Comments on FDA REMS Summary Posting Proposal
Pharmaceutical Research and Manufacturers of America (PhRMA) says that if FDA continues with a plan to post on a Web site a high-level summary of the agency’s review of REMS (risk evaluation and mitigation strategy) assessments, it should consider inviting applicants to review the summaries and discuss with FDA any conclusions that an applicant is not meeting its goals before the publication of the summary. The PhRMA letter also identifies alternative approaches it asks the agency to consider when deciding whether and how to implement the summary approach.
The American Pharmacists Association says it believes making the summaries available will serve healthcare providers and patients by providing transparency and guidance for future REMS program improvements and assessments. The association provides some suggestions for the agency to consider.
AstraZeneca comments that the proposed summary “key findings” topic is a risk because it could cause misunderstanding since members of the public are not experts in the measures and complexities that would be included in the report. It cautions that there could be a negative impact on public trust and confidence.
Finally, Alkermes suggests that the summary as proposed is likely to have limited utility to the broad stakeholder audiences the agency intends to benefit. It recommends that FDA consider the different audiences that might use the summaries and tailor communications to each audience.