Saturday 24 July 2021

US FDA Q Submissions

 Manufacturers shall interact with FDA using Q-Submissions program. They can request clarification regarding medical device submissions.

The following feedback mechanism are described in guidance

  • Pre-Submissions
  • Informational Meetings
  • Study Risk Determinations
  • Formal Early Collaboration Meetings
  •  Submission Issue Meetings
  •  Day 100 Meetings for PMA Applicants

Q-Submission requests must be submitted through the Document Control Center (DCC). Two copies are required (One copy must be an electronic copy or eCopy).

FDA shall share the acknowledgement letter containing Q number to the applicant.

Q-Sub Type: Pre-Submissions

  • This type of submission used during product development and/or application preparation
  • Voluntary program and no user fees required
  • Feedbacks are received mainly through in-person meeting, teleconference or email
  • Timeframe is 75 to 90 days and FDA will respond with in 21 days for urgent public health issues

Recommended information

  • Cover Letter
  •  CDRH Premarket Review Submission Cover Sheet (Form FDA 3514)
  • Table of Contents
  • Detailed Device Description
  •  Proposed Intended Use/Indications for Use
  • Summary of Previous Discussions or Submissions Regarding the Same Device
  •  Overview of Product Development
  • Specific Questions for FDA Feedback
  • Preferred method to receive FDA Feedback
  • Meeting Format, Preferred Dates and Times, Planned Attendees, and Audiovisual Equipment Needs, if meeting or teleconference is requested

Q-Sub Type: Informational Meetings

  • Manufacturer will share the information to FDA without expecting any feedback.FDA is in listening mode.
  • Timeframe: 90 days

Recommandated information:

  • Cover Letter
  • CDRH Premarket Review Submission Cover Sheet  
  • Brief  Statement
  •  Proposed Agenda
  • Preferred Meeting Format
  • Dates and Times (minimum of three)
  •  Planned Attendees
  • Audiovisual Equipment Needs, if any

Q-Sub Type: Study Risk Determinations

  • Used to determine a study risk determination for not exempt studies.
  • FDA will provide a study determination letter and FDA’s determination is final

Recommended information:

  • Cover Letter
  •  CDRH Premarket Review Submission Cover Sheet
  •  Detailed Device Description
  •  Study Protocol
  •  Description of how the device will be used
  •  Description of the population
  • Sponsor’s name and contact person(s), including titles, address, phone number, fax number and email address

Q Sub Type-Formal Early Collaboration Meetings

There are two types.

1.Determination Meeting: Applicable for PMA or PDP applicant.

FDA shall determine the type of valid scientific evidence that will be necessary to demonstrate that the device is effective for its intended use.FDA shall assess whether clinical studies are needed to establish effectiveness

2. Agreement Meeting: Applicable for class III product or any implant.

This meeting is conducted to reach agreement on the key parameters of the investigational plan, including the clinical protocol

 Click here to know more about Early Collaboration Meetings Under the FDA Modernization Act (FDAMA); Final Guidance for Industry and for CDRH Staff

Q Sub Type- Submission Issue Meetings

  • This meeting is used to discuss the deficiencies identified during premarket applications
  • Time frame:21 days

Recommended information:

  • Cover Letter
  • CDRH Premarket Review Submission Cover Sheet
  • Reference to Premarket Submission Number
  •  Brief Statement (including purpose, scope, or objectives of meeting)
  • Proposed Agenda Including Deficiencies for Discussion
  • Focused Questions
  • Preferred Meeting Format
  • Preferred Dates and Times (minimum of three)
  •  Planned Attendees
  •  Audiovisual Equipment Needs, if any

Q Sub Type- Day 100 Meetings for PMA Applications

This meeting is to review the status of PMA .

Click here to know more about Guidance on PMA Interactive Procedures for Day-100 Meetings and Subsequent Deficiencies – for Use by CDRH and Industry

References :

Requests for Feedback on Medical Device Submissions: The PreSubmission Program and Meetings with Food and Drug Administration Staff: http://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGu idance/GuidanceDocuments/UCM311176.pdf

 

 

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