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Ask Me Anything Session: Regulatory Intelligence and Policy

  • 1.  Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 12:59
    Hi Members,

    Recently, RAPS released it's quarterly article series focusing on global best practices in regulatory intelligence (RI) and policy. Today, we have three experts, Kirsten Messmer, Matt Medlin, and Meredith Brown-Tuttle, who will be discussing the article series and available to answer your questions in real time.

    Please use this thread to ask the experts your questions.

    Can't wait to read the discussions!

    Best,
    Emily​​​​

    ------------------------------
    Emily Stamm
    Community Manager
    Regulatory Affairs Professionals Society®
    regex@raps.org
    ------------------------------


  • 2.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:00
    Really excited to be here today to discuss RI!

    ------------------------------
    Meredith Brown-Tuttle, RAC, FRAPS
    President
    Regulatorium
    Santa Clara CA
    United States
    ------------------------------



  • 3.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:09
    Hello everyone, I am very excited to be here for a second time and look forward to great conversations about RI.​

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 4.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:10
    Edited by Emily Stamm 11-Dec-2019 13:12
    Hi fellow RAPS RI Enthusiasts!  Just sending a quick note to say I'm excited about the AMA session today and I look forward to the conversation, discussion, and doing my best to answer anything RI that comes my way!

    ------------------------------
    Matt Medlin RAC
    Manager, US Regulaotry Affairs R&D Pipeline
    Durham NC
    United States
    ------------------------------



  • 5.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    This message was posted by a user wishing to remain anonymous
    Posted 11-Dec-2019 13:14
    This message was posted by a user wishing to remain anonymous

    Thank you for this opportunity! I have questions about using RI to prepare for FDA meetings, particularly in the authoring phase. What records or documents are used to identify potential reviewers? Once found, how do you request those reviewers?


  • 6.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:18
    Once I have the list of attendees for an FDA meeting, I do a search on the FDA website for their names or if I have pharmapendium then I use that to search for specific reviewer names.  Once you find the reviewers names and the drugs associated with it you can go to Drugs@FDA and pull the administrative documents looking for past meeting minutes - this will help you understand the previous questions asked to the Agency and the response by the review team.

    In terms of the authoring phase I use similar class of approved drugs and pull their summary basis of approval documents at Drugs@FDA and review the meeting minutes to help me address questions the Division repeatedly asks about or to assist in regulatory strategy.

    ------------------------------
    Meredith Brown-Tuttle, RAC, FRAPS
    President
    Regulatorium
    Santa Clara CA
    United States
    ------------------------------



  • 7.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 30-Dec-2019 12:40
    Hello Meredith,
    I am new to RA and working on submissions for IVDs (lab developed tests specifically)​. Do you know if meeting minutes are published for pre-subs of medical devices?  I would find it extremely helpful to understand the sort of feedback others have received for similar submissions.

    Thank you in advance!
    Julie

    ------------------------------
    Julianne Cappell
    Quality Coordinator
    Rochester MN
    United States
    ------------------------------



  • 8.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 30-Dec-2019 13:31
    Edited by Julie Omohundro 30-Dec-2019 13:40
    Julie,

    I can assure you that snowballs will freeze before industry and its champions let FDA publish the minutes of pre-sub meetings.  They would undoubtedly be far more amenable to publishing unredacted 510(k)s, because at least by then they will have established market share.  The best you are going to do is to google around and find some guidance written by consultants who have been there and back again.

    Also, the RA motto "It depends" holds in this situation as much as any other.  What feedback others have received on their submissions won't necessarily help you, unless it was a meeting for a very similar test, and the developers had questions for FDA that are very similar to yours.

    I'm curious as to what kind of submissions you are preparing and to whom you are sending them, given that, last time I checked CDRH was still "exercising" enforcement discretion" when it comes to LDTs?

    ------------------------------
    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
    ------------------------------



  • 9.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:19

    Hey, great question!

