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  2. PAAB Q&A
  3. Pre-NOC Submissions

Forum Update: Supporting Community-Led Discussion

The forum was created as a space for shared learning and peer support, and as the community grows, we want to lean more fully into that purpose.

Going forward, PAAB will be taking a more listening-first role in forum discussions. Rather than responding immediately to every question, we’ll be encouraging members to engage with one another, share experiences, and help build collective understanding. PAAB will continue to monitor conversations and will step in to:

  • Correct any misunderstandings
  • Provide guidance when questions remain unanswered after a few days
  • Support discussions where official clarification is needed

Our goal is to foster a collaborative, trusted community where knowledge is shared and strengthened by everyone’s contributions.

Thank you for being part of the conversation.

Pre-NOC Submissions

Scheduled Pinned Locked Moved PAAB Q&A
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  • G Offline
    G Offline
    GMC
    wrote on last edited by
    #1

    With the new Pre-NOC Guidance document, is there a limit to the number of submissions (rounds) we can make for an APS being reviewed during the pre-NOC period?

    Jennifer CarrollJ 1 Reply Last reply
    0
    • G GMC

      With the new Pre-NOC Guidance document, is there a limit to the number of submissions (rounds) we can make for an APS being reviewed during the pre-NOC period?

      Jennifer CarrollJ Offline
      Jennifer CarrollJ Offline
      Jennifer Carroll
      wrote on last edited by Jennifer Carroll
      #2

      Hey @gmc
      Within a pre-NOC submission, there is no limit to the number of rounds of resubmission you can make during the review prior to acceptance.

      There are, however, a few considerations when it comes to resubmissions and number of rounds:

      1. As with any type of APS submission, a supplemental fee will be invoiced on the third resubmission. Additionally, a supplemental fee will be applied every third resubmission thereafter until approval.
      2. If a major change is made to the APS or TMA mid-review, a new file with a new fee may be requested. Please see Appendix A of our Administrative Guideline for the Review of Pre-NOC APS for more information on when a new submission may be requested.
      3. Standard expiry of files at 6 months of inactivity or 12 months since opening still apply.

      With these considerations in mind, we review most APSs in a single submission despite the number of rounds required.

      G 1 Reply Last reply
      0
      • Jennifer CarrollJ Jennifer Carroll

        Hey @gmc
        Within a pre-NOC submission, there is no limit to the number of rounds of resubmission you can make during the review prior to acceptance.

        There are, however, a few considerations when it comes to resubmissions and number of rounds:

        1. As with any type of APS submission, a supplemental fee will be invoiced on the third resubmission. Additionally, a supplemental fee will be applied every third resubmission thereafter until approval.
        2. If a major change is made to the APS or TMA mid-review, a new file with a new fee may be requested. Please see Appendix A of our Administrative Guideline for the Review of Pre-NOC APS for more information on when a new submission may be requested.
        3. Standard expiry of files at 6 months of inactivity or 12 months since opening still apply.

        With these considerations in mind, we review most APSs in a single submission despite the number of rounds required.

        G Offline
        G Offline
        GMC
        wrote on last edited by
        #3

        Jennifer, the Guidance document is not clear on the turnaround time for submissions immediately post-NOC with the final Product Monograph. Would any ARO options be available? Would it be a standard 10-day turnaround? Would it be shorter?

        Jennifer CarrollJ 1 Reply Last reply
        0
        • G GMC

          Jennifer, the Guidance document is not clear on the turnaround time for submissions immediately post-NOC with the final Product Monograph. Would any ARO options be available? Would it be a standard 10-day turnaround? Would it be shorter?

          Jennifer CarrollJ Offline
          Jennifer CarrollJ Offline
          Jennifer Carroll
          wrote on last edited by
          #4

          Hello @gmc

          Please see Appendix A for turn around times. Turn around post approval is impacted by the final approved PM and if it is different from the PM in the previous round of review.

          Whether ARO is available for additional pieces would depend on the ARO requirements (i.e. length, new content, etc.).

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          The responses, guidance, and advisories provided by the Pharmaceutical Advertising Advisory Board (PAAB), including but not limited to those available through the PAAB Forum, the PAAB website, and any PAAB correspondences, are specifically intended to assist individuals navigating the PAAB preclearance system. Repurposing or reproducing this content without written consent from the PAAB Commissioner is strictly prohibited. This prohibition includes, but is not limited to, use in machine learning or AI models.
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