The FDA's new pathway for rare disease drugs, based on causal biology, is scientifically promising. However, the name "plausible mechanism" is a critical flaw. The term sounds weak, creating doubt for patients and giving payers powerful leverage to deny coverage by implying a lower standard of evidence.

An ideologically driven and inconsistent FDA is eroding investor confidence, turning the U.S. into a difficult environment for investment in complex biologics like gene therapies and vaccines, potentially pushing innovation to other countries.

After a decade on the market and multiple shifts in endpoints, Sarepta's definitive Phase 3 study for its DMD drugs failed. This outcome casts doubt on the entire accelerated approval framework for slowly progressive diseases, where surrogate endpoints may not translate to clinical benefit, leaving regulators and patients in a difficult position.

The FDA is predicted to approve new PARP inhibitors from trials like AMPLITUDE only for BRCA-mutated patients, restricting use to where data is strongest. This contrasts with the EMA's potential for broader approvals or denials. This highlights the diverging regulatory philosophies that create different drug access landscapes in the US and Europe.

In high-stakes fields like medtech, the "fail fast" startup mantra is irresponsible. The goal should be to "learn fast" instead—maximizing learning cycles internally through research and simulation to de-risk products before they have real-world consequences for patient safety.

The FDA is shifting policy to no longer allow reliance on immunogenicity data (immunobridging) for approving new or updated vaccines. This move toward requiring full clinical efficacy trials will make it harder to combat evolving pathogens and would have prevented past approvals of key vaccines like those for HPV and Ebola.

The current disconnect between the FDA leadership's public calls for flexibility and its divisions' strict actions is not new. For decades, the agency's hierarchy has acted as a promotional arm to encourage industry, while the review divisions have maintained a more conservative, old-school approach to rigor. This historical pattern is often overlooked.

Biohaven's Complete Response Letter (CRL) offers a rare public insight into the FDA's specific statistical objections to using natural history cohorts. The letter details concerns about selection bias and failures in tipping point analyses, serving as a cautionary guide for other companies like Unicure pursuing similar regulatory strategies.

Modernizing trials is less about new tools and more about adopting a risk-proportional mindset, as outlined in ICH E6(R3) guidelines. This involves focusing rigorous oversight on critical data and processes while applying lighter, more automated checks elsewhere, breaking the industry's habit of treating all data with the same level of manual scrutiny.