FDA Publishes Drug Filing Checklists to Avoid Delays

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To increase transparency and reduce the prevalence of drug regulatory filing deficiencies, FDA has made public the filing checklists CDER uses to determine if a submitted application is complete and reviewable. An agency statement notes that filing deficiencies consume resources and delay promising treatments.

“Drug applications should not be derailed or delayed by preventable procedural oversights,” says FDA commissioner Marty Makary in the statement. “Making these checklists public is a common-sense step to make the FDA process easier to understand and more transparent.”

The statement explains that when an NDA or BLA is submitted to CDER, there is an initial filing period during which staff from each review discipline use specific checklists to assess whether the application is complete and reviewable. While small deficiencies may be quickly remedied with the sponsor, it says, the agency will refuse to file (RTF) applications with more significant deficiencies, generally forcing the sponsors to resubmit a complete application. Moving forward, it says, sponsors will be able to see a checklist for each review discipline performing a filing review.

Over the last 10 years, FDA says, over 200 applications to CDER have resulted in an RTF notification. It reports that applications involving a new molecular entity that receive an RTF experience an average delay of 426 days before application resubmittal.

The statement cautions that the checklists are not necessarily comprehensive and only the agency can determine whether an application can be filed, following applicable legal and scientific standards.

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