FDA launches interactive, PDF-based template to promote greater efficiency and consistency in preparation and review of 510(k) medical device applications

The US Food and Drug Administration (FDA) has announced the voluntary electronic Submission Template And Resource (eSTAR) pilot programme as an alternate method available for selected industry participants in the pilot to prepare a 510(k) submission. The FDA will select up to nine participants who provide a holistic representation of the medical device industry and meet the pilot selection criteria.

As technology advances, the FDA must keep pace with the increasing complexity of rapidly developing technology and continue to modernise and evaluate its programmes and processes, ensuring they continue to be efficient, consistent and scientifically rigorous, Jeffrey Shuren, MD, JD, director of the FDA’s Center for Devices and Radiological Health has said.

He further added, “To promote these goals, we’re launching a new optional 510(k) submission template that allows pilot participants to submit applications to the FDA using a more dynamic electronic format capable of organising the complex information necessary for a robust scientific review. Without changing our statutory or data requirements, this highly-interactive submission template is intended to allow manufacturers to provide information to the FDA that’s complementary to CDRH internal review templates currently used to review 510(k)s, allowing us to receive information and evaluate the submission more efficiently and consistently.”

With an eSTAR, the content of the premarket submission is embedded within a PDF document, which allows applicants more dynamic functionality when developing, viewing and editing a 510(k). eSTAR templates are designed and structured in a similar format as the FDA reviewers’ template, thereby improving consistency in FDA’s review of these premarket submissions.

“The template, referred to as the electronic Submission Template And Resource (eSTAR), will be released as part of an eSTAR pilot programme. eSTAR is intended to improve our overall productivity, enabling the agency’s review staff to put more of our time and resources into evaluating applications for devices that pose the highest potential risks to patients. Additionally, eSTAR is a step towards fulfilling our Medical Device User Fee Amendments of 2017 (MDUFA IV) commitment to streamline the premarket notification review submission process, which is also part of the FDA’s ongoing effort to ensure that we’re giving patients more timely access to safe, effective and high-quality medical devices,” said Shuren.

Submissions using an eSTAR do not change any statutory or data requirements for device sponsors to demonstrate their devices are substantially equivalent to a predicate device. However, a Refuse to Accept review (a preliminary review used to ensure the submission is complete) will not be conducted on eSTAR templates submitted as part of the pilot.