WorkflowMedical Affairs

Promotional Material Pre-Review Agent

MLR review of promotional materials, with every claim checked against its reference page and the label before a reviewer opens the piece

Every claim checked against its reference page and the label before a reviewer opens it.

See one case, screen by screen ↓
demo10findingson one HCP email before a reviewer opened it — 4 high, 2 medium, 4 low, each with its page
demo7live piecesre-checked against the new label in one sweep — 5 revisions, 2 withdrawals proposed
target13.5daysmedian from submission to approval, every piece pre-reviewed
target58%of pieces approved in one round, the evidence beside every finding
The problem

Why a promotional piece takes a month to clear MLR

A draft lands from the agency with a reference pack and an annotation on every claim. Before the medical, regulatory and legal reviewers can judge anything, someone has to open each cited publication at the anchored page, check the number, the population, the endpoint and the timepoint, compare the claim with the Prescribing Information, and read the safety information word for word against the current label.

Most of that is checking, not judgement — and it is where pieces stall. A wrong anchor, an exploratory endpoint dressed as a claim or an ISI from the superseded label goes back to the agency for another round. Committee time goes on pieces that only needed a signature. And when the label changes, nobody can say quickly which approved, live pieces still carry the old safety information.

typical≈29business daysfrom submission to approval, by published MLR cycle-time benchmarks
demo46of 210findings in 30 days were a wrong reference anchor — the most common finding
demo7live piecesstill carried the old safety information after a label change
Where a piece’s working days go, submission to approvalestimated
By hand29 days
With the solution13.5 days
  • Checking claims against the cited pages6 → 1 d
  • Checking the label and safety information3 → 0.5 d
  • Fair balance, required statements and links2 → 0.5 d
  • Rounds of changes with the agency10 → 5 d
  • Waiting for review or the committee6 → 5 d
  • Signatures and the 2253 package2 → 1.5 d

Estimated split for a typical branded HCP piece in working days, by hand and with the solution.

How it works

How a piece moves

Six specialist agents extract, verify and check every claim, then route the piece; medical, regulatory and legal reviewers decide.

What comes in
Piece in4 formats · email, PDF, deck or TV script, with its references
Agents at work
Claim & anchor extractorclaims + anchors
Then
Reference verifier
Label consistency checker
Fair balance & safety checker
Brand & channel rules checker
Then
Risk router & 2253 packagerfast · standard · committee
A person decides
Reviewersmedical · regulatory · legal
What comes out
Annotated piece, findings cited
Routed to the right review
Form 2253 package
One case, step by step

One HCP email, from agency draft to Form 2253

P-2417, a Veltrimab email to US gastroenterologists, is on Thursday’s committee agenda with ten findings against it. Here is what happens to it, screen by screen, in the working solution.

  1. 01Morning

    The review desk, before the committee

    Dr. Maya Chen · Medical reviewer

    Maya opens the solution to 10 pieces in review across Veltrimab, Corventa and Talmirex: 6 waiting for her signature, 18 findings to decide, and the Thursday committee at 10:00. The routing wall shows where the risk router placed every piece — fast track, standard or full committee.

    “Findings to decide: 18 — every one cites its page or label section.”

  2. 0207:52

    A new draft arrives, and the agents check it

    Priya Raman · Account lead, Wrenfield Health

    The agency’s Talmirex HCP email, P-2437, comes in with two references attached. One press of Run pre-review: the extractor finds 6 claims, 6 anchors and 3 statistics; the reference verifier opens TLX-115 and sees the month-1 result is a secondary endpoint; the router scores it 54 and sends it to standard review, three reviewers.

    “Six agents check every claim before a reviewer opens the piece.”

  3. 03Opened

    The piece, marked claim by claim

    Dr. Maya Chen · Medical reviewer

    P-2417, “Remission at week 12 — and at one year”, version 2, risk score 72, full committee. Every claim in the email is marked, and the side panel lists 10 findings — 4 high, 2 medium, 4 low — with 2 claims fully supported. The first one: the week-2 rectal-bleeding line rests on an exploratory endpoint.

  4. 04One click

    The cited page, with the passage highlighted

    Reference verifier

    Maya opens the evidence. VLT-301, page 7, Exploratory endpoints: no rectal bleeding at week 2 in 22% versus 14% — nominal p=0.03, not controlled for multiplicity. The label describes no timepoint before week 12. The verdict is “Not supported as a claim”, at 96% confidence.

    “This endpoint was exploratory and not controlled for multiplicity; no conclusions on early onset should be drawn.”

