This document outlines the performance goals and requirements for submitting Prior Approval Supplements (PAS) under the GDUFA III agreement between the generic drug industry and the FDA. It categorizes changes to approved applications as major, moderate, or minor and specifies varying submission timelines and inspections based on these classifications. Additionally, it addresses grouped supplements, incorrect reporting categories, and the appeal process if an applicant disagrees with FDA's determinations.

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Why this guidance published?
Under the GDUFA III commitment letter, the generic drug industry and
FDA have agreed to certain performance goals, including those
applicable to PASs.
This section describes the specific performance goals that apply to PASs
and amendments to PASs submitted to ANDAs. .
Exemptions
The GDUFA performance goals do not apply to
• NDAs and their supplements
• BLAs and their supplements
• CBE and their supplements and amendments to CBEs for ANDAs
• Annual Report Filings to NDAs, BLAs, or ANDAs.

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A. Changes to an Approved Application
1. Major Change: a change that has a substantial potential to have an
adverse effect on the identity, strength, quality, purity, or potency of a
drug product as these factors may relate to the safety or effectiveness
of the drug product.
A major change requires the submission of a PAS and approval by FDA
before distribution of the drug product made using the change.

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A. Changes to an Approved Application
2. Moderate Change: a change that has a moderate potential to have an
adverse effect on the identity, strength, quality, purity, or potency of a drug
product as these factors may relate to the safety or effectiveness of the drug
product.
Depending on the nature of the change, one of the following two types of
supplements must be submitted to FDA for a moderate change:
- Supplement – Changes Being Effected in 30 Days (CBE-30
supplement):
A CBE-30 supplement involves certain moderate changes that require
the submission of the supplement to FDA at least 30 days before the
distribution of the drug product made using the change.
- Supplement – Changes Being Effected (CBE-0 supplement):
A CBE-0 supplement involves certain moderate changes that allow
distribution to occur as soon as FDA receives the supplement.

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A. Changes to an Approved Application
3. Minor Change: a change that has minimal potential to have an
adverse effect on the identity, strength, quality, purity, or potency of a drug
product as these factors may relate to the safety or effectiveness of the
drug product.
The applicant must describe minor changes in its next annual report.
The criteria for submitting information as a PAS, as a CBE, or in an annual
report were not changed by GDUFA.
This guidance does not discuss the various criteria that apply in determining
the respective reporting categories for these supplements.
For additional information on these reporting categories, referred to:-
Scale-Up and Post-approval Changes (SUPAC) and
Changes to an Approved NDA or ANDA

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B. GDUFA Performance Goals for PAS Submissions
The performance goals for assessing and acting on PASs have not changed
from the GDUFA II commitment letter to the GDUFA III commitment
letter Specifically, under the GDUFA III commitment letter, FDA agreed to
the goals outlined as follows:

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B. GDUFA Performance Goals for PAS Submissions
The performance goals for assessing and acting on PASs have not changed from the
GDUFA II commitment letter to the GDUFA III commitment letter Specifically, under
the GDUFA III commitment letter, FDA agreed to the goals outlined as follows:

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B. GDUFA Performance Goals for PAS Submissions
Notes:
• GDUFA defines the date of submission as the date a generic drug
submission (such as an ANDA, ANDA amendment, or ANDA prior
approval supplement) arrives in the Electronics Submissions Gateway
(ESG) of FDA.
As described in the GDUFA III commitment letter, FDA will calculate the
goal date from the day after a submission.
• Filing an unsolicited amendment to a PAS may revise the existing goal
date associated with that PAS.
• FDA will assess and act on unsolicited PAS amendments submitted during
the assessment cycle by the later of the goal date for the original PAS
submission/solicited amendment or the goal date assigned in accordance
with the above goals for standard and priority PAS amendments FDA will
assess and act on unsolicited PAS amendments submitted between
assessment cycles during the next assessment cycle by the later of the goal
date for the subsequent solicited amendments or the goal date assigned in
accordance with the above goals for standard or priority PAS amendments.

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C. Inspections for PAS Submissions
GDUFA goal date for a PAS depends on whether the PAS requires an inspection.
If a PAS does not require an inspection, the goal date is either 4 or 6 months from
the date of submission;
but if a PAS requires an inspection, the goal date is either 8 or 10 months from the
date of submission.
Determining whether an inspection is required for a PAS is within the discretion of
FDA and depends on the nature of the supplement.
Any submitted PAS that requires an assessment of the need for an inspection,
including, for example, a PAS involving a facility not approved in the original ANDA
or involving a fundamental change in the manufacturing process or technology, will be
treated initially as a PAS requiring an inspection and will be assigned an 8 or 10-
month GDUFA goal date; however, the GDUFA goal date can be revised to 4 or 6
months if it is later determined that an actual inspection is not required for that PAS.
Conversely, an initial goal date of 6 months occasionally may change to a 10-month
goal date if, during the assessment, FDA determines an inspection is necessary.

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D. Submission of Supplements
Any PAS to an approved ANDA should identify on the first page of the submission that
it is a PAS. To facilitate processing, FDA recommends that the applicant provide the
following information on the first page of the submission:
1.Indicating whether the PAS is for a new-strength product
2. Indicating whether the PAS is for a request for proprietary name assessment
3. Indicating whether the PAS is for a Risk Evaluation and Mitigation Strategy
(REMS) or a REMS modification
4. Indicating whether the submission is an amendment to a PAS, and if so, whether it is
a major or minor amendment.
5. Indicating whether the PAS contains any manufacturing or facilities changes
6. A list of the specific assessment disciplines to assess the PAS (Chemistry,
Biopharmaceutics, Labeling, DMF, Bioequivalence, Microbiology, or Clinical)
7. If expedited assessment is requested, the label Expedited Review Request should be
placed prominently at the top of the submission. The submission should include a basis
for the expedited assessment request
8. If the submission is part of a grouped supplement, identifying the additional
submissions for the same/identical proposed change(s)” should be added. This request
would greatly facilitate OPQ’s identification of grouped supplements).

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E. Other Matters
1. Grouped Supplements
Grouped supplements are multiple supplements submitted to ANDAs by a
single applicant for the same chemistry, manufacturing, and controls (CMC)
change to each application. Referred to MAPP Review of Grouped Product
Quality Supplements.
In addition to grouped supplements, there are alternative ways of submitting
multiple PASs for the same change.
For example, for some changes (e.g., widening of an approved specification
or introduction of a new API supplier), once a PAS is submitted and approved
for the lead ANDA, subsequent supplements for the same change to other
ANDAs may be classified as CBE-30s.
The Agency recommends that applicants contact the appropriate assessment
division beforehand to ensure the change is appropriate for a PAS followed by
a CBE-30, or if there are specific questions regarding this alternative.

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E. Other Matters
2. Incorrect Reporting Category
If FDA finds that a supplement submitted as a CBE supplement should have
been submitted as a PAS, it will notify the applicant. The applicant is not
required to withdraw the CBE supplement because when FDA sends a letter
explaining that the applicant’s submission is not accepted as a CBE supplement,
FDA administratively closes the CBE supplement, and it is considered
withdrawn. The applicant may resubmit the supplement as a PAS and the
GDUFA performance goals will apply to that PAS.
3. Reconsideration of Incorrect Reporting Category Determination
An applicant may request reconsideration of FDA’s supplement reporting
category determination. If an applicant disagrees with the outcome of the
reconsideration, the applicant may initiate a formal appeal. Any applicant
seeking an appeal above the division level should first seek reconsideration at
the division level.

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