REMS Logic Model Draft Guidance
FDA has released a draft guidance entitled “REMS Logic Model: A Framework to Link Program Design With Assessment. The document describes FDA’s risk evaluation and mitigation strategy (REMS) logic model, which it describes as a recommended framework to provide applicants with a systematic, structured approach to the design, implementation, and evaluation of a REMS.
FDA says it began in 2018 assessing the feasibility and utility of applying commonly used and validated scientific frameworks to REMS assessments, and it concluded that “frameworks provide a logical, structured approach for determining what outcomes should be measured, when the outcomes should be measured, and the process and health impact indicators for facilitating these measurements.” It also identified areas for strengthening and improving REMS assessments, including the following:
- Linking program design assumptions with program evaluation metrics to validate the assumptions, allow for modifications, and improve program performance
- Improving and increasing outcomes and health impact measures
- Identifying measures to assess integration and sustainability of REMS into the healthcare system and clinical practice to help determine whether the REMS requirements can be eliminated
- Identifying a primary outcome measure to determine whether the REMS goal is being met