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dparkyesterday at 2:31 PM1 replyview on HN

This is all untrue so far as I understand.

A research group can file for a new drug application (or abbreviated new drug application) for an existing drug. There is no mandate that an NDA sponsor be a manufacturer or the existing manufacturer.

Only the entity holding an approved NDA can file a supplemental NDA but that’s not the only path.

The real reason no one files for off label use is that there’s high cost and little to no practical benefit to doing so.


Replies

oeziyesterday at 9:05 PM

On paper you are right. You can file an NDA. But in reality you can't prove that the product on the market (the drug you are adding an NDA to) is sufficiently under your control to enable you to claim that it is safe and effective. Only a manufacturer can control the product. If you want to piggyback on top of an existing product in the market, you have to become a manufacturer or sign a contract with an existing one.

You are absolutely right about the incentives. There are absolutely none except to help humanity which is why only hospitals and universities are doing these off label studies.