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  • 1.  De Novo Review time

    This message was posted by a user wishing to remain anonymous
    Posted 10-Feb-2020 12:47
    This message was posted by a user wishing to remain anonymous

    Hello 

    Can someone explain this sentence :
    Under the MDUFA IV, FDA has committed to completing review of De Novo requests in 150
    FDA review days, with the percent of submissions required to meet this goal increasing from
    50 to 70 percent over the next several years, as detailed in the table below. This is a change
    from the statutorily required review timeline of 120 days.

    What is the difference between the MDUFA IV review time(150 days) and statutorily review time (120days) for De Novo Application?

    Thanks you


  • 2.  RE: De Novo Review time

    Posted 11-Feb-2020 12:20
    Good afternoon,
    The FD&C Act when revised to allow for direct to de novo applications (as opposed to first seeking 510k to then be declined), states a 120 day review time. Very briefly, products requiring a de novo are inherently novel and require additional considerations related to appropriately identifying "special controls" to adequately reclassify. A lot of emphasis is placed on the risk/benefit analysis to support the marketing authorization decision. Thus, 120 days is a challenge to achieve. With MDUFA IV came a commitment to a more realistic review clock and a price tag. I would encourage review of the quarterly performance reports available on FDA's website if you have not already discovered. Right now, FDA is averaging 130 days to a de novo decision (their clock). Typically, a deficiency letter/additional info request is issued which stops the FDA clock and turns on the sponsor's clock. Sponsor time is averaging a 105 days. In total, 230 days is the average from start to finish. Please note, this is not a normal distribution and looks like there may be some significant outliers with a very long decision time pulling this average up a bit. 
    Hope this helps.

    Best,
    Danni

    ------------------------------
    Danielle Briggeman MS
    Clinical & Regulatory Affairs Manager
    Portland ME
    United States
    ------------------------------



  • 3.  RE: De Novo Review time

    Posted 11-Feb-2020 12:41
    Statute states that de novo classification decisions to occur within 120 days, but no statutory timeline enforced against the Agency due to lack of user fees and dedicated resources to handle these requests. As such, FDA has had widespread difficulty adhering to this 120-day review timeline previously. Now under the MDUFA IV, FDA has committed to issue a MDUFA decision within 150 FDA days of receipt of the submission for: 50% of de novo requests received in FY 2018; 55% of de novo requests received in FY 2019; 60% of de novo requests received in FY 2020; 65% of de novo requests received in FY 2021 and 70% of de novo requests received in FY 2022. 

    Hope it helps clarify.

    Regards,
    Jo

    ------------------------------
    Jo Huang RAC
    Assoc Manager - Regulatory Affairs
    Irvine CA
    United States
    ------------------------------



  • 4.  RE: De Novo Review time

    Posted 01-Mar-2020 13:09
    The fact that the statutory deadlines are not enforced is something for which industry, healthcare providers, and patients should all be very, very very grateful.  If CDRH has committed to issuing a decision within hard timeline under MDUFA, the number of decisions reached will either fall off a cliff, or it will be serving all three constituencies very badly.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 5.  RE: De Novo Review time

    Posted 11-Feb-2020 15:52
    I've always admired FDA's facility with numbers. :)

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 6.  RE: De Novo Review time

    Posted 11-Feb-2020 16:13
    Do I sense a touch of sarcasm in your emoticon, Julie? lol

    ------------------------------
    Jo Huang RAC
    Assoc Manager - Regulatory Affairs
    Irvine CA
    United States
    ------------------------------



  • 7.  RE: De Novo Review time

    Posted 11-Feb-2020 22:09

    Maybe more on the order of wry amusement.  And some legitimate admiration.  It's a political environment, which means its all in the presentation.  But how it is presented doesn't change what lies beneath.  They still reviewed the number of submissions they reviewed in the time it took to review them.  So, rightly or wrongly, I'm inclined to think it doesn't matter how they crunch the numbers.

    Corporate annual reports can be pretty creative too. :)



    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------