Tips for Preparing a Successful eCTD

March 10, 2011

Topics

Overview of the eCTD Planning the eCTD eCTD Publishing Biometrics Tasks for eCTD
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Overview of the eCTD

Common Technical Document CTD

CTD is an ICH standard that was adopted in a
consensus process by US, Europe, Japan and other member regions.

eCTD is the only acceptable format for new electronic submissions to CDER and CBER

eCTD - The New Standard

eCTD is highly recommended by FDA

NDAs, BLAs, DMFs and INDs Required by EMEA for Centralized Procedures Transparency of entire submission

Ease of navigation and review

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What is an eCTD?

Electronic transfer of information to Agency based on common format (CTD) PDF documents linked via XML backbone Increased document granularity Relies on formatted files, leaf titles, hyperlinks and bookmarks for ease of navigation
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The CTD (as a pyramid)

Module 1 Module 2 Summaries

Module 2.2 Introduction
2.4 Nonclinical Overview

Module 1 is Region specific & is Not part of the CTD

2.5 Clinical Overview

2.3 Quality Overall Summary

2.6 Nonclinical Summary

2.7 Clinical Summary

Module 3 Quality

Module 4 Nonclinical

Module 5 Clinical

Modules 2-5 contain the CTD: - Intro, Summaries - Quality (CMC) - Nonclinical - Clinical

eCTD Submission Strategy Plan Your Approach to Win

Planning for a Successful Submission

The Challenge

The Solution

CTD prep requires experienced and dedicated resources Demand for resources far exceeds what is required for drug development phase Resource gaps exist that stand between the sponsor and a high quality, on-time, onbudget CTD

Have a clear understanding of eCTD requirements Identify needed expertise early in the process Monitor activities closely to identify and address potential issues so they have low/no impact on timeline Increase quality of the eCTD to speed FDA review Increase chances of approval after first review cycle
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Resource Planning

Comprehensive analysis to identify resource gaps Identify and evaluate essential external partners Set up systems to allow access to information Start planning at least 12 months in advance of eCTD

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Assemble the CTD Team

Assign Team Leader Identify Team members Agree on CTD content; get Mgmt. and Agency buy in Agree on the timeline Agree on how information will flow among team members & between team and senior mgmt

Document/Data deliverables Changes in timelines Budget

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Seek Regulatory Guidance

Sponsors benefit from early regulatory guidance by defining hurdles to registration Review pertinent guidance documents and prior precedents Integration of regulatory strategy with business, marketing and clinical development strategies is key to successful NDA

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Regulatory Considerations

Submission Type Combination Product who is the lead center?

Is the device component approved? If not, have the testing requirements for devices been met?

505b2 Orphan drug, accelerated approval, Fast Track, Rolling NDA, Priority Review, Subpart H & E Special Protocol Assessment Phase 3, Carcinogenicity, Stability

505b1,

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Milestone FDA Meetings

EOP2 For Phase 3 Nonclinical safety data Clinical safety data Phase 3 CMC strategy For NDA Long term tox requirements Size of clinical safety database Pediatric Plan

Pre-NDA Submission structure Acceptability of clinical data REMS Agreements on post NDA submissions e.g., supplemental stability Label Pediatric Plan Data pooling strategies

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Module 1 Tips

Debarment Certification

Request your accounting group to prepare a list of all vendors who were paid
Request your accounting group to prepare a list of payments made to investigators that were not for direct clinical study costs (eg, consulting fees, research grants)

Financial Disclosure

Labeling

The label should not have data presentations or analyses that are not also presented in clinical summaries or CSRs Ensure format conforms with SPL guidance
Can be submitted under IND; submit no later than the NDA FDA will re-confirm acceptance 90 days before PDUFA date
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Trade name

Module 2 Tips

Nomenclature for the drug should be unified in M2

Mod 3-Mod 5 may use earlier research names for the drug

Need a single editor to review Mod 3 and unify writing styles The SCE (2.7.3) and SCS (2.7.4) are not substitutes for the ISS and ISE (Mod 5).

SCE and SCS are higher level summaries of the data (50-400 pages) ISS and ISE are an analysis of the data Omission of ISS and ISE should be agreed with FDA in advance

Data pooling strategies for clinical summaries should be decided and agreed upon at the Pre-NDA meeting. This drives much of the work in preparing the NDA.

