Every stalled submission has a different story—but most require targeted remediation across these key dimensions:
Scientific and Clinical Data Gaps
-
Missing or insufficient statistical analyses
-
Safety signal concerns and risk characterization
-
Subgroup inconsistency, unblinded data, or endpoint ambiguities
-
Clinical data reorganization to improve narrative flow and clarity
-
CMC and Manufacturing Issues
-
Incomplete process validation, inadequate stability data
-
CMC module inconsistencies with facility capabilities
-
Gaps in batch records, raw material control, or comparability data
-
Coordination with manufacturing teams to close readiness gaps
-
Data Integrity and Submission Quality
-
Discrepancies between datasets and summary documents
-
Part 11/e-source compliance concerns in eCTD files
-
Data traceability issues or improper data pooling
-
Corrections and re-verification of source-to-submission linkages
-
Strategic Repositioning
-
Reframing regulatory pathway (e.g., de novo vs. 510(k))
-
Updating the predicate rationale or clinical bridging strategies
-
Reassessing approval endpoints and risk/benefit positioning
-
Supporting narrative redesign to address FDA tone and concerns
-