PAAB Tag Report 2023

A quarterly review of the eFiles tag report 
Total number of submissions
QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4
2969 2621
 Total number of client tags (prior to validation) 
QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4
0 17
 Therapeutic area breakdown
QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4

 0

  Not tags to report

7 Oncology
2 Gastrointestinal
1 Biologic / Immunomodulator
 Total number of tags deemed valid following internal review
QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4
0

10

 

Validated tag breakdown
QUARTER 1 QUARTER 2 QUARTER 3 QUARTER 4
 0
4 Inconsistent with code guidance
3 Inconsistencies with historic approvals for the same brand
2 Request unclear after clarifying call 
1 Issue with level of expertise

Q2 PAAB action taken:

One key issue raised was not being clear on an issue even after a clarifying call. In both instances, the issues had been previously discussed in a past file, so the reviewer did not re-explain. Reviewers have been directed to reiterate the rationale for revisions to facilitate understanding. A trend across the “inconsistent with historical approvals” was that new information had been brought forward since the previous approval. Reviewers have been reminded to clearly convey this to clients when applicable and provide the rationale for why it requires changes to previously approved copy.

A case was identified where a reviewer was inconsistent with the guidance. Discussions with the review team were had on the application of guidance in relation to non-clinical claims.  

Q1 PAAB action taken:

No tags reported in Q1 of 2023. As a reminder, both CEI and Tags are important and serve different but complementary purposes. Additional details can be found in the PAAB resource Client Tagging System Advisory

Confidence in confidentiality

As a reminder, client tags trigger internal audits for validation by PAAB’s Director of Pre-clearance Services, Yin Man. Any tags pertaining to Yin are validated by the Commissioner and removed from the report provided to Yin. No Reviewer, Senior Reviewer or Director is EVER aware of tags generated by clients. You can be confident in the confidentiality of the tagging system. For additional reassurance, the tagging system, tag assessments, and documented actions taken will periodically be reviewed by an external auditor.

What does PAAB use the tags for?

  • Staff and system performance metrics
  • To identify trends and training opportunities
  • To stay inform on what is going well (best practices) and areas for improvement

If you’d like to learn more about the client tagging system, check out the Client Tagging System Advisory. You’ll also find links to useful videos on  tagging a review and tagging phone calls.

Is there more information you would like to know and see in the next quarterly update? Let us know on the Forum.  

Quarter PAAB Tag Q2 2023 .pdf
Quarterly PAAB Tag and CEI Q1 2023.pdf

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