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    Compounding the Dilemma over the Permissibility of Office Use Compounding: Congressman Requests Answers to Questions from HHS Secretary Burwell

    By Karla L. Palmer – On Tuesday, March 15, 2016, HHS Secretary Burwell testified before the House Education and the Workforce Committee, during which Representative Buddy Carter (R. Ga.), who…

    Not a Blowout: DC District Court Upholds FDA’s Pre-2014 Interpretation on NCE Exclusivity for Combos, But Wants Additional Briefing on Retroactivity of Post-2014 Interpretation

    …website a final guidance document (see our previous post here) reinterpreting the statutory NCE exclusivity provisions to award NCE exclusivity for a newly approved Fixed-Dose Combination (“FDC”) drug product containing…

    Everything Old is New Again—FDA Request for Comments on Medical Device Refurbishing, Servicing, and Similar Activities

    …and Original Equipment Manufacturers; Request for Comments” (March 2016 notification).  This notification announces the establishment of a docket to receive comments “concerning the service, maintenance, refurbishment, and alteration of medical devices,…

    Fixing Erroneous FDA Guidance Can Take a Decade – and Persistence

    …one company.  When we contacted FDA on this issue in 2009, a senior FDA official acknowledged the error but also expressed his opinion that FDA was not likely to fix…

    Virginia Tech and HP&M Co-Sponsor Conference: Effective Documentation – Is Your Company Writing Itself Into Trouble?  Learn to Write It Right!

    …documentation (written communications/company records) is critical to the success of any company, most especially any doing business in a regulated industry. Documents speak for the company and the writer. Documents…

    An Oldie, But a Goodie: Revisiting a Not-Quite-Yet Vestigial Remnant of a Pre-MMA Era

    …patent (ANDA 205067), filed a Complaint for Declaratory Judgment (after some previous patent infringement court proceeding) and obtained a Final Judgment on August 28, 2015 that the company’s proposed Propofol…

    NDA Approval Date Resets: More Than a One-off

    …No. 202834), and UCB’s VIMPAT (lacosamide) Tablets (NDA No. 022253) before the drugs were scheduled by the Drug Enforcement Administration under the Controlled Substances Act (“CSA”), and thus, before commercial…

    GPhA Calls for US-EU Convergence in Biosimilar and Generic Medicine Regulation

    …cooperation between the US and the EU in their oversight of traditional generic drugs.  In a joint letter to the European Commission’s Trade Commissioner and the US Trade Representative, GPhA…

    CDRH Releases 2014-2015 Strategic Priorities

    …years will be to “strengthen the clinical trials enterprise,” “strike the right balance between premarket and postmarket data collection,” and “provide excellent customer service.” Clinical Trials Enterprise The key component…

    HPM Fact Sheet: Ensuring FDA and HHS Are Held Accountable For “Radical Transparency” and Communicating Truthful and Non-Misleading Information About DTC Rx Drug Ad “Crackdown”

    …patently false and is designed to justify rulemaking and enforcement activity to effectively shut down pharmaceutical companies from communicating with consumers. FDA is taking action to effectively ban DTC broadcast…

    HP&M Director to Moderate at FDLI REMS Conference

    …Strategies (“REMS”), which were created under the 2007 FDA Amendments Act.  The FDLI conference, for which Ms. Torrente also served on the planning committee, is titled “Issues and Answers: Advancing…

    Breathable Food Draws FDA Warning Letter

    …would enable third parties to notify the company of a serious adverse event.  In an accompanying press release,  FDA “encourages healthcare providers to report to FDA any adverse events in…

    FDA Denies Petition Seeking to Add Application Information to Drug Labels

    …be used in the labeling are moot.”  FDA never finalized the draft guidance, and, in fact, removed the draft guidance from its website after receiving adverse comments.  We understand that…

    FDA Issues Draft Guidance on Responding to Unsolicited Requests for Off-Label Information and Opens Docket on Off-Label and Pre-Approval Communications

    …FDA opened this docket in response to a Citizen Petition filed by several pharmaceutical companies requesting that FDA clarify its policies regarding communications related to off-label uses and pre-approval communications…

    GAO Report Criticizes DEA Diversion Control Performance Measures But Fails to Address Several Issues of Concern

    …combat the diversion of legal controlled substances and listed chemicals.  As the title suggests, “DEA has Enhanced Efforts to Combat Diversion, But Could Better Assess and Report Program Results,” the…

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  • Recent Posts
    • Dompé U.S. Pays $32 Million to Resolve Co-Pay Foundation Kickback Allegations Following Voluntary Self-Disclosure September 15, 2026
    • Confirmatory Evidence for All? FDA’s Approval of Lytenava for Wet AMD Shows How Non-Rare Diseases Can Use Confirmatory Evidence and That “Failed” Studies Can Provide Confirmatory Evidence September 14, 2026
    • FDA and SEC Compare Notes: What the New MOU Means for FDA-Regulated Public Companies September 8, 2026
    • HPM Presenting at IQVIA Annual Controlled Substances & State Regulatory Conference (Sept. 16-18) September 4, 2026
    • Regulating a Moving Target – FDA Seeks Comments on Possible Framework for Regulation of GenAI September 3, 2026
  • Trackers
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  • Orange Book Archives

     

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