NCHR Comment on FDA’s Draft Guidance to Industry on Establishing Effectiveness and Safety for Hormonal Drug Products Intended to Prevent Pregnancy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. We strongly urge the FDA to convey to industry the need for a comparison group instead of historical controls, the need to conduct subgroup analyses of the safety and efficacy of hormonal contraceptives for each of several major patient populations, and the importance of premarket studies that quantify the likelihood of adverse events for different subpopulations.

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