Dear Santa:
I’ve been a good policy wonk this year, so here’s my FDA wish list for 2016 …
· Thoughtful guidance on differential nomenclature for biosimilars that recognizes that “similar” doesn’t mean “identical” and prioritizes the need for savvy pharmacovigilance
· Further agency thinking on biosimilar label extrapolation
· Physician notification x 50 states, Puerto Rico, and the District of Columbia (not under FDA authority -- but since we're on the subject)
· 21st century bioequivalence written guidance for generic drugs (including tighter ranges for narrow therapeutic index medicines and critical dose drugs)
· A super effort from the FDA’s new Super Office of Pharmaceutical Quality
· Aggressive intramural efforts on biomarker development and validation
· A first quarter meeting on off-label communications
· Smart efforts on abuse-deterrent opioid PROs
· Next-step traction for Patient-Centered Drug Development
· More attention to combination products
· And IVDs
· Continued sophisticated thinking (from management) – and action (on the Division level) on adaptive clinical trials
· Completion of the Generic Labeling Rule
· Better oversight of compounding pharmacies
· And drug shortages
· For-real updating of the PMA and 510k processes
· Continued sanity on drug importation
· And medical mobile apps and social media
· Sharper teeth on dietary supplements
· 21st Century Cures legislation with both mandates and budget
· A standardized benefit/risk analysis grid
· Wider lanes on expedited pathways
· A potent PDUFA that recognizes that FDA resides at the center of the precision medicine ecosystem.
· A potent PDUFA that doesn’t use “fast and clean” as it’s sole metric for success.
· A swift, positive vote for Rob Califf
And Santa, this is only a partial list.