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AdvaMed says it appreciates FDA efforts to develop a draft guidance to help support a process for electronic submissions with a De Novo electronic template.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.

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