Under the interim regulations, personnel were allowed to attest to training, education, or experience that was earned before October 1, 1994. Under FDA’s final regulations, will this still be allowed? What about attestation for training or experience earned between October 1, 1994 and April 28, 1999?
In general, personnel may continue to attest to training, education, and experience earned before October 1, 1994, except for the 3-month training alternative to board certification for physicians. Attestation also may not be acceptable for board certification, licensure, or State approvals. FDA generally does not intend to accept attestation for training, education, or experience obtained after October 1, 1994, including training, education, and experience for personnel qualifying after April 28, 1999.