Guidance on CDRH Appeals Process Q & A

FDA has released a guidance entitled “Center for Devices and Radiological Health (CDRH) Appeals Processes: Questions and Answers About 517A.” The document provides the Center’s interpretation of key provisions in the regulation that pertain to requests for appeals of significant decisions on PMAs, 510(k)s, IDEs, and clinical holds, among others. The guidance notes that device submitters should request a “substantive summary” of the scientific and regulatory rationale for any decision they seek to appeal. This should include documentation of how the least burdensome requirements were considered and applied, and documentation of significant controversies or differences of opinion and the resolution thereof.

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