    A good source for this are the reivew documents for *recent* relevant drug/biologic reivews on FDA.gov.  I tend to identify the critical questions for the package then target the discipline specific reivews.  (e.g. My feeling is that CMC will have tough FDA responses, I will search for related therapeutics, recent Quality Reivew summaries and analyze the responses and individual reviewers that provided them.  In many instances the FDA will assign the reviewer, often based on prior experience with related programs, but you can request specific disciplines and indiviuals in the meeting request letter.



    ------------------------------
    Matt Medlin RAC
    Manager, US Regulaotry Affairs R&D Pipeline
    Durham NC
    United States
    ------------------------------



  • 10.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:22
    I would add, given the high rate of turnover at FDA, that a reivew of recent reivews is best.  You can also confirm that a particular reviewer is still with FDA via the HHS Employee Directory.  In my experience that database stays pretty current.  https://directory.psc.gov/employee.htm

    ------------------------------
    Matt Medlin RAC
    Manager, US Regulaotry Affairs R&D Pipeline
    Durham NC
    United States
    ------------------------------



  • 11.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:15
    For Meredith, When you describe RI to someone new to Regulatory Affairs, how do you differentiate the discipline from everything else that a regulatory professional does?

    ------------------------------
    Matt Medlin RAC
    Manager, US Regulaotry Affairs R&D Pipeline
    Durham NC
    United States
    ------------------------------



  • 12.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:27
    Well it all depends of course.....the great regulatory answer.  I usually give an overview of the 3 prongs of RI: policy, strategy and operations to start off with and what each accomplishes.  ​For small companies I usually say that RI is combined into a person's job and every day function and not a distinct function, so you will have to do a lot of everything and RI will not be kept current since it is not a priority.....so for a small company its very muddled and not differentiated.  As a company gets larger, RI needs to be differentiated as a distinct function to support strategy and policy needs - and it is at that transition time for companies that can be the hardest (from small to medium to larger), trying to set up a company, establish the new functions, establish metrics, budget for tools and manage expectations from the internal stakeholders.

    ------------------------------
    Meredith Brown-Tuttle, RAC, FRAPS
    President
    Regulatorium
    Santa Clara CA
    United States
    ------------------------------



  • 13.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:38
    To add to Meredith's response: For me RI works in three steps: we monitor the landscape, analyze the information and then we form a strategy (what actions are needed). In the current fast-moving​ environment it is incredibly important to keep up-to-date with new requirements to ensure time- and cost-effective drug development. An RI professional needs to quickly understand the content of the new regulatory requirements/information and determine what kind of action might be needed.

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 14.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:22
    Edited by Emily Stamm 11-Dec-2019 13:22
    Kirsten,

    A new guideline that impacts your business. What do you do now?


    ------------------------------
    Meredith Brown-Tuttle, RAC, FRAPS
    President
    Regulatorium
    Santa Clara CA
    United States
    ------------------------------



  • 15.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:28
    Great question. Once I've identified that the guideline has an impact on business, I look does it impact a specific group within the company or is it our overall business and also, does it impact clients. A further consideration is if processes have to be changed due to the new guideline.
    These questions help to channel whether the publication of this guideline needs to be disseminated to a specific group, e.g. senior leadership of a therapeutic area, or across the company to all regulatory affairs colleagues. It will also determine the style of presentation - leadership: short and concise, overall: more detail.
    ​Within PPD we also have an escalation mechanism that further assesses the impact and escalates as needed. From my perspective that one would be my first call to bring it to their attention for further actioning.

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 16.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:24
    Hey Matt,

    What training do you attend or provide?

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 17.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:28
    Hey,

    First I learned quite a lot from Meredith's RI 101 book, I think this was a seminal work in the evolving definition of RI, and something that can be absorbed outside of any webinar or conference. After that the workshops offered by RAPS (online or F2F conference workshop) were very helpful for me to get foundational knowledge on the discipline.

    ------------------------------
    Matt Medlin RAC
    Manager, US Regulaotry Affairs R&D Pipeline
    Durham NC
    United States
    ------------------------------



  • 18.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:55
    I've read Meredith's book too. ​

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 19.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    This message was posted by a user wishing to remain anonymous
    Posted 11-Dec-2019 13:27
    This message was posted by a user wishing to remain anonymous

    Hi Experts!

