Sponser Meeting with FDA some facts

There are many meetings which a sponser can have with FDA related to the product being developed and to be approved by FDA. But it can be categorized in to 3 base categories.

Type A: Critical Path (Urgent) meetings – Clinical hold, Safety Issues, Site disqualification, etc (within 30 days)
Type B: Procedural meetings – Pre-IND meeting, EOP2, pre-NDA, etc (within 60 days)
Type C: Miscellaneous meetings – CMC issues, mid-P3, early-review, mid-review, etc ( within 75 days)
Formal meetings are not the only way you communicate with the FDA: comment requests, emails, telecons with the RPMs, etc.

Why meeting FDA?

  • Sponsors have the right to request a meeting with the FDA review division.
  • These meetings are specifically to help prescription drug approvals
  • Not granted if FDA perceives that an IND is not being planned
  • More for issue resolution while product development than scientific rationale
  • Clarification and discussion, not “interrogation”
  • Pre-submission meetings (pre-IND, EOP2, pre-NDA) meetings are considered critical by FDA compared to mid-cycle meetings (mid-P3, mid-review, etc)

Time for meeting

  • Developed “final product” idea
    • Finished formulation
    • Target indication(s) and population(s)
  • CMC information
    • Characterization
    • Manufacturing and packaging (cGMP)
    • Stability studies
  • Basic non-clinical studies (GLP)
    • Acute and sub-acute toxicology
    • Pharmacology
    • In vitro toxicity tests
  • Ready to initiate clinical studies
  • Have sufficient GMP level investigational product
  • The pre-clinical studies demonstrate MTD, NOAEL, major expected adverse events
  • Scientific rationale for mechanism of action is available
  • Clinical development plan is proposed