Q-Submission Guide ‘Step in the Wrong Direction’: Expert

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Senior medical device regulation expert Lisa Baumhardt (Hyman, Phelps & McNamara) says aspects of a recent FDA draft guidance on Requests for Feedback and Meetings for Medical Device Submission: The Q-Submission Program “could have a negative impact on future pre-submissions.” Writing in her firm’s FDA Law Blog, Baumhardt says the draft’s attempt to clarify when a sponsor’s question may be more appropriate for more informal communication “hardly provides clarification and seems to limit the topics that could utilize this method of feedback.”

Baumhardt says she hopes the final guidance provides more clarity on the use of informal interactions with the agency as a method of getting feedback. “We consider the focus on limiting the number of questions that can be addressed in any one pre-submission and the impact that will have on development timelines to be a step in the wrong direction,” she concludes. “The approach to submitting a pre-submission with a limited number of questions and following with additional pre-submission supplements to get feedback and alignment with the agency on a variety of topics does not align with helping ensure timely access to new medical devices.”

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