Pre-Submission Meeting
Formal FDA feedback request prior to a marketing or IDE submission.
Definition
A Pre-Submission (Q-Sub) is a formal mechanism to obtain written FDA feedback on questions related to a planned IDE, 510(k), De Novo, or PMA submission, including study design, predicate selection, and testing strategy.What this means in practice
Strongly recommended for novel devices, AI/ML SaMD, and any submission with non-obvious questions. Free, but timeline (~70–75 days) must be planned into program schedule.Examples
- A startup developing a novel AI-powered diagnostic tool schedules a Pre-Submission meeting to discuss their clinical study design and data requirements with the FDA before initiating patient recruitment.
- A medical device manufacturer planning a 510(k) submission for a modified device uses a Pre-Submission to clarify which performance testing standards are applicable and sufficient for demonstrating substantial equivalence.
- A company seeking De Novo classification for a low-to-moderate risk device without a predicate uses a Pre-Submission to discuss the proposed special controls and risk mitigation strategies with the agency.
- •Assuming the FDA’s feedback in a Pre-Submission is a guarantee of future submission approval, as feedback is non-binding.
- •Failing to prepare a comprehensive and well-organized meeting package, leading to less effective feedback from the FDA.
- •Submitting a Pre-Submission too early in the development process without specific questions or data to discuss, making the interaction less productive.
- •Neglecting to follow up on the FDA’s feedback provided during the Pre-Submission when preparing the actual marketing submission.
- •Using a Pre-Submission solely as a progress check without clear, specific questions for the FDA to address.
Frequently asked questions
Related terms
Grouped by themeEditor's picks
· Hand-selected related conceptsFDA submission demonstrating a device is substantially equivalent to a legally marketed predicate.
Pathway to classify novel low- to moderate-risk devices that lack a predicate.
FDA's most stringent device marketing application, required for high-risk Class III devices.
FDA authorization to use an investigational device in a clinical study.
De Novo & Breakthrough Pathways
· From this learning pathFDA program providing expedited review for devices that treat life-threatening or irreversibly debilitating conditions.
Voluntary mechanism to obtain FDA feedback before a formal premarket submission.
Product comprised of two or more regulated components - e.g., drug-device, biologic-device.
Description of the disease or condition the device will diagnose, treat, prevent, cure, or mitigate.
Primary references
3 sources- 1
FDA Q-Sub guidanceVerifiedFDAfda.gov
- 2
AdvaMed Code of EthicsVerifiedAdvaMedadvamed.org
- 3
AHRMM - Healthcare Supply ChainVerifiedAHRMMahrmm.org
Inline markers like [1] jump to the matching reference above.