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Module 3 CMC Tips

Anything not per the guidance or compendium should be agreed to with FDA in advance. Be careful about making commitments in the NDA for further experiments because it might help explain something. Starting materials make sure they are defined and agreed with FDA in advance of the NDA. FDA is asking for more details on the manufacture of starting materials because they are seeing recalls involving changes to starting materials (esp. for foreign suppliers) Drug Development Report Include only pertinent aspects of history that support the planned commercial product. Get marketing involved with commercial packaging early so that sufficient stability data can be generated, e.g. physician samples Expiration dating will be based on stability data available on registration batches if you plan to do something different be sure to get FDA agreement
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Module 4 Tips

Preparation of M4 can begin as soon as the sponsor decides to file an eCTD.

Legacy studies may require additional formatting Have functional expert review legacy reports or reports coming from a partner to ensure agreement on conclusions Certified translations are needed for reports not in English

Start preparing CTD summary tables Carcinogenicity datasets need to be included Nonclinical references - Mod 4.3
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Module 5 Tips

Identify the patient CRFs that will be included early

SAEs, deaths, drop-outs, others Bookmarked and hyperlinked Preparing the CRFs can be resource intensive

TQT study
Clin Pharm Highlights Table Waveforms ECG Warehouse

Datasets need involvement from data mgmt early in the process (CSRs, PopPK, ISS, ISE) References Mod 5.4

Copies of papers cited in eCTD Bibliography of literature search

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Keys to a Successful eCTD

Plan the eCTD early (12-18 mos before target submission date)

Get the eCTD publisher onboard early Have authors work from standardized templates and style guides Map out the data deliverables for the submission

Dedicated Team including internal and external resources Agreement on content (internally and with FDA) Identify critical path items early Create a solution, no/minimal impact on timeline Manage information and communication flow Review Agency commitments/recommendations Get internal agreement on NDA messages early Build QC steps into the review process Obtain thorough knowledge of FDA standards
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Understand Regulatory Expectations and Plan Accordingly

Sponsor
FDA

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eCTD Publishing
The Tools and the Process
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The CTD: Managing a Mountain of Information

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Know Your Tools

Templates
Style Guide

Properly formatted Word files

Compliant PDFs Publishing

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What Do We Need to Get Started? The Goal:

Provide the Agency with a submission where they can focus on content and be able to navigate the eCTD with ease. This means providing them with high quality formatted documents, as well having a process that ensures quality.
Electronic Submission Tools: Tracker Sheet Templates Style Guide QC Sheet

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Electronic Submission Tools Defined

Tracker Sheet The tracker sheet is used for multiple
purposes. Gather information about submissions (metadata) Helps define submission content Lists documents to be submitted in an application Keeps track of progress on each document

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Electronic Submission Tools Defined

Templates authoring in templates allow writers to focus on content and less on formatting. Word content templates should be regulatorycompliant. Word documents that contain formatting, styles, headers, footers, and instructional text. Templates come in granular parts based on CTD structure.

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Electronic Submission Tools Defined

Style Guide The style guide is a tool which provides authors
and publishers with a guide on format and consistency for word documents

It outlines formatting for headings, body text, figures, tables, punctuations, abbreviations, margins, etc. Standardizes nomenclature e.g., drug name It should be used in conjunction with the Word templates It allows the authors to create submissions that are consistent in style, appearance, and functionality
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Electronic Submission Tools Defined

Quality Control (QC) Sheet is a tool provided to reviewers to keep a list of QC findings

QC is an important part of any submission project. QC process for eCTD submissions takes place after the submission is published and the publishers have done their QC. During a final QC, focus is on quality.

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RPI/Client eCTD timeline

-Tracker Sheet completed by Client -Begin providing any final documents (e.g., M4 reports) to RPI Authors write eCTD sections in templates -Internal review of -Docs finalized drafts (2 rounds) Docs provided -Versions are returned to publishers to RPI for formatting -Client QC submission. -Revisions noted on QC Sheet -ReQC. Ensure all findings are resolved, submission is finalized.

