GDUFA II: Requests for Reconsideration

Similar documents
GDUFA II IR and DR Letters Michael Folkendt, M.S.

POLICY AND PROCEDURES. Office of Generic Drugs and Office of Pharmaceutical Quality. Table of Contents

FDA s ectd Mandate for 2017: Latest Developments. Phillip DeNoble, PharmD, B.Sc.

GDUFA II Pre-ANDA Program Advice for Success

Guidance for Industry ANDA Submissions Prior Approval Supplements Under GDUFA

Guidance for Industry

FDA Reauthorization Act of 2017 (FDARA)

A guide to PDUFA V. Focus US update. Regulatory Rapporteur Vol 9, No 11, November 2012

MDUFA Performance Goals and Procedures Process Improvements Pre-Submissions Submission Acceptance Criteria Interactive Review

CDER Small Business and Industry Assistance (SBIA)

TULSA PUBLIC SCHOOLS Policy 3407 CHARTER SCHOOLS. To establish guidelines for Charter Schools under the Oklahoma Charter

FDA Perspective on the Pre- Submission Program: Updates from MDUFA IV

Appeals Policy. Approved by: Tina Lee Approval Date: 3/30/15. Approval Date: 4/6/15

Center for Drug Evaluation and Research - Compliance Central with FDA Center Compliance Directors: Part 1

Practice Review Guide

Appendix 5A. Organization Registration and Certification Manual

LIONS CLUBS INTERNATIONAL District Restructure and Redevelopment Grant Criteria and Application Format

PDUFA V. New Review Program for NME NDAs and Original BLAs. Enhanced Communications with FDA and Sponsors. Beth Duvall

Appendix A CALL BACK CRITERIA

Mariposa County Behavioral Health and Recovery Services QUALITY IMPROVEMENT WORKPLAN

RULES OF PROCEDURE FOR CALIBRATION LABORATORY ACCREDITATION

DOD MANUAL DOD ENVIRONMENTAL LABORATORY ACCREDITATION PROGRAM (ELAP)

COMPLAINTS TO THE COLLEGE OF PSYCHOLOGISTS OF ONTARIO

Practice Review Guide April 2015

DEVELOPMENTAL PROGRAMS BULLETIN COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF PUBLIC WELFARE

REPORT TO THE CITY COUNCIL & HOUSING AUTHORITY

Patient Decision Aid Certification Process

Community Based Adult Services (CBAS) Manual

COUNTY OFFICIAL PLAN AMENDMENT PROCESS (TYPICAL)

New Requirement for Electronic Submission of DMFs

Chapter 11. Cultural Districts

FDA Guidance Hot Topics: Pre-Submission Guidance Review AMDM Focus Meeting October 25, Elizabeth Hillebrenner, MSE OIR/CDRH/FDA

UTILIZATION REVIEW DECISIONS ISSUED PRIOR TO JULY 1, 2013 FOR INJURIES OCCURRING PRIOR TO JANUARY 1, 2013

Approved by. The Board of Directors of RusnanoMedInvest, LLC. Minutes # 3 dated April 24, 2012

POLICY OFFICE OF PHARMACEUTICAL QUALITY

All Medicaid-Enrolled Nursing Facilities. Minimum Data Set Audit and Rate Calculation Process

Parkview Hospital Medical Staff Bylaws Supplement Allied Health Practitioner Manual

RULES OF THE DEPARTMENT OF MANAGEMENT SERVICES PERSONNEL MANAGEMENT SYSTEM CHAPTER 60L-39 FLORIDA STATE EMPLOYEES CHARITABLE CAMPAIGN

Northeast Power Coordinating Council, Inc. Regional Standards Process Manual (RSPM)

RULES OF PROCEDURE FOR TESTING LABORATORY ACCREDITATION

Appendix 5A. Organization Registration and Certification Manual. WORKING DRAFT-August 26, 2014

Northeast Power Coordinating Council, Inc. Regional Standard Processes Manual (RSPM)

