Before a drug company shows doctors or patients a brochure, an email or a TV spot, it has three kinds of specialist check the piece: medical, legal and regulatory. That sign-off is called MLR review. At its center is a humble job: opening each cited study at the right page to see whether it says what the piece says. Automation now does that opening and comparing, so the three reviewers can spend their time on what only they can decide.
This guide is for anyone who works around promotional review: medical, legal and regulatory reviewers, MLR operations leads, brand teams, agencies, and the leaders deciding whether to automate. It assumes no background.
Imagine you are the medical reviewer at a mid-sized biotech. You have six pieces to sign before Thursday's committee. The next is a four-page tablet presentation that sales representatives will show gastroenterologists, for Veltrimab, an injected medicine for ulcerative colitis, a long-term inflammation of the large bowel. It carries 14 claims and three references. In the middle of page 2, in the largest type on the page, it says two out of three patients stay in remission (their symptoms have settled) at one year.
That is good news, and the footnote points to the maintenance study, a journal article, page 9. So you open the PDF, find page 9 and start reading. The 67% is there. Then you read the words on either side of it.
The piece · page 2
Says
"2 out of 3 patients stay in remission at 1 year"
Reads as
The study's result
The study · page 9
67% of
141 patients already in remission at week 12
Analysis
Descriptive, no statistical test
Main result
55% vs 30% with placebo
The number is accurate. The people behind it are a smaller group than a doctor will picture, and they were already doing well. Across the piece you will do this 14 times, and three more red flags are waiting on pages 2, 3 and 4.
MLR review catches the true number that describes the wrong patients, before a representative carries it into a doctor's office.
MLR review in pharma: the process, the people who sign, FDA's rules and where the days go
What medical, legal and regulatory review is, what each reviewer answers for, which rules sit behind it, how a claim is checked at its page, and what regulators keep objecting to. This part sells nothing, and software vendors appear only as the source of published numbers. If you have never seen a promotional review, start here.
01 · In plain words
What MLR review means: three signatures between a drug company's draft and a doctor's desk
A drug company talks about its medicines constantly. Sales representatives carry tablet presentations called detail aids into doctors' offices. Marketing teams send emails, run web banners, print brochures, build conference displays, and pay for TV spots. Every one of those pieces says something about what a medicine does, and the law holds the company to it. A statement that goes further than the evidence, or that hides the risks, can make the medicine legally misbranded.1
So nearly every company runs an internal check before anything goes out. An advertising agency or brand team draws up the piece and sends it in with copies of the studies it cites.
Then three people read it, each looking for something different. A medical reviewer asks whether the science is right. A legal reviewer asks what risk the wording creates. A regulatory reviewer asks whether it follows FDA's promotion rules and stays true to the approved label. Those three initials give the process its name: MLR review. Some companies call the same group a promotional review committee, or PRC.
The check sounds grand, and most of it is patient clerical work. A claim such as "55% of patients were in remission at week 52" needs a reviewer to open the cited article, find the page, and compare the number, the patients, the measure and the date. A detail aid can hold 14 such claims. The reviewer then comments, the agency revises, the piece comes back, and it may wait for a weekly meeting. Published vendor benchmarks put the whole trip at roughly two to four weeks.2,3,4
Once all three have signed, the piece can be used. On the day it first goes out, the company sends a copy to FDA with a transmittal form, Form FDA 2253.5 FDA may read it later, and if FDA disagrees it can publish a letter that quotes the company's own words.6,7
One colitis detail aid, from the brand team's brief to FDA's inbox
Brief and draftThe brand team asks the agency for a tablet presentation on Veltrimab's one-year results. The agency writes it and attaches references.
Piece submittedMonday, October 5, 2026: version 2 enters review with 14 claims, three references and a due date.
Each claim checked at its pageMedical, legal and regulatory reviewers compare the piece with its sources, comment and request changes. "2 out of 3" is caught here.
Committee and signaturesHard calls go to the Thursday meeting. Three people sign the final version.
First use and Form FDA 2253Representatives start showing it on October 12. That day, the company files it with FDA.
Step 3 is what this guide is about. The medicine, people and figures in this example are fictional.
No US rule we read requires an MLR committee, and three more things that surprise newcomers
The US rules we read name no review committee
US rules fix what a piece may say and when it is filed. None of the texts we read names a review committee, a medical, legal or regulatory signer, or a number of review signatures. The form carries one signature, from the company's named responsible official, who answers FDA's questions about the filing.8 FDA's closest words are a recommendation, in one guidance, that "qualified medical/scientific, legal, and regulatory personnel carefully review" a communication.9 The process is a company's own design.
The texts we read are section 502(n) of the federal Food, Drug, and Cosmetic Act (FD&C Act), 21 CFR 202.1, 314.81(b)(3)(i), 314.550, 601.12(f)(4), 11.10 and 11.50, the Form FDA 2253 instructions, FDA's filing guidance and the questions and answers from OPDP, FDA's drug promotion office.10,1,5,11,12,13,14,8,15,6 A negative rests on what we read, so ask counsel before relying on it.
FDA does not sign off first
"Pre-approval of promotional materials is not required except in rare instances", FDA says. It gives opinions when asked, and medicines under accelerated approval, an FDA route for new drugs for serious or life-threatening illnesses, must submit pieces ahead of use.6,11 Otherwise the company's own signatures are the last check before the public sees a piece.
Most letters land on pieces the company filed
By our count, 80 of FDA's 87 untitled letters dated 2025 and 2026 (public letters saying a piece is false or misleading, a step below a warning letter) say the company submitted the piece under cover of Form FDA 2253.7 The company's process had let it out, and had told FDA so. Method and limits are in section 6.
A true number can still be the problem
When Spanish researchers checked journal ads for blood pressure and cholesterol drugs against their cited studies, 44% of 102 claims were unsupported. The most frequent reason was a slogan recommending the drug for a different group of patients from the one studied.16
Detail aid, annotated reference, label and Form FDA 2253: the words you will meet here
Detail aid
The printed or tablet presentation a sales representative shows a doctor. FDA's rule treats detailing pieces as labeling, so the same duties of truth and balance apply.1
Annotated reference
A copy of the cited study or label with the supporting passage marked, and numbered to match the claim in the piece.
Label, or Prescribing Information
The FDA-approved document that says who a medicine is for, how to use it, what it did in studies and what can go wrong. Abbreviated PI.
Form FDA 2253
The transmittal form a company sends FDA with each promotional piece at the time of first use.5
Medical, legal, regulatory: what each MLR reviewer answers for on a promotional piece
In shortThe three reviewers read the same pages for different failures, and the overlaps are where comments collide. A short written split of who owns which question is often the cheapest improvement a team can make. Everyone else in the room, from the coordinator to the proofreader, exists to keep those three reading the right version.
A best-practice article from DIA, an association for life sciences professionals, describes the seats plainly. The medical reviewer evaluates "scientific/medical validity and consistency with the FDA-approved labeling". Legal advises on legal risk, including fraud and abuse rules. Regulatory checks the piece against FDA's promotion rules and represents the company to the Office of Prescription Drug Promotion (OPDP), the FDA office that polices drug promotion. A meeting administrator runs the agenda, and a proofreader confirms each requested change was made.17
Companies arrange the seats differently. A small biotech may have one regulatory person reading everything, and a large one may split medical review by brand.
Regulatory has the widest brief; medical owns the evidence and legal owns the comparisons
Who usually takes the lead on each question in a piece
RarelySharedLeads
MedicalRegulatoryLegalDoes the source say this number?LeadsRarelyRarelySame patients, measure and time point?LeadsSharedRarelyConsistent with the label?SharedLeadsRarelyExploratory or subgroup data?LeadsSharedRarelyRisk comparable to benefit in prominence?SharedLeadsRarelyRequired statements and links?RarelyLeadsSharedComparison or superiority wording?SharedSharedLeadsTrademarks and third-party names?RarelyRarelyLeadsFraud, abuse and privacy exposure?RarelyRarelyLeadsForm FDA 2253 filing?RarelyLeadsRarely
Our reading of the sources17,1 · Our summary; each company's written procedure decides.
Show the numbers
Medical
Regulatory
Legal
Does the source say this number?
Leads
Rarely
Rarely
Same patients, measure and time point?
Leads
Shared
Rarely
Consistent with the label?
Shared
Leads
Rarely
Exploratory or subgroup data?
Leads
Shared
Rarely
Risk comparable to benefit in prominence?
Shared
Leads
Rarely
Required statements and links?
Rarely
Leads
Shared
Comparison or superiority wording?
Shared
Shared
Leads
Trademarks and third-party names?
Rarely
Rarely
Leads
Fraud, abuse and privacy exposure?
Rarely
Rarely
Leads
Form FDA 2253 filing?
Rarely
Leads
Rarely
Which promotional pieces go through MLR review
FDA's rule sweeps widely. Brochures, booklets, mailing pieces, detailing pieces, calendars, price lists, sound recordings, film and similar matter issued by a company count as labeling when they describe a medicine; journal ads, magazine ads and broadcasts count as advertising.1 Companies usually add anything that might be read as promotion: speaker decks, rep briefing material, web pages, social posts, email, patient support material, payer slides. FDA's recent letters have reached an Instagram post, a video meeting background, an exhibit panel and a podcast.7,18,19
The piece's name changes little. "The same statute and regulations apply regardless of the audience targeted", FDA says of drug ads.6 A sales aid for specialists and a consumer video are held to the same standard of truth, though fair balance, the duty to present risk alongside benefit, works differently by medium. The neighboring guide to fair balance review walks through TV in detail.
03 · The rules and their dates
What the law fixes and what your company invents: promotional review rules as of November 2026
In shortIn the US, the law sets the standard for what a piece says and a filing at first use. Everything about who reviews, in what order and how fast is company practice. The UK and EU are more specific about people: their industry codes name the doctor or pharmacist who approves. Enforcement, quiet for years, rose sharply in September 2025.
The rules behind MLR review barely moved for decades, then enforcement jumped in 2025
Since at least 197521 CFR 202.1
The core rule on false or misleading ads and fair balance. Its source note starts at 1975; newest edition April 1, 2025.
June 2018Consistent-with-labeling guidance
Sets out when data not in the label may be used, and recommends qualified review.
June 24, 2021Electronic filing required
In-scope promotional submissions must be electronic.
November 20, 2024Major statement compliance date
Five standards for spoken and written risk in TV and radio ads. Effective May 20, 2024.
January 2025Unapproved-use guidance
Reads "not for current implementation". The White House budget office (OMB) approved its paperwork July 29, 2025. No FDA notice lifting the line found.
September 9, 2025Presidential memorandum and FDA crackdown
52 of the year's 63 untitled letters carry this date.
December 2026 (listed)Broadcast ad proposal
FDA's agenda lists a proposed rule on adequate provision, the duty to give broadcast viewers access to the approved label. No text published on November 3, 2026.
Ads are false or misleading if they go beyond the label or substantial evidence, compare without proof, use "literature, quotations, or references that purport to support an advertising claim but in fact do not", or present a study "in a way that implies that the study represents larger or more general experience" than it does.1
In force. 2025 is the newest edition on govinfo.
21 CFR 202.1(e)(5) and (e)(7)(viii)
Fair balance between effectiveness and risk; risk information comparable in prominence and readability.1
In force. FDA's 2009 draft on presenting risk is still a draft.25
21 CFR 314.81(b)(3)(i), 601.12(f)(4)
Submit each piece at first use, with Form FDA 2253 and the current professional labeling. Biologics follow the same text.5,12
In force. Electronic for in-scope submissions since June 24, 2021.20,15
21 CFR 314.550
Accelerated approval: pieces for the first 120 days go in during review; later ones at least 30 days before use.11
In force.
Consistent-with-labeling guidance
Data outside the label may be used if consistent with it and "scientifically appropriate and statistically sound".9
Final, June 2018.
Unapproved-use communications guidance
How firms may share scientific information on unapproved uses with health care providers.22
Dated January 2025. FDA's copy still says "not for current implementation". OMB's record shows the paperwork approved July 29, 2025.26 No FDA notice lifting the line found.