-Templates & Styleguide provided to Client -Begin formatting PDFs available

Publishers format draft versions. Draft versions returned to authors for finalization.

-Final formatting on docs -Submission sent -Submission -Publishing of submission, -Resolve QC to FDA via ESG or metadata finalized findings Links created CD/DVD. -Republish -Final generation creation of xml -Source and final of eCTD backbone docs provided to -Validation of eCTD -RPI QC Client

Client/Authors activity RPI Publisher activity

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Preparing the eCTD Granularity, Leaf Titles, and

Life Cycle
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The eCTD structure

Take time to understand the eCTD structure and how it applies to your submission
refer to FDAs Headings and Hierearchies

Some sections are easy to understand, while others take time to figure out.
For every submission, its worth thoughtfully choosing where documents are placed within eCTD tree. Once it is submitted in a particular location, it is not easily moved.

When in doubt, work with regulatory publishers and FDA eSubs group.

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eCTD Granularity - grasping its importance

What is granularity? Level of hierarchy of the folders and files in the eCTD directory or the smallest unit of detail within the eCTD structure. All modules (Modules 1-5) have granularity options. The most challenging are the Quality sections in Modules 2.3 and 3. How granular do you go? Do what makes sense, but within the guidelines. Because only entire documents in the eCTD can be replaced, not sections or pages within a document, your submission's initial granularity choices affect how information is updated in future submissions.
(Refer to the Granularity Document, Annex to M4: Organization of the CTD)

Once granularity is decided, it generally cant be changed for the life of the dossier.

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Granularity in Module 2 and 3

No single granularity option for a compliant eCTD. It will depend on writing strategy. Publishers and Authors must work together to determine granularity prior to authoring and publishing, especially when a Drug has multiple dosage strengths or manufacturers.
In U.S., FDA doesnt expect 2.3 to be updated after initial application, unlike in EU. Generally, one 32P section per dosage form. (Do not create 32P sections for each strength)

Attachments (e.g., COAs) include within a document or as separate files

Good idea to submit attachments as separate files

Excipients determine granularity for this section (3.2.P.4)

CMC MetaData (e.g., DS and DP Name and Manufacturers) choose names that will most likely not change for the life of the application.
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Module 2

2.2 2.3

Intro 2.3.S

Module 2 Granularity
2.3.S.1 2.3.S.2 2.3.S.3 2.3.S.4 2.3.S.5 2.3.S.6 2.3.S.7 2.3.P.1 2.3.P.2 2.3.P.3 2.3.P.4 2.3.P.5 2.3.P.6 2.3.P.7 2.3.P.8 2.3.A.1 2.3.A.2 2.3.A.3

2.3.P

Documents rolled up to gray level are not considered appropriate.

One document may be submitted in Documents in the yellow level

2.3.A

2.3.R 2.4 2.5 2.6

2.7

2.6.1 2.6.2 2.6.3 2.6.4 2.6.5 2.6.6 2.6.7 2.7.1 2.7.2 2.7.3 2.7.4 2.7.5 2.7.6

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Module 3 Granularity
Module 3 3.2 3.2.S 3.2.S.1

3.2.S.1.1
3.2.S.1.2

3.2.S.1.3
3.2.S.2 3.2.S.2.1 3.2.S.2.2 3.2.S.2.3 3.2.S.2.4 3.2.S.2.5 3.2.S.2.6 3.2.S.3 3.2.S.4 3.2.S.3.1 3.2.S.3.2 3.2.S.4.1 3.2.S.4.2 3.2.S.4.3 3.2.S.4.4 3.2.S.4.5 3.2.S.5 3.2.S.6 3.S.2.7 3.S.2.7.1

Documents rolled up to gray level are not considered appropriate.

One OR Multiple documents can be submitted in the orange level.

3.S.2.7.2
3.S.2.7.3

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Module 3 Granularity (Contd)

Module 3 (Contd 3.2 (Contd) 3.2.P 3.2.P.1 3.2.P.2
3.2.P.2.1 3.2.P.2.2 3.2.P.2.3 3.2.P.2.4 3.2.P.2.5 3.2.P.2.6 3.2.P.3.1 3.2.P.3.2 3.2.P.3.3 3.2.P.3.4 3.2.P.3.5 3.2.P.4.1 3.2.P.4.2 3.2.P.4.3 3.2.P.4.4 3.2.P.4.5 3.2.P.4.6 3.2.P.5.1 3.2.P.5.2 3.2.P.5.3 3.2.P.5.4 3.2.P.5.5 3.2.P.5.6

3.2.P.3

3.2.P.4

Documents rolled up to gray level are not considered appropriate.

