs of an organisation.
8
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
In an organisation, planning is a management oriented process, which increases the rational use
of its resources, identifies and reduces the risks and recognises and takes advantage of oppor-
tunities involved in its business activities.
A business plan is an essential roadmap for an organisation that outlines its goals and targets;
i.e. what to be achieved in order to manage business, develop and grow.
A quality plan outlines how business plans should be realised so that the organisation (1) meets
the needs and expectations of its customers and stakeholders; (2) complies with legal and or-
ganisational requirements; and (3) continually improves the effectiveness and efficiency of its
capabilities. High quality is achieved by planning for it rather than by reacting to problems ad hoc
after they have been identified. Incorporating quality into the activities of an organisation in-
creases credibility and accountability and builds trust among its stakeholders.
5
https://en.wikipedia.org/wiki/Planning; downloaded [23/08/2015]
6
For further information on resource management in association with PV activities, please consult Toolkit item:
Resource Management
7
For an explanation of Effectiveness vs Efficiency please refer to the Additional Information.
9
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Quality planning can be a part of business planning or treated as an independent entity de-
pending on the organisational structure and decision of the top/quality management of the or-
ganisation. Nevertheless, some EU NCAs (HR, NL, PT, UK) with a very robust planning process
are concordant in that business and quality planning should be kept integrated as much as pos-
sible. There is a tendency that international quality standards (e.g. ISO 9001:2015) also promote
the existence of one management system within an organisation. The quality policy should fit for
the purpose and context of the organisation and support its strategic direction.8 Top manage-
ment is recommended to integrate and keep quality management policies and objectives con-
sistent with strategies, policies, and objectives for other business areas.9
As a consequence, the upcoming sections of this document will focus on the added value of
quality planning and quality objectives to business planning, keeping in mind that there may be
no rationale in strictly separating business and quality planning and related objectives.
Since the introduction of the current PV legislation in July 2012, PV has increasingly been recog-
nised as a strategic area for NCAs with a significant place among current strategic goals.
Implementation of each strategic goal may concern several or all units in the organisation. At the
tactical and operational level, strategic goals should be broken down to operational objectives,
steps and targets and cascaded down to organisational units, and eventually, to individual em-
ployees who carry out the work. This is generally put in place in the form of annual plans. Each
operational objective should have a connection to the strategic goals.
8
ISO 9001:2015
9
Beecroft GD, Duffy GL, Moran JW (eds) The Executive Guide to Improvement and Change, ASQ Quality Press,
Milwaukee, Wisconsin, (2003) p36.
10
https://www.sba.gov/writing-business-plan; downloaded: [23/08/2015]
11
A Vision statement defines the optimal desired future state of what an organisation wants to achieve over time. A
Mission statement defines the present state or purpose of an organisation; its activities, stakeholders and the way it
achieves its tasks. Source: https://www.psychologytoday.com/blog/smartwork/201004/vision-and-mission-whats-
the-difference-and-why-does-it-matter; downloaded: [07/01/2016]
12
http://www.businessdictionary.com/definition/quality-planning.html; downloaded: [15/10/2015]
10
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Quality plans may also manifest as relevant written quality documents at all levels of the plan-
ning process such as quality manuals, SOPs or WINs that give framework to the quality system,
define basic common supportive (e.g. control of documented information, internal audit, handling
of risks and opportunities, etc.) or specific procedures performed by single or multiple depart-
ments. These ‘plans’ ensure robustness of everyday activities and an easy and effective handling
of non-conformities or deviations from plans.
13
ISO 9001:2015
14
http://askartsolutions.com/quality-objectives.html; downloaded: [15/10/2015]
11
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
15
http://www.almp.hr/fdsak3jnFsk1Kfa/ostale_stranice/Quality_Policy_Statement.pdf; downloaded: [16/01/2016]
16
https://www.hpra.ie/homepage/about-us/quality-management; downloaded: [16/01/2016]
12
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
In relation to stakeholders:
Active participation of SÚKL management in the national drug policy in cooperation with the
Slovak Ministry of Health
Developing of cooperation with organisations ensuring the quality of medicines and medical
devices: on both the national level (professional organisations – Slovak Pharmaceutical
Chamber, Slovak Medical Chamber, Association of Slovak companies in the field of drug
regulation, regional governmental bodies, and other ministries of SR) and on the international
level (EU and Pharmaceutical Inspection Convention Scheme)
Obtaining of a stable and reputable position among medical agencies and related bodies
(EMA, EDQM, and WHO)
17
http://www.sukl.sk/en/about-sidc/quality-policy?page_id=1018; downloaded: [16/01/2016]
13
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
A quality objective is a specified level of quality that must be met by a product, process, service
or any project outcome, to be considered acceptable19. Quality objectives should provide infor-
mation on (1) conformity to legal obligations or organisational requirements; (2) fulfilment of cus-
tomers’ needs and expectations; or (3) the effective and efficient operation of a system or process
or implementation of a project. As mentioned earlier, quality objectives may be interpreted in
conjunction with, integrated into or supplementary to business objectives.
