Guidance for new Marketing Authorisation assessment routes in the UK following Brexit: rolling review procedure
In the second of our series of posts analysing the new access routes developed in the UK, Nasos Kipentzoglou takes a deeper dive into the rolling review procedure.
The rolling review procedure is a new route for marketing authorisation (MA) applications which aims to streamline the development of novel medicines. MA applications for any new active substance, based on a “full dossier’”, including biological products, are eligible for the route. Similar biological applications, i.e., biosimilar products, are also eligible.
Assessment of the first module will start from day 0 with the assessment cycle being completed within 60 days. Following each assessment cycle, a Module Assessment Summary (MAS) will be issued by day 60. The MAS enables the applicant to update the module, and the updated modules should be included in the final phase.
The final phase should be completed within 100 days, in two stages with a clock off period after 60 days. The MHRA may issue an RFI by day 60 and applicants will be able to discuss any issues identified in the RFI with the MHRA within 30 days. The clock then resumes on day 61 with the final decision on approvability reached by day 100. The orphan status will be determined at the time of granting the MA.
Pre-assessment of modules
Applicants should request a pre-submission meeting where the product, its intended target populations and the data in each module to be submitted are discussed. Applicants may specify MA application designations for the UK, GB only or NI only.
To apply for the pre-submission meeting, applicants should forward a copy of the completed application to AcceleratedandRollingReview@mhra.gov.uk. and the MHRA will arrange a mutually acceptable date for the meeting. Applications, including the initial module(s) to be assessed, should be submitted via the MHRA Portal.
Under the modular approach, quality, non-clinical and clinical data may be submitted (in the common technical document format) separately or jointly, depending on individual circumstances and/or data availability.
For the final phase, a paediatric investigation plan (PIP) compliance check should be completed 60 days before the intended submission. Applicants are redirected to the MHRA’s separate guidance on Procedures for UK Paediatric Investigation Plans (PIPs) for information on the compliance check.
The guidance recommends a pre-submission meeting with the MHRA approximately 90 days before the intended submission for the final phase. At the meeting, applicants can provide a summary of the dossier and raise any special issues such as requests for consideration for an orphan or conditional MA or MA under exceptional circumstances. The pre-submission meeting may offer the opportunity for an early engagement with NICE HTA evaluation process.
The MHRA will operate a fixed submission date to enable consultation with the CHM and will publish a schedule of submission dates.
Applicants can request a review of a decision not to grant an MA using the procedure 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 the orphan status is not agreed upon and the company may wish to appeal this decision, the grant of a marketing authorisation will only be possible when the appeal process is completed.
Implications for manufacturers
The MHRA with Rolling review procedure will offer the chance to manufacturers applying for MA to submit increments of the eCTD rather than a consolidated full dossier submission. The rolling review will accelerate the development of novel medicines by offering periodic enhanced regulatory interaction and advice to reduce the risk of failure at the final phase. It may be integrated with the Target Development Profile (TDP) to provide a clearer pathway for development of innovative medicines.
Article published 15 March 2021.