    What is the difference in Reg Intelligence and Reg Policy?

    Thanks!


  • 20.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:32
    Intelligence is reactive, it is the synthesis of the information into actionable items to help ensure the success of the company and it can be new regulations, guidelines, etc., while policy creative and is a predecessor to intelligence (RI) working with legislators to shape future regulations, guideline documents, etc.   Without policy, intelligence wouldn't exist.

    ------------------------------
    Meredith Brown-Tuttle, RAC, FRAPS
    President
    Regulatorium
    Santa Clara CA
    United States
    ------------------------------



  • 21.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:35
    Agreed on this point.  One way to discriminate between regulatory policy and intelligence activities is to consider that often policy work is public and focused on influencing or discussion with external stakeholders.  RI often is a matter of internal dialog within the company.

    ------------------------------
    Matt Medlin RAC
    Manager, US Regulaotry Affairs R&D Pipeline
    Durham NC
    United States
    ------------------------------



  • 22.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:51
    Matt and Meredith, ag​ree with both of you. Perhaps as an example: Policy would be if you comment on draft guidances or comment at public meetings to help shape the regulatory environment versus intelligence being developing strategies for drug development in a cost- and time-efficient manner following these regulations, guidelines and policies.
    FDA usually announces new draft guidances open for comment or public meetings that can be attended. The Federal Register - https://www.federalregister.gov/ - will provide the information on how to provide the comments and deadline. For meetings that information is provided in the announcement.

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 23.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:34
    Hi Experts!

    I had a great question come in before the session. The member wants to know: What are some of your favorite RI Websites?

    Thanks!

    ------------------------------
    Emily Stamm
    Community Manager
    Regulatory Affairs Professionals Society®
    regex@raps.org
    ------------------------------



  • 24.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:36
    Well it all depends on the question and the country it is applicable to......a great place to start is google since you can conduct refined searches there.  For a list of resources please see: https://www.regulatorium.com/intelligence-tools-links-and-resource

    ------------------------------
    Meredith Brown-Tuttle, RAC, FRAPS
    President
    Regulatorium
    Santa Clara CA
    United States
    ------------------------------



  • 25.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:46
    https://www.statnews.com/
    https://pink.pharmaintelligence.informa.com/


    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 26.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:37
    Another new tool I've found is https://clinregs.niaid.nih.gov/ it provides you a cross comparison of clinical trial requirements around the globe and it's free!

    ------------------------------
    Meredith Brown-Tuttle, RAC, FRAPS
    President
    Regulatorium
    Santa Clara CA
    United States
    ------------------------------



  • 27.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:41

    Here are some of my favorites in no particular order:
    https://www.raps.org/news-and-articles/news-articles/2019/12/recon-sanofi-exits-diabetes-research-south-korea

    https://www.fda.gov/industry/designating-orphan-product-drugs-and-biological-products/clinical-superiority-findings

    https://www.fda.gov/patients/learn-about-fda-patient-engagement

    https://www.fda.gov/drugs/development-resources/table-surrogate-endpoints-were-basis-drug-approval-or-licensure

    https://www.mobihealthnews.com/

    https://www.accessdata.fda.gov/Scripts/cder/pmc/index.cfm



    ------------------------------
    Matt Medlin RAC
    Manager, US Regulaotry Affairs R&D Pipeline
    Durham NC
    United States
    ------------------------------



  • 28.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    This message was posted by a user wishing to remain anonymous
    Posted 11-Dec-2019 13:38
    This message was posted by a user wishing to remain anonymous


    My question is regarding managing regulatory updates (in particular Medical Devices) when the guidance / regulations are not in English. For Example - Guidance documents in Chinese, Japanese etc.
    How to do an assessment if the guidance documents can impact a future regulatory strategy or a product under development when the guidance documents are in native languages and not in English? Getting these documents translated is normally very expensive. If the manufacturer does not have a local agent who can guide on the new changes in the legislation or on a new guidance then what is the route the RA team can follow to make sure that the released guidance does not impact their product? Do most companies get these documents translated or buy the English versions?