LPA PARTICIPATION REQUIREMENTS

KANSAS STATE BOARD OF NURSING ARTICLES. regulation controls. These articles are not intended to create any rights, contractual or otherwise, for

Financial Assistance/Sliding Fee Scale Policy Page 1 of 6. Financial Assistance/Sliding Fee Scale Policy

Guidance for Industry and Food and Drug Administration Staff

RULES OF TENNESSEE DEPARTMENT OF LABOR AND WORKFORCE DEVELOPMENT WORKERS COMPENSATION DIVISION

Economic Development Competitive Grant Program for Underserved and Limited Resource Communities

What's New with the 356h Form? Beth Duvall Associate Director for Regulatory Affairs Office of New Drugs Center for Drug Evaluation and Research

NOTE: The first appearance of terms in bold in the body of this document (except titles) are defined terms please refer to the Definitions section.

LCDR Kemi Asante, PharmD, RAC Health Science Policy Analyst Office of Prescription Drug Promotion CDER FDA

Bristol Community College. Office of Grant Development STANDARD OPERATING PROCEDURES FOR GRANT DEVELOPMENT

Summary of NCLB: Service to Private School Students

FISCAL YEAR FAMILY SELF-SUFFICIENCY PROGRAM GRANT AGREEMENT (Attachment to Form HUD-1044) ARTICLE I: BASIC GRANT INFORMATION AND REQUIREMENTS

Received an RTA Deficiency List or AI Letter? Now What?

Brevard County Public Schools Growth Management. School Concurrency Review Fees

Florida Job Growth Grant Fund Public Infrastructure Grant Proposal

Points to Consider regarding the Notification and Publication of Package Insert Language

Draft Procedure for Community gtld Change Requests January 2018

Managed Care Organization Hospital Access Program Hospital Participation Agreement

Topic: CAP s Legislative Proposal for Laboratory-Developed Tests (LDT) Date: September 14, 2015

Policy Number: Title: Abstract Purpose: Policy Detail:

DOCTORS HOSPITAL, INC. Medical Staff Bylaws

PEER REVIEW (AN OVERVIEW)

Technical Charter (the Charter ) for. ONAP Project a Series of LF Projects, LLC

Pre-Submissions and Meetings with FDA Staff

Interactive Review for Medical Device Submissions: 510(k)s, Original PMAs, PMA Supplements, Original BLAs, and BLA Supplements

Bylaws of the College of Registered Nurses of British Columbia BYLAWS OF THE COLLEGE OF REGISTERED NURSES OF BRITISH COLUMBIA

University of Pittsburgh

PLAN OF ACTION FOR IMPLEMENTATION OF 510(K) AND SCIENCE RECOMMENDATIONS

ALABAMA MEDICAID AGENCY ADMINISTRATIVE CODE CHAPTER 560-X-45 MATERNITY CARE PROGRAM TABLE OF CONTENTS

JOHNS HOPKINS HEALTHCARE

STANDARD OPERATING PROCEDURE

California Provider Handbook Supplement to the Magellan National Provider Handbook*

Office of Institutional Diversity Inclusive Excellence Student Program Grant Call for Proposals Information

PROVIDER APPEALS PROCEDURE

COMPLIANCE PLAN PRACTICE NAME

Quality Assurance/Quality Control Procedures for Environmental Documents

1 of 13 DOCUMENTS. NEW JERSEY ADMINISTRATIVE CODE Copyright 2016 by the New Jersey Office of Administrative Law

Department of Defense DIRECTIVE

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION. North American Electric Reliability ) Corporation ) Docket No.

U. S. Virgin Islands Compliance Agreement

AAHRPP Accreditation Procedures Approved April 22, Copyright AAHRPP. All rights reserved.

Q: How does the Assessment of Fair Housing (AFH) compare to the Analysis of Impediments (AI)?

