AdvaMed Comments on Electronic Submission Guide
AdvaMed says it appreciates FDA efforts to develop a draft guidance to help support a process for electronic submissions with a De Novo electronic template. The association’s comment letter raises these concerns for the agency to consider as it develops a final guidance:
- ensure the De Novo eSTAR guidance includes sufficient information to understand the technical standards of the electronic submission template;
- provide flexibility in the De Novo eSTAR template to accommodate large files and diverse content;
- provide a mechanism for feedback on changes to the eSTAR template; and
- allow waivers and exemptions under appropriate circumstances.