Quality objectives should derive from the quality policy of the organisation.
Objectives are set at various functional levels (strategic, tactical or operational, e.g. organisation,
departments, processes, individuals) and should be documented. As such, objectives should be
carefully cascaded down from the strategy to organisational units and individual employees and
broken down and set for shorter, definite time periods to continuously achieve concrete results.
18
http://www.diffen.com/difference/Goal_vs_Objective; downloaded: [07/01/2016]
19
http://www.businessdictionary.com/definition/quality-objective.html; downloaded: [21/10/2015]
20
Please note that the acronym may be interpreted slightly differently by various sources.
21
Government of Canada – “SMART” objectives and performance indicators. http://www.tbs-sct.gc.ca/psm-
fpfm/learning-apprentissage/ptm-grt/pmc-dgr/smart-eng.asp; downloaded: [06/01/2016]
14
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Objectives become assessable when relating them to certain values that can be measured. These
values can either be measures or indicators. Measures and indicators are different from a con-
ceptual approach22, but this document will use the term ‘indicator’ when referring to the meas-
urement of objectives.
Indicators measure to what extent an objective has been met, and may be associated with im-
plementation of a process, achievement of an outcome, performance or impact of an interven-
tion. As such, performance indicators – perhaps the most commonly encountered – are an im-
portant class of indicators that relate strongly to quality management, but it should be realised
that as objectives may vary largely among organisations, types of indicators should not be re-
stricted to ones measuring performance23.
Indicators have limitations, and cannot convey information on several aspects of an implemen-
tation process (e.g. complex relationships and reasons, why and how change occurs); therefore,
indicators should be chosen carefully to be relevant for the objectives and the organisation. Indi-
cators are sometimes easily quantified (numbers or percentages, i.e. quantitative indicators), but
sometimes more descriptive qualitative indicators are needed to assess more complex scenarios
(i.e. changes in attitudes and behaviour) or a mixture of qualitative or quantitative aspects may
be used within the same indicator.24, 25
22
Jones P. What is the difference between a measure and an indicator? (2012 May 19)
http://www.excitant.co.uk/2012/05/what-is-the-difference-between-a-measure-and-an-indicator.html downloaded:
[06/01/2016]
23
For performance and compliance indicators used in PV, please consult Toolkit item: Compliance and
performance management and indicators
24
IBIS Manuals – The programme management manual. Monitoring toolbox – Tool 8. Guidance on objectives,
indicators and annual objectives. http://ibis-admin.org/promm/3-tp-monitoring-guidelines/; downloaded:
[06/01/2016]
25
Lennie J, Tacchi J, Koirala B, Wilmore M, Skuse A Equal Access Participatory Monitoring and Evaluation Toolkit.
Module 2 Setting objectives and indicators. (2011 Feb)
http://betterevaluation.org/sites/default/files/EA_PM%26E_toolkit_front_pages%26introduction_for_publication.pdf;
downloaded: [06/01/2016]
15
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Indicators should always be used in the context of objectives, not in isolation; therefore without
the definition of appropriate objectives, indicators cannot be assigned to them. A reverse order,
setting of indicators without understanding their relationship to local or strategic objectives is
likely to result in failure. When selecting indicators the already mentioned SMART principle can
be applied. Similarly to objectives, indicators are chosen so that they are appropriate and relevant
to the scope and context of the organisation, department, process or project, fits in the way the
organisation is managed, and is preferably free from external influencing factors. Indicators
should be kept simple, they should be clear, easy and feasible to collect without the measure-
ment being too time-consuming or demanding on resources. They should be objective, accurate,
useful and unambiguous to interpret. It should be clear what to do when the indicator indicates
a favourable or unfavourable scenario. On the other hand, as good indicators are simple, there
may be a temptation to use them to simplify complex situations and use measurement instead
of managing the issue; this should be avoided. Finally, the number of indicators is recommended
to be kept to a reasonable minimum, as regular and careful evaluation is more important than
having a larger number of indicators which may result in information overload without a learning
perspective and any added value.26, 27, 28
In summary, indicators useful and relevant for one organisation may be inappropriate for another;
therefore, general examples are hard to provide without having extensive knowledge of what is
important for an organisation and what context it works in. Carefully chosen and communicated
indicators will help manage business, and encourage positive behavioural patterns of employees
and contribute to improvement; whereas indicators used as simplification of complex situations,
without a clear link to strategic or operational objectives will not improve effectiveness and
efficiency.
