Some Agreements in MDUFA 6 Negotiations
Minutes from the 2/11 and 2/18 MDUFA 6 negotiating sessions between FDA and industry representatives indicate agreement was reached on several issues, with others needing further discussion. The 2/18 minutes say the two sides have agreed to proposals on patient science, digital health, third-party 510(k) review program, continuous improvement, deficiencies, international harmonization, 510(k) total time to decision, consensus standards, de novo, pre-submissions, resource capacity planning and management capability development, excluding a capacity planning adjustor, and IT tools. With the agreements in place, the sides will move forward with drafting the Commitment Letter language for those topics.
At the 2/11 negotiating session, the agency provided feedback on the industry’s proposal on periodic reporting to include staffing levels by Office within CDRH. FDA proposed instead to do Center-level reporting, consistent with the other Centers. The minutes show that the industry reaffirmed the importance of reporting at the Office level, and FDA said it would give the proposal further consideration.
In providing its feedback on FDA’s Total Product Lifecycle Advisory (TAP) 2.0 proposal at the 2/11 session, industry opposed FDA’s proposed operations expenses and requested clarity from the agency on what the expenses would cover. Industry reportedly emphasized the need for meaningful metrics for TAP 2.0 moving forward and that the program should provide benefit across the device ecosystem and not just to TAP-designated products.
Also discussed on 2/11 were information technology tools, real-world evidence, de novo and pre-submissions, and operating reserve and trigger reform.
The 2/18 negotiating session discussed carryover, fee structure, and trigger reform; continuous improvement review consistency; and TAP 2.0.