‘Refuse to File’ Policy MAPP
CDER has published a Manual of Policies and Procedures. Good Review Practice: Refuse to File, outlining the policies, responsibilities, and procedures for the Office of New Drugs to follow to determine whether there is a basis to refuse to file (RTF) an NDA, sNDA, BLA, or sBLA submitted to CDER. The document says the MAPP is consistent with existing policies and procedures contained within appropriate sections and resources highlighted in the 21st Century Review process and its accompanying Desk Reference Guide, and is intended to provide additional clarification about the refuse-to-file process.
“RTF is an important regulatory tool to help CDER avoid unnecessary review of incomplete applications or certain applications that are submitted as an NDA but should have been submitted as an ANDA,” the MAPP says. “Incomplete applications could lead to multiple-cycle reviews and inefficient use of CDER resources. CDER also believes an RTF action can allow an applicant to begin repair of critical deficiencies in the application far sooner than if these were identified much later in a complete response action and may lead to more rapid approval of safe and effective drug products.”
The document lists the reasons under regulations that describe the circumstances under which CDER may refuse to file an NDA or BLA application.