Biologics and biosimilars promotion guidance
Must not imply significant differences without evidence. A biosimilar is a close copy of a biologic medicine, measured against its reference product.27
Final, December 9, 2025, as summarized by AMCP.
Directive 2001/83/EC, Article 87
All parts of an ad must comply with the summary of product characteristics (the EU's approved product text, its counterpart to a US label), and ads must not mislead.28
In force. The EU pharma package replacing it is not yet law: Parliament's file read "Awaiting Parliament 2nd reading".29
The UK and EU name the person who approves a piece; the US does not
In the UK, the ABPI Code of Practice, the drug industry's own code, says promotional material "must not be issued unless its final form, to which no subsequent amendments will be made, has been certified" by one person, a UK-registered doctor or pharmacist (a UK-registered dentist for a dental-only product), who "must not be the person responsible for developing or drawing up the material".30
That signatory states that, in their belief, the piece follows the rules, is not inconsistent with the marketing authorization (the medicine's license to be sold), and is "a fair and truthful presentation of the facts". Material still in use is recertified at least every two years.30
The UK's medicines regulator, the MHRA, notes that signatories are a code requirement and "not a legal requirement", and asks companies to tell it who they are.31 That duty sits with the company's own person.
The UK and EU codes spell out who approves; the US leaves it to each company
Who approves a promotional piece, and what stands behind that
Our reading of the sources1,9,30,32,31,33 · Code duties bind members and those who accept them. PAAB's service is recognized by Health Canada for advertising to professionals; the page we read does not say use is mandatory. Our reading; local law and national codes add more.
Show the numbers
Named approver
Set qualification
Outside check first
Periodic re-approval
United States
Not set
Not set
Not set
Not set
United Kingdom, ABPI Code
Set
Set
Not set
Set
Europe, EFPIA Code
Set
Set
Not set
Not set
Canada, PAAB preclearance
Not set
Not set
Partly
Not set
EFPIA, the European industry association, requires a scientific service with "a medical doctor or, where appropriate, a pharmacist" responsible for approving promotional material before release.32 National codes then add their own detail. The UK's complaint system is visible too: its code authority logged 262 complaints in 2025 and 161 rulings, and in 58% of cases received in 2024 at least one breach was found.34
Canada's Pharmaceutical Advertising Advisory Board offers preclearance "recognized by Health Canada for advertising directed to healthcare professionals".33 Whether those rules change the calendar is unproven. One vendor's country figures run 15.4 days in Germany and 27.2 in France under a 2023 heading, two countries under the same EFPIA Code, against 29.9 in the US for 2021, and the vendor gives no cause. Section 10 has the limits of these numbers.35,36
04 · What goes into a review
The MLR review package: the piece, annotated references, data on file, label versions and house rules
In shortA reviewer works from a stack of documents, and the check is only as good as the stack. The usual weak spots are the reference pointing at the wrong page, the data on file nobody else can open, and an old label version sitting beside the new one. For the fictional detail aid, 14 claims lean on six different documents.
Document
What the reviewer uses it for
What commonly goes wrong
The piece
The draft as the audience will see it: every page, frame or line, with claims numbered to references.
A reviewer reads version 2 while the agency revises version 3.
Annotated references
The cited studies, with the passage marked. FDA's filing guidance asks for support identified by "specific page and lines" or "column/paragraph" in advisory submissions, and encourages annotated copies for ordinary Form 2253 filings.15
The anchor points to the wrong page, or a marked passage says less than the claim.
Prescribing Information
The approved standard. Claims must be consistent with it, and safety text must match it.9
The superseded version is still in the folder.
Data on file
The company's own unpublished analyses, market research or audits.
No one outside can check it. In a 2003 Lancet study of journal ads for blood pressure and cholesterol drugs, 18% of references could not be retrieved, including data on file.16
Claims library
Wording already approved, with evidence and required footnotes. DIA says it should be kept up to date and shared with creators and reviewers.17
House rules: approved phrases, trademarks, what each channel must carry.
Reviewers treat a house rule as FDA's, or the reverse.
The studies carry six claims, and the other eight lean on the label and house documents
What the fictional 14-claim detail aid was checked against
14claims
Induction study4
Label3
Maintenance study2
Brand guide2
Channel standard2
Data on file1
Fictional example from this guide
Show the numbers
Source
Claims
Induction study
4
Label
3
Maintenance study
2
Brand guide
2
Channel standard
2
Data on file
1
05 · The check at the page
Value, population, endpoint, timepoint: how an MLR reviewer tests one claim against its cited page
In shortFour questions catch most evidence problems: is the number the same, are the patients the same, was this the measure the study was built to test, and is it the same point in time? Worked on the fictional claim, "2 out of 3" passes the first and last and fails the two that matter. Even the approved replacement deserves a second look, because a maintenance study enrolls only those who already responded.
Question
The piece
VLT-302, page 9 (fictional)
Result
Value: is it the same number?
2 out of 3
67%
Match, once rounded
Population: are these the same patients?
Patients on maintenance
141 patients already in remission at week 12
No
Endpoint and analysis: what was tested?
Stated as the result
A descriptive subgroup, with no statistical test
No
Timepoint: is it the same moment?
1 year
Week 52
Match
The arithmetic behind "2 out of 3" and "55% vs 30%"
Start with the subgroup. 67% of 141 is about 94 patients. They had responded to the induction treatment and were already in remission at week 12, and they were followed to week 52. No comparison with placebo is attached to the figure, and the authors call it descriptive. A doctor reading "2 out of 3 patients stay in remission" pictures something else: two in three of the people she might prescribe for.
The study's own test is the one the label reports. Patients who responded at week 12 were randomized again, assigned by chance to the medicine or to placebo (a dummy treatment), and at week 52, 55% and 30% were in remission. That is a 25-point difference, the number a reviewer can defend.
The headline's 67% sits above the tested result, because of who it counts
Share in clinical remission at week 52 in the fictional maintenance study
Already in remission at week 12 (141 patients, not tested)67%
Responders on the medicine (the tested result)55%
Responders on placebo30%
Fictional example from this guide
Show the numbers
Group
In remission
Already in remission at week 12 (141 patients, not tested)
67%
Responders on the medicine (the tested result)
55%
Responders on placebo
30%
Why even "55% vs 30%" needs its footnote, and may need more than one
Take the replacement wording one step further. In the fictional induction study 58% of patients responded by week 12. If every responder went on to maintenance and 55% of them were in remission a year in, then of 100 patients starting the medicine, about 32 would reach that point. That is our arithmetic on fictional figures, and it counts only the responders.
Of 100 patients who start, about 32 are in remission at one year, on the sample's own figures
Our arithmetic: 100 × 58% × 55%. A fictional illustration of what a responder-only result leaves out
Start induction100 patients
Respond by week 1258 patients
In remission at week 5232 patients
Fictional example from this guide
Show the numbers
Stage
Patients per 100
Start induction
100 patients
Respond by week 12
58 patients
In remission at week 52
32 patients
FDA has made the same point in a real letter. In September 2025, FDA wrote about a TV ad for a skin medicine that promised lasting clear skin. FDA's letter gives the week 48 figures, then adds that "the maintenance period data represents a subset of IGA responders at Week 48 out of the IGA responder subset from Week 16", and that such data "does not support broad efficacy claims".37 (IGA is a doctor's score of how clear the skin is.)
The same reasoning applies to any maintenance result. A footnote explaining the population may satisfy a house rule. Whether it fixes the headline's overall impression is a medical and regulatory judgment, and FDA's rule says a true statement elsewhere does not cure a misleading one.1
What an exploratory endpoint is, and what 20 chances of a lucky result look like
A study names its main measure in advance, then often tests a planned list of others in a fixed order, so that its overall false-alarm rate stays at the promised 5%. Anything else is exploratory: useful for ideas and weak as proof. ICH's statistics guideline says multiplicity (many tests, more chances of a fluke) may call for an adjustment to the error rate.38
The arithmetic shows why. If each test has a 5% chance of a false alarm, then across 20 independent tests the chance of at least one is 1 − 0.9520, about 64%.
Twenty unadjusted endpoints give about a 64% chance of at least one false alarm
Chance of at least one false positive at a 5% level, assuming independent tests
5%1 test
23%5 tests
40%10 tests
64%20 tests
Our reading of the sources38 · Our arithmetic: 1 − 0.95ⁿ, rounded.
Show the numbers
Tests
Chance
1 test
5%
5 tests
23%
10 tests
40%
20 tests
64%
So the fictional piece's "relief from rectal bleeding as early as week 2" (22% vs 14%, nominal p=0.03, a significance figure with no adjustment for the many tests, on a page headed "Exploratory endpoints") looks persuasive and proves little. FDA used nearly these words about an early-onset claim in a TV ad for another medicine: "Claims that draw conclusions from exploratory endpoints are misleading."39
FDA's consistent-with-labeling guidance leaves some room for data outside the label when it is "scientifically appropriate and statistically sound", so a flat ban on exploratory data is a company's house rule, a defensible and stricter one.9
06 · What FDA's letters challenge
We read FDA's 87 untitled letters: on professional pieces, over half attack the evidence itself
In shortFDA's letters jumped from 5 in 2024 to 63 in 2025, with 24 more in 2026 through September. TV ads dominate the count, and their problems are mostly about presentation. Pieces aimed at doctors are different: by our count, 12 of 21 letters on them object to the kind of study or analysis behind a claim, which is exactly what a page-level medical check should catch.
FDA's untitled letters went from a handful a year to 63 in 2025
Letters on OPDP's list by letter date. 2026 runs through September 28
22017
52018
72019
22020
42021
32022
42023
52024
632025
242026
Source7 · 52 of the 63 are dated September 9, 2025. Page content current October 16, 2026.
Show the numbers
Year
Letters
2017
2
2018
5
2019
7
2020
2
2021
4
2022
3
2023
4
2024
5
2025
63
2026
24
Other counts differ for honest reasons. King & Spalding, a law firm, counts 74 letters to drug and biologic makers in 2025, 64 untitled and 10 warning, because it adds warning letters and, it appears from a report by the law firm Covington, a letter from CBER, FDA's biologics center, that is not on OPDP's page.40,41
FDA said on September 9, 2025 that it was sending "thousands of letters" to companies and about 100 cease-and-desist letters, following a presidential memorandum, and that it was already using "AI and other tech-enabled tools to proactively surveil and review drug ads".23,42 The other guides in this series read these letters for claims wording and TV risk passages. This reading asks a different question: what kind of piece drew the letter, and did FDA challenge the evidence underneath?
TV ads draw over half the letters, and about one in four concerns a piece aimed at doctors
The 87 untitled letters dated 2025 and 2026, by the piece FDA reviewed
87letters
TV ads49
Professional pieces21
Other consumer or audience not stated17
Our reading of the sources7 · Our count, from each letter's opening and text. A letter on both a professional and a consumer page counts as professional.
Show the numbers
Piece
Letters
TV ads
49
Professional pieces
21
Other consumer or audience not stated
17
Then we checked each letter for an objection to the analysis itself. Three shapes recur. A letter can fall in more than one, and we count 21 letters with at least one. A letter counts only where FDA itself makes the objection.
Exploratory and unplanned analyses lead FDA's objections to the evidence behind a claim
Letters of the 87 raising each objection. Our count
Exploratory, post hoc or unplanned analysis used as proof10 letters
Single-arm study used for what it could not show9 letters
Open-label design or a selected group of responders6 letters
Our reading of the sources7 · Our count. 21 letters in all, with overlaps. A reader could move a letter between rows.
Show the numbers
Objection
Letters
Exploratory, post hoc or unplanned analysis used as proof
10 letters
Single-arm study used for what it could not show
9 letters
Open-label design or a selected group of responders
6 letters
Evidence objections appear in 57% of letters on professional pieces, against 10% on TV
Share of letters in each group with at least one of the three objections above. Our count
Professional pieces (12 of 21)57%
Other consumer or audience not stated (4 of 17)24%
TV ads (5 of 49)10%
Our reading of the sources7 · Three kinds of objection only. Counting other evidence objections would raise each share.
