2.2 HUMAN DRUGS

2.2.1 Program Description, Context, and Summary of Performance

Total Program Resources:
  FY 01 FY 00 FY 99 FY98
Total ($000) 329,797 308,882 278,299 262,648

The Human Drugs Program assures that all drug products for the prevention, diagnosis, and treatment of disease are safe, effective and properly labeled. This is accomplished through: prompt and efficient review of clinical research; taking appropriate and timely action on new drugs and their generic equivalents; assuring quality of drugs on the market; and minimizing adverse events associated with use of prescription and over-the-counter (OTC) medications. To meet these goals, FDA frequently consults with experts in science, medicine and public health and also coordinates with consumers, product users and industry.

The challenge of assuring drug quality, safety and effectiveness is an ongoing one. While continual growth in the technological complexity of new products promises great health benefits for a growing number of U.S. consumers, FDA must be vigilant in safeguarding their interests. This challenge frames the Agency's strategic goals:

Through the successful pursuit of these goals, FDA is providing health protection and promotion for the American public, from the inception of new drug concepts, through research, product development, manufacturing, marketing and consumption. The Agency's approach to achieving the strategic goals outlined above, as well as key performance goals that will move the Program in these directions, are outlined in the next sections.

FY 99 Program Accomplishments

The Human Drugs Program had numerous noteworthy accomplishments during FY 1999. Among these were the following:

FDA Modernization Act--The Agency asked for over 220 studies to be conducted in the pediatric population and has granted pediatric exclusivity to seven products. FDA published a final rule for OTC sunscreen drug products containing the active ingredients that can be used in these products as well as labeling and testing requirements. It provides for uniform, streamlined labeling for all OTC products intended for use as sunscreens to assist consumers in making decisions on sun protection. FDA approved two products under Fast Track for the treatment of HIV. FDA published a draft Memorandum of Understanding between the states and FDA regarding the distribution of compounded drug products. FDA reviewed the current system of labeling products for use in pregnant women and developed a more comprehensive and clinically meaningful approach.

New Drugs - FDA achieved remarkable success by far exceeding the progressively more stringent performance goals agreed to for each successive fiscal year under PDUFA. Approved under accelerated approval was Ziagen (in 5.8 months) for the treatment of HIV-1 infection in adults and children. FDA approved 11 new drug products and/or new indications for OTC marketing in FY 99.

Antibiotic Resistance - FDA developed an Antibiotic Resistance Coordinating Committee to address the growing problem of antibiotic resistance and its effects on drug development and regulation. Antibiotic resistance refers to the ability of infectious organisms to adapt to new environments. Bacteria may change their cellular structure to be able to survive the attacks of an antibiotic drug. Once bacteria become resistant to a drug, the drug is no longer effective in treating the infection. Some types of resistance also can be passed on to other bacteria so that a growing number of infections can no longer be treated with antibiotic drugs. Because it can affect so many people, resistance is a growing global concern and poses a major public health threat.

Bioterrorism - The Agency continued to develop regulatory policy options for stockpiling and using drug products that may be needed to respond effectively in the event of the deployment of biological weapons.

Generic Drug Review - FDA approved 198 abbreviated new drug applications. Of these, 40 represent the first time a generic drug was available for the brand name product. A first time approval was Ranitidine tablets (generic for Zantac).

Adverse Event Reporting System (AERS) - In FY 99, approximately 261,000 individual safety reports (ISRs) were received for entry into the AERS. FDA evaluates these spontaneous reporting data to identify any serious, rare, or unexpected adverse events.

Establishment Inspections - 773 domestic establishment evaluations were conducted for Good Manufacturing Practices (GMPs) compliance in support of New Drug Applications (NDAs).

Research - FDA continued to strengthen its science base by working with academia and industry to develop an efficient mechanism to conduct pharmaceutical research.

Outreach - FDA gave seminars on new drug therapies and labeling, made information available via the Internet, and established programs to make promising investigational drugs and therapies available to patients with serious and life-threatening diseases.

Electronic Submissions - FDA published guidance for the receipt and archive of full electronic NDAs. The Electronic Document Room was also expanded to manage the receipt and handling of full electronic NDAs.

2.2.2 Strategic Goals

Strategic Goal 1:

Reduce human suffering and enhance public health by providing quicker access to important, lifesaving drugs, and assuring availability of safe and effective drugs.

