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Approved Risk Evaluation and Mitigation Strategies (REMS)

Sodium Oxybate
Shared System REMS
REMS last update: 01/17/2024

What medicines are included in the REMS?

Product Name Application Number Application Holder Added to REMS DailyMed Link FDA Link
sodium oxybate ( Info at Drugs@FDA ) ANDA 202090 HIKMA 01/17/2017 http://www.accessdata.fda.gov/scripts/cder/daf/index.cfm?event=overview.process&varApplNo=202090

What is the purpose of the REMS?

The goal of the Sodium Oxybate REMS is to mitigate the risks of serious adverse outcomes resulting from inappropriate prescribing, misuse, abuse, and diversion of sodium oxybate by:
  1. Informing prescribers, pharmacists, and patients of:
    1. The risk of significant central nervous system (CNS) and respiratory depression associated with sodium oxybate
    2. The contraindication of use of sodium oxybate with sedative hypnotics and alcohol
    3. The potential for abuse, misuse, and overdose associated with sodium oxybate
    4. The safe use, handling, and storage of sodium oxybate
  2. Ensuring that pharmacy controls exist prior to filling prescriptions for sodium oxybate that:
    1. Screen for concomitant use of sedative hypnotics and other potentially interacting agents
    2. Monitor for inappropriate prescribing, misuse, abuse, and diversion of sodium oxybate
    3. Notify prescribers when patients are receiving concomitant contraindicated medications or there are signs of potential abuse, misuse, or diversion

What do participants need to know?

Below is a general overview of the REMS for all REMS participants (e.g., patients, pharmacies, and healthcare providers).

Healthcare providers who prescribe sodium oxybate must:

To become certified to prescribe
  • Review the drug’s Prescribing Information.
  • Review the following: Prescriber Brochure. | Prescriber Brochure |
  • Enroll in the REMS by completing the Prescriber Enrollment Form and submitting it to the REMS. | Prescriber Enrollment Form |
Before treatment initiation (first dose)
  • Assess the patient’s health status to determine if sodium oxybate is medically appropriate by screening for history of alcohol or substance abuse, sleep-related breathing disorders, compromised respiratory function, and depression or suicidality. Document and submit to a certified pharmacy using the Prescription Form. | Prescription Form |
  • Assess the patient’s health status to determine if sodium oxybate is medically appropriate by screening for concomitant use of sedative hypnotics, other CNS depressants, or other potentially interacting agents. Document and submit to a certified pharmacy using the Prescription Form. | Prescription Form |
  • Counsel the patient on the serious risks and safe use, handling, and storage of sodium oxybate using the Patient Quick Start Guide. | Patient Quick Start Guide |
  • Enroll the patient by completing and submitting the Patient Enrollment Form to the REMS. | Patient Enrollment Form |
  • Order the prescription using the Prescription Form and submit it to | Prescription Form |
Before treatment re-initiation
  • For patients disenrolled for suspicion of abuse, misuse, or diversion: communicate with the pharmacy regarding all relevant patient history and re-enroll the patient if the prescriber and pharmacist agree.
  • For patients with a lapse in treatment of 6 months or longer: order the prescription using the Prescription Form and submit it to a certified pharmacy. | Prescription Form |
During treatment; within the first 3 months of starting treatment and recommended every 3 months thereafter
  • Assess the patient for: concomitant use of sedative hypnotics, other CNS depressants, or potentially interacting agents; serious adverse events; and signs of abuse and misuse including an increase in dose or frequency of dosing, reports of lost, stolen, or spilled medication, and drug-seeking behavior.
At all times
  • Report all potential serious adverse events, including CNS depression, respiratory depression, loss of consciousness, coma, and death; and any cases of suspected abuse, misuse, or diversion to the REMS.
  • Assess the patient’s potential for abuse, misuse, and diversion. Document and submit all instances of behavior that give rise to a reasonable suspicion of abuse, misuse, or diversion, including all requests for early refills, and all reports of lost, stolen, destroyed, or spilled drug using the Risk Management Report. | Risk Management Report |
  • Report requests to disenroll a patient for suspected abuse, misuse, or diversion to the REMS using the Risk Management Report. | Risk Management Report |

Patients who are prescribed sodium oxybate:

