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    RegulatoryRegulated PathwaysGlobal MarketsQ-Sub / Pre-Sub

    Q-Submission (Pre-Submission)

    Voluntary mechanism to obtain FDA feedback before a formal premarket submission.

    Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed May 5, 2026

    Definition

    The Q-Submission Program lets sponsors request written feedback or a meeting with FDA on specific questions about a planned device study, submission, or test plan. Pre-Submissions are the most common Q-Sub type.
    What the regulation says
    The FDA

    What this means in practice

    Used to de-risk study protocols, predicate selection, performance test plans, and AI/ML change control plans before investing in execution. Strong Pre-Subs reduce review cycles later.

    Examples

    • A MedTech manufacturer submits a Q-Submission to get FDA feedback on the statistical analysis plan for a novel clinical trial prior to patient enrollment.
    • A company developing an AI/ML powered diagnostic device uses a Pre-Submission to discuss its algorithm change control plan with the FDA to ensure compliance with the agency's evolving guidance on AI/ML in MedTech.
    • Before conducting extensive biocompatibility testing, a device developer uses a Q-Submission to confirm with the FDA that the proposed test battery and materials are acceptable.
    Common pitfalls
    • Misunderstanding the FDA's expectations for Q-Submission content can lead to unproductive interactions and delays.
    • Failing to clearly articulate specific questions in a Q-Submission may result in general feedback that does not address the sponsor's core concerns.
    • Submitting a Q-Submission too late in the development cycle may limit the ability to incorporate FDA feedback effectively.
    • Not adequately preparing for a Q-Submission meeting, such as failing to provide pre-read materials or clearly define meeting objectives, can diminish its value.

    Frequently asked questions

    Sponsors can request written feedback or a meeting to discuss various topics, including planned device studies, submission strategies, or specific test plans. This feedback helps clarify FDA expectations and potential regulatory pathways.
    Shared paths + category

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    Primary references

    3 sources
    Link health: 3 verified· last checked 2026-06-20
    FDA·2European Commission·1
    1. 1
      Q-Submission Program
      Verified
      FDAfda.gov
    2. 2
      FDA - Medical Devices
      Verified
      FDAfda.gov
    3. 3
      European Commission - Medical Devices
      Verified
      European Commissionhealth.ec.europa.eu

    Inline markers like [1] jump to the matching reference above.