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Are Predetermined Change Control Plans on the road to Global Harmonization?

FDA Law

See our prior blog post on the topic here. Risk-based This guiding principle ensures risk management principles are used to evaluate the individual and cumulative changes over the life of the device. If the change does not meet specified performance criteria, it will not be implemented under the PCCP.

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State-Led Food Transparency: Texas and Louisiana Lead the Charge

FDA Law

The warning must “be placed in a prominent and reasonably visible location” and “have sufficiently high contrast with the immediate background to ensure the warning is likely to be seen and understood by the ordinary individual under customary conditions of purchase and use.” What Made the List? Preservatives such as BHA and BHT.

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Could the Road to an AKS Violation Be Paved with Good Intentions? Pfizer Asks SCOTUS

FDA Law

Gaulkin — We previously blogged about Pfizer’s copay assistance lawsuit, which sought to challenge HHS’s interpretation of the Federal health care program anti-kickback statute (AKS) and position that the company’s proposed copay assistance program would violate the AKS. By Sophia R. Background.

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Final Rule for ACNU Arrives in Time for End of Year but Not Much New to Celebrate

FDA Law

We described the 2022 proposed rule and the ten-plus year history leading up to its issuance in our blog post here. At the same time, if the RLD prescription drug and its generics have gone away, these individuals would not be able to obtain the medication by prescription from their healthcare provider.

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It Takes Three [Components] to Make a Thing Go Riiiiiight – OPDP Challenges Two-Part Ad

FDA Law

By Dara Katcher Levy — We are working to keep up with OPDP’s posts over the past few weeks and a blog on its most recent letter to Lilly is forthcoming! In defending the complete broadcast, Lilly called out similar elements from each of the individual components as demonstrating its intent to have all three viewed sequentially.

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Less than Meets the Eye: LDT Small Entity Compliance Guide Adds Little Insight

FDA Law

Laboratories struggling to understand the myriad implications of being regulated as device “manufacturers” were hopeful that additional guidance would shed light on how to apply FDA’s existing medical device regulatory framework to their operations. 803), Reporting of Corrections and Removals (21 C.F.R. § 806) and Complaint Files (21 C.F.R.

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New Breakthrough Devices Program Guidance: Expanding Opportunities for Medical Product Innovations

FDA Law

Compared to the previous version, the new guidance document highlights that the Breakthrough Devices Program may also be applicable to certain devices that benefit populations impacted by health and/or healthcare disparities and to certain non-addictive medical products to treat pain or addiction.

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