Physician Awareness of FDA's Relaxation of REMS-Required Laboratory Testing Requirements and Changes in Prescribing...

The US Food and Drug Administration (FDA) requires pharmaceutical manufacturers to implement Risk Evaluation and Mitigation Strategy (REMS) programs for certain medications that carry serious safety risks. One possible REMS requirement is routine monitoring via laboratory tests. However, in March 2020, the FDA issued a temporary enforcement discretion policy enabling prescribers to apply medical judgment for completing REMS-required laboratory testing.

We aimed to assess whether physicians were aware of the FDA's temporary policy and if they changed their laboratory testing practices during the coronavirus disease 2019 pandemic.

We designed a survey of US physicians prescribing one of seven medications: ambrisentan, bosentan, clozapine, isotretinoin, lenalidomide, pomalidomide, and thalidomide. The study was conducted over two waves, May 2022 to October 2022 and October 2022 to January 2023. Multivariable logistic regression modeling was used to examine predictors of each outcome.

The combined response rate between the two waves of survey administration was 21%. Among 949 physician respondents, 438 (47%; 927 question respondents) reported awareness and 192 (21%; 926 question respondents) reported changing practices. Among the 438 physicians who reported awareness, 176 (40%) reported changing practices. Characteristics associated with awareness included sex (female vs male, odds ratio [OR] = 1.92, 95% confidence interval [CI] 1.37-2.69); recency of medical school graduation (25-34 vs ≤ 15 years, OR = 0.50, 95% CI 0.31-0.81); practice setting (academic hospital vs outpatient group, OR = 0.58, 95% CI 0.37-0.88); prescribing experience (≥ 21 vs ≤10 patients, OR = 2.92, 95% CI 2.06-4.14); and timing of survey completion (wave 2 vs wave 1, OR = 0.47, 95% CI 0.34-0.66). Characteristics associated with practice changes included race (Asian vs White, OR = 0.62, 95% CI 0.38-0.99) and awareness of FDA's policy (yes vs no, OR = 14.07, 95% CI 7.93-24.96), in addition to sex (female vs male, OR = 1.99, 95% CI 1.31-3.01), recency of medical school graduation (≥  35 vs <  15 years: OR = 0.53, 95% CI 0.30-0.93), and timing of survey completion (wave 2 vs wave 1: OR = 0.58, 95% CI 0.34-0.99).

Although policy awareness was correlated with laboratory practice changes, fewer than half of physicians who were aware of the FDA's policy reported changing their practices.