Regulatory Considerations for Determining Postmarketing Study Commitments

Postmarketing Study Commitments (PMCs) are, most commonly, agreements made by pharmaceutical companies at the time of an FDA approval to perform a study or studies to elucidate further characteristics of the drug under consideration. The role of PMCs in drug regulation has come under considerable scrutiny in recent years, particularly as discussions of drug safety have intensified. Although these agreed‐upon PMCs are described in FDA regulations,1 such PMCs are not sought by FDA with every approval, and completion of the agreed‐upon studies is not a requirement for the drug's sponsor (there are required PMCs under certain regulatory provisions and these are discussed below). Requests by FDA at the time of regulatory approval for studies under PMCs have been a common practice for many years. When made, PMCs are described in the approval letters and are therefore publicly available. Concerns over whether PMCs were being duly performed, reported, and reviewed by FDA were addressed in the FDA Modernization Act of 1997, which required more detailed reporting by manufacturers on their progress in meeting the PMCs and required FDA to report certain information publicly.2 Clinical Pharmacology & Therapeutics (2007) 82 228–230. doi:10.1038/sj.clpt.6100238; published online 30 May 2007