PhRMA Raises QMM, KASA Issues
Responding to an upcoming FDA Pharmaceutical Science and Clinical Pharmacology Advisory Committee meeting to discuss CDER’s Quality Management Maturity (QMM) and Knowledge-Aided Assessment and Structured Application (KASA) programs, Pharmaceutical Research and Manufacturers of America (PhRMA) says it has issues that it would like to be considered by the committee. The industry association comment letter says PhRMA recommends that FDA confirm that any QMM program it develops would be voluntary.
Further, it says, under any voluntary program FDA should make clear that any QMM-related value or score would not be publicly disclosed, including rankings or comparisons among and between firms. PhRMA says manufacturers could voluntarily disclose such ratings to appropriate stakeholders such as purchasers in the normal course of business.
The letter contains other comments and suggestions on the QMM program and then expresses significant concerns about implementing KASA for innovative products. “It is not apparent, for example, how KASA’s structure can support risk/benefit decisions regarding new molecular entities,” the letter says. “Moreover, it remains to be seen how KASA will support existing and planned harmonized data submission formats. Maintaining interoperability with global data standards is paramount for a successful data submission program.”