Before treatment initiation
  • Review the Patient Quick Start Guide. | Patient Quick Start Guide |
  • Receive counseling from the prescriber on the serious risks associated with sodium oxybate and safe use, handling, and storage of sodium oxybate using the Patient Quick Start Guide. | Patient Quick Start Guide |
  • Enroll in the REMS by completing the Patient Enrollment Form with the prescriber. Enrollment information will be provided to the REMS. | Patient Enrollment Form |
  • Complete the Patient Counseling Checklist with the pharmacist. | Patient Counseling Checklist |
During treatment
During treatment; within the first 3 months of starting treatment and recommended every 3 months thereafter
  • Be monitored by your prescriber for concomitant use of sedative hypnotics, other CNS depressants, or potentially interacting agents; serious adverse events; signs of abuse and misuse including an increase in dose or frequency of dosing; reports of lost, stolen, or spilled medication; and drug-seeking behavior.
Before treatment reinitiation, after lapse in treatment for 6 months or longer
At all times
  • Inform your prescriber and the pharmacy about any new medications you may be taking or medical conditions you may have.

Pharmacies that dispense sodium oxybate must:

To become certified to dispense
  • Designate an Authorized Representative to carry out the certification process and oversee implementation and compliance with the REMS on behalf of the pharmacy.
  • Have the Authorized Representative review Certified Pharmacy Training Module A and Certified Pharmacy Training Module B. | Certified Pharmacy Training |
  • Have the Authorized Representative successfully complete the Module A Knowledge Assessment and Module B Knowledge Assessment and submit both to the REMS. | Module B Knowledge Assessment | | Module A Knowledge Assessment |
  • Have the Authorized Representative enroll in the REMS by completing and submitting the Pharmacy Enrollment Form. | Pharmacy Enrollment Form |
  • Train all relevant staff involved in dispensing using the Certified Pharmacy Training Module A. | Certified Pharmacy Training |
  • Have all relevant staff involved in dispensing, successfully complete the Module A Knowledge Assessment and submit it to the REMS. | Module A Knowledge Assessment |
  • Train all pharmacists involved in dispensing using the Certified Pharmacy Training Module A and Certified Pharmacy Training Module B. | Certified Pharmacy Training |
  • Have all pharmacists involved in dispensing: successfully complete the Module A Knowledge Assessment and Module B Knowledge Assessment and submit both to the REMS. | Module B Knowledge Assessment | | Module A Knowledge Assessment |
  • Establish processes and procedures to assess the patient’s concomitant use of sedative hypnotics, other CNS depressants, or other potentially interacting agents that are either unknown to the prescriber or pose a high risk of serious interaction.
  • Establish processes and procedures to verify the following: the patient and prescriber are enrolled, the patient has no other active sodium oxybate prescriptions
  • Establish processes and procedures to verify and document the following by contacting all other REMS for oxybate products: the patient has no other active prescriptions that overlap with the current prescription for sodium oxybate by obtaining oxybate prescription information of last dispense date, days’ supply, and prescriber’s name; and the patient and prescriber have not been disenrolled from any of the REMS for oxybate products for suspected abuse, misuse, or diversion.
  • Establish processes and procedures to verify all prescription information including patient name and two additional identifiers, prescriber name and information, dose, titration information (if applicable), number of refills, dosing directions, total quantity (days’ supply), and concomitant medications.
  • Establish processes and procedures to assess the patient’s potential for abuse, misuse, and diversion by reviewing the alerts and Risk Management Report histories in the REMS. | Risk Management Report |
  • Establish processes and procedures to provide 24-7 toll-free access to a Sodium Oxybate REMS trained pharmacist; to dispense no more than a one-month supply for the initial shipment and no more than a three-month supply for subsequent shipments; and to ship, track, and verify receipt of sodium oxybate to the patient or patient-authorized adult designee using an overnight service.
  • Establish processes and procedures to report each prescription filled for sodium oxybate to all other REMS for oxybate products and document to the REMS.
  • Establish processes and procedures to reconcile sodium oxybate inventory using the pharmacy’s inventory management system.
  • Establish processes and procedures to provide dispensing data and shipment and receipt dates to the REMS.
Before dispensing
  • For new patients and existing patients who restart sodium oxybate treatment after not receiving product for 6 months or longer: Counsel the patient using the Patient Counseling Checklist. Document and submit to the REMS. | Patient Counseling Checklist |
  • For patients who report a change in their medication use or medical history: Document the change and submit to the REMS using the Patient Counseling Checklist. | Patient Counseling Checklist |
  • Assess the patient’s concomitant use of sedative hypnotics, other CNS depressants, or potentially interacting agents that either are unknown to the prescriber or pose a high risk of serious interaction through the processes and procedures established as a requirement of the REMS.