A. Strategic Goal Explanation

Approach

Approaches to achieving this goal include continuing efforts to meet or exceed mandated review times for new and generic drug application submissions. This will be accomplished through continued collaboration and cooperation with industry, academia, professional societies and health care organizations. FDA will also continue to compile detailed standards for evaluating drugs so that consistent and high-quality reviews are being performed - premarketing reviews continue to be subject to 100 percent quality control. This plan contains a goal pertaining to evaluating and tracking pediatric clinical trials FDA is requesting under FDA Modernization Act of 1997 (FDAMA) or requiring under the new Pediatric Rule. Section 111 of FDAMA grants drug sponsors additional market exclusivity for performing and submitting pediatric studies during drug development. These additional data will provide doctors with more complete information on how drugs affect children and make it more likely that children will receive improved treatment. Efforts towards achieving a totally electronic submissions environment will continue. In 1998 the equivalent of nearly 10 million paper pages in electronic format were received. Beginning in 1999, drug companies could submit an entire NDA electronically.

Research and Standard-Setting Contributions

FDA must maintain the scientific and technical expertise needed to keep pace with current advances in science and technology. FDA scientists must operate from a strong internal research platform to successfully work with the larger scientific community. Strong research is necessary to provide information on emerging technologies that will result in new products requiring review. Examples of where the Agency must keep abreast of current scientific developments are new uses for botanicals and new areas of risk such as antimicrobial resistance. To accomplish this, FDA will create scientific exchange programs with academic institutions and continue research collaborations such as the Product Quality Research Initiative (PQRI). Collaborations such as these are a method of leveraging external scientific expertise with that of the Agency.

FDA must be proactive in assuring that current and sound science underlies regulatory requirements, while at the same time allowing flexibility to industry to use innovative approaches in product development. FDA will continue to develop and finalize guidances that define its thinking about best practice approaches to address product development and monitoring standards, and provide recommendations to pharmaceutical sponsors and FDA reviewers about how to assure safety, efficacy, quality, and appropriate labeling.

Leveraging/Communication

FDA's ability to provide expeditious drug review is dependent upon enhanced collaboration and cooperation with industry, academia, professional societies and health care organizations. Agency scientists must maintain close communication with product sponsors throughout the product research and development phase. The ability to address problems early in the process prevents larger, costly difficulties and delays from occurring later in the review. This is, in essence, realizing major health benefit gains for a relatively small up-front investment. Additionally, opening access to outside expertise is an excellent way to leverage the Agency's limited science resources and apply the expanded knowledge when it is relevant in the review process.

Reinvention

The Agency is reinventing a critical area of its premarket review process as it relates to drug products affecting children under provisions of FDAMA and its new pediatric rule. FDA also continues to improve the efficiency of the premarket review process through its automation initiative. By the end of FY 00, the Agency will be able to process 75% of all review documents by implementing an electronic document management system throughout new drug review divisions. This should increase to 90% by the end of FY 01. FDA will also be able to receive about one quarter of all abbreviated new drug applications (ANDAs) electronically by the end of FY 01.

B. Summary of Performance Goals

 

Performance Goals Targets Actual Performance Reference1
1. Review and act on 90% of standard original NDA submissions within 12 months of receipt (70% within 10 months); and 90% of priority original NDA submissions within 6 months. (12001) Standard NDAs within 12 months:
FY 01: 90%
FY 00: 90%
FY 99: 90%
Standard NDAs within 10 months:
FY 01: 70%
FY 00: 50%
FY 99: 30%
Priority NDAs within 6 months:
FY 01: 90%
FY 00: 90%
FY 99: 90%
 
FY 01:
FY 00:
FY 99: 90% (expected)
Final data available 1/01
 
FY 01:
FY 00:
FY 99: 30% (expected) Final data available 1/01
 
FY 01:
FY 00:
FY 99: 90% (expected) Final data available 7/00
 
2. Implement, evaluate, track and report on the clinical trials FDA is requesting under FDAMA or requiring under the Pediatric Rule. (12026) FY 01: Implement, evaluate, track and report on the clinical trials FDA is requesting under FDAMA or requiring under the Pediatric Rule.
FY 00: NA
FY 99: NA
FY 01:
 
 
 
 
 
FY 00: NA
FY 99: NA
 
Increase
3. Review and act upon fileable original generic drug applications within 6 months after submission date. (12003) FY 01: 50%
FY 00: 45%
FY 99: 60%
FY 01:
FY 00:
FY 99: Expect to review and act upon approximately 40% of applications received within 6 months.
 
4. Review and act on 90% of resubmitted NDA applications within 6 months of receipt. (12002) FY 01: NA
FY 00: NA
FY 99: 90%
FY 01: NA
FY 00: NA
FY 99: FDA expects to exceed this goal, but final on-time performance information will not be available until 5/00.
 
