| Course | HCR 553 Quality Assurance and Clinical Research |
|---|---|
| Module | Module 5 |
| Paper type | Regulatory case paper |
| Length | About 665 words, 5 pages |
| Format | APA 7 student paper |
| School | Arizona State University |
| Program | MS in Clinical Research Management |
| Updated | October 2026 |
Free sample paper for HCR 553 Module 5
Approved on a Promise: The Rise and Withdrawal of Makena and What It Teaches About Quality in Accelerated Approval
Student Name
MS in Clinical Research Management, Arizona State University
HCR 553: Quality Assurance and Clinical Research
Instructor Name
Month Day, Year
Approved on a Promise: The Rise and Withdrawal of Makena and What It Teaches About Quality in Accelerated Approval
Introduction
Few drugs are withdrawn for doing too little rather than too much harm, but Makena is one. It was the only FDA-approved drug to reduce the risk of preterm birth in women with a previous spontaneous preterm birth, and for a decade it was widely used. Its withdrawal in 2023 followed a failed confirmatory trial and a long regulatory process, and it shows how quality questions about evidence can take years to resolve.
The Product and Its Approval
Makena is a weekly intramuscular injection of hydroxyprogesterone caproate, a synthetic progestin. The FDA approved it in 2011 under the accelerated approval pathway, which allows approval based on a surrogate or intermediate endpoint reasonably likely to predict clinical benefit, on condition that a confirmatory trial follows. The evidence came largely from one trial run by a federally funded maternal-fetal medicine network: among 463 women with a prior spontaneous preterm birth, weekly injections reduced delivery before 37 weeks from 54.9% with placebo to 36.3% (Meis et al., 2003). The approval used delivery before 37 weeks as the endpoint likely to predict reductions in infant illness and death.
The Confirmatory Trial
The required confirmatory trial, PROLONG, randomized 1,708 women at 93 centers, 41 in the United States and 52 elsewhere, in a 2:1 ratio to the drug or placebo. It found no difference in preterm birth before 35 weeks, 11.0% with the drug against 11.5% with placebo, and no difference in a composite of serious newborn complications (Blackwell et al., 2020).
Why the Trials Disagreed
The populations differed sharply. The original trial enrolled women at very high risk in the United States, where more than half of the placebo group delivered before 37 weeks. PROLONG enrolled mostly women outside the United States with much lower baseline risk, so the trial may have had little room to show a benefit even if one existed in the highest-risk group. Supporters argued that the confirmatory trial did not test the population the drug was approved for; the FDA concluded that the original single trial was itself not strong enough to stand alone once a larger trial failed.
| Feature | Original trial, published 2003 | PROLONG trial, published 2020 |
|---|---|---|
| Participants | 463 | 1,708 |
| Setting | U.S. network centers | 93 centers, most outside the U.S. |
| Placebo group preterm rate | 54.9% before 37 weeks | 11.5% before 35 weeks |
| Population | High-risk U.S. women with a prior spontaneous preterm birth | Lower risk; most enrolled outside the U.S., 87% white |
| Result | Benefit | No benefit |
The Withdrawal
In 2020 the FDA's drug center proposed withdrawing approval. The manufacturer requested a hearing, which took place in 2022, and in April 2023 the Commissioner and the agency's Chief Scientist announced a final decision withdrawing approval of Makena and its generics (U.S. Food and Drug Administration, 2023). The process took years because, under the law at the time, withdrawal of an accelerated approval required a lengthy formal hearing. The Food and Drug Omnibus Reform Act of 2022 later gave the FDA faster procedures and the power to require confirmatory trials to be under way before approval.
Quality Lessons
1. A single trial is fragile evidence. Approval based on one study, however well run, leaves regulators exposed if a second study disagrees.
2. Confirmatory trials must be timely. PROLONG reported almost a decade after approval, during which the drug became standard care.
3. The confirmatory population must match the approved population. Enrolling mostly lower-risk women outside the United States made the result hard to apply to the patients who used the drug most.
4. Withdrawal must be possible without years of delay, so that patients do not receive drugs whose benefit is unproven.
Conclusion
Makena's withdrawal was not a safety recall but a judgment that the evidence of benefit had not held up. Its history shows that quality in drug regulation depends as much on the design and timing of confirmatory evidence as on the original approval.