26
Jones P. The KPI substitution heuristic – or why use a KPI in first place. (2014 Oct 26)
http://www.excitant.co.uk/2014/10/the-kpi-substitution-heuristic-or-why-use-a-kpi-in-the-first-place.html;
downloaded: [06/01/2016]
27
IBIS Manuals – The programme management manual. Monitoring toolbox – Tool 8. Guidance on objectives,
indicators and annual objectives. http://ibis-admin.org/promm/3-tp-monitoring-guidelines/; downloaded:
[06/01/2016]
28
Lennie J, Tacchi J, Koirala B, Wilmore M, Skuse A Equal Access Participatory Monitoring and Evaluation Toolkit.
Module 2 Setting objectives and indicators. (2011 Feb)
http://betterevaluation.org/sites/default/files/EA_PM%26E_toolkit_front_pages%26introduction_for_publication.pdf;
downloaded: [06/01/2016]
16
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Complying with the legal requirements for pharmacovigilance tasks and responsibilities
Preventing harm from adverse reactions in humans arising from the use of authorised medic-
inal products within or outside the terms of marketing authorisation or from occupational ex-
posure
Promoting the safe and effective use of medicinal products, in particular through providing
timely information about the safety of medicinal products to patients, healthcare profession-
als and the public; and
[…]
Quality objectives specific to their organisations in accordance with the overall quality objec-
tives and the structure- and process-specific quality objectives in accordance with each Mod-
ule of GVP; and
Supporting the strong relationship to business management, the overall quality objectives de-
fined by GVP may be interpreted as integrated quality and business objectives. Furthermore,
some MSs indicated in the online survey of WP7 that these objectives were considered as general
guiding principles and were not included directly in operational objectives.
GVP Module I remains silent on process-specific PV quality objectives and how to measure
such objectives. Despite this, GVP Modules of PV specific processes may contain hints on quality
requirements. Furthermore, based on specific GVP Modules, the Pharmacovigilance Audit Facil-
itation Group defined objectives to support internal audit of PV processes in the form of check-
lists. According to NCAs’ practice, specific PV (quality) objectives are either incorporated in the
NCAs’ strategic or annual organisational or divisional plans; or quality requirements for PV activ-
ities are defined in relevant SOPs, the quality manual or other written quality documents.
29
Guideline on Good Pharmacovigilance Practices (GVP) Module I – Pharmacovigilance systems and their quality
systems EMA/541760/2011 – 22/06/2012
17
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Further to the above, it may be difficult to provide general examples of PV objectives. It should
be emphasised that there are no limitations as to what a business or quality objective may be –
as long as they fulfil the previously mentioned criteria, can be monitored and measured; their
selection should be based on a good understanding of what is important for the organisation or
organisational units. Therefore, it might not be possible to provide NCAs with general indicators
as they are dependent on specific objectives. Vice versa, without a deep insight into and a thor-
ough assessment of the context, adoption of general examples may not be recommended either.
For examples of indicators used by NCAs, consult the Case studies, where indicators used are
put in context.
Quality planning may be applied prior to the introduction of new structures, processes or projects;
or when changes to the existing processes included in the QMS are required. The continuity and
integrity of the QMS must be maintained in the event of significant changes in the QMS or
organisation. Changes must be carefully planned so as not to disturb the organisation’s ongoing
capability and responsibility to effectively meet customer and regulatory requirements.31 Potential
consequences of the change shall be investigated well in advance (impact analysis). Preliminary
studies may be conducted to compare the new structures or processes to the old one to verify its
suitability. Following implementation, new structures and processes should be evaluated and
adapted as necessary. For examples of such an approach, refer to the Case studies.
A quality plan describes how an organisation will achieve its quality objectives.
Plans are documented outcomes of the planning process at a given point of time. To maintain
flexibility, planning should be an ongoing, active process and plans should be evaluated on a
regular basis for continuing suitability and updated as necessary.
30
Record is used in the previous ISO version 9001:2008. In ISO 9001:2015, it is uniformly referred to as documented
information.
31
http://isoconsultantpune.com/iso-90012008-quality-management-system/iso-9001-requirements/iso-9001-clause-
5-4/; downloaded: [15/10/2015]
18
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
External and internal relevant influences with an impact on the strategic direction and ability
of the proper functioning of the QMS in an organisation:
Legal requirements (national and international)
Benchmarking activities (e.g. BEMA)
Strategic concerns in the EU
Specific organisational requirements
Cost-benefit analysis: the cost of poor quality, the cost of quality improvement and the
cost of benefits to be achieved
Resources available (infrastructure, human, financial)
Risk assessment, analysis of risks and opportunities
Potential/anticipated impact.