  • Verify in this REMS that the patient has no other active sodium oxybate prescriptions that overlap with the current prescription for sodium oxybate through the processes and procedures established as a requirement of the REMS. Document and submit to the REMS.
  • Verify the following by contacting all other REMS for oxybate products through the processes and procedures established as a requirement of the REMS: the patient has no other active prescriptions for oxybate products that overlap with the current prescription for sodium oxybate by obtaining oxybate prescription information of last dispense date, days’ supply, and prescriber’s name; and the patient and prescriber have not been disenrolled from any other REMS for oxybate products for suspected abuse, misuse, or diversion. Document and submit to the REMS.
  • Assess the patient’s and their prescriber’s potential for abuse, misuse, and diversion by reviewing the alerts and Risk Management Report history in the REMS. Document the confirmation to the REMS. | Risk Management Report |
  • Obtain authorization by contacting the REMS to verify the pharmacy is certified, the prescriber is certified, the patient is enrolled, the Patient Counseling Checklist is completed as required, the alerts and Risk Management Report history for the patient and their prescriber are reviewed by the pharmacist and the patient has no active, overlapping prescriptions for oxybate products. | Risk Management Report | | Patient Counseling Checklist |
  • For patients previously disenrolled for suspicion of abuse, misuse or diversion: communicate all relevant patient history to the prescriber and determine whether to re-enroll the patient if the prescriber and pharmacist agree.
  • Verify the patient’s prescription information, including patient name and two additional identifiers, prescriber name and information, dose, titration information (if applicable), number of refills, dosing directions, total quantity (days’ supply), and concomitant medications through the processes and procedures established as a requirement of the REMS.
  • For patients who request an early refill or if abuse, misuse, or diversion is suspected: Discuss the request or concern with the prescriber.
  • Dispense no more than a one-month (30-day) supply for the initial shipment.
  • Dispense no more than a three-month (90-day) supply for subsequent shipments.
After dispensing, within 1 business day
  • Report each prescription filled for sodium oxybate to all REMS for oxybate products through the processes and procedures established as a requirement of the REMS. Document and submit to the REMS.
Before shipping
  • Verify the patient’s shipping address and that the patient or patientauthorized adult designee will be available to receive the shipment through the processes and procedures established as a requirement of the REMS.
  • Ship sodium oxybate directly to each patient or a patient-authorized adult designee through the processes and procedures established as a requirement of the REMS.
  • Provide the patient with the Patient Quick Start Guide with the first shipment. | Patient Quick Start Guide |
After shipping
  • Track and verify receipt of each shipment of sodium oxybate through the processes and procedures established as a requirement of the REMS.
  • Document and submit the dispensing data, and shipment and receipt dates to the REMS.
To maintain certification to dispense
To maintain certification to dispense, every year
  • Train all relevant staff involved in dispensing sodium oxybate using the Certified Pharmacy Training Module A. | Certified Pharmacy Training |
  • Have all relevant staff involved in dispensing sodium oxybate, successfully complete the Module A Knowledge Assessment and submit it to the REMS. | Module A Knowledge Assessment |
  • Train all pharmacists involved in dispensing sodium oxybate using the Certified Pharmacy Training Module A and Certified Pharmacy Training Module B. | Certified Pharmacy Training |
  • Have all pharmacists involved in dispensing successfully complete the Module A Knowledge Assessment, and the Module B Knowledge Assessment and submit both knowledge assessments to the REMS. | Module B Knowledge Assessment | | Module A Knowledge Assessment |
At all times
  • Provide 24-7 toll-free access to a Sodium Oxybate REMS trained pharmacist.
  • Ship sodium oxybate directly to the patient or a patient-authorized adult designee using an overnight service.
  • Document and report all potential adverse events reported by all sources including any CNS depression, respiratory depression, loss of consciousness, coma, and death to the REMS.
  • Report lost, stolen, destroyed, or spilled drug to the REMS using the Risk Management Report. | Risk Management Report |
  • Monitor for all instances of patient and prescriber behavior that give rise to a reasonable suspicion of abuse, misuse, and diversion, including all requests for early refills, and all reports of lost, stolen, destroyed, or spilled drug. Report to the REMS using the Risk Management Report. | Risk Management Report |
  • Report requests to disenroll a patient for suspected abuse, misuse, or diversion to the REMS using the Risk Management Report. | Risk Management Report |
  • Not distribute, transfer, loan, or sell sodium oxybate.
  • Not stock sodium oxybate in retail pharmacies.
  • Maintain records of staff training and completion of knowledge assessments.
  • Maintain records of inventory reconciliation using the pharmacy’s inventory management system.
  • Maintain records of all processes and procedures including compliance with those processes and procedures.
  • Comply with audits carried out by the Sodium Oxybate Applicants or a third party acting on behalf of the Sodium Oxybate Applicants to ensure that all processes and procedures are in place and are being followed.