Show the numbers
Group
Share
Professional pieces (12 of 21)
57%
Other consumer or audience not stated (4 of 17)
24%
TV ads (5 of 49)
10%
How we made this count, and what it leaves out. These counts are ours, and FDA publishes no such tally. We took the 87 letters dated 2025 and 2026 from FDA's table, searched every letter for terms such as exploratory, post hoc, prespecified, multiplicity, single-arm, open-label and subset, and read each match. We then read by hand the nine letters on professional pieces outside the count and ten others drawn at random, and none of them belonged in it.
The hand reading moved letters between rows and left 21, 12, 5 and 4 unchanged: three letters carry "exploratory" or "nonprespecified" only in the piece's own words, while FDA's stated ground is the single-arm design, so they count in that row.
The count covers only the three objections charted. It leaves out letters that fault evidence in other terms, such as a retrospective claims study, a trial not designed for the claim, or missing data, along with warning letters and letters not on this list. FDA chooses what to write about, so these shares describe FDA's letters. They are no measure of how often pieces contain errors.
Piece FDA reviewed
What the letter says, from FDA's copy
The page check it maps to
Professional visual aid, July 28, 2026
A bar graph on complete remission rested on an exploratory endpoint with "no alpha" allocated (no share of the study's allowance for false alarms), so the data "do not support conclusory claims". FDA acknowledged a disclaimer on page seven.43
Endpoint and analysis
Professional web pages, June 24, 2026
Claims drew on open-label and post hoc analyses, and with no planned control of false positives "it is not possible to ascertain" whether findings were due to treatment.44
Endpoint and analysis
Professional sales aid, September 9, 2025
A disease control rate came from a single-arm trial, which "did not establish" whether stable disease was the drug's effect or the disease's natural history.45
Endpoint and analysis
Speaker deck, April 28, 2025
A "demonstrates consistency" claim rested on pooled studies that "were not designed to assess the difference" it described, with no planned control of false positives.46
Population and endpoint
Exhibit panel table, February 3, 2025
A table headed as a real-world comparison of adherence cited data on file, and "the referenced study does not support conclusions" on comparative adherence, because of its design and methods.18
Comparison, data on file
Exhibit panel, February 3, 2025
The panel "fails to include any risk information" for a medicine with serious known risks, and a complaint had come in through FDA's Bad Ad program.18
Fair balance
TV ad, September 9, 2025
An itch claim "as soon as 48 hours" rested on a post hoc, descriptive analysis, and the longer-term figures on "a subset of IGA responders".37
Endpoint, population, timepoint
Real letters are quoted from FDA's own copies and only for what they say. A letter is FDA's view of a piece, and the products are named only in the source list. Letters are read from FDA's copies as posted. None of them is connected to this guide's fictional example.
What FDA's letters ask for. All 87 give 15 working days to respond, and 86 ask for a list of all promotional communications carrying similar representations, "with the 2253 submission date".7 Answering that takes a record linking each claim to every piece that used it. A team without one finds out during those 15 working days. The label change guide covers the same need from the other direction.
07 · Routing by risk
Risk tiers in promotional review: when one reviewer is enough and when a piece needs the full committee
In shortReading every piece the same way spends the same hours on a resized banner and a launch TV spot. Many teams sort pieces into tiers: a fast lane, a standard lane and a full committee. FDA sets no tiers and no public study ranks them, so each tier is a judgment your company writes down, and defends.
Routing asks two questions of a piece: how much new judgment does it need, and how much harm follows if it is wrong? A banner reusing approved wording, on a brand with a stable label, carries little of either. A first TV spot for a launch carries both. Teams often set rules such as "broadcast always goes to committee" and "a new claim can never be fast-tracked".
No regulation requires any of this, and DIA's best-practice article does not cover tiers at all.17 Veeva's paper promotes "tier-based reviews", with business rules moving much of the content through streamlined lanes; that is a vendor's recommendation.47
Reach and novelty decide the lane: reused banners go fast, launch TV goes to committee
Audience reach →
Standard, broadcast rules
Full committee
Fast track
Standard
Resized bannerLibrary-claims emailJournal adNew-claim detail aidOn-file comparisonLaunch TV spot
New judgment needed →
Illustrative · replace with your own numbers · A way to draw your own map. Where a piece falls depends on your brands and house rules.
Show the numbers
Item
New judgment needed (0–1)
Audience reach (0–1)
Resized banner
0.10
0.15
Library-claims email
0.10
0.33
Journal ad
0.30
0.66
New-claim detail aid
0.75
0.24
On-file comparison
0.80
0.05
Launch TV spot
0.72
0.72
Good reasons to raise a tier
Good reasons to lower one
What a tier should never do
New claim, comparison or superiority wording, exploratory or subgroup data, data on file, patient audience, broadcast, a recent label change, a brand under an open FDA letter.
Every claim matches the library word for word, safety text is the current module, only format or size changed, the audience is unchanged.
Drop the filing, skip a required signature under your own procedure, or let the same person write and approve.
What a weekly committee adds to the calendar, before anyone reads a word
A piece that is ready on a random day waits, on average, half the gap until the next meeting. With a weekly committee that is 3.5 days; with a meeting every two weeks, 7. If a piece misses a cut-off, add a full cycle.
That arithmetic is why many teams keep meetings for live disagreements and let reviewers read and comment in parallel between them. The DIA article describes a standing committee, and vendors report the time in review as a whole. We found no published split between waiting and reading.17
A committee every two weeks adds a week of waiting to the average piece, on arithmetic alone
Average calendar days a ready piece waits for the next meeting
Reviewers comment in parallel, meeting only for disputes1 day
Weekly committee3.5 days
Committee every two weeks7 days
Weekly, and the piece misses a cut-off10.5 days
Illustrative · replace with your own numbers · Half the interval, plus one full cycle for a missed cut-off. One day for parallel review is an assumption. Replace with your own.
Show the numbers
Set-up
Average wait
Reviewers comment in parallel, meeting only for disputes
1 day
Weekly committee
3.5 days
Committee every two weeks
7 days
Weekly, and the piece misses a cut-off
10.5 days
08 · Why pieces come back
Why pieces go through more than one MLR round, and why legal approves fewest on the first pass
In shortVendors report about 1.3 to 1.5 review rounds a piece, and legal reviewers approve the fewest on the first circulation. A low rejection rate per piece still means most campaigns hit a rework, because any one of several assets can send the campaign back. No independent study has broken comments down by cause, so count your own.
Legal approves about 56% on first circulation, and marketing about 79%
First-circulation approval by reviewer role, 2025 benchmark. Vendor's data
Marketing79.2%
Medical66.7%
Regulatory64.6%
Legal55.7%
Source2 · Vodori, from its own customers' data; sample and method are not stated on the page we read.
Show the numbers
Reviewer
Approved first time
Marketing
79.2%
Medical
66.7%
Regulatory
64.6%
Legal
55.7%
The figures do not say why legal comes last. One reasonable reading is that legal reviews comparisons and wording that have no page to settle them, while a medical question often ends once the page is open. Treat that as a question to put to your own comments.
The campaign arithmetic that turns 74% first-time approval into 95% rework
Veeva's 2021 benchmark, its latest in that form we could read, says 74% of digital content is approved in the first cycle. Klick, an agency, points out that the chance of at least one asset in a ten-asset campaign needing rework is then 1 − 0.7410, about 95%, if outcomes are independent. Klick reports about 72% for a 12% rejection rate, its own figure from more than 40,000 reviews, and it sells a tool in this field.48,3
Even with 74% first-time approval, a ten-asset campaign almost always meets a rework
Chance at least one asset needs another round, assuming independent outcomes
74% approved first time (Veeva, 2021)88% approved first time (Klick's own figure)
0%25%50%75%100%95%72%
1 asset3510
Our reading of the sources3,48 · The method and the 95% and 72% are Klick's; the other points are our arithmetic. Vendor data.
Show the numbers
74% approved first time (Veeva, 2021)
88% approved first time (Klick's own figure)
1 asset
26%
12%
3
59%
32%
5
78%
47%
10
95%
72%
Five habits that create rounds nobody planned for
Habit
What it does
What to try
Reviewing in sequence
Legal's comment undoes medical's approved wording, and the piece circulates again.
Comment in parallel, on one version, and resolve conflicts once.
Late sight of the claims library
Agencies write new wording for things that have approved wording.
Give agencies the library before layout. Klick argues for moving checks upstream.48
Comments without a reason
"Please revise" leaves the agency guessing, and the guess gets reviewed.
Every comment names the page, the section or the rule, with the wording wanted.
Preference as requirement
Style edits sit among legal risks with the same weight.
Mark each comment "must" or "suggest". Track who overrides what.
No final check on the fixes
An agreed change never makes it into the piece.
A proofreader, as DIA describes, confirms changes, "often times eliminating the need for the MLR committee to review the material again".17
09 · Filing with FDA
Form FDA 2253 at first use: what MLR review hands to the agency, and when
In shortWhen a piece first goes out, the company files a copy with FDA on Form FDA 2253 along with the current label. The filing is a duty, and it starts no review and brings no approval. OPDP receives over 70,000 submissions a year and comments only on request, on a 45-day goal for launch materials that it sometimes misses.
Signed is the end of the company's review, and first use starts the filing duty
1Final piece signed
All required reviewers have signed the final version.
Medical, legal, regulatoryYour procedure
2Package assembled
Form FDA 2253, the piece, and the current professional labeling. Annotated copies encouraged.
RegulatoryBefore first use
3First use
The piece is disseminated or published.
Brand teamThe trigger
4Filed with FDA
Electronic submission for in-scope pieces, at the time of first use.
RegulatorySame time
5FDA may read it
No approval comes back. FDA may write if it objects.
All required reviewers have signed the final version.
Medical, legal, regulatory
Your procedure
Package assembled
Form FDA 2253, the piece, and the current professional labeling. Annotated copies encouraged.
Regulatory
Before first use
First use
The piece is disseminated or published.
Brand team
The trigger
Filed with FDA
Electronic submission for in-scope pieces, at the time of first use.
Regulatory
Same time
FDA may read it
No approval comes back. FDA may write if it objects.
OPDP
Any time
The rule's words are short: submit "at the time of initial dissemination of the labeling and at the time of initial publication of the advertisement", with "a completed transmittal Form FDA-2253" and "a copy of the product's current professional labeling".5 For biologics, 21 CFR 601.12(f)(4) points to the same rule.12 Filing is tied to an event, so a piece signed in June and first used in October is filed in October, and someone has to watch for that date.
FDA's guidance says firms are "encouraged, but not required" to send annotated versions with ordinary 2253 submissions.15 Annotation matters more to the company than to FDA: it is the record of what supported each claim on the day it was signed.
OPDP's Form 2253 submissions climbed from 59,000 to 70,000 in three years
"Over" each figure, calendar years, as FDA's newsletter states them
59,0002021
64,0002022
67,0002023
70,0002024
Source20,49,50,51 · FDA's 2022 issue says submissions "decreased by 5%" and also prints over 64,000, against over 59,000 for 2021. Those pieces numbered over 145,000 in 2021 and over 150,000 in 2024. Later years appear only in chart images on OPDP's page.
Before use, on request. Annotated copy with page and line support.15
Comments. For launch materials, a 5-business-day screening, then a 45-day goal; some recent reviews took longer.6,52
Accelerated approval presubmission
During review for the first 120 days; then at least 30 days before use.11
Required to receive it before use.
Missing the filing draws its own heading. FDA's warning letter of March 13, 2026 has a section titled "Failure to Submit Under Form FDA 2253" on a podcast, and asks for a corrective plan.19 Covington also reports a 2025 warning letter alleging failure to submit the form at initial dissemination.41 Two untitled letters, on company webpages, say a copy "was not submitted to FDA under cover of Form FDA-2253".7 A piece nobody thought of as promotional, an interview or a podcast, may be the likeliest to miss both review and filing.
10 · How long review takes
How long MLR review takes: 14.8, 21, 24 or 29.9 days, depending on who measures and how
In shortEvery published MLR benchmark comes from a company selling something, and they measure different things. They suggest two to four weeks, with the US at the slow end. None of the reports states whether its days are business or calendar days, and we found no public figure for reviewer hours or cost per piece. Your own number is the only one you can act on.
