The convergence of three independent ibogaine cardiac papers in a single 48-hour window — covering QT prolongation, ventricular arrhythmia risk, and unrecognized OUD comorbidity — constitutes precisely the kind of clustered safety signal that triggers FDA Risk Evaluation and Mitigation Strategy (REMS) requirements. Historical precedent is instructive: the FDA's 2019 REMS for esketamine (Spravato) mandated in-clinic administration and post-dose monitoring for 2 hours, adding ~$300-500 per patient session in facility overhead. Ibogaine's cardiac liability is substantially more acute than esketamine's dissociation risk — QT prolongation and arrhythmia require continuous ECG monitoring, cardiologist sign-off protocols, and crash-cart readiness that most addiction treatment facilities cannot absorb. The 5-to-2 agent consensus here is significant. The two dissenters (veterans_advocate and maps