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.

Must-Have Requirements, Recognized Standards, and Certifications:
- POA
- Questions, Suggestions and Proposals
Nice-to-have:
- Regulatory Intelligence Report see GP-PhR-RI-SR card
- Intellect. Prop. Rights Evaluation see GP-PhR-IP-SR card
- Regulatory Compliance Analysis see GP-PhR-GAP-SR card
- 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