Quality objectives and indicators, method and frequency of data collection and method of
evaluation of indicators including acceptance and rejection criteria
Process steps: inputs, outputs, value adding or conversion activities, sequence of steps
Nature, method, frequency and timing of interaction with other processes and where this
interaction will occur
Process controls: Controls to detect and manage any non-conformities (audits, manage-
ment review); measures to be taken if non-conformities or deviations occur
19
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Process documentation (e.g. written procedures with reference to WINs, forms, templates,
records to be generated, etc.)
Schedule (the timeframe in which the work will be achieved together with major milestones)
Methods to monitor, analyse and address risks and opportunities (what could go wrong
together with strategies for risk reduction and deployment of opportunities).
Evaluation is determining, through systematic, regular research, the value and outcomes of ac-
tivities (e.g. on stakeholders of the organisation), in order to improve effectiveness, better reach
of objectives, and make informed decisions about future plans.
If monitoring systems are working well, evaluation of the achievement of goals is needed less
often and is much easier to carry out.
Monitoring and evaluation may be accomplished via various means, e.g. management reviews,
internal or external audits, stakeholder surveys or staff feedback for continuous improvement and
corrective action.
32
Lennie J, Tacchi J, Koirala B, Wilmore M, Skuse A Equal Access Participatory Monitoring and Evaluation Toolkit.
Definition of key terms (2011 Feb)
http://betterevaluation.org/sites/default/files/EA_PM%26E_toolkit_front_pages%26introduction_for_publication.pdf;
downloaded: [06/01/2016]
20
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Objectives need to be communicated to people at all levels of the organisation so that each
employee understands how their job supports the realisation of business objectives and contrib-
utes to high quality work. The message of the strategy should be preserved top-down so that
there is no gap between high level objectives and local indicators which helps create clarity for
staff, better commitment and ownership.33, 34
33
IBIS Manuals – The programme management manual. Monitoring toolbox – Tool 8. Guidance on objectives,
indicators and annual objectives. http://ibis-admin.org/promm/3-tp-monitoring-guidelines/; downloaded:
[06/01/2016]
34
Jones B. Effective KPI development (2012 Jan 27) http://www.excitant.co.uk/2012/01/effective-kpi-
development.html; downloaded: [06/01/2016]
21
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
3. Case studies
In this section, case studies obtained from 4 NCAs (HR, NL, PT, UK) are presented with a specific
focus on PV activities. Case studies bring examples to demonstrate that/how:
Strategic goals are broken down to measurable objectives (indicators), what action steps,
responsibilities and timeframes are assigned to them
Various departments (including PV) may relate their objectives to the same strategic goal
NCAs derive their quality objectives from the quality policy and what indicators they measure
The quality policy, organisational strategy and performance are communicated to individual
employees.
22
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
A Strengths, Weaknesses, Opportunities and Threats (SWOT) analysis36 has been performed
based on the self-assessment of organisational maturity in accordance with the BEMA require-
ments. The results of the analysis were used to define the goals and specific objectives of the
Development Strategy.
For each specific strategic objective the strategic document defines strategy, action steps, pre-
requisites, responsibility, indicators and timelines.
Table 1. Strategic goals for HALMED between 2014 and 2018 and related strategic
objectives
35
http://www.almp.hr/fdsak3jnFsk1Kfa/ostale_stranice/Development_strategy_2014-2018.pdf; downloaded:
[16/01/2016]
36
For an explanation of SWOT analysis (Strengths, Weaknesses, Opportunities and Threats), refer to the
Additional information.
23
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
For a thorough understanding of setting objectives, planning the implementation process and
assigning indicators, an extract from the current Development Strategy is outlined in Table 2: a
strategic objective related to PV (Objective 1.1) associated with the first strategic goal. For more
examples or the complete strategic document, please refer to HALMED’s website.
24
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Objective 1.1 Ensure that medicines and medical devices on the market in Croatia are
Strategy regularly and actively monitored due to possible ADRs/events and the
consequent impact assessment on health issues (supported by PV and
vigilance of medical devices).
Action steps Develop a training programme to support the increase in patient and
HCP reporting ADRs for medicines and adverse events for medical
devices by enhancing public awareness on the importance of reporting
Support scientific efforts in the field of PV and rational pharmacotherapy
with the inclusion of information on pharmacogenomics in written
responses to ADR reporters, where relevant
Collaborate with other competent authorities in the EU involved in signal
detection activities
Collaborate with HCP bodies, patient associations and academia in
education training programmes
Collaborate with national and international health institutions in the
development of mutual interoperable system and the sharing of relevant
information of common importance
Develop new tools such as database for pharmacoepidemiology and an
on-line application dedicated to HCPs for medicines ADR reporting.
