About the Author
Proxima CRO Team
Isabella Schmitt, MBA, RAC
Director of Regulatory Affairs
Ms. Schmitt has also served in additional regulatory affairs and clinical research roles in which she contributed to multiple regulatory submissions and clinical affairs projects across a wide range of indications.

In addition to the general information that should be included in a cover letter for any Q-Sub type to ensure appropriate login and submission tracking, a Study Risk Determination Request should include the protocol for the proposed clinical study.

There is no Acceptance review for a Study Risk Determination request. Once a determination is made, FDA will issue a letter to the submitter indicating whether the study is exempt, or, if not exempt, is considered Significant Risk (SR) or Not Significant Risk (NSR). You may copy the letter to submit it to IRB(s) with the protocol. Once FDA has made a determination, the IRB does not need to conduct an independent assessment of risk; FDA’s determination is final.

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