NCHR Comment on FDA’s Draft Guidance to Industry on Establishing Effectiveness and Safety for Hormonal Drug Products Intended to Prevent Pregnancy

September 10, 2019: In response to FDA’s request for public comments, we stated that the agency should require better testing of hormonal birth control pills and patches. Current studies don’t include enough women with higher BMIs or track blood clot risks properly. Our comments push for stronger safety standards that test hormonal contraceptives on women of all weights, especially since some birth control methods may be less effective or more dangerous for larger women.

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NCHR Testimony on Descovy for PrEP

August 7, 2019. We understand the desire to provide a new PrEP treatment indicated for a broad population, especially when that new treatment is expected to potentially have fewer risks for kidneys and bone density. However, it is inappropriate and potentially dangerous to approve this drug for subgroups of patients that haven’t been adequately studied.  The FDA law requires substantial evidence that the benefits outweigh the risks for each subpopulation that the new indication would include.

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