Showing posts with label Service Level Agreements. Show all posts
Showing posts with label Service Level Agreements. Show all posts

Sep 22, 2019

Service Level Agreement (SLA) in Pharmacovigilance perspective

Service Level Agreement (SLA) is generally mutual commitment between service provider and a client. In pharmacovigilance industry, pharmacovigilance service provider and pharmaceutical company (client) come together in agreement for various PV activities. This could be single PV activity or End to End PV activities on behalf of client.

Pharmacovigilance SLA is not differ from another domain like IT industry where it prevails since long. It contains following common components of any SLA like –

·         Nature and scope of work
o   Region specific (USA, EU or ROW) or Worldwide
o   Single PV activity (ICSR processing  or literature review, etc.) or End to End PV Activity (ICSR processing, Literature Review, Aggregate Reports (PSUR/ADCO/PADER), Risk Management Plan (RMP), Signal Detection, etc.)  
o   ICSR Processing - All type of ICSR processing (Regulatory, Literature, Spontaneous) or specialized ICSR processing i.e. clinical trial or litigation, processing and case submission timelines
o   Literature Review – Literature review from global databases like Embase, PubMed or local journal review or both local and global review, preparation and maintenance of search strings
o   Aggregate Reports – Aggregate Report schedule preparation and maintenance, Ad-hoc reports, Nature of report format (PSUR, PBRER or regional specific like ANVISA, CDSCO, COFEPRIS, etc.), timeline related to finalization of draft and submission
o   Risk Management Plan (RMP) – New RMP or Maintenance of RMP, preparation and management of additional risk minimization measures (ARMM) or additional pharmacovigilance activities like non-clinical studies, clinical trials or non-interventional studies.

·         Work management procedure
o   SOP to be followed (Client SOP or Service Provider SOP)
o   Work on inhouse client database or other commercially available database i.e. ARISg, ARGUS
o   Timelines to be followed for each activity

·         Quality parameters
o   Quality scoring for ICSR, Literature Review, Aggregate Reports, RMP and Signal detection activities

·         Compliance check
o   Regulatory compliance check
§  ICSR submission
§  Aggregate report submission
o   SLA compliance check
o   SDEA compliance

·         Business Continuity Plan (BCP)
o   Business Continuity Plan (BCP) details in case of natural disaster or man-made disaster

·         Audits & Inspection
o   Internal audit and frequency
o   Audit of each other
o   Audit of business partners and affiliates
o   Inspection handling plan, if any specific condition.
·         Penalty
o   Financial penalty in case of quality and quantity deviation from SLA

·         Termination clauses
o   Terms and conditions where termination of SLA to be impose like significant non-conformity in PV process
o   Critical regulatory observation due significant defect in service provider’s procedure

One should remember that SLA is a dynamic document and can be drafted and modified based upon the business need of pharmacovigilance service provider and pharmaceutical company (aka client).

Though dynamism present in SLA, each points of SLA should be thoroughly reviewed by each party who enters in to agreement.