Procedure: Pre-Sub Activities
Country: Global Procedure
Version #: 11/30/2023
Author: Daria Kostiuchenko
Editor: Daria Kostiuchenko

ID: GP-PhR-PSA-SR
Category: Pharmaceuticals
Validity: Until Submission
Certified by: Vlad Reznikov
Copyright: Pattern of USA Inc.

SUMMARY

Pre-Sub Activities refer to the regulatory activities conducted by an National Regulatory Agency (NRA) prior to the submission of a marketing authorization application for a medicinal product.
These activities aim to ensure that the submitted data and documentation meet the regulatory requirements and address any potential gaps or deficiencies before the formal submission of the application, and can include scientific advice, protocol assistance, and qualification of novel methodologies to ensure the quality, safety, and efficacy of medicines before they are approved for market release.
During Pre-Sub activities, the NRA engages in discussions with the applicant to provide guidance and feedback on various aspects of the submission. This includes discussions on study design, data collection, analysis plans, and regulatory requirements. The purpose is to help the applicant understand the NRA’s expectations and requirements, and to ensure that the submission is complete, accurate, and of high quality. This includes FDA CDER’s Pre-Investigational New Drug Application (IND) Consultation Program, also EMA procedural advice, drug designation, PIP-, SA-, ITF-, SME- meetings, etc.

Gp Pharmaceuticals Pre Sub Activities Simplified Regulations Card Gantt Chart Page 0001

Must-Have Requirements, Recognized Standards, and Certifications:

  • POA
  • Questions, Suggestions and Proposals

Nice-to-have:

  • MAs in other countries
  • R&D studies and documents

Typical Gaps and Deficiencies: Incomplete or insufficient data, non-compliance with regulatory requirements, inadequate risk assessment, unprepared meetings and communications with NRA

Implementation Period: Immediately

Deliverables: NRA Advise

PHASE

TASK

TASK

START

DURATION

 

Fee

 

KPI

NUMBER

TITLE

OWNER

W/M/Q/Y

in weeks

3rd Party 

Service 

State

 

0

In-house Pre-Submission Activity

       

  0.1

NDA signing or validation

Executor

week 1

1

    

  0.2

Contract Closing

MAH

week 1

1

    

  0.3

POA issuance and shipping

MAH

week 1

1

    

  0.4

Invoice is sent to MAH and paid

Executor

week 1

1

    

  0.5

Document processing

Executor

week 2

1

    

  0.6

Translations, Notary, and Apostilles 

3rd party

week 2

2

    

  0.7

SOW is approved by MAH

Executor

week 4

1

   

Application

I

Pre-Sub Feedback Request

       

  I.1

Pre-Sub Preparation (documents and data assembling)

MAH

week 5

2

    

  I.2

Requesting pre-submission feedback from NRA

Executor

week 7

1

    

  I.3

Communication with NRA

Executor

week 8

2

    

  I.4

Scheduling pre-submission meeting (online or in-person)

Executor

week 10

2

    

  I.5

Conducting the pre-submission meeting if so

Executor

week 12

2

    

  I.6

Follow-up and further discussions

Executor

week 14

1

   

Decision or Q&A

F

Final Phase In-house Post-Authorization Activity

       

  F.1

Service Acceptance Certificate Signing

MAH

week 15

1

    

  F.2

Final Invoice

Executor

week 16

1

    

  F.3

Final Payment

MAH

week 17

1

    

  F.4

Contract Termination

Executor

week 18

1

    

  F.5

Archiving and limiting access

Executor

week 18

1

   

Archiving

 

Feel free to submit a Request for Proposal (RFP) for a specific country or territory to info@patternofusa.com