Drug Safety and the Cost of Monitoring: The Role of REMS in Risk Management

Background: The mission of the US Food and Drug Administration (FDA) can be viewed as a pendulum that swings between protecting public health and patient safety and promoting the public health through the drug review and approval process. Two decades of legislation have by and large provided the FDA with additional resources under the successive reauthorizations of the Prescription Drug User Fee Acts (PDUFA) to provide a necessary infusion of funds to hire medical experts, scientists, and epidemiologists, among other disciplines, to expedite review of new drug and biologic applications. However, a renewed attention to potential adverse drug experiences, culminating in the Vioxx withdrawal, has resulted in the passage of the Food and Drug Administration Amendments Act of 2007 (FDAAA). Under this act, the FDA was authorized to impose postapproval requirements on the biopharmaceutical industry through the imposition of risk evaluation and mitigation strategies (REMS) and postmarketing trial (PMT) requirements to improve drug safety. Despite the extensive dialogue between stakeholders and lawmakers in the development of the FDAAA, there remains some uncertainty as to the exact impact of REMS on not only operational costs for both industry and health care professionals but also product sales and prescribing habits in the 5 years since its implementation. Methods: Recognizing that in the past 2 years, the use of REMS has shifted markedly, we sought to provide greater clarity on the duration of REMS requirements and impact of REMS on drug sales. Results: While in absolute terms, the use of REMS may be declining, the REMS experience has provided an important, perhaps even critical, step in the development of current risk management strategies aimed at improving patient safety.