17
Jul

AAM Says PBMs May Select the Higher Branded Product to Enhance Their Benefits

Biosimilars are advancing the cause of affordable medications; however, in some instances, patient savings do not appear to be the primary concern of Pharmacy Benefit Managers (PBMs).  The Association of Accessible Medicines (AAM) points to the fact that “[j]ust two weeks ago, the U.S. biosimilars industry entered a new phase when eight biosimilar versions of […]

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14
Jul
PostMarketing Study Requirements - Lachman Consultants

What Constitutes “Good Cause” for Noncompliance with PostMarketing Study Requirements?

The FDA answers this question in a newly released guidance titled Postmarketing Studies and Clinical Trials: Determining Good Cause for Noncompliance with Section 505(o)(3)(E)(ii) of the Federal Food, Drug, and Cosmetic Act (here).  “[H]olders of applications for human prescription drugs (hereafter applicants) who are required to conduct postmarketing studies or clinical trials under section 505(o)(3) of the […]

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12
Jul
Pediatric Exclusivity List - Lachman Consultants

Pediatric Exclusivity List Updated – Not Much Activity??

As we know, many drug products are approved initially only for adult patients. The Pediatric Research Equity Act (PREA) of 2003 “gives FDA the authority to require pediatric studies in certain drugs and biological products. Studies must use appropriate formulations for each age group. The goal of the studies is to obtain pediatric labeling for […]

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07
Jul

Unofficial ANDA Approval Actions for June 2023

Another bit of good news for generic approvals!  June unofficially recorded seventy‑five full‑approval actions and thirteen tentative‑approval actions for a total of eighty‑eight approval actions for the month.  The seventy‑five full approvals represent the second highest number of full‑approval actions in a month thus far this FY, with the big daddy still being March with […]

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06
Jul
MaPP 5014.1 - Understanding CDER’s Risk‑Based Site Selection Model - Lachman Consultants

MaPP for Site Surveillance Inspection Procedure Gets a Facelift

The FDA has just revised its MaPP 5014.1 titled Understanding CDER’s Risk‑Based Site Selection Model.  Remember, MaPP stands for Manual of Policy and Procedures, and MaPPs instruct internal FDA staff on proper procedures.  The FDA publishes these MaPPs to provide greater transparency to stakeholders so they can better understand how the Agency does something or […]

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05
Jul

May 2023 Official Statistics Are in The Books

Well, we’re just four months from the end of FY 2023 and the approval numbers still stand strong.  In May, the OGD issued sixty‑three full‑approval actions and eighteen tentative‑approval actions for a total of eighty‑one approval actions.  Of the sixty‑three full‑approval actions, six were first‑time generic approvals and thirteen (20.6%) were approved in the first cycle.  […]

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28
Jun
Wholesaling by 503B Outsourcing Facilities - Lachman Consultants

What Constitutes Wholesaling by 503B Outsourcing Facilities?

The FDA released a guidance yesterday titled Prohibition on Wholesaling Under Section 503B of the Federal Food, Drug, and Cosmetic Act (here), which (as its title suggests) fully outlines what the Agency does and does not consider wholesaling by an outsourcing facility.  The examples of what a firm can and cannot do under the provisions of […]

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21
Jun

Unofficial Mid-June 2023 ANDA Approval Tally

Well, June got off to a rousing start!  In the first fifteen days, the OGD issued forty‑six full‑approval actions and nine tentative‑approval actions.  This represents one of the best mid‑month totals (fifty‑five) that we’ve seen in a long time.  If the month continues at this pace, we’re likely to see over 100 approval actions for […]

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