FDA HAS MADE PROGRESS

1010 E UNION ST, SUITE 203 PASADENA, CA 91106

Provider Rights. As a network provider, you have the right to:

DEPARTMENT OF HUMAN SERVICES AGING AND PEOPLE WITH DISABILITIES OREGON ADMINISTRATIVE RULES CHAPTER 411 DIVISION 069 LONG TERM CARE ASSESSMENT

Identification and Protection of Unclassified Controlled Nuclear Information

REGIONAL FIRE SERVICES TRAINING FACILITIES POLICY

Monday, October 28, Pre-Conference API Workshop (separate registration is required)

MEMORANDUM OF AGREEMENT BETWEEN THE FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION AND THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Section VII Provider Dispute/Appeal Procedures; Member Complaints, Grievances, and Fair Hearings

Commodity Credit Corporation and Foreign Agricultural Service. Notice of Funding Availability: Inviting Applications for the Emerging Markets

Medical Staff Bylaws: Compliance Challenges Updating Bylaws to Comply with Joint Commission Standards

CNL-CNSC Administrative Protocol for the Renewal of the Whiteshell Laboratories Licence and the Proposed In Situ Decommissioning of the WR-1 Reactor

Stay Compliant! Electronic Submission of Drug Master Files (DMFs) is MANDATORY starting May 5, 2017: What You Need to Know

ALABAMA BOARD OF NURSING ADMINISTRATIVE CODE CHAPTER 610-X-3 NURSING EDUCATION PROGRAMS TABLE OF CONTENTS

DATE: June 15, SUBJECT: AIDS Home Care Program (Chapter 622 of the Laws of 1988)

Department of the Army Volume 2014 Defense Civilian Intelligence Personnel System Employee Grievance Procedures March 25, 2012 Incorporating Change

Transcription:

GDUFA II: Requests for Reconsideration Priya Shah, Pharm.D. Immediate Office Project Manager Office of Regulatory Operations, Office of Generic Drugs

Purpose To provide an overview of requests for reconsideration under GDUFA II with a focus on industry impact 2

Commitment Letter Language II. Original ANDA Review Program Enhancements C. Review Classification Changes During the Review Cycle 6. If an applicant requests a teleconference as part of its request to reclassify a major amendment or standard review status, FDA will schedule and conduct the teleconference and decide 90% of such reclassification requests within 30 days of the date of FDA s receipt of the request for a teleconference. This goal only applies when applicant accepts the first scheduled teleconference date offered by FDA. 3

Commitment Letter Language II. Original ANDA Review Program Enhancements E. Dispute Resolution 1. An applicant may pursue a request for reconsideration within the review discipline at the Division level or original signatory authority, as needed. 2. The OGD Office of Regulatory Operations Associate Director will track each request for Division level reconsideration through resolution. 4

Commitment Letter Language II. Original ANDA Review Program Enhancements E. Dispute Resolution 3. Following resolution of a request for reconsideration, an applicant may pursue formal dispute resolution above the Division level, pursuant to procedures set forth in the September 2015 Guidance, Formal Dispute Resolution: Appeals Above the Division Level. 4. FDA will respond to appeals above the Division level within 30 calendar days of CDER s receipt of the written appeal pursuant to the applicable goal. a. In FY 2018, the goal is 70 percent. b. In FY 2019, the goal is 80 percent. c. In FY 2020, 2021, and 2022 the goal is 90 percent. 5. CDER s Formal Dispute Resolution Project Manager (or designee) will track each formal appeal above the Division level through resolution 5

Working Group Organization Center for Drug Evaluation and Research Office of Generic Drugs Office of New Drugs Office of Pharmaceutical Quality Office of Regulatory Operations Office of Generic Drug Policy Office of Bioequivalence Office of Research and Standards Office of Process and Facilities Office of Lifecycle Drug Products Office of Policy for Pharmaceutical Quality Office of Program and Regulatory Operations 6

What is New/Changed? GDUFA II Performance Goals Guidance for Industry Standardized Process for Requests for Reconsideration 7

GDUFA II Performance Goals Schedule, conduct teleconference, and decide 90% of reclassification requests of a major amendment or standard review status within 30 days of receipt* of the request Respond to appeals above the Division level within 30 calendar days of CDER s receipt of the written appeal In FY 2018, the goal is 70 percent. In FY 2019, the goal is 80 percent. In FY 2020, 2021, and 2022 the goal is 90 percent. *received by the FDA via the Electronic Submissions Gateway (ESG) 8

