De Novo Regulatory Strategy for a First-in-Class PDT

Situation

  • First in class Prescription Digital Therapeutic (PDT) required a credible FDA package despite limited precedent.
  • Evidence was distributed across multiple studies and needed to be packaged into a cohesive submission strategy to achieve a broad label.

Approach

  • Evaluated regulatory pathway options and organized De Novo pathway support.
  • Designed evidence package and submission narrative for FDA engagement.
  • Synthesized findings across three clinical trials.
  • Mined precedent cases to strengthen classification rationale.
  • Developed investor materials aligned to the regulatory story.

Outcome

  • Established a clear regulatory pathway for a novel product category.
  • Improved coherence and defensibility of the submission narrative.
  • Enabled consistent communication across regulatory and investor audiences.