5. Review and act on 90% of standard efficacy supplements within 12 months (30% within 10 months of receipt) and priority efficacy supplements filed within 6 months of receipt. (12004) FY 01: NA
FY 00: NA
FY 99: 90% within 12 mos
30% within 10 mos
priority within 6 mos
FY 01: NA
FY 00: NA
FY 99: FDA expects to exceed this goal, but final on-time performance information will not be available until 10/00.
 
6. Review and act upon 90% of manufacturing supplements within 6 months and act on 30% of manufacturing supplements requiring prior approval within 4 months. (12005) FY 01: NA
FY 00: NA
FY 99: 90% within 6 mos
30% within 4 mos
FY 01: NA
FY 00: NA
FY 99: FDA expects to exceed this goal, but final on-time performance information will not be available until 4/00.
 
7. Continue to automate NDA and ANDA submission and archiving process. (12008) FY 01: NA
FY 00: NA
FY 99: Electronic submission and archive capacity for NDAs and ANDAs.
FY 01: NA
FY 00: NA
FY 99: Approx. 40% of NDAs received include electronic submissions. Published guidance documents and held workshops for industry.
 
TOTAL FUNDING:
($000)
FY 01: 234,156
FY 00: 244,017
   
1 Increase: Indicates achievement of the goal is dependent upon increased resources in FY 01.
NPR: Goal supports an FDA National Partnership for Reinventing Government Goal

C. Goal-by-Goal Presentation of Performance

1. Review and act on 90% of standard original NDA submissions within 12 months of receipt (70% within 10 months); and 90% of priority original NDA submissions within 6 months. (12001)

Fiscal Year 1998 Cohort as of 9/30/99
Submission Type Number of Submissions Filed with CDER Goal (months) Number of Reviews "On Time" Percent of Reviews "On Time"
Priority New Drug Application 30 90% in 6 months 30 100%
Standard New Drug Application 83 90% in 12 months 83 100%

2. Implement, evaluate, track and report on the clinical trials FDA is requesting under FDAMA or requiring under the Pediatric Rule; conduct research initiatives and activities to define the quality of the clinical studies, usefulness of data generated from these trials, changes in drug product labeling and resultant public health benefits for children. (12026)

3. Review and act upon 60% of fileable original generic drug applications within 6 months after submission date. (12003)

MEDIAN APPROVAL TIME
Abbreviated Applications

FISCAL YEAR MONTHS
1997 19.6
1998 18.7
1999 17.3

4. Review and act on 90% of complete NDA applications resubmitted following receipt of a non-approval letter, within 6 months after resubmission date. (12002)

Fiscal Year 1998 Cohort as of 9/30/99

Submission Type Number of Submissions Filed with CDER Goal (months) Number of Reviews "On Time" Percent of Reviews "On Time"
Class 1 Resubmission 22 30% in 2 months 18 82%
90% in 6 months 22 100%
Class 2 Resubmission 31 90% in 6 months 31 100%

5. Review and act upon 90% of standard efficacy supplements within 12 months (30% within 10 months of receipt) and priority efficacy supplements filed within 6 months of receipt. (12004)

Final on-time performance information for the FY 99 submission cohort is not yet available but FDA expects to exceed this goal. For the FY 99 submission cohort, 140 efficacy supplements were filed. This FY 99 goal is included for reporting purposes. The goal does not continue into FY 00 or FY 01.

Fiscal Year 1998 Cohort as of 9/30/99 Submission Type Number of Submissions Filed with CDER Goal (months) Number of Reviews "On Time" Percent of Reviews "On Time" Priority Efficacy Supplement 9 90% in 6 months 7 78% Standard Efficacy Supplement 120 90% in 12 months 119 99%

6. Review and act upon 90% of manufacturing supplements within 6 months and act on 30 percent of manufacturing supplements requiring prior approval within four months. (12005)

Fiscal Year 1998 Cohort as of 9/30/99
Submission Type Number of Submissions Filed with CDER Goal (months) Number of Reviews "On Time" Percent of Reviews "On Time"
Manufacturing Supplement 1,463 90% in 6 months 1,442 99%

7. Continue to achieve capability and capacity for electronic submission and archiving of information required to submit NDAs and ANDAs. (12008)

Strategic Goal 2:

Prevent unnecessary injury and death to the American public caused by adverse drug reactions, injuries, medication errors and product problems.