Published averages run from about 15 days to about 30, and each one is a vendor's
Average days to approval or per job, as each source defines it. Do not compare closely
Vodori 2025, whole job14.8 days
Veeva, Germany, 202315.4 days
Veeva 2021, all countries20.5 days
Veeva 2025 paper, global21 days
EY page, no method stated24 days
Veeva 2021, US29.9 days
Source2,36,47,4,35 · The Germany figure was read only as an excerpt. Vodori's review stage alone is 7.6 days. Veeva's 21 days is a 2021 figure for digital content, restated as consistent in its 2025 paper.
Show the numbers
Source
Days
Vodori 2025, whole job
14.8 days
Veeva, Germany, 2023
15.4 days
Veeva 2021, all countries
20.5 days
Veeva 2025 paper, global
21 days
EY page, no method stated
24 days
Veeva 2021, US
29.9 days
Two details keep these numbers honest. Vodori's 14.8 days is the whole job, up from 13.8 in 2024, and its review stage is 7.6 days, up from 6.6.2 Veeva's 2021 report splits its 21 days into 6 before review and 15 in it.3
Veeva's 2025 paper adds that pre-review work ranges "from five to 150 days for each asset".47 The biggest delay may not sit in the review at all. The same paper says field teams "rarely or never use 77% of approved content".47 On day type, Veeva's product help says its Days to Approval field includes weekend days, which points to calendar days for that vendor; its reports do not say.53
In Veeva's 2021 count, more than a quarter of the wait comes before review begins
Average days to approval, 21 in all. Vendor's data
Reviewer hours and cost per piece: numbers nobody publishes, and how to get your own
Reviewer hours per piece, cost per piece, errors per piece, how many comments are avoidable: we found no public figure for any of these.
EY says MLR review costs the pharma and medtech industries "tens of millions of dollars per year", with no method.4 Veeva's paper puts the industry's content spending at about $30 billion a year, and a 2019 JAMA paper put US medical marketing at $29.9 billion in 2016.47,54 Those figures show scale and say nothing about review. A two-week study of your own logged pieces will tell you more than any of them. Section 18 shows how.
11 · What goes wrong
Seven ways a claim gets past promotional review, and what happens when one reaches FDA
In shortThe errors that get through are often right numbers about the wrong patients, old safety text, a footnote that points nowhere, a comparison broader than its data, or risk set in small gray type. The consequences run from one public letter and a list of every similar piece to, in the worst past cases, billion-dollar settlements over wider conduct.
Failure
Fictional example
Why it gets through
The rule it touches, 21 CFR 202.1(e)
Subgroup shown as the result
"2 out of 3 stay in remission"
The number matches, and the reviewer ticks it.
(6)(v) larger experience than the study represents
Exploratory endpoint as efficacy
"Relief as early as week 2"
Early onset is what the brand team wants most.
(6)(i) beyond substantial evidence
Risk played down
"Safety profile similar to placebo" with serious infections at 2.1% vs 1.4%
Numbers may be close, and the phrase feels mild.
(6)(iv) safer than demonstrated
Superseded safety text
Safety block from the March 2025 label after a September 2026 revision
Safety text gets pasted from the last piece.
(6)(iii) rendered invalid by newer information
Comparison wider than its data
"#1 prescribed" on office-based GI prescribers for one quarter
Data on file is hard to open, and the claim sounds like a fact.
(6)(ii) comparison not demonstrated
Reference that does not support
An anchor to page 5 when the result is on page 6
Nobody opens a reference for a claim that looks familiar.
(6)(x) references that do not support the claim
Risk out of sight
Safety text in 8 point, 45% contrast, last page, after the references
Claims are read line by line; layout is seen once at the end.
(7)(viii) prominence and readability
The little independent evidence on how often claims fail their references
Independent measurement is thin and old, and it looks at published journal ads. One often-cited study examined ads for blood pressure and cholesterol drugs in six Spanish medical journals from 1997, and in 45 of 102 retrievable claims (44.1%) "the promotional statement was not supported by the reference", most often because the slogan recommended the drug for patients other than those studied.16
A 2009 systematic review of 24 studies across 26 countries found less than 67% of claims rested on a systematic review, a meta-analysis or a randomized trial.55 Neither speaks directly to a modern company's reviewed pieces, and we found no current study that does.
In the 2003 audit, 44% of checked claims were not supported by the study cited
44 in 100
journal ad claims for blood pressure and cholesterol drugs not supported by their cited reference, in six Spanish journals in 1997. Most often the slogan named a different patient group. Dated and local, and the best direct measure we found.
journal ad claims for blood pressure and cholesterol drugs not supported by their cited reference, in six Spanish journals in 1997. Most often the slogan named a different patient group. Dated and local, and the best direct measure we found.
44 of 100
What follows a letter: 15 working days, a list, and sometimes a corrective plan
An untitled letter names the piece and quotes it. FDA asks for immediate action and a response within 15 working days, listing similar communications.7 A warning letter adds a warning of legal action, "including, without limitation, seizure and injunction", and may ask for a corrective plan.19 Letters are public, and FDA posts them under the company's and product's name.
The larger cases reach far beyond one piece: DOJ lists off-label settlements of $2.3 billion (Pfizer, 2009) and $1.5 billion (Abbott, 2012), each covering wider conduct than one piece.56 A 2019 JAMA paper counted 103 settlements worth over $11 billion for off-label or deceptive marketing since 1997.54 The patient harm is harder to count. A doctor who believes a medicine helps two in three, or carries little risk, makes a worse decision with that patient, and no published figure measures it.
12 · AI and its limits
AI in MLR review: what software can compare, what reviewers keep, and what regulators have said
In shortSoftware is well suited to comparison: finding a page, reading a number, matching safety text word for word. Judgment stays with people: whether a piece leaves a fair impression, and whether a claim should be made at all. No regulator has written rules for AI in promotional review. Published work warns that AI citations often fail, and our PubMed and web searches found no peer-reviewed test on promotional claims.
A useful test sorts the checks. If a person could verify the answer in seconds by looking at a page, software can do the first pass and show the page. If the answer depends on how a reader will take a sentence, or on how much risk a company will accept, a person decides.
Comparison suits software; overall impression and acceptance of risk stay with reviewers
WeakPartialStrong
Software first passPerson decidesFind every number and anchorStrongWeakOpen the cited page, compare valueStrongWeakCompare population, endpoint, timepointStrongPartialMatch safety text to current labelStrongWeakMeasure type size, contrast, word shareStrongPartialFlag exploratory or subgroup wordingPartialStrongIs a comparison fair?WeakStrongDoes the whole piece mislead?WeakStrongDismiss a finding; approve the pieceWeakStrong
Our reading of the sources1,9,57 · Our judgment, offered as a starting point. Test it on your own pieces.
Show the numbers
Software first pass
Person decides
Find every number and anchor
Strong
Weak
Open the cited page, compare value
Strong
Weak
Compare population, endpoint, timepoint
Strong
Partial
Match safety text to current label
Strong
Weak
Measure type size, contrast, word share
Strong
Partial
Flag exploratory or subgroup wording
Partial
Strong
Is a comparison fair?
Weak
Strong
Does the whole piece mislead?
Weak
Strong
Dismiss a finding; approve the piece
Weak
Strong
Text
What it says that bears on promotional review
Status, November 3, 2026
FDA draft on AI for regulatory decisions
Excludes AI "when used for operational efficiencies (e.g., internal workflows, resource allocation, drafting/writing a regulatory submission) that do not impact patient safety, drug quality, or the reliability of results". It does not mention promotional review.58
Draft, January 2025. No final version found. Be ready to say why your use fits the exclusion.
EMA reflection paper on AI
Responsibility stays with the marketing authorization holder across the medicine's lifecycle.59
Adopted by EMA's human medicines committee September 9, 2024.
EU AI Act
High-risk rules for Annex III uses apply from December 2, 2027, and for AI in regulated products from August 2, 2028. A claims check looks unlikely to be high-risk, by our reading; ask counsel.60
Regulation (EU) 2026/1744 in force July 27, 2026.
21 CFR Part 11
Where an FDA-required record is electronic: audit trails and signatures showing name, date and time, and "the meaning (such as review, approval, responsibility, or authorship)".13,14
In force. Whether your review record falls under it is a question for your quality team.
Draft EU GMP Annex 22, FDA Computer Software Assurance
Written for other work. The draft Annex covers critical manufacturing uses, and says generative AI and large language models "should not be used" there. FDA's guidance covers device production and quality system software.61,62
Annex 22 still a draft; EudraLex lists none and Annex 11 at January 2011.63 The FDA guidance was finalized in February 2026. Neither governs promotional review.
ISPE GAMP AI guide
Industry practice for AI-enabled computerized systems in GxP areas, the regulated work of drug development, manufacturing and quality. A useful checklist to borrow.64
July 2025.
What the published evidence warns about AI and citations
The study closest to this work tested seven large language models, the kind of AI behind chatbots, and checked whether their cited sources backed what they said.57
800 questions
medical questions, with about 58,000 statement-and-source pairs.57
One study, on models answering freely
50 to 90%
of model responses were not fully supported by the sources they cited.57
Medical questions in general
About 30%
of statements were unsupported even for one model with web search on.57
SourceCheckup, 2025
That is about models answering freely, and a checker that opens a known page and quotes a passage is a narrower task. We searched PubMed and the web for a peer-reviewed test on promotional claim checking and found none as of November 3, 2026, which is no proof that none exists. So ask for measurements on your own pieces, including planted errors, and read vendor benchmarks as a vendor's.
EY's "at least 54% of errors" and "51% of reviewer time" come with no method on the page.4 Klick reports a 16-day shorter cycle at one unnamed client.48 Veeva's "up to 75%" appears as Veeva's estimate.47
One thing automation can make worse. A green mark is a strong signal, and a tired reviewer may stop reading past it. A tool that says "matches the cited page" has told you about the page. Whether the claim leaves a fair impression is still open, and the design should make that plain.
13 · How teams do it today
A typical promotional review today: agency, coordinator, three reviewers, a Thursday meeting
In shortA piece passes through an agency, a brand coordinator, three reviewers and often a committee. In our planning estimate, most hours go to opening references and working through comments, and much of the calendar goes to waiting between people. Teams run the work in house with an agency's help, buy content approval software, or outsource parts of it, and the split of hours below is for you to replace.
Agency lead to committee chair: who touches an MLR submission
AL
Agency account lead
Delivers pieces and revisions, marks references, turns comments around.
Cares about: one clear list of changes, each with its reason.
BC
Brand coordinator
Submits for the brand team, watches dates, chases decisions.
Cares about: the campaign date that was promised to sales.
MR
Medical reviewer
Checks the science against each reference and the label.
Cares about: judging claims, instead of hunting for footnotes.
RR
Regulatory reviewer
Checks the label, fair balance and FDA rules, and files Form 2253.
Cares about: no old safety text in the field.
LR
Legal reviewer
Reads comparisons, trademarks and exposure under wider laws.
Cares about: the population behind every "#1".
OL
MLR operations lead
Owns routing rules, the calendar and the metrics, and often chairs the committee.
Cares about: meeting time spent on real judgment calls.
Eight steps and seven hand-offs separate an agency's draft from first use
1Draft in
The agency sends the piece and references.
Agency, brand coordinatorDay 0
2Triage
Complete? Which lane? Which reviewers?
MLR operations1 to 2 days
3Reference check
Each claim opened at its page.
Medical2 to 5 days
4Label and legal read
Safety text, fair balance, comparisons.
Regulatory, legal2 to 4 days
5Comments to agency
Revisions, then back through the check.
Agency, all reviewers3 to 8 days
6Committee
Open questions resolved.
All three, chairNext meeting
7Signatures
Final version signed; proof checked.
All three1 to 2 days
8First use and filing
Form FDA 2253 at first use.
RegulatoryOn the date
Illustrative · replace with your own numbers · Illustrative durations, in the range of the benchmarks above. Time your own.
