Newly appointed FDA leaders exhibit an ideological "dualism" by promoting unproven therapies like bone marrow stem cells while showing deep skepticism towards vaccines with robust safety data. This signals a concerning shift where regulatory decisions may be driven more by ideology than by rigorous biomedical science, creating uncertainty across the industry.

A significant disconnect exists between the FDA leadership's public statements promoting flexibility and the stringent, delay-prone reality faced by companies. For areas like gene therapy, firms report feeling the "rug was pulled out," suggesting investors should be skeptical of the agency's accommodating PR.

The FDA publicly promotes regulatory flexibility for rare diseases, yet industry insiders perceive it as less permissive than prior administrations. This disconnect between the agency's messaging and its actual decisions is fueling widespread criticism, investor uncertainty, and accusations of 'moving the goalposts'.

Disagreements between FDA review teams and senior leadership, like CBER head Vinay Prasad, create contradictory guidance for drug sponsors. Companies follow the review team's advice, only to be overruled by leadership, leading to wasted resources, delayed approvals, and significant frustration.

Despite the FDA leadership co-authoring an editorial supporting single-trial approvals, the industry is skeptical. The agency's recent inconsistent actions mean no executive or investor can confidently build a development strategy or financial model based on this policy, rendering the announcement largely ineffective.

Unicure's setback with its Huntington's gene therapy demonstrates a new political risk at the FDA. A prior agreement on a trial's design can be overturned by new leadership, especially if the data is not overwhelmingly definitive. This makes past regulatory alignment a less reliable indicator of future approval.

Internal power shifts at the FDA, such as Vinay Prasad's rising influence, create a chilling effect on review teams. Even without direct orders, reviewers feel less emboldened to be flexible when leadership's public stance favors greater rigor. This 'tone from leadership' can shift regulatory outcomes more than explicit policy changes.

Moderna spent $1 billion on a trial based on FDA guidance that was later deemed unacceptable. This arbitrary "changing of the rules" after the fact makes long-term, capital-intensive investment in new medicines like vaccines extremely risky for pharmaceutical companies.

FDA CBER Director Vinay Prasad is reportedly overriding staff recommendations not just in his own center (vaccines), but also in CEDAR (drugs), as seen in the Disc Medicine case. This consolidation of decision-making power in one individual is making FDA approvals far more unpredictable for drug developers.