Over the past year, the U.S. Food & Drug Administration (FDA) has broken with its historical practices. A recent spike in denials of new drug applications by the FDA has prompted pharmaceutical companies and patients to ask difficult questions. The operational inconsistencies have many biopharma leaders and rare disease advocates asking what it means for them and the patients they serve.
In the eight months leading up to March 2026, the FDA denied or discouraged the applications of approximately 20 new drugs. At least eight of these potential therapies targeted rare diseases, including gene therapies for Huntington’s Disease and Hunter Syndrome, as well as a new treatment for a rare blood condition. In many cases, companies were aligned with the FDA on methodology early, only to receive conflicting feedback from the regulatory authority.
Perhaps most surprising was the agency’s initial refusal to review a flu vaccine application by Moderna, followed shortly thereafter by a swift reversal of that decision. Moderna’s share price moved sharply after the FDA first refused, then agreed, to review its flu vaccine filing-illustrating how quickly regulatory decisions can become market-moving news.
In another case, uniQure has experienced significant share price volatility following the FDA’s unusual public criticism of its clinical data and development program in Huntington’s disease. The agency indicated it would not approve the therapy based solely on comparisons to natural-history data, a position the company described as a “key shift” from feedback it had previously received before changes in FDA leadership.
In yet another example, Biohaven received a Complete Response Letter (CRL) for troriluzole in adults with the neurodegenerative disease spinocerebellar ataxia (SCA) following a three-month delay and a cancelled advisory committee meeting. Despite clinical data suggesting the drug slowed disease progression by as much as 70 percent compared with untreated external controls, the FDA cited potential bias in the real-world evidence. As a result, Biohaven was forced to cut its R&D spending by more than half.
In fairness, despite new twists and turns, the rare disease community has achieved some regulatory wins. The FDA this week approved leucovorin to treat patients with FOLR1-related cerebral folate deficiency, a genetic condition estimated to affect only about one in one million people. Although it’s a generic drug previously indicated for this, the FDA approved it based on a systematic review of the available literature and natural history data. If you have read this far, you know that is exactly what they told uniQure they could not do. Again, unclear guidance in practice creates confusion in the marketplace.
Nevertheless, the recent pattern of surprise refusals and reversals has altered expectations around trial controls and endpoints, making CEOs and investors less confident that prior FDA feedback will reliably predict regulatory outcomes. This matters even more in rare diseases, where development programs often depend on small datasets, external controls, surrogate endpoints, and a narrow financing window.
So, What Pray Tell is a Biopharma Brand Manager to Do?
The larger issue is that rare-disease companies can adapt to strict but predictable regulatory standards more easily than they can navigate shifting expectations. In 2026, uncertainty is becoming the real commercial risk, but there are ways to adapt. For the brand managers working to bring therapies to market, sustained regulatory volatility would represent a significant shift. The uncertainty makes long-term planning more difficult, including how companies position new treatments ahead of potential approval.
So, what’s the cure? Here are a few things biopharma brand managers should keep in mind:
- Expectation Management is Everything: Marketers should expect a growing need to overcommunicate and manage expectations within patient communities and to repair trust as skepticism emerges. FDA leaders have publicly emphasized their intention to maintain flexibility for rare diseases, and the agency recently issued draft guidance for ultra-rare, individualized therapies that contemplate approvals when randomized trials are not feasible. Yet recent enforcement actions and rejection decisions have created a perceived gap between policy rhetoric and regulatory practice. That gap is creating skepticism among patients, advocates, and investors-skepticism that companies must navigate carefully and transparently.
- Build Launch Plans Based on Integrated Communications: Life science and biopharma leaders need tighter alignment between marketing, investor relations, and corporate communications. In this environment, every regulatory interaction can influence valuation, partnership interests, and patient expectations. Communications teams are therefore becoming less like launch amplifiers and more like risk managers.
- Your Disease-State Campaign is Your Most Important Commercial Asset: In a world of regulatory uncertainty, unbranded disease education isn’t just medical affairs compliance filler; it’s your insurance policy. If the product gets delayed, you still own the conversation. If it gets approved, you’ve already built the demand. Brand managers who treat unbranded work as secondary are playing a losing game in 2026.
- Build Relationships with Advocates as Partners, not as Audiences: Patient advocacy groups are no longer just stakeholders you “engage.” They’re testifying before Congress, shaping FDA policy debates, and influencing investor sentiment. Treat them like strategic partners. Stop just briefing advocates. Start co-developing with them. Invite advocacy leaders into your commercial planning process early.
- Run a Regulatory “Worst Case” Scenario Planning Exercise: Most pharma companies have a launch plan for approval and a vague “contingency” for delay. Almost none have planned specific failure scenarios in a way that prepares every function to respond in real time. Build a cross-functional task force that proactively maps out what your brand says, where your stock price goes, what your KOL network does, and what your patient community hears. Do this quarterly. Most pharma companies have never done it once.
Changes Underway Inside FDA Could Bring Clarity
Uncertainty is not limited to the clinical programs under review. Since May 2025, Vinay Prasad has led the FDA’s Center for Biologics Evaluation and Research (CBER), which oversees vaccines and gene therapies. His tenure has been unusually turbulent. Prasad was dismissed in July 2025, only to be rehired a few weeks later. This month, he announced plans to step down and is expected to leave the agency in April.
Prasad’s time helming CBER has been marked by unpredictability and is widely viewed as a sharp departure from the more predictable regulatory approach to rare diseases under his predecessor, Peter Marks. Several companies have reportedly encountered evolving regulatory expectations during development discussions with the agency.
Time will tell if Prasad’s replacement brings more predictability from the regulatory authority. However, one thing is certain: those living with rare diseases and those developing treatments for them deserve a more predictable future.