Show the numbers
Step
What happens
Who
Time
Draft in
The agency sends the piece and references.
Agency, brand coordinator
Day 0
Triage
Complete? Which lane? Which reviewers?
MLR operations
1 to 2 days
Reference check
Each claim opened at its page.
Medical
2 to 5 days
Label and legal read
Safety text, fair balance, comparisons.
Regulatory, legal
2 to 4 days
Comments to agency
Revisions, then back through the check.
Agency, all reviewers
3 to 8 days
Committee
Open questions resolved.
All three, chair
Next meeting
Signatures
Final version signed; proof checked.
All three
1 to 2 days
First use and filing
Form FDA 2253 at first use.
Regulatory
On the date
Where a piece's hours go when references are opened by hand
Opening references and re-reading revisions take more hours than the committee does
Hours on one mid-size detail aid, all people, by our estimate
References and claimsLabel, fair balance, house rulesComments and revisionsCommittee and signatures
Illustrative detail aid, 32 hours11 h6 h10 h5 h
Illustrative · replace with your own numbers · No published split exists. Replace with a log of your own pieces.
Show the numbers
References and claims
Label, fair balance, house rules
Comments and revisions
Committee and signatures
Illustrative detail aid, 32 hours
11 h
6 h
10 h
5 h
In-house reviewers, content approval software, or an outside reviewer: three ways teams run MLR
Way
What you get
Where it strains
In house, with shared folders and email
Low cost, full control, suits a few pieces a month.
No record linking a claim to its pieces. Version mix-ups grow with volume.
Content approval software
One version, tracked comments, routing, signature history, a library of materials.
Reviewers still open references themselves unless the software checks the page.
Outside reviewers or submissions help
Flexible capacity for launches, and filing help.
The company still signs and answers for the piece, and knowledge leaves with the contract.
Part B · See it working
Botminds MLR Review Automation on one colitis detail aid at a fictional biotech
This part shows how Botminds does the work Part A described. Northwind Bio, its brands, its people, its agency and its studies are sample data, and so is every number on the screens.
14 · P-2417, start to finish
Detail aid P-2417: 14 claims pinned, four red, three signatures and a Form 2253 package
In shortThis is the example from the top of the page, inside the product. Six agents (pieces of AI software, each with one job) find every claim in the piece, open each cited source at its page, and mark each claim green, amber or red on the piece itself. Dr. Maya Chen, Omar Haddad and Lena Ortiz decide every finding and sign. Only then is the filing package built.
1
Thursday's work is in one queue, each piece with its lane and what is open
Dr. Chen starts with the review queue. P-2417, "Remission at 12 weeks and at 1 year", is in reviewer check on the full-committee lane, due October 8, with 4 red and 6 amber findings. Two new pieces wait above it: a Talvoren email from Priya Ranvelle at the agency, Wrenfield Health, and a Veltrimab rep-triggered email.
The review queue. Every piece with its tier, stage, red and amber counts and who has signed.
2
The piece itself is the workspace, with every claim numbered on the page
She opens P-2417. The four tablet pages fill the left of the screen, with 14 claims underlined and pinned: 4 not supported, 6 to fix, 4 supported. Clicking a pin opens its evidence on the right. Pin 6, the large line on page 2, is open first.
The pinned piece. The evidence for the open pin sits beside the page it belongs to.
3
"Re-check every claim" shows the page check running, pin by pin
Pressing the button replays the agents in view. The extractor drops 14 gray pins, and each one takes its color as the reference verifier opens its page. Here 4 of 14 are done: page 7's week-2 relief rests on an exploratory endpoint, page 6 says the same as the piece, and one anchor pointed at page 5 when the result is on page 6.
The check, in view. Each line names the source, the page and what was found there.
4
Page 9 shows why "2 out of 3" turned red
The panel quotes the piece, then opens VLT-302 at page 9 with the passage marked. A short table sets the piece against the source. Value and timepoint match. Population and analysis do not: the 67% comes from the 141 patients already in remission at week 12, a descriptive subgroup. The panel adds that the label and the primary analysis report 55% vs 30% at week 52 in week-12 responders.
Piece against source. A cross marks each row that fails. The study and journal are fictional.
5
"Use approved claim" puts CL-036 in, with its footnote
She accepts the suggestion. Approved claim CL-036 replaces the line: "At week 52, 55% of patients were in clinical remission vs 30% with placebo†", and the footnote names the population, patients with a clinical response at week 12 who were re-randomized. Pin 6 turns green and reads "Fixed". She can undo it, send it to the agency instead, or dismiss it with a reason.
Green here means the wording matches an approved claim and its page. Part A shows why a reviewer may still ask whether a footnote is enough. In the sample's own numbers, about 32 of 100 patients starting the medicine get to that result.
The approved claim in place. The change goes into the marked-up draft and into the record.
6
With every finding decided, the medical signature records what it means
Dr. Chen applies the remaining suggestions she has read. Anything she unticks stays open. All 10 findings are now decided, every pin is green, and the piece is at version 3. The signature screen shows the count (10 accepted, 0 with agency, 0 dismissed, 0 open), the meaning of the signature, and asks for her password before it is written.
A signature with its meaning. Name, time and meaning go on the record, the items 21 CFR 11.50 lists for signed electronic records.14
7
Regulatory and legal sign, and only then does the package build
Omar Haddad signs the regulatory review with label revision 09/2026 confirmed, and Lena Ortiz signs for legal, both on October 7. The packager then builds the Form FDA 2253 package: form fields, the final piece clean and annotated, the current Prescribing Information and the annotated references. P-2417 no longer needs Thursday's meeting.
Approved, package ready. Each row of the record names a person or an agent. Omar files at first use.
8
The filing preview shows first use on October 12, and a person files
The preview lays out the transmittal details: applicant, application, material type and ID, first-use date of October 12, 2026, labeling enclosed, signatures and enclosures. Filing stays a person's act. Omar schedules it for the day representatives start using the piece, which is when the rule says it is due.5
The package preview. The application number and company are sample data.
Ten of the 14 claims needed a decision, and four needed a different claim or safety text
The fictional detail aid's pins, as first checked
Not supportedTo fixSupported
14 claims on P-2417464
Fictional example from this guide
Show the numbers
Not supported
To fix
Supported
14 claims on P-2417
4
6
4
15 · The other nine findings
From "similar to placebo" to a misplaced anchor: what each reviewer decides on the same detail aid
In shortThe other findings on P-2417 show the range of a review. Three more red pins need medical or regulatory judgment. Amber pins are mostly wording, anchors and required links. Each one names its page, its label section or its house rule, and each goes to the reviewer who owns that kind of question.
1
Pin 4: week-2 relief rests on an exploratory endpoint
"Relief from rectal bleeding as early as week 2" opens VLT-301 at page 7. The passage reads 22% vs 14%, nominal p=0.03, "exploratory and not controlled for multiplicity", and the authors say no conclusion on early onset should be drawn. The label describes no timepoint before week 12. The closest approved claim is CL-031: clinical response at week 12, 58% vs 33%.
An exploratory endpoint. This team's setting treats exploratory data as unsupported for a claim. That is a house rule, stricter than FDA's guidance.9
2
Pin 10: "similar to placebo" against the label's own numbers
"Well tolerated, with a safety profile similar to placebo" opens the current label at page 5. Serious infections occurred in 2.1% vs 1.4%, and the new section 5.3 adds an injection-site warning. The regulatory reviewer gets a rewrite taken from the label wording.
A phrase checked against the label. Labeled "misleading", for the regulatory reviewer to decide. The label text is sample text.
3
Pin 11: the data on file behind "#1"
"The #1 prescribed biologic for new UC patients" opens data on file DOF-VLT-0412. It covers gastroenterology office prescribers only, new-to-brand prescriptions among advanced therapies, June to August 2026: 24.6% against 22.1%. Population, comparator and period do not match. The suggested wording qualifies it, and Lena Ortiz decides: she may also decide the line should not run at all.
A comparative claim. Data on file opens at its page, like any study.
4
Pin 13: safety text from the superseded label
The Important Safety Information block, the risk summary a piece carries, matches the March 2025 label word for word. The current label, revision 09/2026, added Warning 5.3 Injection-site reactions on September 18, 2026. The fix swaps in the standard safety text module for the new revision, approved by Omar Haddad on September 22.
An old label version. Only the version marked current counts.
5
Pin 9: "once-monthly" where the label says every 4 weeks
A small wording fix with a real point behind it: thirteen doses a year are not twelve. The brand guide and label section 2.2 both say every 4 weeks. The suggestion is one click, and the panel still shows its page.
A wording fix. House rule and label together.
6
Pin 2: right number, wrong page
"Clinical remission at week 12: 31% vs 12%" matches the publication and label section 14.1. The annotation linked page 5, and the agent moved it to Table 2 on page 6. No text changes. A wrong anchor still matters: it is the most common finding in the sample's dashboard, and it wastes the next reviewer's time.
An anchor moved. A person confirms it.
7
Fair balance as a reading for the reviewer, 41 against a team threshold of 70
On the marked version, risk carries 14% of the words, in 8 point against a 22-point benefit headline, at 45% contrast, on the last page after the references, with no direction to the full Prescribing Information. The screen calls this evidence and leaves the verdict with a reviewer. FDA's rule asks for comparable prominence and readability and names no point size, so the threshold is this team's setting.1
A reading, for a person. "A reviewer makes the call."
8
Dismissing a finding takes a reason, and the reason goes on the record
A reviewer can disagree. Lena could dismiss the "#1" finding if another reference supports the claim. The reason is required, and it stays with the piece, so a later reader can see who overruled what and why.
A dismissal with a reason. Saying no to a finding costs one sentence.
9
All 14 claims and all 10 findings, for whoever prefers a list
The same evidence can be read as a table of every claim, with where it was checked and its verdict, or as findings sorted by severity and by who owns them. The steps run across the top with a Re-run link.
Findings by severity. Each shows who owns it. Confidence is the model's own figure, for sorting; a reviewer still reads the page.
10
Same check on a TV script, by the second
Pieces come in other shapes. P-2421 is a 60-second TV script, with pins on the audio and video columns. Its benefit lines run at 2.6 words a second and its major statement at 3.9, and fast cuts sit under the risk audio.
FDA's rule asks that spoken risk be at least as understandable as the rest.21 By our count, no FDA letter of 2025 or 2026 raises voice pace specifically, though many raise distracting visuals.7 Pace is a useful measure for a person to weigh, and FDA has drawn no line on it.
A TV script, pinned. Broadcast pieces always go to the full committee under this team's setting. The fair balance guide covers TV review in depth.
16 · Committee and operations
Routing lanes, Thursday's agenda and the label watch: what an MLR operations lead runs
In shortDana Okafor, the operations lead, sets who reads what once, then sees where each piece landed. Thursday's agenda holds open judgment calls only. A label change sets off a re-check of live pieces. The dashboard shows how long approval takes, and its sample readings are design targets until a customer measures its own.
1
Ten pieces in three lanes, each with a reason
The router scores each piece and places it: fast track, one reviewer and two days; standard, three reviewers and five days; full committee, the Thursday meeting. The rules are Dana's. A person can always move a piece up.
Routing lanes. Ten pieces in review, filtered by brand if needed.
2
The agenda carries open questions, beside a watch on the label
Thursday, October 8, 10:00 am: four pieces and their open items. Beside the agenda, the label watch reports that Veltrimab's revision 09/2026 added Warning 5.3 and retired claim CL-019, and that 7 approved, live pieces carry the old safety information.
Agenda and label watch. Judgment calls on the left, live pieces with old safety text on the right.
3
One click re-reads seven live pieces against the new label
The result: five revisions to swap the safety information, and two withdrawals, one that also says "similar to placebo" and one using the retired claim. A person confirms each. The label change guide takes this step much further.
The label sweep. Each live piece is reread, each with its proposed action.
4
Claims with their pages, and label versions kept side by side
The claims library holds approved wording, its reference page, its label section, its status and how many pieces use it. Retired claim CL-019 is still listed in 7 pieces, which is the point of keeping it. References are indexed by page, and the two label versions sit together with what changed.
