Posts Tagged ‘ParagonRx’

Ethnographic Research and REMS

Monday, July 12th, 2010

-Guest Blog by Andrea J. Simon, PhD.-

In the past year, pressures to integrate observational or ethnographic research (which really are one and the same) in pharmaceutical and biotech industries are increasing as the value of this research is becoming better understood. In particular, Phase IV research involving the management and use of a drug protocol is becoming more and more important; i.e., when a drug is in widespread use, risks need to be better understood. At the same time, there is a growing sense of uncertainty around ethnography’s legitimate role, how to integrate it into quantitative research, and when to use its information and insights to support or alter a previously defined direction. Along with this greater scrutiny, there is rising debate about ‘best practices’ in observational research processes, especially regarding the need to define protocols to ensure that research is conducted with proper rigor and is producing suitable, credible results. (more…)

REMS Assessments: Designing and Evaluating REMS

Wednesday, May 26th, 2010

Sponsors are struggling with how to adapt research survey methods to meet the regulatory reporting standards of REMS assessments.  Assessments need to be designed in a way that measure risk mitigation.  Reports and interpretation of findings are highly qualitative and declarations of success may be inconsistent with those findings.

REMS assessments should be designed in a meaningful manner for measuring specific objectives.  It’s important to start with a rational design – balance the interests of regulators, customers, and manufacturers.  The design should be evidence-based and include end users in the design process.  (more…)

REMS Coordination Office

Monday, April 26th, 2010

The REMS Coordination Office (RCO) is the organizing hub among a Sponsor’s cross-functional team. The RCO is responsible for coordinating and tracking various aspects of REMS and the activities of outside service providers. The RCO features a core team of individuals tasked with managing REMS activities and processes.

This was the topic of a recent webinar hosted by ParagonRx. Jeff Fetterman, ParagonRx President, opened the webinar by borrowing two examples from the nuclear industry to illustrate how two different principles for organizing operational processes and systems have the potential for two different outcomes - flawless or disastrous. (more…)

Organizing for REMS Effectiveness: A View from the Field

Tuesday, March 30th, 2010

- Guest blog by Andrea J. Simon, PhD -

This blog by Andrea Simon, PhD, a corporate anthropologist, is one in a series that ParagonRx has initiated to help our readers better understand some of the trends taking place in the field of Risk Evaluation and Mitigation Strategies (REMS) and risk management under the FDA  draft guidance.  We know you will find them of value and encourage you to comment on them.

In April, ParagonRx is hosting its Wednesday FoREMS webinar on the topic of organizing to effectively manage Risk Evaluation and Mitigation Strategies (REMS).  And, in May, the Wednesday FoREMS will host a panel of industry leaders discussing how their organizations are building REMS capabilities and resourcing them in their product development and commercialization functions.  In preparation for these upcoming webinars, I thought I would share with you some of my observations from the field and encourage you to share your own company’s perspectives on how you are reorganizing to create and effectively manage REMS. (more…)

The REMS Sensitivity Index

Tuesday, March 23rd, 2010

Below is a qualitative index of the likelihood that FDA may require a REMS for a specific development compound as part of the NDA submission.

The presence of any attribute increases the probability of a REMS requirement; some items may be more highly weighted than others: (more…)

FDLI Conference on REMS: Benefits and Risks Meet Liabilities and Opportunities

Wednesday, February 24th, 2010

- Guest blog by Roger Morris, The LondonBritian Company -

You’ve heard all the analogies:  Is the glass half empty or half full?  Does the dark storm cloud have a silver lining?

I was constantly reminded of this during the Food & Drug Law Institute’s latest conference on REMS held February 16 in Washington, D.C., as the residents and transportation system was trying to dig out of one-two snowstorms.  It was an interesting conference, one that built substantially on the groundwork done at last year’s REMS conference which the FDLI co-hosted with ParagonRx. (more…)

Are You Attending the FDLI’s Important REMS Conference in Washington?

Friday, February 5th, 2010

- Guest blog by  Roger Morris, The LondonBritain Company -

Having worked in communications in the pharmaceutical industry for more than 25 years, I continue to be amazed at how even strong competitors remain so open to sharing information and experiences.  Perhaps it’s the academic nature of pharmaceutical research that filters out to everyone else in the business, but the industry is constantly talking within itself - from scientific publications about new compounds to physician disease-state annual meetings to specialty conferences.

(more…)

We’ve Grown to Better Support Our Clients

Friday, January 8th, 2010

Since 2003, ParagonRx has helped design, document, or negotiate dozens of risk management programs and REMS for pharmaceutical products.  Clients who choose to work with us have done so because of three operating principles:

  1. We believe in a balanced approach to REMS design in which safety objectives are achieved while preserving commercial viability.
  2. We employ science-based methods to reliably design and measure rational, defendable programs.
  3. We strive to inspire confidence in clients facing uncertain situations by providing specialized thinking, expert analysis and remarkable responsiveness by our experienced staff.

Those potential clients who did not choose to work with us often cited the need for a firm with broader capabilities to implement communication plans and elements to assure safe use.

At the start of this year, ParagonRx fulfilled its vision of being able to provide end-to-end REMS and risk management services by joining inVentiv Health. (more…)

REMS Assessments

Tuesday, December 22nd, 2009

As we advise clients about REMS design and implementation, the most frequent concern we encounter is related to REMS assessment.  A look at the math reveals why this is so.  Over 63 REMS have been approved since FDAAA statutes for REMS became effective in March 2008.  Of those, more than 90% are comprised of Medication Guides and/or Communication Plans, plus an assessment.  (more…)

An excerpt from Expert Evaluation of RxFMEA™, a white paper by Benjamin A. Berman

Thursday, September 24th, 2009

Description of RxFMEA™

RxFMEA™ is a proprietary modification and extension of the basic FMEA methodology and that of Healthcare FMEA (HFMEA™), an adaptation of FMEA that was developed by the U.S. Veteran’s Administration. My review of the process suggests that the objective of RxFMEA™ is the comprehensive management of risks in the pharmaceutical industry. Because of the active involvement of trained personnel and untrained consumers in the distribution and use of pharmaceuticals, RxFMEA™ extends the basic FMEA and HFMEA™ processes in the following ways (more…)