MPJE Federal Flashcards
- Prohibited foods and drugs to be distributed if adulterated or misbranded
Pure Food and Drug Act of 1906
- New drug cannot be marketed unless it was safe with directions of label
- Required that labels include adequate directions for use and warnings about habit-forming drugs
- First law that applied to cosmetic products
- Drugs marketed prior to 1938 were grandfathered and did not have to be proven safe
Food, Drug, and Cosmetic Act
- Amendment to FDCA
- Established 2 classes of drugs: legend and OTC
- Drugs that required medical supervision required to include “Caution: Federal Law prohibits dispensing without a prescription”
- Legend drugs
o Adequate directions for use = pharmacist putting label with physicians directions - Nonprescription or OTC
- Allowed for oral prescriptions and prescription refills
Durham-Humphrey Amendment of 1951
- Resulted aver concern of thalidomide (birth defects)
- Amendment to FDCA
- Drugs must be safe and effective
- Prescription drug adverting must be regulated by FDA
o OTC advertising is regulated by the FTC (Federal Trade Commission) - Required informed consent for clinical trials, reporting of ADRS, and creating good manufacturing practices
Kefauver-Harris Amendment of 1962
- Amendment of FDCA
- Classification of medical devices by function, establishment of performance standards, pre-market approval requirements, GMP standards, and requirements for reporting
Medical Device Amendment of 1976
- Tax and licensing incentives to make developing orphan drugs more appealing
- Rare disease = <200,000 people in the US
Orphan Drug Act of 1983
- Hatch-Waxman Amendment
- Streamlined drug approval process for generic products
o Only need an abbreviated new drug application (ANDA)
o Does NOT require clinical testing
o Requires proof of bioequivalence with brand name counterpart - Brand name products had incentive by gaining 5 additional years of patent protection
- Patent does not have to expire before researchers begin
Drug Price Competition and Patent-Term Restoration Act
- More stringent controls on distribution of prescription drugs
- Wholesalers by be licensed by states under federal guidelines
- Banning re-importation of prescription drugs produced in the US
- banning the sale, trade, or purchase of samples
- specifying storage, handling, and records of drug samples
- Prohibiting resale of prescription drugs purchased by hospitals or health care facilities
Prescription Drug Marketing Act of 1987
- Touches almost every aspect of FDAs activities
- Fast track NDA for treatment of serious or life-threatening conditions
- Extemporaneous compounding of prescriptions in pharmacies
o States regulate compounding
o Pharmacies are exempt from GMP - Prescription drug legend “Caution: Federal law prohibits dispensing without a prescription” replaced by “Rx Only”
- “Warning- may be habit forming” was eliminated (FDCA)
- Encouraged manufacturers to submit supplemental NDAs for uses
o Can publicly disseminated limited info about unapproved uses – must specify not approved by FDA - Manufacturers get 6 months extra of marketing exclusivity if study in pediatric population
FDA Modernization Act of 1997
- No longer allowed to deny coverage to children with pre-existing illnesses
- Children can stay on parent’s insurance until 26
- No insurance for 6 months and receive subsidy to enroll in high-risk insurance companies by the state
- All new insurance plans must exempt preventative care from deductibles
- Businesses with < 25 employees receive up to 3.5% tax credit for providing health insurance to employees
- Senior citizens in donut hole can get 50% discount on some drugs
- W-2 forms to include cost of health care
- Women’s Preventative Health Care Amendment – STD, contraception, etc
Affordable Care Act
- Not published by the government
- Contains monographs of drugs
- USP and NF are 2 separate entities even though published in 1 book
USP/NF
- Private organization that updates homeopathic products
* *without designation of USP/NF or HPUS the drug is considered misbranded or adulterated
Homeopathic Pharmacopeia of the US (HPUS)
- Find labels for approved drug products
- Find generics for a brand
- Find all drugs with a specific active ingredient
- View regulatory history
- Find consumer information after 1998
Drugs@FDA
- Price pharmacy pays for the drug. Discounted from the AWP
AAC- actual acquisition cost
- Average price paid by wholesaler to manufacturer
AMP- average manufacturer price
- Published wholesale price that can be used for pricing prescription drugs. Pharmacies usually purchase at a lower price
AWP- average wholesale price
complementary alternative medicine
CAM
department of health and human services
- Includes FDA
DHHS
- Can stand repeated use
- Used for medical purpose
- Appropriate for use in home
DME- durable medical equipment
- Estimated cost of drug to pharmacy based on info collected by DHHS
- Costs are based upon quantity purchased
EAC- estimated acquisition cost
