Home Forums Where do I file…. ? FDA mandatory Diversity Plan

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    • #5122
      Debra Wells
      Participant

      Hi – where are folks filing the mandatory FDA Diversity Plan? Is there a place in the TMF Ref Model established or planned?

      Thanks as always!

    • #5123
      Eldin Rammell
      Participant

      Hi Debra,

      In general, the proposed Diversity Plans will not be trial-specific but will rather be plans across a product development program. On this basis, I suggest they would not be expected to be filed in the Trial Master File.

      Were a trial-specific Diversity Plan to be created, my suggestion would be to file under 01.01.02 Trial Management Plan on the basis that its purpose is aligned with the definition/purpose of this artifact

      or 03.01.01 Regulatory Submission on the basis that it is a trial-related document that is submitted to a regulatory agency (filed to the IND).

      The draft guidance seems to suggest that its use will be recommended rather than mandatory, though it does sound as though the FDA are being pressurized to mandate its use.

      Any thoughts from others?

      Kind regards,
      Eldin.

      • #5127
        Debra Wells
        Participant

        Thanks, Eldin. Your opinion was in line with mine as well.

        As an FYI, we are learning that this has been requested during inspections by FDA already, to some of the larger pharma.

        Thanks again.

    • #5134
      Donna Dorozinsky
      Participant

      Hi Debra and Eldin, I would agree. I think filing this with the Trial Mangement Plan makes sense. If you system allows you to file to multiple studies at one time, but might be a good option.
      Kind regards,
      Donna

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