References
Blackwell, S. C., Gyamfi-Bannerman, C., Biggio, J. R., Jr., Chauhan, S. P., Hughes, B. L., Louis, J. M., Manuck, T. A., Miller, H. S., Das, A. F., Saade, G. R., Nielsen, P., Baker, J., Yuzko, O. M., Reznichenko, G. I., Reznichenko, N. Y., Pekarev, O., Tatarova, N., Gudeman, J., Birch, R., . . . Krop, J. (2020). 17-OHPC to prevent recurrent preterm birth in singleton gestations (PROLONG study): A multicenter, international, randomized double-blind trial. American Journal of Perinatology, 37(2), 127-136. https://doi.org/10.1055/s-0039-3400227
Meis, P. J., Klebanoff, M., Thom, E., Dombrowski, M. P., Sibai, B., Moawad, A. H., Spong, C. Y., Hauth, J. C., Miodovnik, M., Varner, M. W., Leveno, K. J., Caritis, S. N., Iams, J. D., Wapner, R. J., Conway, D., O'Sullivan, M. J., Carpenter, M., Mercer, B., Ramin, S. M., . . . Gabbe, S. G. (2003). Prevention of recurrent preterm delivery by 17 alpha-hydroxyprogesterone caproate. New England Journal of Medicine, 348(24), 2379-2385. https://doi.org/10.1056/NEJMoa035140
U.S. Food and Drug Administration. (2023, April 6). FDA commissioner and chief scientist announce decision to withdraw approval of Makena [Press release]. https://www.fda.gov/news-events/press-announcements/fda-commissioner-and-chief-scientist-announce-decision-withdraw-approval-makena
What the HCR 553 Module 5 instructions ask for
Major Assignment 2 spans Weeks 5 and 6 of HCR 553. Part A, worth 100 points, asks you to identify and discuss a product that has been pulled from the market by the FDA, following the full rubric posted in Canvas; Part B, worth 50, is a critique of your assigned partner's Part A. Because the course is about quality, the strongest choices are products whose withdrawal reveals something about how evidence, manufacturing or monitoring can fail. A product withdrawn for lack of confirmed benefit, for a safety signal or for manufacturing contamination each teaches a different quality lesson. Plan to explain the product and its approval, the evidence or event that led to its removal, the regulatory process the FDA followed and the lessons for quality in clinical research, using the FDA's own documents and the published studies behind the decision. APA style is the default.
Inside the HCR 553 Module 5 example
The sample opens by explaining why Makena is an unusual withdrawal. It describes the product and the accelerated approval pathway, then reports the original trial's numbers. The confirmatory trial's design and null result follow. A table compares the original and confirmatory trials feature by feature, and a section explains how their different populations produced different answers, presenting both the manufacturer's and the agency's view. The withdrawal section traces the regulatory process from proposal to hearing to final decision and notes the 2022 law that changed it. Four numbered quality lessons turn the case into guidance, and the conclusion distinguishes this withdrawal from a safety recall. The sources are the two published trials and the FDA's own announcement, so every number in the paper can be checked by a partner during Part B.
Where the marks sit in the HCR 553 Module 5 rubric
Canvas scores Part A out of 100. A strong paper chooses a product the FDA genuinely removed, describes its approval and the evidence or event behind its removal accurately, explains the regulatory process the FDA followed, connects the case to quality in clinical research and draws specific lessons. It loses points when the product was only recalled in a few lots rather than pulled, when facts come from news stories instead of FDA documents and published studies, when the regulatory process is skipped and when lessons are generic. Because Part B is a peer critique, Part A should be clear enough for a classmate to evaluate, with sources a partner can check.
HCR 553 Module 5 help with common mistakes
Choose a product whose removal you can document from FDA sources, such as a press release, a withdrawal notice or a hearing record. Find the trial or report that led to the action and read it. Explain the approval pathway, since accelerated approval cases raise different questions from safety withdrawals. Use a table to compare evidence before and after. Draw three or four quality lessons. Write clearly enough for your partner's critique. If you are deciding between products, the desk can suggest ones with well-documented histories. Remember that a classmate will critique your paper in Part B, so cite pages and figures precisely enough that your partner can verify them in a few minutes.
Write yours, or have the desk draft it
This paper is an original model document written by our desk, not a submitted student paper and not an official Arizona State University document. Read it for the moves, then write your own to the instructions in your classroom. If you want one built to your exact prompt and rubric, the first custom sample is free and arrives in 24 to 48 hours.
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HCR 553 Module 5 questions, answered
Where can I find a free HCR 553 Module 5 sample paper?
This page reproduces a full Part A paper on Makena, the preterm birth drug the FDA withdrew in 2023.
Why did the FDA withdraw Makena?
Its confirmatory trial found no reduction in preterm birth or newborn complications, so its accelerated approval was not confirmed.
What is accelerated approval?
Approval based on a surrogate or intermediate endpoint likely to predict benefit, with a required confirmatory trial afterward.
What changed after the Makena case?
The Food and Drug Omnibus Reform Act of 2022 gave the FDA faster withdrawal procedures and power to require confirmatory trials earlier.
What is Part B of HCR 553 Major Assignment 2?
A 50-point critique of a partner's Part A paper.