There are two main aspects to FDA’s review policies and procedures:
- Acceptance should not be based on a substantive review of the information provided in the De Novo request. The acceptance review is merely conducted to assess whether the De Novo request contains all necessary elements, not the adequacy of the information provided. Evaluation of quality only occurs after the request has been accepted.
- FDA staff should determine whether the requester provided a justification for any alternative approach. The De Novo requester may provide rationale for why a certain criterion is not applicable to the device, and it is the FDA’s job to determine whether or not this is true.