FDA Draft Guide on ANDA Facility Pre-submissions

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FDA has issued a draft guidance on ANDAs: Pre-Submission Facility Correspondence Associated with Priority Submissions. During user fee negotiations, the agency and industry agreed to pre-submission facility correspondence (PFC) to help obtain a shorter GDUFA goal date for priority ANDAs, their amendments, and prior approval supplements. The document encourages PFS submissions two to three months prior to the ANDA, supplement or amendment, saying they will “facilitate the FDA’s assessment of the facilities in the application, including whether an inspection is necessary.”


The guidance also outlines the information that should be submitted in a PFC. “In order to qualify for the shorter review goal date, the information submitted in the PFC must be complete and accurate; there must be no changes with respect to facility information when the applicant submits the associated ANDA, [supplement], or amendment; and the application when submitted must meet the FDA’s criteria for expedited review under the Center for Drug Evaluation and Research’s Manual of Policy and Procedure 5240.3, Prioritization of the Review of Original ANDAs, Amendments, and Supplements,” it says. “As defined in the Commitment Letter, a change with respect to facility information is a change to information in the PFC that causes the FDA to re-evaluate its facility assessment.”

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