A. Strategic Goal Explanation

Approach

FDA uses a number of postmarketing risk assessment approaches to ensure the continued safe use of drug products. The Agency's current adverse event database for drugs and therapeutic biological products, the AERS, contains approximately 2 million reports. In FY 98, more than 230,000 reports of suspected adverse events were received by the AERS. FDA evaluates spontaneous reporting data from the AERS to identify any serious, rare, or unexpected adverse events or an increased incidence of events. Based on its evaluation, FDA may decide to disseminate risk information, such as Dear Healthcare Professional letters, and may initiate regulatory action. Through a program called MedWatch, the FDA Medical Products Reporting Program, healthcare professionals and consumers are encouraged to report serious adverse events and product problems to FDA, the manufacturer, or both. FDA's Drug Quality Reporting System (DQRS) receives reports of deviations from Good Manufacturing Practices that occur during the manufacturing, shipping, or storage of prescription or OTC drug products. FDA receives medication error reports on marketed human drugs and maintains a central database within the DQRS and the AERS for all reports involving a medication error or potential medication error. The Agency puts substantial effort into reviewing medication error case reports to identify serious or potentially serious outcomes that might be avoided by modifying the labeling or packaging.

Research and Standard-Setting Contributions

FDA experiences continuous pressure for speedier approval of new products that hold the promise of new cures or symptom relief. The availability and increased use of medications also raises concern about the nearly inevitable circumstance that, after a drug is placed into general practice, harmful side effects will emerge that were not observed during pre-market investigations. Some side effects may be predictable but many are not. FDA has instituted a comprehensive postmarketing review system for identifying, evaluating, dealing with and possibly preventing adverse drug reactions. Additional research is needed on problem identification and reporting, and better methods of educating medical professionals and consumers on recognizing and reporting medical product problems should be implemented.

Information to support the science and technical positions of a guidance must be located or developed, and then analyzed carefully to allow an optimal set of recommendations to industry sponsors and Agency review staff. To extend Agency resources and incorporate the expertise of stakeholders into developing the information needed to establish policy, FDA supports collaborative efforts with extramural constituencies. Two recent examples include the PQRI and the Collaboration for Drug Development Improvement (CDDI). The PQRI focuses on product quality and the CDDI focuses on safety and efficacy. Both initiatives include stakeholders from the pharmaceutical industry and academia.

A safe medical product is one that has reasonable risks, given the magnitude of the benefit expected and the alternatives available. Research, and as a part of that, the development of standards and guidances has a major impact on the benefits of taking the drug as opposed to the level of risk.

Leveraging/Communication

FDA draws on outside resources to strengthen its ability to assure the quality and safety of approved drugs. Research collaboration is an excellent method of leveraging external scientific expertise with that of the Agency. A prime example is the PQRI, a nonprofit foundation that serves as a vehicle for FDA, industry and academia to collaborate on key issues in pharmaceutical product quality through research and expert group analysis. (See performance goal 5.)

Many examples of leveraging exist in the Agency's compliance activities. FDA works with regulatory scientists in state and local organizations as well as national and international experts. Industry has widely participated in FDA-sponsored workshops to explain safety issues. One example is FDA's informal partnership to share test methods and procedures for drugs with regulatory scientists in the United Kingdom, Germany, Australia, Canada and the Netherlands. Combining samples has allowed the FDA to assemble a database of pharmaceutical ingredients, which serves as a reference in stopping the use of counterfeit drug ingredients. FDA has also worked with industry in technical workshops on laboratory testing of drugs.

The Agency looks upon consumers as partners in safe drug use. Communication is a critical element in managing risk associated with approved medical products. FDA has measured the usefulness of drug label information to the consumer and redesigned the label for OTC drugs, with prescription labels to follow. In partnership with national consumer organizations, FDA is disseminating educational information to consumers and health professionals about choosing the right medications, taking medications correctly and reporting adverse reactions (See performance goal 8). More drug information targeted to consumers is being made available on the Agency's website. "Take Time to Care" is an outreach program directed to women about the safe use of medications. In cooperation with over 80 national organizations, including the National Association of Chain Drug Stores, FDA expects to reach 6.5 million women and positively affect their use of medications.

Reinvention

FDA has increasingly used Agency-industry workshops to address safety issues in specific product areas, partnerships with state regulatory agencies, and research-oriented groups to expand the knowledge base. FDA field offices are encouraged to develop pilot programs in a continual effort to increase safety for consumers in the most effective, efficient manner and successful pilot programs have been adopted by the Agency.

Reinvention-oriented pilot programs have also been used in the surveillance area across the Agency. Development of sentinel sites has been a pilot program in the Medical Device Program, and offers a benefit to consumers and health professionals to be expanded to cover the Human Drugs Program.

