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Chris Newmarker, featuring work by I. Glenn Cohen (Faculty Director)
Medical Design and Outsourcing
October 12, 2018

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From the article:

In another post on Aug. 16, 2017, on Health Affairs, Nathan G. Cortez, Nicolas Terry, and I. Glenn Cohen described the pre-cert program as “an experiment in medical product regulation” that lacks any statutory backing, even with passage of the 21st Century Cures Act, which FDA commissioner Scott Gottlieb has cited as an authorizing text. They seemed to be asking how the FDA will execute the plan without the legislative support of the 21st Century Cures Act, which doesn’t specifically call for the precertification program? (The authors note the plan “will likely be implemented through nonbinding guidance.”)

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health law policy   i. glenn cohen   regulation