Starting to implement a law before it is signed sounds dangerous. Just suggesting the possibility has an insidious undertone; but, in the case of some recent actions by the FDA in advance of the Prescription Drug User Fee Act reauthorization, it looks more like a sign of the wise use of the full PDUFA process to manage the agency efficiently.
In several areas, FDA has begun processes that are well within its current authority so that it will be ahead of the game when PDUFA V is signed. The agency...
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