Well after the first 5 years of GDUFA I, we now have a comparative look at all 5 years for various metrics reported by the FDA in their Activities Report of the Generic Drug Program. In the chart below the 5- year highs are bolded and some trends can be seen. For instance, the number of post CRL meetings was highest in year two of the GDUFA program. Perhaps as firms better understood the comments received the need for post CRL meeting was tempered.
Other notable items include:
- RTRs increased as guidance became available and OGD began enforcing its contents more strictly. Albeit the number almost halved in year 5 of the program. Does this mean sponsors are learning?
- Withdrawals are higher in the last two years of the program possibly because of all the M&A activity, or, because firms were paring down their applications to gain a lower tier in the GDUFA II program fee structure (end of year 5). Probably a combination of both.
- Approvals continue to climb with new highs hit in the last three years of GDUFA I
- CRL appear to have declined over the last two years and this is thought to be due to the increase in approvals. As I have mentioned in previous posts, when CRLS go down approvals seem to go up!
- ANDA receipts surprised everyone. We know what the big bump was in FY 2014 with the new stability requirements and firms beating the clock by making submissions before the new requirements took effect. But the 2017 numbers are high because firms tried in part to beat the new GDUFA II ANDA fees. Over all the pace of ANDA submission is well above FDA estimates.
- DMF completeness review decrease over time to be expected, as fewer new DMF are introduced into the system.
- Controls are skyrocketing – I assign two reasons to this, 1) firms don’t want to get it wrong and 2) they are seeing things in the OGD reviews that they have never seen in previous reviews. As one sponsor noted we asked a lot of “nice to know questions but not need to know for approval”.
|Refuse to Receive||150||173||236||246||142|
|DMF Completeness Rev||1699||1706||880||886||820|
|Post CRL Meeting Request||23||717||56||36||30|
NA- not reported in the same format as later years so omitted from this chart
So there you have it. GDUFA I in a single table and although these metrics don’t come close to telling the entire story they certain are fun to look at and speculate about!