Procedure: Type IB variation notifications
Country: Global Procedure
Version #: 01/03/2024
Author: Mariya Ivanova
Editor: Daria Kostiuchenko
ID: GP-PhR-VIB-SR
Category: Pharmaceuticals
Validity: Until next MA expiration or update
Certified by: Vlad Reznikov
Copyright: Pattern of USA Inc
SUMMARY
A Type IB variation is characterized as a variation that does not fall within the categories of Type-IA, Type-II, or extension. Minor variations of this nature necessitate notification to the National Regulatory Authority (NRA) prior to implementation; however, they do not mandate formal approval. It is imperative that the NRA deems the notification acceptable through a “tell, wait, and do” procedure before the change is executed.

Must-Have Requirements, Recognized Standards, and Certification:
- Annex A Comparative Table
- Annex IV Elements
- Grouping of Type IB variations
- Applicable SmPC, or Annexes I, II, IIIA/B
Nice-to-have:
- Confirmation of the original variation
- Pre-notification checklist
Typical Gaps and Deficiencies: Non-eCTD, Insufficient regulatory documentation, confusing dossier presentation
Implementation Period: With a new batch, defined by MAH and NRA or up to a 12-month period
Deliverables: Confirmation of the MA terms adjustment
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 | SOW is approved by MAH | MAH | week 1 | 1 | SOW | |||
0.4 | POA issuance and shipping | MAH | week 2 | 1 | ||||
0.5 | Invoice is sent to MAH and paid | MAH | week 3 | 1 | POP | |||
I | Submission | |||||||
I.1 | Information assembling, forwarding to Executor | MAH | week 4 | 1 | ||||
I.2 | Application form and Registration form development | Executor | week 5 | 2 | Application | |||
I.3 | Application form and Registration form approval | MAH | week 7 | 1 | ||||
I.4 | NRA payment | MAH | week 7 | 1 | ||||
I.5 | Application submission to NRA | Executor | week 8 | 1 | Submission | |||
II | Official Evaluation | |||||||
II.1 | Official Dossier Evaluation | NRA | week 9 | 4 | ||||
II.2 | Approval (Skip Ph.III) or Query (GoTo Ph.III) | NRA | week 13 | 1 | Approval or Q&A | |||
III | Q&A | |||||||
III.1 | Analysis and addressing Qs to MAH | Executor | week 13 | 1 | ||||
III.2 | Answering with relevant documents | MAH | week 14 | 1 | ||||
III.3 | Official Response Evaluation | NRA | week 15 | 8 | ||||
III.4 | Approval (GoTo Ph.IV) or Query (Rpt. Ph.III) | NRA | week 23 | 1 | Approval or Q&A | |||
IV | Approval | |||||||
IV.1 | NRA Conclusion draft verification | NRA | week 24 | 1 | ||||
IV.2 | NRA Conclusion publication | NRA | week 25 | 1 | ||||
IV.3 | State Listing update | NRA | week 26 | 1 | ||||
IV.4 | Reporting to MAH | Executor | week 26 | 1 | Report | |||
F | Final Phase In-house Post-Authorization Activity | |||||||
F.1 | Service Acceptance Certificate signing | MAH | week 27 | 1 | ||||
F.2 | Final Invoice | Executor | week 27 | 1 | ||||
F.3 | Final Payment | MAH | week 28 | 1 | ||||
F.4 | Contract Termination | Executor | week 28 | 1 | ||||
F.5 | Archiving and limiting access | Executor | week 29 | 1 | Archiving |
Feel free to submit a Request for Proposal (RFP) for a specific country or territory to info@patternofusa.com