B. Summary of Performance Goals

 

Performance Goals

Targets

Actual Performance

Reference1

8. Improve adverse drug event reporting system. (12007) FY 01: Separate data entry and retrieval functions throughout new drug review divisions. Pilot test advanced analytical techniques. Develop and implement special report module.

FY 00: Implement software to make the AERS more compatible with International Conference on Harmonization requirements. Develop next generation of the AERS to enhance functionality.

FY 99: Implement AERS for the electronic receipt and review of voluntary and mandatory ADE reports.

FY 01:
 
 
 
 
 
 
FY 00:
 
 
 
 
 
 
FY 99: implementation of selected periodic industry reports expected by end of FY 99.
 
9. Initiate all research programs approved by the PQRI Steering Committee (12016) FY 01: 50%
FY 00: 25%
FY 99: NA
FY01:
FY00:
FY 99: NA
 
 
 
Increase
10. Inspect 28% of registered human drug manufacturers, repackers, relabelers and medical gas repackers. (12020) FY 01: 28%
FY 00: 22%
FY 99: 22%
 
FY01:
FY00:
FY 99: 26%
FY 98: 24%
FY 97: 26%
 
 
 
 
11. Assure that FDA inspections of domestic drug manufacturing and repacking establishments result in a high rate of conformance (at least 90%) with FDA requirements.
(12006)
FY 01: at least 90%
FY 00: at least 90%
FY 99: at least 90%
FY 01:
FY 00:
FY 99: 95%
FY 98: 96%
FY 97: 95%
 
12. Give consumers and health professionals more easily understandable OTC drug information.
(12027)
FY 01: Give consumers and health professionals more easily understandable OTC drug information.
FY 00: Make new drug approval information increasingly available via the Internet. Develop partnerships with national organizations to disseminate educational information to consumers.
FY 99: NA
FY 01:
 
 
 
FY 00:
 
 
 
 
 
 
FY 99: NA
 
 
Increase
NPR Related
13. FDA will evaluate drug information provided to 75% of individuals receiving new prescriptions. (12009) FY 01: NA
FY 00: NA
FY 99: FDA will evaluate drug information provided to 75% of individuals receiving new prescriptions.
FY 01: NA
FY 00: NA
FY 99: 1998 National Telephone Survey completed. Risk/Benefit Communication study of gender differences in risk communication completed.
NPR
Related
14. FDA will continue to improve the legibility and clarity of OTC drug labels. (12010) FY 01: NA
FY 00: NA
FY 99: FDA will continue to improve the legibility and clarity of OTC drug labels.
FY 01: NA
FY 00: NA
FY 99: Final regulation was issued in 3/99 to require new, easy-to-understand labeling on OTC drugs
 
 
 
NPR Related
TOTAL FUNDING:
($000)
FY01: 95,641
FY00: 64,865
   
1 Increase: Indicates achievement of the goal is dependent upon increased resources in FY 01.
NPR: Goal supports an FDA National Partnership for Reinventing Government Goal

C. Goal-by-Goal Presentation of Performance

8. Expedite processing and evaluation of adverse drug events through implementation of AERS which allows for electronic periodic data entry and acquisition of fully coded information from drug companies. (12007)

9. Initiate all research programs approved by the PQRI Steering Committee in FY 00 and complete 50% of the projects initiated in FY 99 under the auspices of the PQRI, a collaboration among FDA, industry and academia established to provide a scientific basis for policy and guidance development in CDER on issues of drug product quality and performance. (12016)

10. Inspect 28% of registered human drug manufacturers, repackers, relabelers and medical gas repackers. (12020)

11. Assure the FDA inspections of domestic drug manufacturing and repacking establishments, in conjunction with the timely correction of serious deficiencies identified in these inspections, result in a high rate of conformance (at least 90%) with FDA requirements. (12006)

12. Make available to consumers and health professionals more easily-understandable information on choosing and taking prescription and OTC drugs to prevent and reduce their misuse, take more of an activist role in how consumers use these drugs, and improve drug risk management, analysis, and communication procedures. (12027)

13. FDA will: (a) evaluate the availability, quality and usefulness of prescription drug information provided to 75% of individuals receiving new prescriptions; and (b) complete two studies that will aid in development of comprehensive drug information. (12009)

14. FDA will continue to improve the legibility and clarity of OTC drug labels, and improve the consumer's ability to read and understand important warnings and usage directions. (12010)

2.2.3 Verification and Validation

A preliminary assessment for data completeness, accuracy, and consistency and related quality control practices was done for each performance goal. The purpose of the assessment was to determine if the data was of a sufficient quality to document performance, whether the data was appropriate for the performance measure and if it was considered sound and convincing. Assessments will be use to determine the need to conduct further program evaluations.


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