CDRH, Industry Mull Improvements to Pre-Submission Process
CDRH and the medical device industry are exploring the addition of more resources and performance goals under the next Medical Device User Fee Program to improve the Center’s Pre-Submission (Pre-Sub) process. In just-released user fee negotiation meeting minutes, FDA explained that the Pre-Sub consultation process is currently implemented as resources permit, without any specific user fee performance goals attached to the process. As negotiations continue to finalize the next user fee program, FDA and industry continue to work on identifying a mix of resources and performance commitments that will “achieve meaningful and feasible improvements to the process.”
An industry counter proposal on enhancing the user fee program included resources for establishing a Quality Management system at a funding level that FDA estimated was needed,” according to the minutes. “Industry’s counter proposal regarding establishing a more integrated review process for ODE [Office of Device Evaluation] was below the level of resources that FDA estimated would be needed to make the transition. Industry’s counter proposal for the De Novo process also fell short of the resources FDA had estimated are needed to achieve the goals proposed. Likewise, the level of resources industry proposed for improving the CLIA waiver review process was below the amount FDA had estimated is necessary to achieve the performance goals that industry proposed. Additionally, FDA noted that the CLIA waiver program proposals will need a legal review before moving forward. Industry’s counter proposal also included another independent assessment similar to the one conducted during MDUFA III.”
Meeting minutes from a 5/15 negotiation noted that FDA’s latest user fee funding proposal included a base of $680 million plus inflation to maintain the performance goals that will be in place in the final year of MDUFA III. FDA proposed two options with different levels of performance targets and associated resource needs. “The low option included an additional $291 million spread out over five years to support an additional 186 FTEs by the end of MDUFA IV,” the agency said. “The high option included an additional $321.7million spread out over five years to support an additional 215 FTEs by the end of MDUFA IV.” FDA noted that the components of the two options could be reorganized into a hybrid counterproposal, and that all proposed performance goals assume agreement on a fee setting algorithm with inflation and volume adjusters.