Wholesalers-Distributors that distribute sodium oxybate must:

To be able to distribute
  • Establish processes and procedures to ensure that the drug is distributed only to certified pharmacies.
  • Train all relevant staff involved in distributing sodium oxybate on the REMS requirements.
At all times
  • Distribute only to certified pharmacies.
  • Maintain records of all drug distributions.
  • Comply with audits carried out by the Sodium Oxybate Applicants or a third party acting on behalf of the Sodium Oxybate Applicants to ensure that all processes and procedures are in place and are being followed.

View additional drug-specific postmarket safety information from the FDA

What materials are included in the REMS?

The REMS includes a REMS Document. In addition, the REMS includes the following materials intended for patients and healthcare providers. For a specific Medication Guide of a product in the Sodium Oxybate REMS, see the DailyMed link on the Products tab.

Material Name Material Name Link
Certified Pharmacy Training (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Certified_Pharmacy_Training.pdf
Dear Healthcare Provider Letter (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Dear_Healthcare_Provider_Letter.pdf
Dear Professional Society Letter (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Dear_Professional_Society_Letter.pdf
Module A Knowledge Assessment (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Module_A_Knowledge_Assessment.pdf
Module B Knowledge Assessment (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Module_B_Knowledge_Assessment.pdf
Patient Counseling Checklist (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Patient_Counseling_Checklist.pdf
Patient Enrollment Form (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Patient_Enrollment_Form.pdf
Patient Quick Start Guide (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Patient_Quick_Start_Guide.pdf
Pharmacy Enrollment Form (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Pharmacy_Enrollment_Form.pdf
Prescriber Brochure (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Prescriber_Brochure.pdf
Prescriber Enrollment Form (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Prescriber_Enrollment_Form.pdf
Prescription Form (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Prescription_Form.pdf
REMS Document (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_REMS_Document.pdf
REMS Fact Sheet (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_REMS_Fact_Sheet.pdf
REMS Full (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_REMS_Full.pdf
REMS Website (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_REMS_Website.pdf
Risk Management Report (PDF) https://www.accessdata.fda.gov/drugsatfda_docs/rems/Sodium_Oxybate_2024_01_17_Risk_Management_Report.pdf

What assessment is available to the REMS?

Assessment Plan
REMS assessment plan unavailable for posting at this time.

What updates have been made to the REMS?

Date Summary of change
01/17/2024 Revised to make editorial changes.
12/08/2023 Modified to remove the Medication Guide as an element of the REMS, reflect a change in vendor, remove the use of electronic telecommunication to query multiple stakeholder databases, alignment of the Patient Quick Start Guide with the Instructions For Use of labeling, as well as other changes to all REMS materials to allow the REMS to be operational.

Also, all REMS materials were modified to reflect the following additions to the REMS requirements:

  1. Prescribers are required to assess the patient’s potential for abuse, misuse, and diversion and to document and submit all instances of behavior that give rise to a reasonable suspicion of abuse, misuse, or diversion
  2. Pharmacies are required to verify the following by contacting all other REMS for oxybate products through the processes and procedures established as a requirement of the REMS: the patient has no other active prescriptions for oxybate products that overlap with the current prescription for sodium oxybate and the patient and prescriber have not been disenrolled from any other REMS for oxybate products for suspected abuse, misuse, or diversion
  3. Pharmacies are required to report each prescription filled for sodium oxybate to all REMS for oxybate products
  4. Applicants are required to report patient and prescriber disenrollment in the Sodium Oxybate REMS due to suspected abuse, misuse, or diversion to all other REMS for oxybate products by phone
  5. Applicants are required to maintain a process to provide certain sodium oxybate prescription information to verify that the named patient has no other active, overlapping prescriptions for oxybate products and that the patient and prescriber have not been disenrolled from the Sodium Oxybate REMS for suspected abuse, misuse, or diversion
01/17/2017 Approval of the REMS.

Disclaimer: This webpage provides general information about REMS programs to various REMS participants (e.g., patients, pharmacies, and healthcare providers). The summary information provided herein is not comprehensive and may not include all of the information relevant to REMS participants. This webpage does not constitute a replacement, modification, or revision of the approved REMS document, including any appended REMS materials. Refer to the approved REMS document for complete information on the REMS requirements for each approved application.

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