  5. 05Next

    Every claim, its reference and its verdict

    Claim & anchor extractor

    The Claims tab is the claim-to-reference verification table: each claim, the reference and page it rests on, the verdict and the confidence. “2 out of 3 patients stay in remission at 1 year” is overstated — it comes from a descriptive subgroup of 141 patients. “Similar to placebo” is misleading. The ISI is outdated. “#1 prescribed biologic” is broader than the data on file.

  6. 06Measured

    Fair balance, measured — not guessed

    Fair balance & safety checker

    A balance reading of 41 against the team’s line of 70. Risk carries 14% of the words, is set in 8 pt against a 22 pt headline at 45% contrast, and sits in the footer below the sign-off. The safety text is from label rev 03/2025, and only the Prescribing Information link is there — no Medication Guide.

    “A reviewer makes the call — the reading is evidence, not a verdict.”

  7. 07Decided

    Approved claims in, then the medical signature

    Dr. Maya Chen · Medical reviewer

    For the week-2 line Maya uses approved claim CL-031 — clinical response at week 12, 58% vs 33%. She reads the remaining nine suggestions, including the current safety information with 5.4 Hepatotoxicity, and applies them to draft v3. Then she signs the medical review with her password and the meaning of her signature.

    “I reviewed this piece for medical accuracy and confirm each claim is supported by the cited evidence and consistent with the current label.”

  8. 08Signed

    Three signatures, then the package

    Omar Haddad · Regulatory reviewer and Lena Ortiz · Legal reviewer

    Omar signs the regulatory review with label rev 09/2026 confirmed; Lena signs the legal review of comparative wording and trademarks. Only then does the 2253 packager build the package: Form FDA 2253 fields completed, the final piece clean and annotated, the current Prescribing Information and 7 annotated references.

  9. 09First use · Oct 12

    Form FDA 2253, ready to file at first use

    Omar Haddad · Regulatory reviewer

    The package carries the application, material type, material ID VLT-US-2417 v3 10/2026, the date of initial dissemination, the current labeling enclosed and all three signature dates. Omar downloads it or schedules the filing for first use.

  10. 10The same week

    A label change, swept across live pieces

    Dana Okafor · MLR operations lead

    Veltrimab rev 09/2026 added Warning 5.4 Hepatotoxicity on Sep 18 and retired claim CL-019. The label checker re-reads all 7 approved, live pieces against it and proposes revising five and withdrawing two — a speaker deck that also says “similar to placebo” and a leave-behind with the retired claim. Dana confirms; the requests go to the agency.

Who it’s for

Built for everyone around the MLR table.

The same piece, seen by the five people who carry it — what their week looked like, and what it looks like now.

MC
Dr. Maya ChenMedical reviewer
Medical reviewer
Before
Opens every reference at every anchor herself before she can judge a single claim.
Now
Starts from the passage already highlighted and the verdict beside it, and spends her time on the judgement calls.
OH
Omar HaddadRegulatory reviewer
Regulatory reviewer
Before
Reads the ISI word for word against the label and builds the 2253 package by hand.
Now
Sees the safety text compared with the current label version, and a package built the moment the last signature lands.
LO
Lena OrtizLegal reviewer
Legal reviewer
Before
Checks comparative wording, “#1” claims and trademarks by hand on every draft.
Now
Gets comparative claims, trademarks and channel rules flagged on arrival, with the qualified wording suggested.
DO
Dana OkaforMLR operations lead · committee chair
MLR operations lead
Before
Fills the Thursday agenda with pieces that only needed a signature, and chases live pieces after a label change.
Now
Takes only the pieces with open judgement calls to committee, and closes a label change in one sweep.
PR
Priya RamanAccount lead · Wrenfield Health
Agency account lead
Before
Learns what was wrong with a draft after a full review round.
Now
Gets change requests with the reference and the suggested text, and the revised version is re-checked on arrival.
Built on the engine

6 agents. Each with one job, and hard limits.

Six specialist agents extract, verify and check every claim, then route the piece; medical, regulatory and legal reviewers decide.

Claim & anchor extractor

Finds every claim, statistic and reference anchor in a piece — email, PDF, deck or TV script — and classifies it as efficacy, safety, dosing, comparative or market.

  • Quotes claims verbatim, never paraphrased
  • Every claim keeps its page and position
Reference verifier

Opens each cited reference at the anchored page, finds the supporting passage and checks the value, comparator, population, endpoint type and timepoint; re-anchors a wrong page.

  • Cites the page and passage for every verdict
  • Exploratory and subgroup results are never “supported” as efficacy claims
Label consistency checker

Compares each claim with the current Prescribing Information, and the safety information word for word with the current label version, naming any missing warning.