  • 29.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:42
    Great question and I fully understand where you are coming from. Even for a large company like PPD these translations are cost-prohibitive unless absolutely necessary. Cortellis does provide translations for many languages, but there is a t​ime-delay. Often we will utilize internal colleagues that do speak that language to provide us the main points for further assessment.

    ------------------------------
    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
    ------------------------------



  • 30.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:43
    The cheap answer is https://translate.google.com/  - I use that as a first pass to see if I want to have the document translated and determine if it is important to know about.  Once I make the determination that it is important and the distributor doesn't have a translation then I buy it in English (if available) or have it translated.  I work with the same translation company consistently so that I always get the best deal in terms of cost.

    ------------------------------
    Meredith Brown-Tuttle, RAC, FRAPS
    President
    Regulatorium
    Santa Clara CA
    United States
    ------------------------------



  • 31.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:45
    Another great question: 

    How do you manage non-regulatory team members that disseminate RI without analysis or a complete understanding?



    ------------------------------
    Emily Stamm
    Community Manager
    Regulatory Affairs Professionals Society®
    regex@raps.org
    ------------------------------



  • 32.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 13:55

    Hey,

    The answer to this is that you can't.  It's impossible to manage the dissemination of RI information from all corners of the company to stakeholders.  Often times non-Reg folks within the company consider this just a helpful heads-up to all involved and that they are assisting as a team player.  What you can do is discourage the activity within the organization, or signal that you (or whoever is responsible for RI) is happy to be the first gate for this information.  What you can control completely is that the RI function within the company provides considered and thoughtful synthesis and impact analysis along with any hard-hitting late-breaking piece of Regulatory information when it's disseminated.  If you establish yourself or your function as an oasis in the ongoing onslaught of new regulatory developments then key stakeholders will eventually recognize this and learn that your response and analysis of a new piece of RI is worth the wait.



    ------------------------------
    Matt Medlin RAC
    Manager, US Regulaotry Affairs R&D Pipeline
    Durham NC
    United States
    ------------------------------



  • 33.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    This message was posted by a user wishing to remain anonymous
    Posted 11-Dec-2019 13:58
    This message was posted by a user wishing to remain anonymous

    Hi Experts!

    Thanks for all the great information. I was wondering if you could give me the single best google search tip you have.

    Thanks.



  • 34.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 14:01

    Hi Anon!

    First start with google advanced search:  https://www.google.com/advanced_search?q=how+to+use+google+fu&rlz=1C1GCEA_enUS773US773&sxsrf=ACYBGNSCQEgVtiqArKGVTwJiCFDgGb1kcw:1576090629734&hl=en

    Just seeing the fields is enlightening regarding what is possible in your pursuit to become a master of Google-Fu!

    One quick trick I love is to search just a specific site, i.e. "site:fda.gov "search term""

    Also try another search engine with different algorithms like duck.duck.go.  Surprising sometimes what that will yeild with the same terms.



    ------------------------------
    Matt Medlin RAC
    Manager, US Regulaotry Affairs R&D Pipeline
    Durham NC
    United States
    ------------------------------



  • 35.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 14:02
    I will let Matt answer with some technical tips as he has really taught me a lot of things - I think the best things to remember is to let your curiosity take hold and ask the question - that's really the first step for any search and it's amazing what you will find it you ask the question in a variety of ways using a potpourri of terms - because if you don't get it with searching "IB" then use "investigator's brochure" or investigator brochure" - don't be afraid to ask and don't be afraid to dig deeper and go through more than a page of Google search returns.  It sometimes feels like finding a needle in a haystack but the information is out there (isn't than an "X Files" quote?)......

    ------------------------------
    Meredith Brown-Tuttle, RAC, FRAPS
    President
    Regulatorium
    Santa Clara CA
    United States
    ------------------------------



  • 36.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 11-Dec-2019 14:00
    Thanks for joining us for this wonderful session, and a big thank you to our experts Kirsten, Meredith, and Matt.

    As a reminder, you can find the Regulatory Focus Article Series, Regulatory Intelligence and Policy: Shaping the Global Landscape, HERE.