The claims library. Every approved claim is one click from its page.
5
The dashboard's sample: 13.5 days, 58% in one round, routing 41, 43, 16
Median submission to approval, approved in one round, findings reviewers kept, and where pieces went. These are the sample company's readings and the solution's design targets: 13.5 days against a 29-day baseline, and 58% approved in one round. Your numbers come from your own baseline and your own run.
The dashboard, sample data. The chart below redraws its trend. Treat every figure as a target to measure.
6
Wrong anchors top the sample's findings, ahead of unsupported claims
Of 210 findings in the last 30 days of sample data, 46 are wrong reference anchors, 38 claims not supported on the cited page and 27 outdated safety text. Dana can see where they come from by brand, and which pieces have waited longest.
What the check finds. A team sees which fixes belong upstream with the agency.
7
Thresholds, signers and checks are the team's own settings
Fast track below score 30, full committee from score 60, broadcast and first pieces of a launch always to committee, fair balance line at 70, and who signs for each brand. Each check can be turned on or off, a rule can be added in a sentence, and every change is versioned and on the audit trail.
The rules are yours. None of these numbers comes from FDA.
The sample's median falls from 29 days toward the 13.5-day design target
Days from submission to approval by month, sample data
0 days10 days20 days30 days
NovJanMarMayJulSep
Fictional example from this guide36 · Fictional sample and a design target. The sample's 29-day start is slower than most published averages (section 10) and close to Veeva's 29.9-day US figure for 2021; 13.5 days is also the figure Veeva gives for its fastest customer that year.
Show the numbers
Median days
Nov
29 days
Dec
28 days
Jan
30 days
Feb
27 days
Mar
26 days
Apr
22 days
May
19 days
Jun
17 days
Jul
16 days
Aug
15 days
Sep
14 days
Oct
13.5 days
In the sample, 41% of pieces need one reviewer and only 16% reach the committee
Routing mix, last 30 days of sample data. Design target
Fast track, one reviewerStandard, three reviewersFull committee
61 submitted pieces41%43%16%
Fictional example from this guide
Show the numbers
Fast track, one reviewer
Standard, three reviewers
Full committee
61 submitted pieces
41%
43%
16%
The design target more than halves the sample's 29 days to approval
The sample's baseline and the solution's design target
Sample baselineDesign target
Median days to approval29 days13.5 days
Fictional example from this guide · Measure your own baseline first. Published averages run from about 15 to about 30 days.
Show the numbers
Sample baseline
Design target
Median days to approval
29 days
13.5 days
17 · Who checks, who signs
Six agents check and package; medical, regulatory and legal reviewers decide and sign
In shortEach agent has one job and a written limit. None approves a piece, signs for a person or files with FDA. On fast track one person signs; on standard and committee, three. The whole record, people and agents together, supports your compliance work, and the controls are yours to validate.
From the claim extractor to the 2253 packager: each agent's job and its limit
Claim and anchor extractor
Finds every claim, statistic and reference anchor in an email, PDF, deck or TV script, and pins each on the piece, with value, comparator, endpoint and timepoint held for each statistic.
Never paraphrases a claim.
Reference verifier
Opens each cited reference at the anchored page, finds the passage, compares the claim with it and moves an anchor that points to the wrong page.
Never calls a subgroup or exploratory result "supported" as efficacy.
Label consistency checker
Compares each claim with the current Prescribing Information, and safety text word for word with it, naming any missing warning and its section.
Never uses a superseded label.
Fair balance and safety checker
Measures how prominent risk is next to benefit: share of words, type size, contrast, placement and, for audio, words a second. Checks required statements and links for the channel.
Never passes or fails a piece on its own.
Brand and channel rules checker
Checks approved phrasing, trademarks, absolute and superiority words and channel rules against your brand guide.
Never invents a claim.
Risk router and 2253 packager
Scores each piece, routes it to a lane, and builds the Form FDA 2253 package on approval.
Never approves a piece, or builds a package before every required signature.
Dr. Chen, Omar Haddad, Lena Ortiz and Dana Okafor: the people in P-2417's record
"I reviewed this piece for medical accuracy and confirm each claim is supported by the cited evidence and consistent with the current label."
Omar Haddad, regulatory reviewer
Label, safety text, fair balance, required links, the filing.
Label revision confirmed; files Form 2253 at first use.
Lena Ortiz, legal reviewer
Comparative wording and trademarks.
Legal decisions on the record.
Dana Okafor, MLR operations lead
Routing rules, signers and the agenda.
Chairs the committee; does not sign pieces in this sample.
Signers are a setting, so a UK or EU procedure can name its own people. In the UK, the signatory who certifies a piece stays your own registered doctor or pharmacist.30
Detail aids, labels and references in; pins, an agenda and a Form 2253 package out
From your agency
Detail aids, emails, decks, video and TV scripts, banners
Annotated references and data on file
From your team
Current and earlier Prescribing Information
Approved claims library and safety text modules
Brand guide and channel standards
Routing rules and named signers
Agents pin, open and compareEach claim checked at its cited page, under your rules
Reviewers decide every finding
Three people sign
What you get
The piece with every claim pinned green, amber or red
Piece-against-source check per claim: value, population, endpoint, timepoint
Approved claim or label wording for each problem
Risk lane and committee agenda
Form FDA 2253 package at first use
An audit trail of people and agents
Content approval, reference and label systems around the claim check
Kind of system
What it supplies or receives
Content approval system
Pieces and versions in, findings and decisions back. Your approval record stays where it is.
Reference and claims library
Studies, data on file and approved wording, indexed by page.
Label and regulatory information systems
Label versions, with the one marked current.
Submissions publishing
The package, for electronic filing with FDA.
Identity and single sign-on
Named users, roles and maker-checker separation, so the person who prepares a piece cannot approve it.
Enterprise controls, and what they do not replace. Roles, a four-eyes rule that keeps the author from approving, an audit trail with export, and signatures carrying their meaning all support your compliance with rules such as 21 CFR Part 11 where they apply. Botminds is SOC 2 Type II audited and manages information security to ISO 27001. Validating the system for your intended use remains your quality team's decision, and your reviewers remain responsible for every piece.13
Part C · Are you ready to automate?
Automating MLR review: what rounds and waiting cost you, what a page check returns and how to test it
You run promotional review, or you depend on it, or you answer for what your company says about its medicines. This part is written for you: what delay and rework cost today, what automating could return, whether your team is ready, and what to ask any vendor, us included.
18 · What delay costs you
What another MLR round costs you: reviewer hours, missed committee slots and field dates
In shortNobody publishes a cost per piece. Published figures frame the size of the problem: a two-to-four-week trip, about one piece in four going round again, and FDA reading more closely than it has in years. The number that decides your case is your own, and you can have a first version within a week.
14.8 to 29.9 days
from vendors' published averages for a piece's trip through review.2,35
Vendor data; definitions differ
1.5 rounds
on average per job, with first-circulation approval from 56% for legal to 79% for marketing.2
Vodori, 2025; a vendor's data
63 letters
on FDA's untitled letter list dated 2025, against 5 in 2024, with 24 more in 2026 through September.7
Page current October 16, 2026
Most of the hours a page check can give back sit in opening references and second rounds
Hours on one mid-size detail aid, all people
By hand (our estimate)With a page check (our estimate)
References and claims11 hours4 hours
Label, fair balance, house rules6 hours3 hours
Comments and revisions10 hours7 hours
Committee and signatures5 hours4 hours
Illustrative · replace with your own numbers · Neither column is a measurement. Time ten pieces, and measure the second column in a pilot. Reviewers keep their judgment time.
Show the numbers
By hand (our estimate)
With a page check (our estimate)
References and claims
11 hours
4 hours
Label, fair balance, house rules
6 hours
3 hours
Comments and revisions
10 hours
7 hours
Committee and signatures
5 hours
4 hours
Numbers to ask a vendor to prove, ours included. You will see "51% of reviewer time" (one vendor, no method on the page),4 "16 days" off the cycle (one vendor's case study),48 "up to 75%" (a vendor's estimate),47 and our own design targets of 13.5 days and 58% approved in one round. None is independent. Ask for the dataset, the baseline and what counts as a day.
Six costs of a hand-checked MLR review, and how to find each number in a week
Cost
Where it hides
How to find your number in a week
Reviewer hours per piece
Inside salaried time, across three departments.
Ask three reviewers to log the next five pieces, split into opening references and judging.
Agency revision fees
Agency invoices, under project management or rework.
Ask your agencies for hours per round on the last ten pieces.
Rounds and their causes
Your content system's history, uncoded.
Export 50 pieces; code comments as evidence, label, wording, preference or error.
Waiting for committee
The calendar. No one is working, so it looks free.
Days between ready and reviewed, on the last 20 committee pieces.
Field and launch dates missed
Brand plans, as "content late".
List pieces that missed a planned first use last year, and by how long.
Old claims still live
Pieces approved long ago that no one rechecks.
Pick your last label change, and count how long it took to find every affected piece.
A line quoted in public, a 15-working-day scramble: MLR costs no calculator can price
A line quoted back in publicFDA posts its letters, with your product's name and your own words.7
The 15-working-day scrambleFDA's letters ask for all similar communications and their filing dates within 15 working days.7
Corrective workA warning letter may ask for corrective communication across the same audience.19
Your best reviewers leavingMedical and legal staff hired to judge claims, spending their week checking footnotes.
Content nobody usesVeeva says field teams rarely or never use 77% of approved content, a vendor's figure.47 Each unused piece still went through review.
19 · Your return
What a page-level claim check returns in reviewer hours, avoided rounds and days to the field
In shortThree levers pay for the check: hours released from opening references, rounds avoided by catching problems early, and days given back to a brand. Hours count only if you decide what they are for. Below a certain volume, a well-kept library and clearer house rules will return more than any software.
Reference hours, fewer rounds and committee time: where MLR automation earns its keep
Reference checks
Evidence opened before a reviewer starts
Each claim arrives with its page and a comparison, so reviewers confirm and judge.
pieces × hours saved a piece × loaded hourly cost
Rounds
Fewer second circulations
Anchors, old safety text and wording get fixed before the first circulation, or in one list to the agency.
pieces × drop in return rate × hours per round × hourly cost
Routing
Committee time for real disputes
Pieces with no open judgment call skip the meeting and its wait.
pieces moved off the agenda × average days waited
Live pieces
Label changes answered in hours
A record of each claim's use tells you which pieces a new label touches.
label changes a year × hours to find affected pieces × hourly cost
Work out your MLR return from pieces a year, hours and your return rate
No published figure supports these defaults. Every input marked illustrative is an assumption; replace it with your own.
Your volumeHours per piece, all peopleRounds and your cost
Illustrative yearly value
Review work today, valued$0
Hours released, valued$0
Extra rounds avoided, valued$0
After your yearly cost$0
Hours released a year0
Pieces a year to cover your cost0
Formulas, per year: Work today = pieces × hours today × hourly cost Hours released = pieces × (hours today − hours with a page check) × hourly cost Rounds avoided = pieces × (return rate today − return rate with a page check) × hours per round × hourly cost After your cost = hours released + rounds avoided − yearly cost Break-even pieces = yearly cost ÷ ((hours saved + drop in return rate × hours per round) × hourly cost). With no hours or rounds saved, no volume covers the cost, and that row shows a dash.
Not counted: fewer FDA letters, field dates kept, faster label change response, and audit evidence. Released hours are value only when you decide what they are for: fewer agency hours, more pieces reviewed, or reviewers on harder work.
At $200,000 a year, about 111 pieces cover the cost if each saves 14 hours
Pieces a year to cover $200,000, at $120 an hour and a 10-point drop in returns of 10 hours each
Saves 14 hours a piece111 pieces
Saves 7 hours a piece208 pieces
Saves 3 hours a piece417 pieces
Illustrative · replace with your own numbers
Show the numbers
Hours saved
Pieces a year
Saves 14 hours a piece
111 pieces
Saves 7 hours a piece
208 pieces
Saves 3 hours a piece
417 pieces
A team reviewing 60 pieces a year on one brand may gain more from a current claims library, one written house rule list and a parallel comment habit than from new software. Volume, agencies and the number of label changes are what change the answer.
