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  • Month: June 2018

    • CDRH Issues Draft Guidance Regarding Test Reports for Nonclinical Bench Studies in Premarket SubmissionsJune 7th, 2018

      On May 31, 2018, CDRH issued the draft guidance, “Recommended Content and Format of Complete Test Reports for Non-Clinical Bench Performance Testing in Premarket Submissions.” The draft guidance is intended to provide an outline of the type of information to be included in non-clinical bench …

    • Connecticut Becomes Seventh State to Enact Drug Price Transparency LawJune 6th, 2018

      With the enactment of Public Act 18-41 on May 31, 2018, Connecticut joined the growing list of states (see our posts here and here) requiring drug manufacturers to submit reports on price increases. Three different reporting requirements are imposed on manufacturers under the law. First, …

    • FDA Draft Guidance for GRAS Panels: Unintended Consequence?June 5th, 2018

      Much to our surprise, we found the following recommendation for GRAS Panel members in FDA’s draft Guidance on GRAS Panels issued in November 16, 2017:  . . . avoid filling a gap in the available data and information through theoretical considerations and relevant experience – e.g., …

    • FDA to Modernize Drug Review Office Structure and ProcessesJune 5th, 2018

      On June 4, 2018, FDA posted a statement from CDER Director Janet Woodcock announcing a multi-pronged FDA initiative to modernize FDA’s drug review offices and processes.  The initiative will involve: Staffing increases Increasing the number of review offices from the current 5 to 9 and the review …

    • Fifth Delay for 340B Final Rule ImplementationJune 4th, 2018

      On June 1, 2018, the Health Resources and Services Administration (“HRSA”) released a final rule delaying the effective date of implementation and enforcement of the previously issued final rule implementing the 340B Drug Discount Program (“Substantive Final Rule”). The Substantive Final Rule, which was originally …

    • FDA’s Ninth Annual Report to Congress on 505(q) Citizen Petitions: New Numbers and a New ToneJune 1st, 2018

      More than 10 years after the enactment of FDC Act § 505(q), titled “Petitions and Civil Actions Regarding Approval of Certain Applications,” interest in citizen petitions remains high. Each year we see several analyses of the effects of citizen petitions on generic competition, as well as …