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Pre-Subs (Q-Submissions) in plain terms

Draft, not yet reviewed by a regulatory professional. Written from FDA's published guidance, which is cited below; read the guidance itself before you rely on any of it.

A Pre-Submission (Pre-Sub) is the most common kind of Q-Submission: you send FDA specific questions about a planned submission and get written feedback, optionally with a meeting. It has no user fee, and it is the cheapest way to avoid a surprise at review.

What to ask

Specific questions FDA can answer from your package: is this predicate appropriate, is this test plan adequate, does this clinical study design address the risk, are these proposed special controls right for a De Novo. "Will you clear my device?" isn't one; FDA won't pre-decide a submission.

What goes in the package

A cover letter, the device description and intended use, the regulatory history, the planned submission, and for each question the background FDA needs to answer it: protocols, rationale, the data you have so far. Fewer, sharper questions get better answers.

Timing

FDA aims to send written feedback within 70 days of receipt, or at least five days before a scheduled meeting, whichever is sooner. You can ask for a meeting by teleconference or in person. Afterwards you send meeting minutes, and FDA confirms or edits them.

Other Q-Submissions

The same program carries Breakthrough designation requests, study risk determinations, informational meetings and submission-issue meetings after a deficiency letter.

Sources

  • Requests for Feedback and Meetings for Medical Device Submissions: The Q-Submission Program (FDA guidance)

General information, not regulatory advice. FDA decides every classification and submission; confirm your route with FDA (a Pre-Sub or a 513(g)) or a qualified regulatory professional. Fees and review goals are planning figures; check FDA's current schedule.

More: Choosing an FDA pathway · Traditional, Special or Abbreviated 510(k) · De Novo in plain terms · 513(g) requests in plain terms · The Breakthrough Devices Program

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Regulatory Copilot is a documentation and workflow tool; it does not provide legal or regulatory advice or guarantee any FDA outcome. Fees, timelines, and requirements shown are illustrative planning estimates. Confirm current requirements with FDA and a qualified professional.

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