20 · Readiness check
How ready your MLR process is: lanes, references, label versions, signers and baselines
In shortPick the answer closest to your team today. Eight questions score 0 to 2, and the last is for reflection. The meter adds up as you go, and each question says why it matters and what a strong answer sounds like.
1
Pieces a year
How many promotional pieces go through review each year, across brands and agencies?
Why it mattersVolume turns hours per piece into capacity. FDA received over 150,000 individual pieces in 2024.51
A strong answer"About 500 a year across four brands, with email and web growing fastest."
2
Written review lanes
Do you have written rules for which pieces get fast, standard or full review?
Why it mattersSoftware can only route by rules you own. FDA sets none for you.
A strong answer"Three lanes in our procedure, with named triggers such as broadcast and new claims."
3
References at the page
Do agencies send annotated references, with each claim tied to a page?
Why it mattersFDA's filing guidance describes support by "specific page and lines". A check at the page needs readable files.15
A strong answer"Yes, one submission standard for every agency, and scans are converted to text."
4
Label versions
Can you find each label version, with its effective date and which is current?
Why it mattersFavorable information made invalid by newer information is misleading under FDA's rule.1
A strong answer"One store, each version dated, with one person marking the current one."
5
Claims library and safety text
Is there an owned list of approved wording, plus approved safety text modules?
Why it mattersA suggested fix needs approved wording to point to. DIA calls for a core claims document kept up to date.17
A strong answer"One per brand, with its page and footnote, and an owner for each."
6
Who owns which question
Is it written which reviewer decides which kind of finding, and how a dismissal is recorded?
Why it mattersA flagged finding needs one owner. Overlaps between reviewers are a common cause of extra rounds.
A strong answer"A one-page split, with a written reason for any override."
7
Your baseline
Do you know your median days, rounds and first-pass rate, by piece type?
Why it mattersPublished benchmarks differ by definition. Only your baseline shows whether anything improved.
A strong answer"Median 22 days on detail aids, 1.6 rounds, measured for 12 months."
8
Quality and IT path
Do your quality, privacy and IT teams have a way to assess AI in a promotional review system?
Why it mattersYour signed record may need Part 11 controls, and AI needs a stated use.13,58
A strong answer"A named reviewer in quality, a risk-based assessment and a test set on our own pieces."
9
For reflection · the 15-working-day letter
If FDA's letter arrived tomorrow on one line in a live detail aid, what would have to be true for you to list every similar piece and filing date within days?
Why it mattersYour answer lists the gaps. Each is a candidate job for software or for your process.
A strong answerA short specific list: "each claim tied to a page, a record of where it is used, each decision named."
A low MLR score means fixing lanes and references before buying anything
0–6
Explore
Write your review lanes, ask agencies for annotated references, keep label versions dated, and measure a baseline. Start with safety text checks against the current label.
7–11
Ready to pilot
Run a measured pilot on 30 to 50 past pieces, some with planted errors. Compare catches, false alarms and hours with your process, with your reviewers signing everything.
12–16
Ready to implement
Plan the rollout: your rules as settings, named signers, agency standards, links to your content system and libraries, and the evidence an auditor will ask for.
21 · Questions for any vendor
What to ask an MLR review software vendor about pages, subgroups, labels and signatures
In shortAsk each vendor the same questions, us included. The answers show whether a tool checks the content of a cited page or only confirms that a reference is attached, whether reviewers can see why, and how it behaves when it is wrong.
A
Does it open the cited page and compare?
A1
For one claim, show me the page, the passage, and the comparison of value, population, endpoint and timepoint.
Why it mattersA present reference proves little: FDA's rule treats references that do not support a claim as misleading.1
Strong answer · warning sign
A live click to a marked passage.
"Reference found" with no page.
A2
What does it do with a descriptive subgroup, a post hoc analysis or an exploratory endpoint?
Why it mattersBy our count, 10 of 87 FDA letters raise exactly these, and 9 fault a single-arm design used for what it could not show.7
Strong answer · warning sign
It flags the analysis type and quotes the page.
It matches numbers only.
A3
How does it read data on file, tables, charts and scanned pages?
Why it mattersHard-to-open evidence goes unchecked.16
Strong answer · warning sign
A test on your own files.
"PDFs are supported."
B
How do you know it works on promotional pieces?
B1
What are your catch rate and false alarm rate on planted errors, on my pieces?
Why it mattersWe found no peer-reviewed test, and AI citation studies warn of failures.57
Strong answer · warning sign
"Plant them; we will score together."
An accuracy figure with no method.
B2
What does your days-saved figure measure, and from what baseline?
Why it mattersBenchmarks differ from 14.8 to 29.9 days by definition.2,35
Strong answer · warning sign
Dataset, baseline and day type stated.
One unnamed customer.
C
Who decides, and what does the record show?
C1
Can any part of your software approve, sign or file?
Why it mattersNamed people answer for a piece. FDA recommends qualified review; UK and EU codes name who approves.9,30,32
Strong answer · warning sign
No, enforced by role.
"Auto-approve below a score."
C2
Show me the record of one piece: who decided, on what, what a dismissal said, and which label was current.
Why it mattersLetters and audits arrive long after the people have moved on. Signatures should show name, time and meaning where Part 11 applies.14
Strong answer · warning sign
An exportable trail of people and software.
A status history.
C3
How does the screen stop a tired reviewer from trusting a green mark?
Why it mattersA match to a page says nothing about overall impression.1
Strong answer · warning sign
The evidence is shown even on green, and sampled for audit.
Green items are hidden.
D
What happens after approval?
D1
When a label changes, how fast can you list each live piece and each claim it touches?
Why it mattersFDA letters ask for a list with filing dates within 15 working days.7
Strong answer · warning sign
A live demonstration on your data.
A search by keyword.
D2
What claims do you make about certification or regulator approval?
Why it mattersSoftware cannot hold a GxP, Part 11 or Annex 11 certificate. Controls can support your compliance.
Strong answer · warning sign
Named audits, such as SOC 2 Type II.
"FDA-compliant AI."
22 · A pilot on past pieces
Testing MLR automation on 40 past pieces with planted errors, then a parallel run
In shortStart with pieces you have already reviewed, so nothing is at risk and the right answers are known. Plant errors of the kinds that matter, score catches and false alarms, then run alongside your live process on one brand. Decide on four numbers set in advance.
Weeks 1 to 3: baselineTime ten pieces and code the comments on 50. Set your four decision numbers.
Weeks 2 to 5: test setPick 40 past pieces across channels, and plant 40 errors: subgroups, old safety text, wrong anchors, widened comparisons.
Weeks 4 to 6: blind runThe tool checks the test set. A reviewer who did not plant the errors scores it.
Weeks 6 to 12: parallel runLive pieces on one brand, both ways. Your reviewers still sign under your procedure.
Weeks 12 to 14: decideScore, read every miss, and decide.
A 14-week MLR pilot ends with a decision on four numbers
Your teamVendor
Baseline: time ten pieces, code 50
Choose 40 pieces, plant 40 errors
Load references, labels, library, rules
Blind run on the test set
Score catches and false alarms
Parallel run on one brand
Read every miss
Decide
Week 0481214
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Baseline: time ten pieces, code 50
0
3
Choose 40 pieces, plant 40 errors
1
5
Load references, labels, library, rules
2
5
Blind run on the test set
4
6
Score catches and false alarms
5
7
Parallel run on one brand
6
12
Read every miss
11
13
Decide
13
14
Scoring the pilot: catch rate, false alarms, reviewer hours and first-pass rate
Number
How to measure
A pass mark you set before you start (illustrative)
Catch rate
Planted errors found, of those planted, by error type.
At least 90% overall, and none of the subgroup or old-label errors missed.
False alarms
Findings reviewers dismiss, per piece.
Few enough that reviewers keep reading them. Agree a number with them.
Hours per piece
Logged, both ways, on the parallel run.
A drop your finance lead accepts, with judgment time unchanged.
First-pass rate
Approved with no second round, against your baseline.
Up by a margin larger than month-to-month noise.
Deeper questions for your working session, in three groups
Bring MLR operations, medical, regulatory, legal, a brand lead, an agency lead, quality and IT together.
E
Which review rules are FDA's and which are yours
E1
Which of your review rules come from FDA, and which are your own?
Why it mattersA tool will enforce whatever you load, including habits.
Strong answer · warning sign
Each rule marked with its source.
"It has always been done this way."
E2
Is exploratory data banned as a claim, or judged case by case?
Why it mattersFDA's consistent-with-labeling guidance leaves some room.9
Strong answer · warning sign
A written position, with who may override it.
Different answers from medical and legal.
F
What agencies see before they submit
F1
Will agencies see findings before submitting?
Why it mattersCatching problems upstream avoids a round.48
Strong answer · warning sign
A pre-check, with library access.
Findings only after committee.
G
What reviewers do with released hours and green marks
G1
What will reviewers do with released hours?
Why it mattersHours only count if they go somewhere useful.
Strong answer · warning sign
More volume, or harder claims.
"We will see."
G2
How will you audit green marks?
Why it mattersTrust grows faster than accuracy.
Strong answer · warning sign
A monthly sample, re-read by hand.
No sampling.
23 · Questions people ask
MLR review questions answered: process, committee, Form 2253, timing and AI
In shortThe questions reviewers, agencies and buyers search for, each answered on its own.
What is MLR review in pharma?
MLR review is the check of promotional material by medical, legal and regulatory reviewers before a drug company uses it. Medical checks the science against the label and references, legal checks wording and legal exposure, and regulatory checks FDA's promotion rules. Some companies call it a promotional review committee, or PRC.
Does FDA require an MLR committee?
No US rule we read requires a review committee, a medical, legal or regulatory signer, or a set number of review signatures; we read FD&C Act section 502(n), 21 CFR 202.1, 314.81, 314.550 and 601.12(f)(4). The rules fix what a piece may say and require filing at first use, and Form FDA 2253 carries a responsible official's signature. FDA recommends, in its 2018 consistent-with-labeling guidance, that qualified medical or scientific, legal and regulatory people carefully review such a communication before it goes out.
What is MLR review automation?
MLR review automation uses software to do the comparing in a review: finding each claim, opening the cited page, checking the number, population, endpoint and timepoint, and comparing safety text with the current label. Reviewers then decide each finding and sign. Good tools show the page and leave approval to named people.
How long does MLR review take?
Published averages run from 14.8 days to 29.9 days, all from vendors: Vodori reports 14.8 days per job in 2025, Veeva 21 days in 2021 with 29.9 in the US, and EY 24 days with no method stated. None of these reports says whether its days are business or calendar days, though Veeva's product help says its field includes weekends. Measure your own by piece type.
Can AI do MLR review?
AI can do a first pass on comparison work that a person can verify quickly on a page. It cannot decide whether a piece leaves a fair overall impression, whether a comparison is fair, or whether to approve. We found no peer-reviewed test of AI on promotional claims as of November 2026, so test on your own past pieces with planted errors.
Does FDA's AI guidance apply to promotional review?
FDA's January 2025 draft does not mention promotional review, and it excludes AI used for operational efficiencies that do not affect patient safety, drug quality or the reliability of study results. FDA's page still labeled it a draft on November 3, 2026, and we found no final version. A company should be able to say why its use fits, which is easier when a named person decides.
When is Form FDA 2253 due?
Form FDA 2253 is due at the time of initial dissemination of labeling or initial publication of an advertisement, under 21 CFR 314.81(b)(3)(i); biologics follow the same text through 601.12(f)(4). Each submission includes the completed form and the current professional labeling. In-scope submissions have been electronic since June 24, 2021.
Does FDA approve promotional materials before use?
Generally no. FDA says pre-approval is not required except in rare instances, such as a compliance action. Companies may ask FDA's promotion office, OPDP, for advisory comments, with a 45-day goal for launch materials that some recent reviews have exceeded. Accelerated approval products must submit materials ahead of use.
What is an untitled letter from OPDP?
