FDAAA Impact Analysis (Year 5): The REMS Paradox

FDA is approving new molecules at the fastest rate of the REMS era, while actually imposing REMS obligations less frequently than ever. That is good news for sponsors—but it doesn’t make a lot of sense if the REMS are working as intended. After five years, the role of REMS is still very much a work in progress.

When the Risk Evaluation & Mitigation Strategies authority took effect five years ago, there was tremendous uncertainty about how big a deal the REMS would be.

Speculation ranged from the view that the Food & Drug Administration would almost never use the new authority to the opposite extreme that a REMS would slowly but surely become...

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