    Feel free to keep the conversation going by adding your question to this thread.

    Thanks again!

    Emily

    ------------------------------
    Emily Stamm
    Community Manager
    Regulatory Affairs Professionals Society®
    regex@raps.org
    ------------------------------



  • 37.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    This message was posted by a user wishing to remain anonymous
    Posted 11-Dec-2019 15:11
    This message was posted by a user wishing to remain anonymous

    This discussion is helpful as I continue to establish an RI function within my organization. What do you see as the future of RI?


  • 38.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    This message was posted by a user wishing to remain anonymous
    Posted 20-Dec-2019 13:05
    This message was posted by a user wishing to remain anonymous

    I need some advice on stating who I worked with on a project at FDA.. I recently applied for a position and the Sr VP has asked who I interacted with on my IDEs and PMAs/pre-subs.  They are looking for people with lot of FDA interaction experience. IMO, those names and titles might be available via the FOI release of some documents; however, since those discussions are confidential I do not believe it would appropriate or ethical to divulge the names of the lead, technical or clinical reviewers and branch chief i interacted with while managing the submissions.   I can only state i was the Official Correspondent for the file and i can list the titles (branch chief, technical reviewer, lead reviewer, statistician) of those who i interacted with on these long term projects.   If you can provide recommendations or FDA reason for not disclosing this information I would appreciate it..I have never been asked this before and I wonder if its because the individual is a R&D representative and historically most RD representatives have an lack of understanding of FDA requirements and ask regulatory counterparts off the wall questions or have extreme demands.   Thank you


  • 39.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 23-Dec-2019 10:03
    I know the title of the thread is "Ask Me Anything," but because the topic is RI, your question may not be as widely read as if you posted it as a question to the full forum.

    The only situation I can think of that the participants in a confidential discussion might also be confidential is when the identity of the participants would reveal the nature of the discussions, e.g., senior executives of two companies are meeting to discuss potential acquisition or merger.  However, in that case, it is not so much the identity of the participants that is the issue, but the fact that their two companies are talking.  Whether it's the CEOs, the CFOs, etc, doesn't matter.

    Of more interest to me would be why do they want to know?  I can think of one bad reason, a couple of rather naive reasons, and no good reason.  In light of these alternatives, I've always made it a policy not to share the names of any FDA (or other regulatory) staff I've interacted with in discussions with potential employers or clients.  And I personally would want a compelling reason as to why they want to know, or I would continue my job search.


    ------------------------------
    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
    ------------------------------



  • 40.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    This message was posted by a user wishing to remain anonymous
    Posted 23-Dec-2019 12:07
    This message was posted by a user wishing to remain anonymous

    Anon,
    For any submissions that are still under review or were withdrawn/disapproved, I agree that it would be inappropriate to discuss these in a job interview.  That would include the specifics of the reviewers and the reviewing group.  

    For submissions that are held as confidential by FDA (e.g., IDEs are not released via FOIA), also agree that detailed discussions are out of bounds.

    For successful submissions that have publically available information posted, there should be no confidentiality issue associated with an acknowledgement of the reviewers involved with the approval.  The nature of the device, signatories on public documents, recipients of FDA letters, are all readily available. 

    Employers who have products focused in specific device types or therapeutic areas want to know who you worked with at the Agency for legitimate reasons.  For example, every review group consists of individuals and internal practices that can vary between groups.  Experience with specific groups gives us insight into what they look for.  This helps us anticipate questions and be better prepared for the review process.  Why wouldn't that be a reasonable question to ask a potential employee?  Your answers, of course, should be appropriately structured without revealing confidential information (noted above).


  • 41.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 26-Dec-2019 23:20
    Edited by Julie Omohundro 27-Dec-2019 13:27
    "...every review group consists of individuals and internal practices that can vary between groups.  Experience with specific groups gives us insight into what they look for."

    The interviewer didn't ask about a specific group, but the names of specific FDA staffers.  I think therapeutic area is enough already.

