• where experts go to learn about FDA
  • Michelle L. Butler

    • Inaugural Class of Commissioner’s National Priority Voucher Recipients AnnouncedOctober 17th, 2025

      We previously blogged about the Commissioner’s National Priority Voucher (CNPV), FDA’s new pilot program to expedite the reviews of selected programs that meet certain national priorities.  As a reminder, these national priorities were described as including (but not limited to): Addressing a U.S. public health crisis Delivering …

    • CRLs Today, (Potential) Lawsuits TomorrowSeptember 16th, 2025

      FDA’s recent release of 89 Complete Response Letters (“CRLs”) for pending or withdrawn applications (which we blogged about here), and its promise to continue to do so in “real-time” going forward (here), has marked a significant change in FDA policy.  Before that, the agency generally …

    • Radical Transparency, Act II: FDA Releases 89 Previously Unpublished Complete Response LettersSeptember 5th, 2025

      Yesterday, FDA announced the publication of 89 previously unpublished Complete Response Letters (“CRLs”), which appears to be the next step in FDA’s effort towards “radical transparency.” The first step was the posting of 200 already-published CRLs on July 10, 2025, which we blogged about here. …

    • And We’re Off: FDA Announces That the Commissioner’s National Priority Voucher Program is Open for ApplicationsJuly 23rd, 2025

      We blogged recently about the new Commissioner’s National Priority Voucher (“CNPV”) program, noting that we were eagerly awaiting additional details. On July 22, 2025, FDA announced some of these additional details and opened the CNPV program for applications. These additional details are to be found on …

    • Radical Transparency or Radical Redundancy? FDA Publishes 200+ Complete Response Letters, Most of Which Are Already PublicJuly 11th, 2025

      In a move FDA is calling “radical transparency,” the Agency announced on July 10, 2025 that it has published 200+ Complete Response Letters (CRLs) issued in response to marketing applications for drugs and biologics on its openFDA database.  These particular CRLs were issued in response …

    • FDA’s New Priority Voucher Pilot Program Has Landed: CNPVJune 19th, 2025

      After teasing a new rapid review pilot program for the past few weeks, on June 17, 2025, FDA officially announced the Commissioner’s National Priority Voucher (“CNPV”) program to expedite new drug and biologic (but not device or drug-device combination product) reviews.  As described in the …

    • Reports Document FDA Review Delays: What Drugmakers Should Know NowApril 22nd, 2025

      Recent reductions in force (RIFs) and leadership changes at FDA are already affecting key agency functions—and as the administration plans a broader reorganization, the impact will likely grow. One area drawing increasing attention is how these changes will affect the drug development and review process. As …

    • CMS Issues Proposed Rule on the Medicare Part B and Part D Inflation Rebate Program; HPM Issues Detailed SummaryAugust 15th, 2024

      Enacted in 2022, the Inflation Reduction Act (IRA) amended the Medicare provisions of the Social Security Act to impose several discount requirements on pharmaceutical manufacturers.  In addition to the widely publicized drug price negotiation program, the IRA established inflation rebate programs under Medicare Part B …

    • FDA Flexes its New FDORA Muscles in Withdrawing an Accelerated ApprovalFebruary 29th, 2024

      On Friday, February 23, 2024, FDA announced its final decision to withdraw the approval of Pepaxto (melphalan flufenamide), which was approved in February 2021 in combination with dexamethasone for the treatment of adult patients with relapsed or refractory multiple myeloma (RRMM) who have received at …

    • The ACA Contraceptive Mandate (Part 2)October 30th, 2023

      Just over two years ago, I wrote about the challenges with implementation of the contraceptive mandate in the Patient Protection and Affordable Care Act (ACA).  You will recall that, despite the ACA, a 2019 HRSA Guideline, and guidance from the federal agencies responsible for enforcing …

    • Landmark Drug Pricing Bill Set to Become Law; HP&M Releases Summary Slide DeckAugust 15th, 2022

      The Inflation Reduction Act of 2022 (“IRA”) has now passed both the Senate (on August 7) and the House (on August 12), and is headed to President Biden for signature.  We have prepared a slide deck that summarizes Subtitle B of the IRA, entitled “Prescription Drug …

    • More of a Bad Thing? Thoughts on FDA’s Proposal to Extend the FDR Process to Withdrawals of Accelerated ApprovalsApril 13th, 2022

      On March 28, 2022, FDA transmitted its justification to Congress for its Fiscal Year 2023 budget.  This document contains a number of legislative proposals, including three proposed amendments to the accelerated approval statutory provisions in section 506(c) of the Federal Food, Drug, and Cosmetic Act.  …

    • Ensuring the ACA Contraceptive Mandate Meets the Original Intention of CongressOctober 28th, 2021

      Having a hand in the FDA approval of important new prescription drugs is one of the things that makes our work at HPM so gratifying.  FDA approval is a significant hurdle to overcome, occurring only after scrupulous review of data collected over many years confirm …

    • FDA Cracks Down on ClinicalTrials.gov Reporting FailuresMay 4th, 2021

      On April 28, FDA issued its first Notice of Noncompliance for failure to submit required clinical trial results information to ClinicalTrials.gov.  The notice was given to Acceleron Pharma, Inc., for failure to submit the required information following completion of a clinical trial evaluating the safety …

    • Higher Medicaid Rebates Will Help to Fund COVID Rescue PlanMarch 15th, 2021

      Last Thursday March 11, the American Rescue Plan Act of 2021 was signed by President Biden. Out of the hundreds of pages of this COVID relief legislation, our pinpoint focus here is on several pages relating to Medicaid coverage and drug rebates.  The legislation requires Medicaid …