Concerns Raised with FDA Priority Submissions Guidance
The Association for Accessible Medicines (AAM) says that a draft FDA guidance on “Abbreviated New Drug Applications: Pre-Submission Facility Correspondence Associated with Priority Submissions,” represents a fundamental departure from the GDUFA 2 comment letter and may unintentionally discourage ANDA sponsors from submitting a priority review request. In its comment letter, AAM says that as written, the draft “is not in the best interest of the public health and defeats the mission and goal of the new commissioner to increase access to affordable generic medicines in a timelier manner.”
The letter says that ANDA sponsors will forego submission of priority review requests due to the fact that FDA has placed a huge hurdle in front of industry with the requirement in the guidance that facility information (pre-submission facility correspondence or PFC) be submitted in advance of the actual ANDA. “The sole purpose of the PFC was to provide advance notice, enabling FDA to better anticipate and coordinate its resources to meet the GDUFA 2 commitment for priority review,” the letter says.
AAM also submits line-by-line comments, as do Apotex and Perrigo.