First Cycle Review Metrics Debated at PDUFA Session
Minutes from the 12/2/2025 meeting of the PDUFA Reauthorization FDA and Industry Premarket Subgroup show the two sides debated metrics on agency first-cycle review times and goals. At an earlier meeting, industry representatives had presented data supporting their Facilitate First Cycle Review proposals. Session minutes show that FDA indicated that it had successfully incorporated and implemented the program agreed to in the PDUFA 7 commitment letter, based on meeting and often exceeding the performance goals.
FDA also challenged the industry’s assertions that the first-cycle approval rate had decreased and the first-cycle complete response letter (CRL) rate had correspondingly increased.
FDA representatives said they do not agree with the industry’s overall proposal for Facilitate First Cycle Reviews because there are no data to support the assertion that the agency has not been meeting program objectives.
The industry representatives said the current CRL rate is not achieving the stated goal in PDUFA 7 of promoting the efficiency and effectiveness of the first cycle review process and minimizing the number of review cycles necessary for approval. They said the industry expects to see more efficiencies in the review process.
Ultimately, FDA asked for clarification on what problem industry was trying to solve, and industry responded that it is trying to address information requests late in the review cycle leading to delays, including CRLs. FDA agreed to review industry’s counterproposal on tracked metrics in further detail and respond at a future meeting.
The sides also discussed the agency’s model-informed drug development (MIDD) proposal and began negotiating FDA’s rare disease proposal. The sides tentatively agreed on the value of the MIDD program and will move the discussion of resources to the Finance subgroup. The sides agreed to continue discussing the rare disease proposal and what the Rare Disease Innovation Hub provides, and to consider the resources needed for the rare disease proposal.