Industry MDUFA 4 Proposal Discussed

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FDA officials and industry representatives discussed a comprehensive MDUFA 4 reauthorization package offered by AdvaMed, MDMA, and MITA at their 4/27 reauthorization meeting. Meeting minutes say that the package included potential commitments and proposed resource estimates for several areas, including pre-submissions, quality management, total product life cycle, de novo, CLIA waiver, independent assessments, IT improvements, recruitment, third-party review program, digital health, and standards. It also included enhancing the total time to decision goals for PMAs and 510(k)s to capture the efficiencies and process improvements from investments in the proposal.

Agency officials expressed appreciation for the proposal, saying it represented a step forward. They also noted that significant gaps remain between the provisions supported by industry and by FDA.

The minutes detail many aspects of the industry plan and the resources offered to support it. The three associations said that the resources should create program efficiencies enabling reductions in the goals for average total time to decision to 108 days for 510(k)s and 300 days for PMAs, both by the end of 2022.

FDA said that funding levels for many of the proposal areas were significantly less than the agency’s estimates for resources needed to achieve the proposals. It said its estimates were based on careful analysis of program performance and trends. For instance, it said, recent data indicate the agency is unable to consistently issue timely decisions on de novo submissions with existing resources. The agency also noted that its proposals for additional managers and review capacity were not included in the industry package, despite FDA’s emphasis that they are needed to support the program. FDA expressed concern that without additional review capacity and infrastructure, it would not be able to fulfill the request for substantial reductions in the total time to decision goals.

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