Prerequisites Sufficient and well-educated trained staff
Allocation of financial resources
Adequate IT tools
Preparedness and willingness for collaboration on the part of national
and international institutions and bodies, as well as HCPs and patient
associations
Responsibility Head of Department for PV and Rational Pharmacotherapy
Head of the Department of Medical Devices
Evaluation of Increased number of ADR reports, including serious cases with higher
indicators quality information received from patients and HCPs
Increased levels of ADR assessments connected to pharmacogenomics
issues
An increased number of signals detected that are assessed according to
the EMA’s active substance list for signal management work sharing
Strong links with other national and regional institutions and patient
associations involved in patient safety and close collaboration to
maximise patient safety
A database for epidemiological data is used in benefit-risk assessments
and ongoing therapeutic risk management
With the help of an on-line tool, ADR reporting by HCPs is increased and
report quality is improved
HALMED is recognised as a relevant and useful source of information on
safe medicines by HCPs and patients.
Time Actions start in 2014 and are supposed to be finished by the end of 2018.
25
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
From the strategic plan, annual business plans are assembled (according to the SOP ‘Annual
Planning’) in which strategic objectives are cascaded down to the divisions and departments.
Annual business plans are mandatory in the organisation.
Specific PV objectives are derived from the overall objectives and are incorporated into strategic
(long term) or annual (short term) plans, or broken down for each relevant PV procedure in re-
spective SOPs. Table 3 presents some examples of short term PV objectives relevant for the
recent years.
In addition, common changes to procedures (updating SOPs) are done in order to streamline
processes and improve compliance and outcomes. This is done either following the result of an
internal audit or when possible improvements are defined at the level of the PV Department.
Reports of audits carried out in the Agency are made publicly available on HALMED’s website.
26
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Internal meetings of the Department (PV) at least every six months, and in the case of
risk assessment as required and more often
Internal/external audit of the PV quality system
Management review
Implementation of procedures for managing compliance
Assessment of risk minimisation activities.
There are regular meetings between the Head of Agency with his/her deputy and heads of units
where the most important issues regarding set goals, objectives and plans are discussed. Final
conclusions are met giving the answers to open questions and direction for further performance.
There are also regular division/department meetings where the most important issues regarding
the strategic objectives of concern, plans and activities are discussed. Participation of staff in the
discussions is strongly encouraged and regarded as a valuable tool for possible improvements
of processes and the QMS. Final conclusions encompass the staff suggestions and proposals.
Through direct and open communication the heads ensure that the staff has a good understand-
ing of strategic direction and operational priorities.
The heads are involved daily in realisation of business plan objectives and they communicate
constantly in formal and informal ways with the staff in order to resolve any possible issue that
could arise, and to define operational priorities. In specific processes like marketing authorisa-
tions and PV, coordinators are nominated that cooperate closely with heads and co-workers
responsible for scientific assessment. This communication is open to any kind of suggestions
and proposals that are mutually discussed. The staff informs the heads and coordinators about
realisation of operational priorities through pre-set monitoring, and heads discuss weekly with
staff about realisation and further actions. The results are always discussed at top level and pre-
sented to the Management Board.
27
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Table 5. Extract from the Strategic Business Plan (2014-2018) of the MEB
Furthermore, MEB has carried out a scenario analysis on the position of MEB in 2030. Information
obtained from the 4 scenarios anticipated, is reflected in the Strategic Business Plan (2014-2018)
that is available at the MEB website.37
37
http://english.cbg-meb.nl/about-meb/documents/publications/2013/06/05/sbp-2014-2018; downloaded:
[20/10/2015]
28
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
In its Strategic Business Plan (see Table 5 above for a high level extract) the MEB defines its high
level goals (i.e. patient oriented evaluation, proper use and innovative development), and elabo-
rates 10 concrete ways to promote progress in terms of the strategic goals. Rather than focusing
on predictions on production, productivity and capacity that are no longer realistic in an unpre-
dictable environment, the MEB focuses more on collaboration, effective communication and con-
tinuous monitoring of its surroundings to improve flexibility, effectiveness and efficiency.38 Pro-
grammes and objectives are elaborated at lower levels and in annual business plans.
Once the strategy is finalised, it is used as a framework to set annual goals in the annual business
plan. This is done by discussion between top management and middle management. Middle
management (department level) is responsible for involving staff in the draft department plan (or
even department overarching project plans). It is an iterative process resulting in a plan that is
supported by management and staff.
A strategic objective always applies to more than one department (for an example, refer to
Table 6), leading to activities for multiple (or all) departments. The MEB translates and cascades
strategic objectives to departmental objectives which are described in an operational
(quantitative) manner.
38
http://english.cbg-meb.nl/about-meb/documents/publications/2013/06/05/sbp-2014-2018; downloaded:
[20/10/2015]
29
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
The policy cycle document includes deadlines for each stage of the annual planning process, the
process owner and the deliverables. Every department provides a year plan, key elements of
which are highlighted in Table 7.
Achievement of previous year’s goals and areas for improvement; management review
External and internal relevant influences
Goals for next year
Means to achieve those goals
Risk management
Budget.
