Does the definition of Applicable Clinical Trial under FDAAA 801 only include studies conducted under an FDA Investigational New Drug Application (IND) or Investigational Device Exemption (IDE)?

No. A clinical investigation of a drug can be an Applicable Drug Clinical Trial under FDAAA 801 even if it does not require an IND, and a clinical investigation of a device can be an Applicable Device Clinical Trial whether or not an IDE is required.

See Elaboration of Definitions of Responsible Party and Applicable Clinical Trial (PDF) for more information.