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Inspection Decision Scenarios Investigation Closure Decisions

FDA Inspection Decision Scenario

Who Authorized the Complaint Investigation Closure?

21 CFR 211.19821 CFR 820.198

What FDA investigators are actually asking

FDA Investigator Question

"Who made the determination that this complaint investigation was complete and that no further action was required?"

Inspector's Line of Inquiry

When investigators ask this question, they typically follow with:

  • Who reviewed the investigation findings before the closure decision was authorized?
  • What MDR or reportability analysis was conducted and who made that determination?
  • What regulatory standard governed the decision that no further action was required?
  • What findings would have required a reportable event determination?
  • When was the complaint closure authorized, and who is named as the decision owner?

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The authorization gap this scenario reveals

The investigator is reviewing a closed complaint file. The complaint was received, investigated, and closed. The investigator asks who authorized the closure — not who documented it.

Authorization Gap

The complaint record documents the investigation steps and conclusions. It does not document who made the formal authorization that the investigation was sufficient and that no reportable event had occurred. This is the authorization gap: the decision was made, but it was never documented as an authorization event — with a named decision owner, the evidence reviewed, the regulatory standard applied, and a timestamped record of when the authorization occurred.

What evidence the investigator expects

Organizations operating with authorization infrastructure produce this record at the moment the decision is made.

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These gaps are not documentation failures. They are authorization failures. The Authorization Assessment maps exactly where your decision trail is missing these elements.

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Authorization Assessment

Which of your decisions
have an authorization gap?

The Authorization Assessment identifies where your compliance decisions are undocumented as authorization events — the exact gap inspectors expose in scenarios like this one.

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Inspection Case Files document the authorization gap in detail — showing exactly what a Decision Defense Record resolves and what inspectors expect to see.

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