Planning is bottom up and top down, through an iterative process. First draft of plans ensures
that dependencies are known between departments. Dependencies are also discussed and
agreed on in Management Team meetings. Objectives should be SMART.
Recently MEB has changed its annual business planning cycle and introduced the Objectives,
Goals, Strategies and Measures (OGSM)-method39 to lower the administrative burden, achieve
consistency between plans at department level, monitor plans during the year and define SMART
objectives. For examples of annual objectives of the PV Department for 2015, see Table 8.
Develop national policy for Implementation and evaluation of additional risk minimisation
measures
Translate insights gained through Regulatory Science project to daily practice
Strengthen risk communication via DHPCs (content, uptake and timeliness)
Strengthen collaboration with national PV centre LAREB for signal detection and signal
validation.
39
For an explanation of the OGSM method (Objectives, Goals, Strategies and Measures), refer to the Additional
information.
30
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
For pre-requisites with regard to which processes are defined, refer to Table 9.
Prerequisites Workflow
Tasks and responsibilities
Review and escalation
Decision making
Qualification of staff
Training new staff
Assessment policy – criteria based on procedure and role of MEB in the
EU.
It is legally required
It reduces the risk of failure in the implementation process
It increases the detectability and traceability of results
The process description is required cf. ISO 9001
The complexity of the process demands it
It is necessary for exchange of knowledge
The degree of detailing follows staff competence
It achieves consistency (alignment) between staff/departments.
31
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Table 11. Example of planning for and implementation of a new procedure at MEB
1 Assess the nature of the new procedure to be implemented by looking at the process
itself (e.g. can it follow a similar workflow as other procedures, or is another workflow
required), the people (required expertise, impact on other departments and/or external
stakeholders), and the tools (assess use of existing tools and/or IT systems, need to
adapt tools or develop new tools).
32
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Triggers Link to the MEB strategic business plan (‘proper use of medicines’)
Findings from a PhD thesis with MEB involvement on risk communication
Recommendation following an internal audit on DHPCs
Current procedure being outdated (not completely in line with GVP)
External signals indicating that the content of DHPCs could be improved
by consulting relevant HCPs and/or ‘expert patient’ groups before
distributing the DHPCs
Action Improve content of DHPCs:
steps Explore possibilities for consulting HCPs before DHPCs are distributed
Update guidance for MAHs
Review internal WINs and procedures
Address DHPCs in education of PV staff and other staff involved
At the operational level, peer review mechanisms are in place for PV processes within the PV
division, but review also takes place through discussion of reports in meetings with the Board in
which the assessors have to reflect with the Board members on the assessment reports. After
each meeting the Board gives feedback on the quality of the reports and the discussion being
held.
At the business level, several management reports are available at the department level, at the
process/procedure level, and at the individual level. Also a balanced scorecard (BSC) is monthly
available. For the business planning, management also performs a yearly forecast on the re-
sources required by the MEB. PV activities are included in this forecast.
33
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Most staff members are mainly involved at the operational level regarding ongoing QMS matters:
WINs, templates and internal audits. For the QMS documentation the MEB has internal working
groups for most parts of the quality manual, e.g. there are working groups for mutual recognition,
centralised procedure, medical devices, validation and site clearance, legal affairs, and PV. Staff
from all departments can volunteer (intrinsic motivation) to become a member of one or more
groups. The chair of the group is responsible for keeping all documentation under their respon-
sibility up-to-date. The chair can ask group members to do a certain amount of work. For all
group meetings there is an agenda and an action list or minutes.
34
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
INFARMED has a 5 year strategy road-map that defines 6 strategic objectives. PV activities are
included in 2 strategic objectives of INFARMED.
The directorates identify the operational objectives, in line with these strategic objectives and
their relative weight (also defined by the Executive Board), and give input to the Annual Business
Plan, which includes the INFARMED’s Balanced Scorecard (BSC)40.
The BSC presents the most relevant performance indicators for each directorate (strategic ob-
jectives, operational objectives, weight of each indicator, method of calculation and goals).
The Annual Business Plan and another national model of evaluation of performance (QUAR)41,
which has three chapters of key performance indicators (KPIs) (Efficacy, Effectiveness and Qual-
ity), are approved by the Executive Board of INFARMED and by the Health Ministry. The Planning
and Quality Office of INFARMED communicates to all directorates that the Annual Business Plan
and QUAR were approved.
The directorates’ operational objectives are then reflected by cascading them to the individual
staff objectives. In Table 13, an example is provided on how quality objectives are derived from
the quality policy of INFARMED and the relationship of strategic and operational objectives is
demonstrated. Furthermore, indicators are assigned to each objective. PV specific indicators are
highlighted in bold.
40
For an explanation of the BSC (Balanced Scorecard), refer to the Additional information.
