NCHR Comments on USPTO-FDA Collaboration and Engagement

February 6, 2023: NCHR’s public comments strongly support FDA’s decision to prioritize USPTO-FDA collaboration. Access to generic drugs and biosimilars is critically important and abuse of the patent system remains a major barrier. We are hopeful that meaningful collaboration between the FDA and the USPTO will result in substantial improvements.

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NCHR Comment on FDA Proposed Rule on the Protection of Human Subjects and Institutional Review Boards(IRB)

December 28, 2022: NCHR public comments on FDA’s proposed rule supports a single IRB for all U.S. centers in multi-center clinical trials and greater diversity among IRB members. We urge the FDA to require more explicit improvements to address known weaknesses in oral and written informed consent procedures and address demographic differences in efficacy and safety of treatments studied clinical trials.

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NCHR Comments on FDA Ethical Considerations for Clinical Investigations of Medical Products Involving Children

December 27, 2022: We address suggestions of how to improve this guidance to promote safety and efficacy in clinical investigations of medical products involving children. Many new medical products that are used by children are never actually tested on them or approved for them prior to entering the market. Many children are either left with no treatment options or given products “off label” that have not been tested for safety, effectiveness, or dosage requirements in patients of their age, size, or weight.

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