Evaluate GDUFA Changes to See if Needed: GPhA

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The Generic Pharmaceutical Association (GPhA) says that the new Generic Drug User Fee Agreement (GDUFA) program has had significant impact on both the industry and the agency and there have been enormous changes to ensure the success of all parties. “As we transition from GDUFA 1 into GDUFA 2, we need to evaluate all changes to determine those that are necessary and required from those that are not necessary/required,” the association says in a comment letter. “GPhA would like to request that FDA undertake this evaluation of all past, present and future changes under GDUFA 1 and as we go into GDUFA 2 that are in line with new requirements and mandates.”

The group asks FDA to consider two questions in its evaluation: 

  •          does the process change and/or mandate improve the review and approval process by making it more streamlined and efficient; and
  •          what significance, if any, does the new process change and/or mandate contribute to the approvability of an ANDA application in determination of safety or efficacy.

“If the answer to either or both of these questions is none, then the agency must discontinue the process(es) as they are an unnecessary burden on both the agency and industry,” GPhA says. “In our current climate of cost controls and containment across industry and government alike, especially the cost of medicines to the end user, the patient, we as an industry and FDA as the regulator must pause and give more thought as to how we are unintentionally adding to the burden and bottom-line costs of our organizations. Any unnecessary processes and/or mandates will only over-burden both industry and FDA and will lead to the unintended consequence of delaying generic competition and access to more affordable medicines to the American public.”

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