REMS (Risk Evaluation and Mitigation Strategy)

A Risk Evaluation and Mitigation Strategy (REMS) is an FDA-required drug safety program for certain medications with serious safety concerns, designed to ensure that the benefits of the drug outweigh its risks through specific requirements such as medication guides, communication plans, and restricted dispensing programs.

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Exam Tip

REMS = FDA safety program for high-risk drugs. Know iPLEDGE (isotretinoin) and Clozapine REMS as examples. ETASU = most restrictive component (restricted distribution, certified prescribers/pharmacies). Technicians verify enrollment before dispensing.

What Is REMS?

A Risk Evaluation and Mitigation Strategy (REMS) is a program required by the FDA under the FDA Amendments Act of 2007 (FDAAA) for medications that pose significant safety risks. REMS programs impose additional requirements beyond standard labeling to ensure that a drug's benefits outweigh its risks during post-market use.

REMS Components

ComponentDescriptionExample
Medication GuidePatient-friendly safety information distributed at dispensingAntidepressant Black Box Warning guides
Communication PlanLetters/materials sent to healthcare providersSafety alerts for prescribers
Elements to Assure Safe Use (ETASU)Restricted distribution, special certification, monitoringiPLEDGE (isotretinoin), TIRF REMS (fentanyl)
Implementation SystemInfrastructure to support ETASU requirementsRegistries, databases, certified pharmacies

Notable REMS Programs

DrugREMS ProgramKey Requirements
Isotretinoin (Accutane)iPLEDGEPregnancy testing, registered prescribers/pharmacies, patient agreements
ClozapineClozapine REMSRegular blood monitoring (ANC), certified prescribers/pharmacies
TIRF opioids (fentanyl)TIRF REMS AccessEnrolled prescribers, certified pharmacies, patient agreements
MifepristoneMifepristone REMSCertified prescribers, specific dispensing requirements
TestosteroneClass-wide REMSMedication guide for patients

ETASU Requirements May Include

  • Prescribers must be specially certified or trained
  • Pharmacies must be certified to dispense the drug
  • Drug dispensed only in certain healthcare settings
  • Patient must undergo specific lab testing before receiving drug
  • Patient must be enrolled in a registry
  • Patient must sign a patient agreement form

Pharmacy Technician's Role in REMS

  • Verify the patient is enrolled in the REMS program before dispensing
  • Confirm prescriber is certified for the REMS drug
  • Ensure required lab results are current and documented
  • Distribute Medication Guides when required
  • Flag any REMS compliance issues for the pharmacist

Exam Alert

REMS falls under the Patient Safety and Quality Assurance domain on the PTCE. Know the key REMS components (Medication Guide, Communication Plan, ETASU), examples like iPLEDGE and Clozapine REMS, and the pharmacy technician's role in verifying REMS compliance before dispensing.

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