OGD Announces Changes in Key Leadership Positions as Part of its Reorganization

The Office of Generic Drugs’ (OGD) elevation to a Super Office in the Center of Drug Evaluation and Research has come at a challenging time for the Generic Drug Program. The new Office structure is presented below and represents a dramatic organizational change to us old timers. But this is progress and represents the need to move the program in a different direction for today’s environment.

OGD to Reach Decision Soon on Stability Requirements for RTR ANDAs First Submitted Before June 20, 2014

If you are one of the about 600 ANDA applicants submitted in the first 19 days of June, or have one of the additional ~ 100-200 ANDAs that have not yet received notification of acceptance for ANDAs submitted prior to June 2014, a decision is expected soon on what stability requirements you will need to meet upon resubmission.

Nine Months into FY 2014 and the Numbers Stagger the Mind

With 9 months gone in FY 2014 and the June Generic Drug Activity Report just released, things don’t look so good! The June ANDA submissions not only beat any previous one-month total ever, but shattered the previous record by almost 275%. The big problem when looking at the numbers in the Activity Report is not only seen in the number of ANDAs submitted, but also in the disturbing trend in the numbers in general.

Two GDUFA Guidances Announced in the Federal Register and Published On CDER’s Web Page

The FDA announced the availability of two Guidance documents – on Prior Approval Supplements and the other concerning Easily Correctable Deficiencies (ECDs). These eagerly anticipated documents have also published on the CDER web page.

The FR notice states relative to the Prior Approval Supplements (PAS) Guidance that “this draft guidance is intended to assist applicants preparing to submit to FDA PASs and amendments to PASs for abbreviated new drug applications (ANDAs). It describes FDA’s performance metric goals for PASs and clarifies how FDA will handle a PAS and amendments to a PAS for an ANDA subject to the GDUFA performance metric goals.”

Compounding Back in the News as FDA Adds 25 Drugs to the Do Not Compound List

The FDA is proposing to update its list of drug products (previously found in its regulations at 21 CFR 216.24) that have been removed from the market for safety or efficacy and cannot be legally compounded. It has also revised one product relative to its dosage form that allows compounding under the pharmacy compounding exemption. Since FDA has approved an ophthalmic form of bromfenac, it has removed the restriction to now permit the compounding in certain situations for this drug product but only for ophthalmic use, whereas this drug was previously excluded for any use by the Rule.

Holy Moly! Buckle Up! The Blip Turns Out to Be Mount Everest with about 600 ANDAs in June so Far!

The Office of Generic Drugs (OGD) confirmed today that the rush to get ANDA applications into the Agency before the new stability requirements go into effect on June 20, 2014 flew past all estimates and landed at just under 600 (the unofficial count is 598). OGD was shocked by the number of submissions with many there predicting a figure around 350. The rush was certainly on with a total of about 370 ANDAs submitted in the last 4 business days leading up to the June 20 deadline. One positive comment from OGD was at least we know the Electronic Gateway can handle the volume!

Poll Produces Interesting Results on Generic Drug Labeling Rule

The Generic Pharmaceutical Association (GPhA) commissioned a survey organization (PublicMind) to poll physicians, physician assistants and pharmacists about how much they knew about the proposed generic drug labeling rule, how it would impact their practice (if at all), and how they felt about the current system of how generic drug labeling is approved by the FDA. The survey had some interesting results, which are summarized below.

OGD Approves Only 20 ANDAs in May

With the approval of only 20 ANDAs in May (information derived from the CDER application approvals report), a statistic that is sure to give CEOs heartburn, the industry may start to question the GDUFA goals, unless many more ANDAs are driven to approval. As I have written before, Complete Response Letters (CRL) are the measure of GDUFA success based on the GDUFA metrics, but you can’t market products that receive Complete Response Letters. If I am not mistaken, the 20 monthly approvals are perhaps the lowest since the generic drug scandal back in the late 1980s and early 1990s.