Declaring Victory: How FDA Releases REMS

There is a new category of FDA action letter: a REMS release. Dozens of sponsors of “MedGuide-only” REMS received them after an FDA policy change. But now, FDA is issuing them regularly to sponsors whose communication plans have met their goals – or at least run their course.

It speaks volumes about the current state of Risk Evaluation & Mitigation Strategies that FDA has released more REMS than it has imposed for each of the past two years.

In the fourth year of the REMS era (April 2011-March 2012), that was a function of a policy changed: FDA concluded that a mandatory Medication Guide no longer automatically requires...

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