Incentivize production and provision of products and R&D for the public good
Minimize direct and indirect harm to public by production or consumption of products
Promote efficiency in “natural monopolies”
Information asymmetry
Intrastate Commerce Clause of the Constitution gives authority to U.S. Congress and federal administrative agencies
State governments may regulate in areas not delegated to the Federal government and enact laws to promote the health, safety, and welfare of its people (general intrastate; professional practice).
In some areas, neither federal nor state governments have power to act – left to individuals
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Authority by interstate Commerce clause of the Constitution
Administrative agencies under the executive branch makes statutes
Administrative agencies under the legislative branch makes statutes
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Judicial
Legislative
Executive
Federal Register is printed weekly
Code of Federal Regulations is printed annually
Notice and Comment Rulemaking occurs at the federal level
Notice and Comment Rulemaking occurs at the state level
Promulgating regulations may be out of the scope of the agency's authority
Easy to enact and change
Violation usually results in criminal penalties
Detail implementation of statutes
The burden of proof for a civil case is beyond a reasonable doubt
The purpose of enforcement is compliance
Civil cases are usually brought on by individuals
Can occur if one breaks regulations
Can occur if one breaks statutes
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Primary agency that enforces FDCA through regulation and issuance of guidance documents
Component of the Department of Health and Human Services (DHHS)
FDA Commissioner appointed by the President and confirmed by the Senate
Required safety
Required efficacy
Set more controls for clinical trials
Established cGMP
Differentiated Rx and OTC drugs
Required the label "legend only"
ANDA
PDUFA
Monograph Process
DESI
FDA evaluates on the basis of therapeutic category rather than individual drugs
Recommendations published in the Federal Register
Final Monograph identifies active ingredients generally recognized as safe and effective
Evalutes Rx drugs only for safety that were marketed between 1938 and 1962
Evalutes Rx and OTC drugs for safety that were marketed between 1938 and 1962
Evalutes Rx drugs only for safety that were marketed between 1938 and 1982
Evalutes Rx and OTC drugs for safety that were marketed between 1938 and 1982
None of the above are correct
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It contains a new substance
It is a combination of two already approved drugs
The proportion of ingredients change
A new use is indicated
The dose changed
The duration of action changed
Products may be marketed without proven efficacy
Products on market do not have to have proven safety
May be intended to for diagnosis, treatment, or prevention of a disease
Dietary supplements must be intended for ingestion (taken by mouth)
True
False
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True
False
Must be included on the labeling as a linear bar code
Serves to facilitate automated processing of drug claims and drug distribution
Contains 9 digits
Required on all prescription labels & labeling
Required on all OTC labels & labeling
Indicates that the product has either NDA or ANDA approval
Private, independent organization
Standards enforceable by FDA under FDCA
Refilled without authorization
Packaging violates poison prevention packaging act
Fails to have "adequate directions for use"
Fails to meet compendial standards
Fails to meet cGMP
Label is false/misleading
Causality is a prerequisite for reporting
It is voluntary for industry and providers
You may report serious adverse events
You may report suspect counterfeit
You may report device use errors
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True
False
Class I
Class II
Class III
MedGuides
Specialized provider training
Limit dispensing to specialized practice settings
Patient monitoring or testing
Sped up the approval of generic drugs
Made manufacturers pay for their own ANDA
Grants manufacturers incentives to continue reserach and development
Set up additional post marketing surveillance programs (such as VAERS)
Made a list of bioequivalent drugs
Set standards for expiration dating and beyond use dating of medications
Codify ANDA process
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It is an official compendium
Includes drugs that have never been marketed
Does not include OTC drugs
Provides therapeutic equivalence evaluations for single source drugs
Includes pre-1938 drugs
Safe
Effective
Bioequivalent
Adequately labeled
Comply with cGMP
Pharmaceutically equivalent
Contain the same inactive ingredients
Same dosage form
Identical in strength or concentration
Same route of administration
AA
AB
AB1
AO
AX
BB
BB1
BO
BX
Prescription drug advertising is enforced by the FTC
Reminder ads do not need to have a fair balance and include SEs, etc.
Guidance allows brief summary of risks as long as “adequate provision” for obtaining information included (such as a toll free number, webpage, referral to magazine or health care provider)
Kefauver Harris
Waxman Hatch
Durham Humphrey
PDUFA
Prescription Drug Marketing Act (PDMA)
PPI
MedGuide
REMS
CMI
Require state licensing of drug wholesalers
Limit re-importation of exported US drugs to the manufacturer
Changed the "legend" requirement to "rx only"
Placed controls over drug sampling
Placed restrictions on resale of drugs by hospitals and other health care entities
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Renew PDUFA
Changed "legend" to "rx only"
Clarify the parameters of pharmacy compounding
Low risk
Medium risk
High risk
True
False
True
False
Any non-oral drugs
Birth control
Sublingual NTG
Prednisone
Z-pak
Questran
Six months from the date the drug is packaged into the single-unit or unit-dose container
90 days from the date the drug is packaged into the single-unit or unit-dose container
One year from the date the drug is packaged into the single-unit or unit-dose container
25% of the manufacturer's expiration date
10 days
14 days
28 days
30 days
One year
PPIs are limited to estrogen containing oral products only
MedGuides are required to accompany drugs that pose serious and significant public health concerns
MedGuides are required for new prescriptions
MedGuides are required for refilled prescriptions
REMS are required for thalidomide, clozapine, and olosetron (lotronex)
IPledge is an example of a REMS
It must ALWAYS be sold with a child-resistant cap
One can only sell up to 30ml OTC
Ipecac is not synonymous with ipecac fluid extract
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