41
QUAR (Quadro de Avaliação e Responsabilização) is part of the Integrated System for Management and
Performance Assessment in Portugal, and is related to health services. QUAR contains the most important key
performance indicators of INFARMED. INFARMED’s performance is evaluated by the Health Ministry based on the
results of the indicators included in the QUAR.
35
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Table 13. Relationship of strategic and operational quality objectives with the quality
policy
36
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
The general quality objectives are transversal to all directorates of the Portuguese NCA, which
includes PV processes and are related to registries of non-compliances, corrective/preven-
tive/improvement actions and complaints, their implementation and effectiveness, external and
internal clients’ complaints. For examples of annual specific PV quality objectives/indicators at
INFARMED, see Table 14.
Performance data is electronically submitted by each directorate into the business intelligence
tool and automatically the dashboard shows all INFARMED’s results regarding strategic objec-
tives, operational objectives, indicators and the results of each directorate. These results are also
documented in the Summary Executive document (with an analysis and justifications regarding
the deviations from targets) that is sent by the Planning and Quality Office to the Executive Board,
the directorate’s managers and quality managers. The results are assessed by the directorates
in order to decide if preventive and/or corrective actions are necessary to ensure that objectives
and targets are achieved. INFARMED also monitors the effectiveness of the implementation of
these preventive and/or corrective actions. This way, INFARMED has updated information about
the status of performance, if objectives are being met or not and so resources can be adjusted
whenever necessary.
INFARMED’s self-evaluation is also approved by the Executive Board of INFARMED and by the
Health Ministry.
37
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
There is a ‘welcome manual’ to all new staff that includes the quality policy. Additionally, new PV
staff always have an initial training plan that includes information on the QMS of INFARMED,
highlighting the following aspects: (1) quality policy; (2) description of the operational processes
with the objectives associated; (3) the importance of optimisation and improvement of
INFARMED’s processes, through the involvement of all staff, in order to facilitate the work on a
daily basis.
The head of the PV directorate sends quarterly, by email, the Performance Evaluation Report
regarding the specific PV quality objectives (with an analysis and justifications regarding the de-
viations of the targets) to all staff. The quality manager of the PV directorate sends quarterly, by
email, the results of the performance in terms of the general quality objectives (related to regis-
tries of non-compliances, corrective/preventive/improvement actions and complaints, their im-
plementation and effectiveness, external and internal clients’ complaints) to all staff.
38
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Vigilance and Risk Management of Medicines (VRMM) to which PV belongs, has a divisional plan
which brings together its contributions to the work of the agency and to the delivery of the Agency
Business Plan for 2015-2016 and the Corporate Plan for 2013-2018. Key strategic priorities for
the annual and divisional business plan are summarised in Table 15.
The MHRA established a formal QMS which is certified to ISO 9001:2008. The divisional, agency
and corporate business plans take into account all quality objectives (see next section), as refer-
enced in the quality documents (quality manual and SOPs). Examples of the integration of these
set quality objectives into each business plan are described below (Table 16).
39
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Table 16. Example of the association of corporate, agency and divisional objectives
Strategic goal Development of a Joint Patient Safety and Surveillance Strategy (to
establish a common vigilance platform which maximises synergies while
allowing for local differentiation in order to protect public health).
Strategic The effective capture of information from incident reports and also the
objective wider scientific evidence base, including social media information and
other technologies such as the Yellow Card App.
Agency Lead the further development of incident reporting systems to embed
business plan Yellow Card reporting into National Health Service (NHS) and the care
(2015/16) system, working with UK healthcare bodies to ensure safety measures for
medicines and devices contribute to safe care and reducing avoidable
harm.
Divisional Lead the further development of incident reporting systems to embed
business plan Yellow Card reporting into NHS and the care system, and champion
(2015/16) reporting as an indicator of safe care with NHS and Arm’s Length Bodies
stakeholders by end quarter four.
The principal quality objectives of the QMS of MHRA are summarised in Table 17.
Specific examples of quality objectives in association with PV are summarised in Table 18.
40
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
ADR Objectives:
management To capture information on suspected ADRs in high quality and
structured manner that supports accurate detection and analysis of
safety signals
To continuously improve the quality of PV data classified into the ADR
database through conducting audits.
Performance targets: Maximum timescale between receipt of reports and
making them available for evaluation and analysis
For fatal UK ADRs: 90% within 24 hours and 100% within 72 hours
For serious UK ADRs: 95% within 72 hours and 100% within 5 days.
Contributing Objectives:
to the EU Facilitation of improvements to the ADR reporting systems
regulatory
network Membership in expert committees
Contribution to SCOPE Project
Contribution to work sharing activities.
Business In terms of:
performance Work volumes (e.g. number of variations received)
Public health (e.g. number of Yellow card reports by HCPs and the
public)
Capacity, efficiency and capability (e.g. HR metrics such as staff in post).
