Analysis of FDA's Information Sharing Regulation (Waiting AE recommendation)
By Parshuram Hotkar, Diwakar Gupta
Manufacturing & Service Operations Management (MSOM)
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Hotkar, Parshuram., Gupta, Diwakar. Analysis of FDA's Information Sharing Regulation (Waiting AE recommendation) Manufacturing & Service Operations Management (MSOM) .
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Manufacturing & Service Operations Management (MSOM)
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Abstract
In the US, there are frequent shortages of sterile injectable drugs. Firms often do not maintain either backup capacity or sufficient inventories to mitigate supply disruptions. To address this, the Food and Drug Administration (FDA) implemented the Safety and Innovation Act (FDASIA), requiring manufacturers to share disruption information. FDA makes this information public, hoping that other firms will be incentivized to cover the shortfall. However, the impact of FDASIA on drug supply, both short and long-term, remains largely unexplored. This manuscript uses equilibrium analysis to study FDASIA's effects.

Methodology/results: We model a market with two firms selling partially substitutable drugs. Firm makes two production decisions. Early production occurs before knowing the rival's disruption status. Under FDASIA, late production occurs after knowing such information. Pre-FDASIA, late production is based on probabilistic information about the rival's disruption status. We find that firms benefit from information sharing and increase their investments in capacity. However, they may reduce production post-FDASIA, especially when disruptions are frequent. Consequently, information sharing substitutes proactive production. Furthermore, we find that when capacity cost is not high, firms may substitute reliability with inexpensive capacity, leading to shorter yet more frequent shortages.

Managerial implications: Our analysis informs pharmaceutical firms’ managers and regulatory agencies how edicts such as FDASIA could impact them and the market. Policies such as FDASIA benefit firms by reducing competition, but they might not necessarily increase supply. Although sharing information can mitigate intense shortages, direct incentives to enhance reliability are essential to prevent frequent shortages.

Parshuram Hotkar is an Assistant Professor of Operations Management at the Indian School of Business (ISB). His research examines strategic interactions within supply chains, with applications ranging from omnichannel retail to healthcare. In recent years, his work has increasingly focused on healthcare supply chains, addressing challenges such as drug shortages, quality, and access—issues with direct implications for public health and policy. By combining analytical modeling with practical insights, his research aims to contribute to both academic understanding and real-world solutions.

Professor Hotkar’s work has been recognized with best paper awards from leading academic bodies, including INFORMS and the Decision Sciences Institute (DSI). Beyond healthcare, he has collaborated with think tanks, government agencies, and industry partners to extend the societal impact of his research.

At ISB, he teaches courses on supply chain management, supply network design, strategic procurement, and operations management, with an emphasis on helping students break down complex, real-world challenges into simpler, actionable frameworks.

He earned his PhD and MS in Information, Risk, and Operations Management from the McCombs School of Business at the University of Texas at Austin. He also holds an MS in Operations Management and a dual degree (BTech and MTech) in Biotechnology from IIT Madras.

Parshuram Hotkar
Parshuram Hotkar