Last updated: 17 April 2024
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The MHRA has published guidance on a new route for Marketing Authorisation Applications (MAAs) based upon rolling review, from 1 January 2021.
What is the rolling review?
It is a new route for marketing authorisation applications (MAA), where an applicant submits increments of the eCTD dossier for pre-assessment by the MHRA rather than as part of a consolidated full dossier submission.
How does a rolling review help in the development of medicine?
It is intended to streamline the development of novel medicines by offering periodic enhanced regulatory interaction and advice to reduce the risk of failure at the final phase and may be integrated with the Target Development Profile (TDP) to provide a clearer pathway for development of innovative medicines.
Which products will be eligible for a rolling review?
MAAs for any New Active Substance (NAS) based on a ‘full dossier’, including biological products, are eligible for the rolling review. Similar biological applications, i.e., biosimilar products, are also eligible.
What is the procedure for submission of a Marketing Authorisation Application?
Pre-submission meeting
- Companies wishing to enter the rolling review should request a pre-submission meeting to discuss the product, its intended target populations and the data in each module to be submitted.
- Companies may specify future MAA designated for UK, Great Britain (England, Scotland and Wales) only, or Northern Ireland only.
- To apply for a pre-submission meeting, a completed application should be forwarded to the presubmission@mhra.gov.uk.
- Following receipt of the request, the MHRA will arrange a mutually acceptable date for the meeting.
- There is no fee payable for the pre-submission meeting.
- Applications, including the first module(s) to be assessed, should be submitted via the MHRA Portal.
What fees will be charged for the application?
Each phase of assessment (for quality, non-clinical and clinical modules) will attract a fee payable as set out in Regulation 28(A) of Schedule 2 to the Medicines (Products for Human Use) (Fees) Regulations 2016.
Process and sequence
- The process is a modular approach to submission and evaluation.
- The quality, non-clinical and clinical data may be submitted separately or jointly, depending on individual circumstances and/or data availability, in the format of common technical modules (CTD modules 3-5, as appropriate).
Pre-assessment of modules
- Following the process by the Information Processing Unit (IPU), the assessment of the first module will start from Day 0.
- The assessment cycle will be completed within 60 days.
- Following each assessment cycle, a Module Assessment Summary (MAS) will be issued by Day 60.
- The MAS will offer the applicant opportunities to update the module which should be included in the final phase.
- The same timeline above will be applied to other module assessments.
The assessment process may include consultation with the CHM and/or therapy area experts (specialty expert groups) during the pre-assessment process.
Final phase for marketing authorisation application
Before submission
Refer to the guidance on Procedures for UK Paediatric Investigation Plans (PIPs) and complete the the UK compliance check (CC) 60 days before the intended submission date.
Pre-submission meeting
- A pre-submission meeting with the MHRA around 90 days in advance of the intended submission date for the final phase is recommended.
- At the meeting applicants may wish to provide a short summary of the dossier, as well as to raise any special issues such as requests for consideration for orphan MA, conditional MA or MA under exceptional circumstances.
- The pre-submission meeting may offer the opportunity to enhance joint discussion with the National Institute for Health and Care Excellence (NICE) Health Technology Assessment (HTA) evaluation process.
The MHRA will operate a ‘fixed submission date’ system to facilitate consultation with the Commission on Human Medicines and will publish a set of submission dates to facilitate planning the submissions and coordinate with appropriate meeting dates of CHM.
Validation of MAA applications
A valid application/dossier should include submission of any unassessed modules or data, which may include:
- the clinical module,
- UK specific CTD module 1, consisting of an appropriate Risk Management Plan (RMP), UK CC and/or orphan designation application (if applicable).
The SmPC/PIL may be submitted as word documents in the working documents folder. There is an option to put the UK specific SmPC/ PIL/ Labelling text/ mock-ups in the UK specific folder which is available within the eCTD structure.
The assessment clock will begin after validation of the application.
Final phase assessment
- The final phase should be completed within 100 days in two stages as 60 + 40 days with an intervening clock off period.
- If required, a letter requesting further information (RFI) may be issued by Day 60 with the clock stopped.
- Applicants will have the opportunity to discuss any issues identified with the MHRA within 30 days.
Once the RFI response is received, the clock will resume on Day 61, and the EAG/CHM will be consulted again with the final decision on approvability reached by Day 100. The orphan status will be determined at the time of grant of the marketing authorisation.
Appealing a decision to refuse
- If the MHRA proposes to refuse to grant the MA based on advice from CHM, there is an opportunity for the applicant to request a review of the decision.
- The procedure for such review is set out in Schedule 5, and paragraph 11 of Schedule 11, to the Human Medicines Regulations.
- The MHRA decision letter will detail the appeal process and timelines.
- If orphan status is not agreed and company may wish to appeal this decision, the grant of a marketing authorisation will only be possible when the appeal process is completed.
Publication
Grant of a Great Britain marketing authorisation will lead to the publication of a Great Britain Public Assessment Report for the product.
Source: MHRA website