FDA Piloting New Combination Product Consult Process

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FDA officials say the agency will begin piloting a new inter-Center consult request (ICCR) procedure for proposed combination products. In a new agency blog post, they say that “close inter-Center collaboration and communication are important to facilitate timely, appropriately-tailored and well-informed submission review. A combination product will generally have a lead Center which may seek consults from the other Centers that oversee one of the product’s constituent parts. Timely and consistent consults are critical, yet achieving this has been challenging due to different policies, practices, and timelines for consults across Centers and insufficient communications between Centers and sponsors.” Under the pilot, the following four new process improvements will be evaluated:

  • Establishing timelines, specific to Center and submission type, for identifying products as combination products and issuing and completing consults needed to support the review;
  • Developing a tiered consult approach that streamlines interactions across Centers and identifies a clear process for identifying the right experts for a consult;
  • Defining clear roles and responsibilities for the lead Center, the consulted Center(s), the Office of Combination Products, and the Combination Product Council for reviewing a combination product submission; and,
  • Creating a standard, semi-automated, user-friendly ICCR form that is managed electronically to ensure users always have the most updated version and all forms and consults are tracked through a single system.

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