Guidance for Industry 9

Guidance for Industry Outlines considerations for applicants before submitting a request for reconsideration Matters that are not appropriate for a request for reconsideration will not be accepted for review A request for reconsideration that includes new information will not be accepted for review Outlines timelines and procedures for submitting and responding to a request for reconsideration Written request via Electronic Submissions Gateway Cover letter identifies submission as a Request for Reconsideration 10

Process for Requests for Reconsideration ANDA applicant submits request for reconsideration via ESG Project Manager conducts a preliminary review of the request to evaluate whether the request should be accepted If request is accepted, original signatory authority will evaluate and send a written decision to the applicant 11

Who is Responsible? Applicant Project Manager Original Signatory Authority Associate Director of Operations 12

Applicant Responsibilities ANDA applicant submits request for reconsideration via ESG Submits request for reconsideration to the ANDA file Should not submit a request for a matter that is not appropriate for this process Should not include new information in the request FDA encourages the applicant to submit the request according to the draft guidance Submit courtesy copies to the appropriate individuals Submit within 7 calendar days from the date of the regulatory action Identify the request as a Request for Reconsideration on the cover letter 13

Project Manager Responsibilities Project Manager Project Manager conducts a preliminary conducts a review of the request to preliminary review evaluate whether the of the request to request should be evaluate whether accepted the request should be accepted If request is not accepted for review Inform the applicant on behalf of the signatory authority Identify the reason why the request was not accepted If request is accepted for review Forward the request to the signatory authority Send the applicant an acknowledgement letter identifying the signatory authority including the GDUFA goal date, if applicable including the date of the teleconference, if applicable 14

Original Signatory Authority Responsibilities Project Manager If Project conducts request Manager is a accepted, preliminary review original conducts of signatory a the request to authority preliminary review evaluate will whether evaluate the and of the request to request send a should written be evaluate decision whether accepted to the request applicant should be accepted Review the request once it has been deemed accepted for review May consult with subject matter experts regarding the matter under reconsideration Provide the applicant with a final written decision either granting or denying the request *the original signatory authority may delegate their request for reconsideration to another deciding official* 15

Associate Director of Operations Responsibilities Track each request for division level reconsideration through resolution Serve as the administrative contact for the FDA and industry for all procedural related issues regarding reconsideration requests ANDA applicant submits request for reconsideration via ESG Project Manager conducts a preliminary review of the request to evaluate whether the request should be accepted If request is accepted, original signatory authority will evaluate and send a written decision to the applicant 16

What should Industry expect? Predictable timelines for responses to requests for reconsideration Receipt of Not Accepted letters for requests that contain new information or that are not appropriate for this process Teleconferences to discuss the issue(s), but not opportunities to seek a decision from FDA 17

What can Industry do to assist? Send courtesy copy to appropriate individuals identified in the draft guidance Submit within 7 calendar days from the date of the regulatory action Identify the request as a Request for Reconsideration on the cover letter 18

Tips for Industry Do not submit requests for matters that are not appropriate for this process, including, but not limited to: Information requests and discipline review letters General advice letters and advice communicated during meetings or teleconferences Meeting minutes Do not submit new information as part of the request Do not submit for reclassification of a Major amendment to an easily correctable deficiency, information requests, or discipline review letter The review cycle has been closed by FDA by taking the action of issuing the complete response letter 19

Resources GDUFA II Commitment Letter: GDUFA Reauthorization Performance Goals and Program Enhancements Fiscal Years 2018-2022 Draft Guidance for Industry: Requests for Reconsideration at the Division Level Under GDUFA Draft Guidance for Industry and Review Staff: Formal Dispute Resolution: Appeals Above the Division Level 20

External Contact Inquiries related to specific requests: contact the project manager Inquiries related to the process: contact the Associate Director of Operations at ANDAReconsideration@fda.hhs.gov 21