The 2 new MaPPs: 5200.4 Criteria and Procedures for Managing the Review of Original ANDAs, Amendments and Supplements and 5240.3 (a revision of the old 2006 MaPP entitled Review Order of Original ANDAs, Amendments and Supplements) Prioritization of the Review of Original ANDAs, Amendments and Supplements were released today by FDA. These two MaPPs describe how the Office of Generic Drugs (OGD) will prioritize review of ANDAs.
Although Office of Generic Drugs (OGD) total activity numbers (including issuance of Complete Response Letters (CRLs), etc.) will not be posted until about 2 weeks after the close of the month, it is disappointing that the number of approvals this late in the month appears only in the teens.
While there are many things going on at OGD (training of new staff, Guidance and Policy development, the reorganization to a Super Office, among other important things) the bottom line for industry is the number of approvals that OGD issues and the number and timeliness of OGD deficiency responses it receives. But approvals rule the roost in terms of industry importance because, after all, you cannot sell products that receive CRLs.
In previous post earlier this week, we were hoping to discover the Agency position on this particularly important issue. Thus, the Agency has decided to make a bright line of June 20, 2014 as the start date for the requirement for 3 batches with 6 months room temperature and 6 months of accelerated stability at time of original submission.
The Office of Generic Drugs’ (OGD) elevation to a Super Office in the Center of Drug Evaluation and Research has come at a challenging time for the Generic Drug Program. The new Office structure is presented below and represents a dramatic organizational change to us old timers. But this is progress and represents the need to move the program in a different direction for today’s environment.
If you are one of the about 600 ANDA applicants submitted in the first 19 days of June, or have one of the additional ~ 100-200 ANDAs that have not yet received notification of acceptance for ANDAs submitted prior to June 2014, a decision is expected soon on what stability requirements you will need to meet upon resubmission.
With 9 months gone in FY 2014 and the June Generic Drug Activity Report just released, things don’t look so good! The June ANDA submissions not only beat any previous one-month total ever, but shattered the previous record by almost 275%. The big problem when looking at the numbers in the Activity Report is not only seen in the number of ANDAs submitted, but also in the disturbing trend in the numbers in general.
The FDA announced today that the total collectable amount of fees under the GDUFA program (adjusted for inflation and salary increases) will be $312,224,000, up from the original $299 million that was authorized for year 1 of GDUFA. The good news/bad news is that ANDA and PAS fees decreased.
The FDA announced the availability of two Guidance documents – on Prior Approval Supplements and the other concerning Easily Correctable Deficiencies (ECDs). These eagerly anticipated documents have also published on the CDER web page.
The FR notice states relative to the Prior Approval Supplements (PAS) Guidance that “this draft guidance is intended to assist applicants preparing to submit to FDA PASs and amendments to PASs for abbreviated new drug applications (ANDAs). It describes FDA’s performance metric goals for PASs and clarifies how FDA will handle a PAS and amendments to a PAS for an ANDA subject to the GDUFA performance metric goals.”
If you think the just-issued prior approval supplement (PAS) Draft Guidance was complex, wait until you read this one! Entitled “ANDA Submissions – Amendments and Easily Correctable Deficiencies under GDUFA”, the document:
One of the hottest topics over the last few years has been that of drug shortages and what to do about them. The FDA video explains that the Food and Drug Administration Safety and Innovation Act (FDASIA) made important changes to the way industry must report drug shortages.
The FDA is proposing to update its list of drug products (previously found in its regulations at 21 CFR 216.24) that have been removed from the market for safety or efficacy and cannot be legally compounded. It has also revised one product relative to its dosage form that allows compounding under the pharmacy compounding exemption. Since FDA has approved an ophthalmic form of bromfenac, it has removed the restriction to now permit the compounding in certain situations for this drug product but only for ophthalmic use, whereas this drug was previously excluded for any use by the Rule.
I was asked by a reporter how the Office of Generic Drugs (OGD) and FDA were going to respond to the overwhelming number of abbreviated new drug applications (ANDAs) that have been submitted not only in June of this year, but to the record numbers of ANDA submissions in since 2012.
The Office of Generic Drugs (OGD) confirmed today that the rush to get ANDA applications into the Agency before the new stability requirements go into effect on June 20, 2014 flew past all estimates and landed at just under 600 (the unofficial count is 598). OGD was shocked by the number of submissions with many there predicting a figure around 350. The rush was certainly on with a total of about 370 ANDAs submitted in the last 4 business days leading up to the June 20 deadline. One positive comment from OGD was at least we know the Electronic Gateway can handle the volume!
The Generic Pharmaceutical Association (GPhA) commissioned a survey organization (PublicMind) to poll physicians, physician assistants and pharmacists about how much they knew about the proposed generic drug labeling rule, how it would impact their practice (if at all), and how they felt about the current system of how generic drug labeling is approved by the FDA. The survey had some interesting results, which are summarized below.
The Health and Human Services published its semiannual regulatory agenda and guess what popped up on review? The proposed date of finalization of the Rule on label changes that can be made by an ANDA holder relative to newly acquired safety information is listed as December 2014.