FDA Draft Guide on Determining When REMS is Necessary

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FDA has released a draft guidance on “FDA’s Application of Statutory Factors in Determining When a REMS Is Necessary” that is intended to clarify how it applies factors in determining whether a risk evaluation and mitigation strategy (REMS) is necessary to ensure that the benefits of a drug outweigh its risks. The agency says the document is one of several being developed to fulfill performance goals it agreed to during the last user fee reauthorization in 2012.

Determining whether a REMS is necessary for a particular drug is a complex, drug-specific inquiry, “reflecting an analysis of multiple, interrelated factors,” the guidance says.“ In conducting this analysis, FDA considers whether (based on premarketing or postmarketing risk assessments) there is a particular risk associated with the use of the drug that, on balance, outweighs its benefits and whether additional interventions beyond FDA-approved labeling are necessary to ensure that the drug’s benefits outweigh its risks,” it says.

FDA’s regulations require it to consider the following six factors in making a decision about whether to require a REMS:

  • The seriousness of any known or potential adverse events that may be related to the drug and the background incidence of such events in the population likely to use the drug
  • The expected benefit of the drug with respect to the disease or condition
  • The seriousness of the disease or condition that is to be treated with the drug
  •  Whether the drug is a new molecular entity
  • The expected or actualduration of treatment with the drug
  • The estimated size of the population likely to use the drug

These six factors influence the decisions on whether a REMS is required for a particular drug and what type of REMS might be necessary (i.e., what specific elements/tools should be included as part of the REMS). “No single factor, by itself, is determinative as to whether a REMS is necessary to ensure that the benefits of a drug outweigh its risks,” the guidance says.

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