    Yes, people and practices can vary from group to group. They can also change over time, along with applicable law, regulations, guidances, the political winds, and with the economic, technical, clinical, and scientific competitive environments. (That is the whole point of regulatory intelligence, after all.)  IMO, the fact that some specific individuals focused on specific issues for a specific device at a specific time is not likely to have reliable enough predictive value for what is actually going to happen when your submission finally comes up for review for it to be worth asking about in an interview.

    "Why wouldn't that be a reasonable question to ask a potential employee?"

    Well, remember, you asked...

    Here are some scenarios that come to mind when I hear this question:

    - The company may be focused on What FDA Wants instead of what data it needs to support its claims because it lacks confidence in its device, its submission, and/or itself. Probably for good reason. As an RA professional, maybe this presents an opportunity to do some good, but it may also represent an opportunity to beat your head against a brick wall.

    - The company may be trying to study to the test, which is to say, to figure out the minimum it will have to know to satisfy certain reviewers, rather than having to learn all the material.  This probably works out sometimes. Other times, it doesn't.  Again, not worth the effort, IMO, and not attractive to me.  I like to learn all the material.

    - If it's a startup, it may just want to hire someone who will make it look good to investors.  No harm done there, except maybe to investors,depending on how well this approach works out.

    But these are not the scenarios suggested when this topic has come up in discussions with colleagues on and off over the years. What I virtually always hear from them (and what I think is highly likely myself) is that these companies are looking for someone who can game the system, by working their personal contacts to shove a less than stellar submission through FDA. 

    I think this is considered to be a "reasonable," even wise, approach in some circles, and it may well work...rarely, sometimes, often, I can't say.  I think this approach is sometimes based on an assumption of facts not in evidence, but again, I can't say. From a personal perspective, this is a bad, as much or more on FDA as on the company. From an RA perspective, I myself do not want to shove a less than stellar submission through FDA. I want to put together a stellar one that glides through on its own merit.

    If you have your reasons for asking, then it is a reasonable question.  They may be good reasons, but I think it is a question that is likely raise a red flag for some candidates, and, once raised, is not easily furled. Whether or not that is a problem for you, is for you to decide.

    Anyway, thanks for asking. It's an interesting question to ponder.

    ------------------------------
    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
    ------------------------------



  • 42.  RE: Ask Me Anything Session: Regulatory Intelligence and Policy

    Posted 27-Dec-2019 12:57
    Interesting question - I would say as long as the applications were NOT approved, that information should remain confidential. Although some practices are a little different in the US, I think we can learn a lot about a two your inquiry by the European Union Ombudsman on EMA procedures which may be perceived as presenting a bias.
    One specific point of discussion is Scientific Advice provided - it was a two main point inquiry:
    1. Separation of those staff that provided scientific advise from those that will eventually review the application - public could conceive a bias of reviewers that were involved early in the final application (which is indeed very unlikely since the application review team is larger etc). This was based on an unnamed companies press release that that interacted with the EMA and there was some positive support (we see that in the US, but it's not appropriate in the EU).
    2. Public release of the reviewer names involved in scientific advice to allow for public scrutiny. - This is kind of similar to your interview situation, although of course that was not public.
    The inquiry was resolved by the EMA ​agreeing to try as best as possible to use different marketing authorization reviewers with a maximum of one of the Rapporteurs having been involved in Scientific Advice also providing input on the authorization application - and the EMA needs to justify that too.
    The second point - Scientific Advice Rapporteurs will be made available with the EPAR AFTER the product is approved. That decision, I believe would fit your situation also.
    A public consultation and workshop was part of the entire process and the opinion field was split in two:
    Academic Researchers and Non-Government organizations: Wanted more transparency, wanted names early and no overlap to be able to provide scrutiny.
    Medical product sponsors and regulatory agencies: Processes are fine, no changes needed and be careful with company confidential information.
    The Ombudsman decision is here: https://www.ombudsman.europa.eu/en/decision/en/116683 - original inquiry should be there two. The EMA response and agreement are on the EMA website.

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    Kirsten Messmer RAC
    Principal Regulatory Affairs Specialist
    Garner NC
    United States
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