An OPDP untitled letter is a public FDA letter saying a promotional piece is false or misleading, below the level of a warning letter. OPDP is FDA's Office of Prescription Drug Promotion. The letter quotes the piece, asks the company to act, and asks for a response within 15 working days listing similar communications. OPDP's list shows 63 dated 2025 and 24 in 2026 through September 28.
What do FDA's letters most often object to in the evidence?
By our count of the 87 untitled letters dated 2025 and 2026, the commonest evidence objection is an exploratory, post hoc or unplanned analysis used as proof (10 letters), then single-arm studies used for what they could not show (9) and open-label designs or selected responders (6). On pieces aimed at professionals, 12 of 21 letters raise one of these. The count is ours, from FDA's copies, and leaves out evidence objections in other terms.
What is the difference between MLR review and claims substantiation?
Claims substantiation is the work of tying each claim to approved wording and the page that supports it, usually before and during review. MLR review is the wider decision by medical, legal and regulatory reviewers on the whole piece, including fair balance and legal exposure. Substantiation feeds it.
Who signs promotional material in the UK?
Under the ABPI Code, promotional material must be certified in its final form by one person, a UK-registered doctor or pharmacist (a dentist for a dental-only product), who must not be the person who developed it, and material still in use is recertified at least every two years. The UK's medicines regulator, the MHRA, notes this comes from the code and adds that it is not a legal requirement. That person is the company's own, and software cannot take the role.
What should be in an MLR submission?
Typically the piece as the audience will see it, with claims numbered; annotated references with passages marked; the current Prescribing Information; any data on file; and the brand's approved claims. A clear note of audience, channel and first-use date helps routing. Complete submissions avoid an early round spent asking for missing items.
How do you reduce MLR review cycle time?
Start by measuring where days go, since waiting and pre-review may outweigh reading. Then route low-risk pieces to a lighter lane, comment in parallel on one version, give agencies approved wording up front, and keep committee time for real disputes. Software that opens references helps most where volume is high and references are already tidy.
24 · MLR review on one page
MLR review automation on one page: the method, the November 2026 rules, scores and terms
Print this page
In shortThe whole guide on one screen: the method, the rules as of November 2026, the readiness bands and the terms.
The method
Take in the piece, its references, data on file and the current label.
Find every claim and number each one on the piece.
Open each cited page. Compare value, population, endpoint and timepoint.
Compare claims and safety text with the current label version.
Measure risk against benefit, and check house rules and required links.
Route by risk: fast, standard or full committee.
Named reviewers decide every finding, with a reason for any dismissal, and sign.
File Form FDA 2253 at first use. When a label changes, re-check what is live.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of November 2026: 21 CFR 202.1(e) in force · 63 untitled letters dated 2025, 24 in 2026 through September · FDA's agenda lists a broadcast proposal for December 2026, no text published · consistent-with-labeling guidance final, June 2018 · unapproved-use guidance dated January 2025 still reads "not for current implementation" · FDA's AI draft of January 2025 not final · no AI rule specific to promotion · EU pharma package not yet law · draft EU GMP Annex 22 and revised Annex 11 still drafts, and outside this work.
14 terms
MLR review
Medical, legal and regulatory review before use; also PRC.
Detail aid
The presentation a sales representative shows a doctor.
Claim
Anything a piece states or implies about a medicine.
Annotated reference
A study or label with the passage marked and numbered to the claim.
Prescribing Information
A medicine's full approved label; also PI.
Data on file
A company's own unpublished analysis or audit.
Endpoint
The result a study measures.
Exploratory endpoint
A measure outside the study's planned testing; good for ideas, weak as proof.
Subgroup
Part of a study's patients, analyzed separately.
Multiplicity
More tests means more chances of a false alarm.
Fair balance
Benefit and risk presented with comparable prominence.
Form FDA 2253
The transmittal filed with each piece at first use.
OPDP
FDA's Office of Prescription Drug Promotion.
Untitled letter
A public FDA letter that a piece is false or misleading.
25 · Sources
Sources
Accessed November 2026. Regulatory status statements are as of November 3, 2026. Benchmarks from software vendors and agencies are labeled as theirs.
21 CFR 202.1, Prescription-drug advertisements, 2025 edition (revised as of April 1, 2025). govinfo.gov
A. Ludtke, Vodori, "How your medical legal regulatory review compares in 2025", from its 2025 benchmarks report. Vendor data; sample and day type not stated on the page. vodori.com
Veeva, "Commercial Content Trends Shaping the Future of HCP Engagement: 2021 Veeva Pulse Content Metrics Report". Vendor data. veeva.com
EY, "Smart Reviewer" page. Vendor data; no method stated. ey.com
21 CFR 314.81(b)(3)(i), Advertisements and promotional labeling, 2025 edition. govinfo.gov
FDA, "OPDP Frequently Asked Questions", content current May 31, 2024, read November 3, 2026. fda.gov
FDA, "Office of Prescription Drug Promotion Untitled Letters", table and the 87 letters dated 2025 and 2026, content current October 16, 2026. Counts and classifications are ours: method in section 6. fda.gov
FDA, "Instructions for Completing Form FDA 2253", items 10 to 12. fda.gov
FDA, "Medical Product Communications That Are Consistent With the FDA-Required Labeling: Questions and Answers", guidance, June 2018. fda.gov
21 U.S.C. 352(n), FD&C Act section 502(n), 2024 edition of the US Code. govinfo.gov
FDA, "Providing Regulatory Submissions in Electronic and Non-Electronic Format: Promotional Labeling and Advertising Materials for Human Prescription Drugs", guidance, Revision 1, April 2022. fda.gov
Villanueva P, Peiró S, Librero J, Pereiró I, "Accuracy of pharmaceutical advertisements in medical journals", Lancet 361(9351):27-32, 2003 (abstract). pubmed.ncbi.nlm.nih.gov
E. Dankiewicz, "Time to Review Your Promotional Review? Best Practices in the US", DIA Global Forum, April 2021. globalforum.diaglobal.org
FDA, untitled letter on an exhibit panel, February 3, 2025 (Hemady). fda.gov
FDA, warning letter 725468, March 13, 2026 (Anktiva). fda.gov
FDA OPDP, "The Brief Summary", OPDP Data Digest for 2021. fda.gov
FDA, final rule, Direct-to-Consumer Prescription Drug Advertisements: Presentation of the Major Statement, 88 FR 80958, November 21, 2023. govinfo.gov
FDA, "Communications From Firms to Health Care Providers Regarding Scientific Information on Unapproved Uses of Approved/Cleared Medical Products", January 2025; the copy read November 3, 2026 says "not for current implementation". fda.gov
FDA, "FDA Launches Crackdown on Deceptive Drug Advertising", press announcement, September 9, 2025. fda.gov
Unified Agenda, RIN 0910-AJ14, "Transparency in Direct-to-Consumer Advertising": proposed rule stage, notice of proposed rulemaking 12/00/2026. reginfo.gov
FDA, "Presenting Risk Information in Prescription Drug and Medical Device Promotion", draft guidance, May 2009, docket FDA-2008-D-0253. fda.gov
Office of Management and Budget, information collection review 202501-0910-004, OMB control number 0910-0686, approved without change July 29, 2025. reginfo.gov
AMCP, Regulatory NewsBREAK on FDA's final guidance on promotion of prescription biologicals, biosimilars and interchangeable biosimilars, December 2025. We read this summary, not the guidance itself. amcp.org
European Parliament, Legislative Observatory, procedure file 2023/0131(COD), read November 3, 2026. oeil.secure.europarl.europa.eu
Prescription Medicines Code of Practice Authority, 2024 ABPI Code of Practice, clause 8, in operation October 1, 2024. pmcpa.org.uk
MHRA, "The Blue Guide: Advertising and Promotion of Medicines in the UK", third edition, third revision, November 2020. assets.publishing.service.gov.uk
EFPIA, Code of Practice, final consolidated version 2026, section 20.01. efpia.eu
Pharmaceutical Advertising Advisory Board (Canada), home page, read November 3, 2026. paab.ca
Veeva Systems, "Using Benchmarks to Speed and Scale Life Sciences Content", European page giving Germany (15.4 days) and France (27.2 days) under a 2023 heading. We read only an excerpt, not the full page. Vendor data. veeva.com
Veeva Systems, "Using Benchmarks to Speed and Scale Life Sciences Content", PDF, Veeva Pulse Content Metrics data for 2021: US 29.9 days and 1.5 cycles, all countries 20.5 and 1.3, best in class 13.5 and 1.1. Vendor data. veeva.com
FDA, untitled letter on a TV ad, September 9, 2025 (Nemluvio). fda.gov
ICH, E9 Statistical Principles for Clinical Trials, February 5, 1998, section 5.6, on adjusting significance for multiplicity. database.ich.org
FDA, untitled letter on a TV ad, September 9, 2025 (Ingrezza). fda.gov
King & Spalding, "2025 Year in Review: FDA Drug and Device Advertising and Promotion Enforcement", January 21, 2026. kslaw.com
Covington, "FDA Advertising and Promotion Enforcement Activities: 2025 Year in Review", March 2026. cov.com
The White House, "Addressing Misleading Direct-To-Consumer Prescription Drug Advertisements", presidential memorandum, September 9, 2025, Government Publishing Office copy. govinfo.gov
FDA, untitled letter on a professional visual aid, July 28, 2026 (Filspari). fda.gov
FDA, untitled letter on professional web pages, June 24, 2026 (Vyepti). fda.gov
FDA, untitled letter on a professional sales aid, September 9, 2025 (Pemazyre). fda.gov
FDA, untitled letter on a professional speaker deck, April 28, 2025 (Nextstellis). fda.gov
Veeva Systems, "Building the Future of MLR with AI: Fastest Path to Approved Content", white paper, 2025. Vendor data. veeva.com
A. Whitehead, S. Ito, "From Checkpoint to Input: A Different Model for MLR", Klick Ideas Exchange, June 18, 2026. Vendor article. idx.klick.com
FDA OPDP, "The Brief Summary", OPDP Data Digest for 2022. fda.gov
FDA OPDP, "The Brief Summary", OPDP Data Digest for 2023. fda.gov
FDA OPDP, "The Brief Summary", January 2025, OPDP Data Digest for 2024. fda.gov
FDA, "Office of Prescription Drug Promotion (OPDP) Metrics", content current November 2, 2026. fda.gov
Veeva Vault Help, "Using PromoMats Standard Metrics", read November 3, 2026. Vendor documentation. commercial.veevavault.help
Schwartz LM, Woloshin S, "Medical Marketing in the United States, 1997-2016", JAMA 321(1):80-96, 2019 (abstract). pubmed.ncbi.nlm.nih.gov
Othman N, Vitry A, Roughead EE, "Quality of pharmaceutical advertisements in medical journals: a systematic review", PLoS One 4(7):e6350, 2009 (abstract). pubmed.ncbi.nlm.nih.gov
US Department of Justice, fact sheet on health care fraud recoveries, fiscal years 2009 to 2016. justice.gov
Wu K, Wu E et al., on SourceCheckup, Nature Communications 16, 2025 (abstract). ideas.repec.org
FDA, "Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products", draft guidance, January 2025. No final version found on November 3, 2026. fda.gov
European Medicines Agency, "Reflection paper on the use of Artificial Intelligence (AI) in the medicinal product lifecycle", adopted by CHMP September 9, 2024. ema.europa.eu
European Commission, AI regulatory framework page, on Regulation (EU) 2026/1744, in force July 27, 2026. digital-strategy.ec.europa.eu
European Commission and PIC/S, "Annex 22: Artificial Intelligence", draft for consultation, July 7 to October 7, 2025. picscheme.org
FDA, "Computer Software Assurance for Production and Quality Management System Software", final guidance, February 2026. fda.gov
European Commission, EudraLex Volume 4, read November 3, 2026. health.ec.europa.eu
ISPE, "GAMP Guide: Artificial Intelligence", July 2025. ispe.org
Next step
See it on a few of your own past pieces.
Explore the solution, or bring a past detail aid with its references and label, and we will pin each claim with you and open each cited page, while your reviewers decide.
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