FDA Revamping NDA/BLA Information Requests
FDA is seeking public comments on a “Statement of Work” mandated by the recent drug user fee reauthorization to assess communication between the agency and sponsors through product quality information requests (IR) during NDA/BLA reviews, and to identify best practices and areas of improvement. The independent assessment will also examine the agency’s compliance with the application of “Four-Part Harmony” in product quality IRs, in which reviewers are expected to communicate:
- what was provided;
- the issue or deficiency;
- what is needed; and
- why it is needed.
The goals of the assessment are articulated in a document entitled Prescription Drug User Fee Act Reauthorization Performance Goals and Procedures Fiscal Years 2023 through 2027 (“PDUFA VII”) (page 48). For example, by the end of FY 2023, FDA says it will update and conduct training on CDER MAPP 5016.8, “Communication Guidelines for Quality-Related Information Request and Deficiencies” and CBER SOPP 8401.1, “Issuance of and Review of Responses to Information Request Communications to Pending Applications” describing the guidelines for the content of information requests. The updates and training are intended to promote FDA reviewers’ use of Four-Part Harmony, the performance goals document says.