Hi Bharath,
Yes, it’s OK! to submit observational study data to FDA without EX domain.
It is always a good practice to communicate to your FDA reviewers in advance about your proposed plan. There are two major options:
- Use Study Data Standardization Plan (https://www.pinnacle21.com/blog/how-prepare-study-data-standardization-plan-sdsp-fda)
- Email your question to FDA eData team at cder-edata@fda.hhs.gov (https://www.fda.gov/drugs/electronic-regulatory-submission-and-review/study-data-submission-cder)
EX domain is not applicable in some observational studies. Current CDISC and FDA validation rules are designed for clinical trials. Recently CDISC has started addressing this issue of limited standards support for observational studies. See https://www.lexjansen.com/phuse-us/2019/si/SI08_ppt.pdf
Kind Regards,
Sergiy