<img alt="" src="https://secure.perk0mean.com/171547.png" style="display:none;">
CALL US +44 (0)1462 440 084 | +1 919-882-2016 | Contact | Submit RFI

Regulatory Submission Review

Looking to increase your first-time approval submission rate?

“FDA makes data-driven regulatory decisions based on the information submitted in the Sponsor's application. The quality and integrity of the submitted data are essential for FDA’s review process.” - Ethan Chen, Director FDA CDER

At Quanticate we provide three services to help assure that a regulatory submission isn’t needlessly delayed through a lack of quality or integrity of data submitted to the FDA or other regulatory authorities.  These are a critical review of:

Can you Afford Risking a Delayed Regulatory Submission?

Before the FDA start reviewing a submission, your submission must first overcome the new hurdle of ensuring that it conforms to the standards required in the FDA Data Standards Catalog. 

“The FDA may refuse to file for New Drug Applications (NDAs) and Biologics License Applications (BLAs) or refuse to receive for Abbreviated NDAs (ANDAs) any electronic submission whose study data do not conform to the required standards specified in the FDA Data Standards Catalog.”  - FDA

In a recent analysis conducted by the FDA, 32% of submissions with study data had critical data conformance issues

When a submission is rejected for lack of study data conformance, the submission sequence is not even transferred from the FDA Electronic Submission Gateway into the FDA electronic document rooms where the FDA Review process officially starts!

Then only 50% of new NME/IND applications that passed the screening process for study data conformance are approved on first submissions by the FDA.  There is a median delay of 435 days to approval following the first unsuccessful submission and 24% of the first-time submission failures include inconsistent study results either across endpoints or sites and studies.

Re-submission of failed applications is costly, delaying marketing approval as the process needs to start again with increased timelines, and delaying the availability of vital new drugs to patients.

 

The efficacy associated reasons for failed first-time submissions are:

Efficacy_icon

Poor efficacy when compared with the standard of care

dose icon

Uncertainties related to dose selection

different end points

Choice of study endpoints that fail to adequately reflect a clinically meaningful effect

inconsistent results endpoints

Inconsistent results with different end points selected

missing data icon

Study conduct due to missing data and/or data integrity issues

inconsistent results sites trials

Inconsistent results when different trials or study sites are compared

How to Reduce the Risk of a Delay?

Quanticate provide a hierarchy of services by reviewing your submission content to:

  • Ensure that data are formatted and submitted according to the correct data standards
  • Uncover atypical data patterns within or across studies that act as a red flag warning to investigate further for an FDA Reviewer
  • Investigate the influence of atypical data patterns on the robustness of the submission efficacy and safety conclusions

As a customer you choose whether to make use of all or just some of the services provided by us:

 

Study Data Conformance

Quanticate offers CDISC Compliance services and CDISC mapping expertise across multiple situations. When reviewing submission data our team will ensure that CDISC standards are met before the submission is sent with support on:

  • SDTM Compliant Datasets and supporting documentation (define.xml, cSDRG, aCRF)
  • ADaM Compliant Datasets and supporting documentation (define.xml, ADRG)
  • Integrated summaries
  • eCTD Compliance

Quanticate are vigilant in keeping up-to-date with the latest CDISC, regulatory and other news, such as PhUSE guidance to ensure that you have the latest accepted standards applied and comply with the FDA Data Standards Catalog.

 

Data Quality Oversight

Quanticate provide a Data Quality Oversight (DQO) service to examine the quality and fitness of the data package associated with the submission.  Quanticate has selected the industry leading FDA endorsed software of CluePoints to perform its DQO analysis.  We use CluePoints’ machine learning functionality to detect spurious data patterns both within and across studies.  If appropriate, we also use software such SAS JMP for further statistical investigation. DQO enables the quick identification of outliers and inconsistencies across studies which can then be addressed to improve data quality.

CluePoints Logo_for_web SAS_JMP

 

Statistical Review of Submission Data

Our biostatisticians review the impact of anomalies and missing data on the results of the submission in an attempt to pre-empt the regulatory reviewer’s likely comments so that they can be addressed in the initial submission. 

In addition, we can broaden the review to:

  • Review of the distribution and balance of the study populations across studies, sites and regions
  • Confirm populations are as defined in protocol
  • Analyse the consistency of efficacy analyses across studies, sites, regions, populations and timepoints
  • Review dosing evidence used to justify the dosing decision
  • Examine appropriateness of endpoints, by reviewing existing regulatory guidance and relevant literature
  • Understand confounding factors, for example use of concomitant medication
  • Review distributions of adverse events, including, for example, severity, seriousness and death across studies, sites, regions and populations
  • Check for dose-related toxicity effects
  • Determine whether correct interpretations have been made along with robustness of conclusions

Quanticate will work with you to determine the level of service you need to assure that your submission is ready for review by the regulatory authority.

Please submit an RFI or speak to a member of our team to learn more about our Regulatory Submission Review  services and discover how our biostatisticians can support the first-time submission of your clinical study. 

Submit a Request for Information 

Latest Blogs on Regulatory Submissions

cdisccdisc-provider uk-business-awards-2017 cro-leadership web-catalyst-pharma-top-10-2016 investors-in-people