Percent Pick-Up Highlighting
We're confused about the reasoning behind the change to highlighting requirements when there is verbatim content picked up from previous efiles.
Highlighting what is old rather than what is new is a very strange process, when in every other submission the highlighted copy is intended to show PAAB what has changed from the previous version.
Are these new guidelines subject to change based on feedback, or are they set in stone?
Jennifer Carroll last edited by
Feedback is always appreciated, and we will compile and be reassessing on a continuous basis to optimize the submission process for both clients and PAAB.
The degree to which content in a submission has been previously approved is a key determinant of the PAAB resources consumed during the review process. While reviewers are required to reassess previously approved content to ensure they still adhere to Code standards in the context of a dynamic marketplace, changes to the Terms of Market Authorization, and occasional advertising complaints, the assessment does not typically require re-evaluation of the claim’s underlying evidentiary basis. The fee schedule has been modernized to reflect this fact. There are many features in the new fee schedule that cause APS comprised of a higher proportion of previously approved content to have a reduced fee versus similar APS with a lower proportion of previously approved content. These features include, the criteria for applicability of series fees, minor updates, APS with little new content (note that this differs from “minor updates”), and the incremental “per page of new content” component of the supplementary length fee.
Clients who wish to benefit from the savings associated with previously approved components must do their part by clearly identifying the PAAB file number for each component that they desire to be credited as having been previously approved. While we are open to modifying how the previously approved components and past file numbers are identified, it is absolutely critical that this be done in a manner that supports review efficiency and that enables our admin staff to quickly assess the approximate percentage of new content. The new guidance document, which the question makes reference to, outlines the way to deliver on these needs in a standardized manner. We looked to pick two colors that were both faint and not often used by industry so as to visually block off the copy that has been previously approved. But we’d be happy to consider alternate ways to meet this same end. Ultimately, our main criteria will be that the realized efficiency gain and resulting time-savings at PAAB must be commensurate to the impact on client cost.
Note that the requirement to identify content changes between rounds of revision within a file still applies. The above discussion pertains specifically to the initial submission of new files containing previously approved content from prior files. Also note that leaving copy that was previously approved unhighlighted would not visually distinguish it from brand new submissions with no previously approved copy.
We offer this explanation to help you formulate recommendations for changes to the submission requirements. We look forward to your continuous feedback.
@jennifer-carroll Thanks, Jennifer. When it comes to those subsequent rounds of feedback when new changes would need to be highlighted, would we retain the highlighting of the previously-approved content as well? Or would it be okay in that circumstance to remove them as they've been seen and accepted?
Jennifer Carroll last edited by
The base highlighting for previously approved copy should remain throughout the review process. It should not change. The reviewer still needs to be able to easily locate and assess the areas of the piece that are “new” content. The only highlighting that would be changing is in the sections which are “new content”. These sections would have no background highlighting so if you are picturing overlapping highlighting, this would not happen.