621 - Has the PAAB ever considered providing review comments as annotations on submission documents, rather than an itemized review letter? This would seem to save both PAAB and Clients time.

  • This was considered when we first created the eFile system for the very reason you suggested. On the surface, it appears to be a good idea, but it was deemed at the time not to be practical. Itemized correspondence letters appear to be a more efficient way (for clients and PAAB) to engage in the back-and-forth that frequently occurs during the review process. The copydeck would get quite crowded with the reasoning and counter-reasoning defending each party’s position. This would be true whether the comments appeared directly on the copydeck or as digital sticky notes. The lion’s share of the time use appears to be due to the back and forths. It might therefore be counter-productive to take a step which could impair either party’s ability to follow the flow of reasoning and counter-reasoning. Keep in mind that the reasoning or counter-reasoning in a single correspondence for a single comment can sometimes be multiple pages long. This was the thinking at the time. Years have passed and technology has evolved so feel free to reach out to me if you have ideas on how the system can be improved.