# The Safety of Switching Between Complex Branded and Generic Drugs: Developing a Semi-Automated Sequential Surveillance System Using Tree-Based Scan Statistics

> **NIH FDA U01** · BRIGHAM AND WOMEN'S HOSPITAL · 2024 · $298,422

## Abstract

Drug-device combinations containing active pharmaceutical ingredients marketed together with their
delivery devices are among the costliest medications in the US. Generic competition is vital for lowering prices
in the US and improving access, but generic entry can be slow for drug-device combinations. The Food and
Drug Administration (FDA) applies a necessarily rigorous set of requirements before approving these products,
given the complex interactions between ingredients and devices and the need for proper self-administration.
Despite the many regulatory challenges required for evaluation of drug-device combinations, the FDA does not
actively surveil adverse effects after approval, relying instead on spontaneous reports by patients and
clinicians. These may be subject to reporting bias and often lack the granularity needed for regulators to
distinguish among specific generic and brand-name products. Therefore, the FDA is increasingly considering
real-world evidence (RWE) generated from large longitudinal healthcare database studies as a tool for
informing regulatory decisions. Routine use of RWE to monitor the safety and effectiveness of generic drug-
device combinations can help ensure the reliability of pharmaceuticals, instill confidence in patients and
prescribers, facilitate timely regulatory action, and promote the public health goals of access and affordability.
 The proposed research will develop a principled, scalable, and reproducible approach for rigorous and
timely evaluation of the safety and effectiveness of generic drug-device combinations compared to brand-name
reference products using healthcare databases. We will demonstrate this approach for generating multi-phase
actionable RWE in 2-3 use cases, including description of utilization patterns, evaluation of comparative
effects, and systematic screening for unsuspected safety issues. The work will build on state-of-the-art
methods in pharmacoepidemiology to conduct research in a transparent and reproducible fashion.
 We will first rigorously describe the uptake and clinical characteristics of patients using generic drug-
device combinations compared to those taking branded versions (Aim 1). We will then examine several
prespecified safety and effectiveness outcomes for selected products, adjusting for confounding using
traditional propensity score methods with investigator selected covariates and high-dimensional propensity
score approaches, which semi-automatically adjust for hundreds of covariates selected through machine-
learning algorithms (Aim 2). We will supplement these analyses with studies to detect unsuspected safety
signals using tree-based scan statistic methods, which simultaneously evaluate thousands of correlated safety
outcomes while formally controlling type 1 error (Aim 3). We will then refine our understanding of potential
safety signals in fully specified protocols with confounding adjustment tailored to specific outcomes (Aim 4).
The end result will be a r...

## Key facts

- **NIH application ID:** 11062850
- **Project number:** 1U01FD008316-01
- **Recipient organization:** BRIGHAM AND WOMEN'S HOSPITAL
- **Principal Investigator:** William Brand Feldman
- **Activity code:** U01 (R01, R21, SBIR, etc.)
- **Funding institute:** FDA
- **Fiscal year:** 2024
- **Award amount:** $298,422
- **Award type:** 1
- **Project period:** 2024-09-01 → 2027-08-31

## Primary source

NIH RePORTER: https://reporter.nih.gov/project-details/11062850

## Citation

> US National Institutes of Health, RePORTER application 11062850, The Safety of Switching Between Complex Branded and Generic Drugs: Developing a Semi-Automated Sequential Surveillance System Using Tree-Based Scan Statistics (1U01FD008316-01). Retrieved via AI Analytics 2026-05-23 from https://api.ai-analytics.org/grant/nih/11062850. Licensed CC0.

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