I'd like to get your thoughts on the current timelines. Do you think Auricle is on track with their progress? Specifically, I'm wondering if it's normal for a clinical trial to be completed in 2022, a paper to be published in mid-2023, and for them to be hesitant about disclosing their planned FDA submission dates. I'm trying to determine if their pace is typical or if they might be moving slowly.
Thanks!
It's impossible to tell if they're on track. In my experience with
preparing a regulatory submission, and bearing in mind that the company I work for has around 100 full-time regulatory experts, internal timelines always either go overdue or you make it by a matter of hours. And that's from a global $9B+ turnover company. As I said, Auricle most definitely does not have the resources or the headcount to make water-tight milestones, and I think that's why they've removed any mention of these.
We never disclose our regulatory timelines or progression externally. While there are no rules about it, many regulators do not appreciate it as any delays in the approval process, or god forbid a rejection, look like it's the regulator's fault as an announcement you've submitted can sometimes be viewed as an overconfident "it's only a matter of time until we're approved." In the past 6-8 months, the FDA has not consistently met its own internally recommended timelines.
A lot of scientific investigation reports are just not suitable for a regulator either. You might have to re-write years' worth of data to remove sections (sometimes less is more to a regulator) or completely reformat it into a regulatory-friendly layout. You don't want to leave something in a development report that the regulator asks for more detail on, and it's totally irrelevant, so you remove it. Re-doing these reports takes time, and going back through your internal approval process for these also takes time. Nothing moves fast.
As anecdotal as this is, here's a little story from my company's start of this year. One of our gas chromatography/mass spectrometry instruments within our lab failed suddenly and was beyond repair. This instrument is used to control raw material quality in one of our manufacturing processes. It's absolutely critical to the business. We managed to procure a brand new, absolutely identical instrument from the supplier and carry out all of our required internal validation and verification activities within three weeks; we had scientists working around the clock confirming installation qualification, operational qualification, performance qualification, and test method migration from the old system—an enormous amount of work.
It then took our regulatory department 2.5 months to prepare a notification (note: notification, NOT a submission) to the FDA to inform them that one of our quality control instruments had been swapped for a like-for-like model and validated.
The regulatory business is slow.
So, in my opinion, Auricle is up against it. I don't know exactly who they're working with, but even regulatory consultants are slow as they don't have the knowledge and history with the device the development team does. But, again, this is just my opinion; there is absolutely nothing I can see that will stop this from getting approval. It's just a time game.