- Highest price allowed under a specific plan for a specific drug
- If a person wants a more expensive drug, they must pay the difference
MAC- maximum allowable cost
- Excipients or adjuvants
GRAS- generally recognized as safe
- Used when considering OTC
GRASE – generally recognized as safe and effective
- Article intended to be rubbed, poured, sprinkled, sprayed or applied to human body for cleansing, beautifying or altering appearance
- Soap is NOT a cosmetic
Cosmetic
instrument, apparatus, implant,
device
Part A
hospital
Part B
medical insurance for physican services
part c
medicare managed care (medicare advantage)
part D
prescription drug
MMA- Medicare Prescription Drug Improvement and Modernization Act
- Part A = hospital
- Part B = medical insurance for physician services
- Part C = Medicare managed care (Medicare Advantage)
- Part D= prescription drug
CMS
centers for Medicare and Medicaid services
covers everything original Medicare covered with lower costs and extra services
MA- Medicare Advantage
- cannot enroll in Part _ and Medicare Advantage
D
PDP- prescription drug plan
- monthly premium, annual deductible, co-payments
o premium and deductable cannot change Jan 1 – Dec 31st but copay can - based upon individual – spouses cannot share a plan
- Tier 1 – least expensive generic
- Tier 2- preferred brand
- Tier 3- nonpreferred brand name
- Tier 4- rarer, high cost drugs
- Donut hole
o Gap between initial coverage and catastrophic coverage - Covers vaccines
Part D
Formulary requirements
- Plans must include drugs within all therapeutic classes in USP
- Companies who want to design their own plan must have P&T Committee
- Insurers do not have to include all drugs, but there are 6 classes where they have to include most
o Anticonvulsants
o Antidepressants
o Antineoplastics
o Antipsychotics
o Antiretrovirals
o Immunosuppressants - Formulary changes must be given within 60 days to CMS
medicare enrollment
3 months before and 3 months after their birthday
o 7 months
- Health insurance sold by private companies
- Cannot sell prescription drug plans
medigap
- Part D sponsors must provide MTM programs
- Targeted quarterly
o 2 or more disease states
o Taking 2-8 drugs
o Predicted to incur part D annual cost - Must target 4/7 core disease states:
o HTN, HF, diabetes, dyslipidemia, respiratory, bone disea/arthritis, mental health - Report outcomes to CMS
- Minimum requirements
o CMR – comprehensive medication review
o Targeted medication review
o Interventions to prescribers- fax, mail, face to face
MTM
- 1st application to FDA before drug can be used on humans
- Intended to protect rights and safety of humans
- IND sponsors: pharmaceutical companies, researcher, academic personnel, organizations
- FDA has 30 days to decide if drug can be tested on humans
IND- investigational new drug application
Clinical Trials
- Phase : small group of healthy individuals
o Test toxicology, PK, and pharmacological properties
phase 1
Clinical trials
- Phase : larger group, 100 or more
o Patients with the disease
o Determine efficacy, info on dosing, relative safety, and adverse events
2:
- Phase : larger groups, sometimes thousands
o Controlled clinical studies
o Efficacy compared to placebo
3
- Can receive drug without being in study if have life-threatening illness
- Drug must be in phase 2 or 3 (need safety and efficacy data)
treatment INDs
New Drug Application (NDA) process
- Submit to FDA with data from phases 1, 2, and 3
- If NDA is approved, manufacturer can market
- After drug is marketed, phase 4 studies are conducted
o Health professionals encouraged to report problems
o Manufacturer must submit yearly reports
o Phase 4 utilized to determine if drug should remain on the market - Manufacturers must describe manufacturering process for cGMPs
FDA expedited review – for
life-threatening diseases or potential to provide large benefit
FDA expedited review:
1)
a. NDA or biologics license application
b. Reduces by 10-6 months
Priority review
FDA expedited review:
2)
a. May be requested for IND prior to BLA or NDA submission
b. Intended for drugs with unmet need
c. Early reviews/meetings of their product
Fast Track
FDA expedited review:
3)
a. Can request for IND or prior to end of phase 2
b. Must show early clinical evidence
c. Greater emphasis on early meetings
Breakthrough therapy
FDA expedited review:
4)
a. Discuss during development
b. Intended for drugs with long-term endpoints (mortality, etc)
c. Required to confirm efficacy in post-market trials
Accelerated approval
- Require less data but need to show PK data
- 1st applicant to complete formal review will have 6 months of exclusive rights of the generic
- Generic companies cannot be sued for defective design or failing to warn about drugs dangers
Abbreviated New Drug Application (ANDA) - generics
- After marketing changes to synthesis, manufacturing locations, production procedures, labeling
- Do not need a new NDA
Supplemental new drug agreement
- Company that filed original NDA will probably at SNDA
ANDA vs SNDA