One OR Multiple documents can be submitted in the orange level.

3.2.P.5

3.2.P.6 3.2.P.7 3.2.P.8

3.2.P.8.1 3.2.P.8.2 3.2.P.8.3

3.2.A

3.2.A.1 3.2.A.2 3.2.A.3

3.3

3.2.R One file per reference

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Module 4 and 5
Preparation for Modules 4 and 5: Determine

Number of reports eCTD location(s) for each report ahead of time Naming Standards for reports and how they will be referenced in Module 2 (use CRO number vs. internal number) Which literature references to submit

Legacy vs. granular (ICH E3) study reports avoid scanned reports. If outsourcing CSR writing, work with CRO ahead of time to ensure reports are formatted properly and eCTD ready. Work with data management groups regarding data expectations. If CRFs are included, know how many to expect and the level of complexity ahead of time. These can be resource intensive. Provide ready reports and literature refs to your publishers ASAP. The more module 4 and 5 documents that can be prepared ahead of time, the more time there will be to process the M2 summary docs.

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Module 1

Differs by region (US, EU, etc.) Contains all forms and administrative information The label documents are also contained in this module Module 1 specifications will be changing in the near future. It is currently in draft at FDA. Tips: PreIND able to submit PreIND submissions in 1.6, as long as you know the IND application number. Form 3674 and Reviewers Guide submit in 1.2 with Cover Letter Labeling (PDF, Word, and SPL) in 1.14. External Linking required for annotated label. DMFs - submitted in 1.4.1 not Module 3.
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File Name vs. Leaf Titles

Each document that is submitted in the eCTD tree has both a file name and a leaf title. File name is the actual name of the file FDA doesnt see this. (e.g., cover-letter.pdf & coa-tb-033a.pdf are the file names) Leaf Title is displayed when FDA views the submission. Short, meaningful, & indicative of the contents. Smart leaf titles provide efficiency for the reviewers.
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FDAs view on Navigation: DO: Provide functional hyperlinks Provide sufficient number of hyperlinks. Err on the side of more hyperlinks to enhance navigation. Format Module 2 with sufficient hyperlinking to support docs in Modules 3-5. TOCs of a document should contain hyperlinks to the corresponding sections within the document. Supply descriptive and brief bookmarks. Have at least as many bookmarks as there are items in the TOC. DONT: Link to wrong document or the wrong page within a document. Avoid scanned documents they typically arent searchable and dont contain useful links. Avoid broken links!

Navigation

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Lifecycle
Critical to understand operation attributes within the CTD to facilitate document authoring. Lifecycle of documents: New original or new documents Replace replaces existing files Append adds new info to an existing file (use carefully) Delete No new file, flags an existing file as obsolete. Establishing process for identifying appropriate operation attributes will help minimize mistakes work with your publishers!
For example: Cover Letter New Annual Reports New Draft Labeling Text Replace Amended Protocols Replace
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FDAs Perspective
If I was a reviewer, could I.? Easily locate the information/document Easily copy and paste from the document Print the document and see page numbers Easily differentiate between same type documents displayed in the eCTD tree Rely on a uniform, consistent format in your submission Easily navigate and access references in documents via bookmarks, links and the Table of Contents Easily identify the most current version of a document (protocol, IB, label, stability data, etc.)

The ultimate goal is to provide the agency with a reviewer-friendly eCTD so that the focus of their review is content, not on the format.
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Benefits of eCTD
Improves reviewer efficiency Can reduce time to approval

Submission via ESG allows immediate receipt by FDA

Benefits of eCTD
Allows for repurposing of docs for submission in other regions

Improved handling and archiving of submissions (both sponsor and FDA)

Accessibility to documents across modules

Search functionality and increased tracking ability

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Thank You!

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Contact Information

Donna Kato, MBA Regulatory Professionals, Inc [email protected]

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