Tasks were identified and broken down into small work streams, each of which had a responsible
owner who produced finding reports. There was independent oversight (Regulatory Board) to
advise and consult on strategic decision making and stakeholder analysis was conducted to
measure the internal and external impact.
Once the changes were rolled out, there was user testing and training, with various measure-
ments used to assess the effectiveness of the new activity.
41
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
The MHRA has an SOP in place to manage non-conformity and corrective action. This action is
intended to prevent the recurrence of non-conformities or to avoid circumstances that resulted
in an adverse situation. This document identifies different methods used to detect non-conform-
ities (Table 20).
42
IMI-PROTECT: Innovative Medicines Initiative – Pharmacoepidemiological Research on Outcomes of
Therapeutics. The project aims at developing innovative tools and methodological standards to enhance the
monitoring of the safety of medicinal products and to better evaluate and communicate their benefit-risk profile
throughout their lifecycle.
Source: https://www.imi.europa.eu/content/protect, downloaded: [19/08/2016]
42
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
Customer Qualitative and quantitative data collected and reviewed to identify any
satisfaction repetitive adverse comments and direct performance improvements
measurement
Management Annual review to assess whether the system remains suitable and
review effective in the implementation of quality management; includes review of
customer feedback, complaints, internal/external audits and performance
against targets
Depending on the nature of the action needed, the corrective process may or may not make up
a formal change control. A formal documented action will identify persons responsible for plan
management, timelines, verification process and criteria for success measurements. The method
of recording and assessing corrective action is documented in official SOPs.
VRMM management is responsible for reviewing PV and quality systems at regular internal meet-
ings to verify they are fit for purpose and that all appropriate measures are in place to measure
their success. Management reviews and internal/external audits identify improvement areas in
PV systems. Self-assessments conducted as part of BEMA also inform system improvements.
43
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
The MHRA holds biannually agency-wide meetings for staff to comment on the direction of the
agency, comments which can be taken forward into the following year’s business plans. The
agency is committed to embedding strategic objectives in the day-to-day work. Staff are
encouraged to further engage in developing strategic priorities. For example, plans to refresh the
agency’s corporate strategy including engaging staff through team briefings and a series of
workshops.
44
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
This toolkit item intended to raise awareness of PV assessors and interested staff at NCAs on
quality planning and the selection and measurement of quality objectives. Quality planning was
introduced in context with business planning, and it was demonstrated that quality management
can add value when integrated to business processes in terms of achieving effectiveness and
efficiency. Various levels of planning were described, and the importance of a clean-cut and vis-
ible ‘thread’ linking strategies to individual objectives was outlined. The concept and selection of
quality objectives was detailed and the setting of appropriate indicators to measure such objec-
tives. Finally, theory was put in practice by presenting case studies from 4 NCAs with a robust
planning process in place, focusing on the place of PV in the planning process.
45
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
5. Additional information
This section contains basic definitions of some related concepts mentioned in the document.
They are not intended to be in-depth clarifications, and readers are referred to the literature for
further information.
Effectiveness indicators measure the extent to which planned activities are realised and results
achieved. They relate actual to expected values. A process is effective if its outcomes match the
stated goals. These types of indicators require a plan: effectiveness cannot be measured without
a set target.
Efficiency indicators measure how well resources (e.g. human, financial, equipment) were used
to produce the output. It is rarely possible to describe in absolute terms. One process is ‘more
efficient’ than another if it achieves the same outcomes at lower cost/time, etc.
Efficiency measures concentrate on how well a task is being performed, not whether the task
itself is correct. Effectiveness concentrates on the correctness of the process and whether the
process produces the required result..43, 44, 45
43
Carmichael RM. Measures of efficiency and effectiveness as indicators of quality – a systems approach;
downloaded: [15/10/2015]
44
Terry Wireman: Developing performance indicators for managing maintenance, 2nd ed., Industrial Press, New York,
2005, p210
45
http://www.cbsolution.net/techniques/ontarget/effectiveness_vs_efficiency; downloaded: [15/10/2015]
46
https://en.wikipedia.org/wiki/SWOT_analysis; downloaded: [19/10/2015]
46
SCOPE Work Package 7
Quality Management Systems
Quality Planning and Quality Objectives
It helps in translating strategy into operational and measurable actions and achieve strategic
implementation.48, 49
47
https://en.wikipedia.org/wiki/OGSM; downloaded: [20/10/2015]
48
Balanced Scorecard Basics. http://balancedscorecard.org/Resources/About-the-Balanced-Scorecard;
downloaded: [20/10/2015]
49
Shehu S. Business performance management, balanced scorecards and the decision model. (2013 Jul 11)
http://blog.bizzdesign.com/business-performance-management-balanced-scorecards-and-the-decision-model;
downloaded: [21/10/2015]
47