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Components of a REMS program that impose access restrictions, such as prescriber/pharmacy certification, patient registries, or dispensing requirements.
ETASU for a teratogenic drug requires: pregnancy testing before each prescription, prescriber enrollment, pharmacy certification, and mandatory patient registry enrollment.
FDA REMS Guidance
Implementing ETASU without adequate infrastructure to track compliance and assess effectiveness.
How do you monitor ETASU compliance? What metrics do you track?