Drug developers often operate under a hyper-conservative perception of FDA requirements, avoiding novel approaches even when regulators might encourage them. This anticipatory compliance, driven by risk aversion, becomes a greater constraint than the regulations themselves, slowing down innovation and increasing costs.

Many peptides are unlikely to ever receive FDA approval because their simple, easily replicated structures make them commodities. Pharma companies won't fund billion-dollar trials for drugs they can't patent, leaving them in a permanent gray market.

A key tension is emerging in orphan drug development. While the FDA's approval standards appear to be rising and becoming more erratic, Congress has simultaneously created a powerful economic incentive by exempting orphan-only drugs from Medicare price negotiation, creating a complex strategic landscape.

While the FDA is often blamed for high trial costs, a major culprit is the consolidated Clinical Research Organization (CRO) market. These entrenched players lack incentives to adopt modern, cost-saving technologies, creating a structural bottleneck that prevents regulatory modernization from translating into cheaper and faster trials.

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.

The gap between U.S. and international drug prices is a structural feature of the pharma economy. High profits from the U.S. market fund expensive R&D that ultimately benefits the rest of the world, which pays far less for the same innovations. This reframes the debate around high American healthcare costs.

Despite scientific breakthroughs and better technology, the cost per approved drug has steadily increased over the last 60 years. This phenomenon, the reverse of Moore's Law, is called Eroom's Law and highlights a fundamental productivity problem in the biopharma industry, with costs approaching $1B+ per successful drug.

The process of testing drugs in humans—clinical development—is a massive, under-studied bottleneck, accounting for 70% of drug development costs. Despite its importance, there is surprisingly little public knowledge, academic research, or even basic documentation on how to improve this crucial stage.

The FDA now allows a single, well-designed pivotal trial instead of the traditional two. This reform significantly cuts costs by $100M-$300M and shortens development timelines, enabling companies to test twice as many potential drugs with the same capital.