  • Only the current label version counts
  • Names the label section for every finding
Fair balance & safety checker

Measures how prominent risk is next to benefit — share of words, type size, contrast, placement and, for audio, words per second — and checks required statements and links for the channel.

  • Reports measurements, never a pass or fail on its own
Brand & channel rules checker

Checks approved phrasing, trademarks, absolute words, comparative wording and channel rules.

  • Suggests the approved phrasing, never invents a claim
Risk router & 2253 packager

Scores each piece and routes it to fast track, standard review or full committee, then builds the Form FDA 2253 package on approval.

  • Broadcast pieces always go to full committee
  • A package is built only after every required signature
Reviewers

Medical, regulatory and legal sign. The agents propose; a named person decides.

Ask in plain words

Ask about any piece, claim or label

Reviewers and coordinators ask in plain words — or tell it what to change. Answers point to the page they rest on.

What is blocking P-2417?

10 findings are open, 4 of them high: the week-2 relief rests on an exploratory endpoint; “2 out of 3” comes from a descriptive subgroup; “similar to placebo” minimises the safety profile; the safety information is from the superseded label. Plus medium and low findings on wording, links and the ® mark. Each high finding has an approved claim or the label wording ready.

Which live pieces still carry the old Veltrimab safety information?

Seven approved, live pieces still carry the rev 03/2025 safety information, which has no hepatotoxicity warning — five to revise and two to withdraw. Two also use retired wording. The sweep is on your desk: one click re-checks them and sends the requests.

Flag “well tolerated” unless the adverse-event rates are beside it

Added. The rule “well tolerated” needs the rates beside it is now a check in Settings, and the fair balance agent applied it to the pieces in review: P-2402 slide 22 says “well tolerated” with no rates — discontinuations were 4.2% vs 3.9%. It is flagged for Thursday.

Prepare Thursday’s committee agenda

Thursday Oct 8, 10:00–11:00 — four pieces, only the open judgement calls: P-2417 at 10:00, P-2421 at 10:15, P-2402 at 10:35, P-2419 at 10:50. The agenda pack carries each piece with its findings and evidence; the other pieces in review are decided without the meeting.

Every screen

The working solution, as it ships.

12 screens from the working solution, on its sample data. Pick one to see it large.

The review deskWhat needs the reviewer today: signatures waiting, findings to decide, live pieces on an old label, and the routing wall with every piece placed by risk.
Pre-review at workSix agents run in view on a new agency draft — claims and anchors, references, label, fair balance, brand rules, then the router.
The marked pieceEvery claim marked on the piece, findings by severity beside it, each with the reference page and the label section.
The cited pageThe reference opened at the anchored page, with the passage the verdict rests on highlighted.
Claim-to-reference tableEvery claim with its reference and page, the verdict and the confidence.
Fair balance readingShare of words on risk, type size, contrast, placement, safety text version and required links — against your threshold.
Medical signatureThe reviewer signs with a password and the meaning of the signature, after every medical finding is decided.
Sign-off and recordMedical, regulatory and legal signatures, the 2253 package checklist and the immutable record of people and agents.
Form FDA 2253 packageApplication, material ID, date of first use, current labeling and signatures — ready to download or schedule.
Label change sweepEvery approved, live piece re-checked against the new label, with revise or withdraw proposed for a person to confirm.
Claims libraryPre-approved claims, the references behind them and the label versions the agents check against and suggest from.
Your review rulesRouting thresholds, the fair balance line, who signs per brand and the checks the agents run.
Governance

Built for promotional review: cited, signed, on the record.

Every finding cites its pageEach verdict shows the reference, the page and the highlighted passage — and the label section where one applies. Open it at the passage in one click.
Only the current label countsClaims and safety information are checked against the label version marked current. When a new version is approved, every live piece is re-checked and a person confirms revise or withdraw.
Reviewers decide, agents proposeEvery finding is accepted, sent to the agency or dismissed by a reviewer. A high finding cannot be dismissed without a reason, and the fair balance reading is evidence, not a verdict.
Signatures with their meaningMedical, regulatory and legal each sign with a password and the meaning of the signature, on the audit trail. Standard and committee pieces need three signatures; fast track needs one.
No package before approvalThe Form FDA 2253 package is built only after every required signature, and filed at first use with the current Prescribing Information enclosed.
Every step on the recordEach agent run and each human decision is on the piece’s record — people and agents, immutable. Every change to settings is versioned and on the audit trail.
Configuration

Your review rules, not ours

Routing, signers and the checks the agents run are settings your MLR lead owns.

SettingDefaultChoose from
Fast track belowScore 30Score 20 · 30 · 40
Full committee fromScore 60Score 50 · 60 · 70
Always full committeeOn — broadcast and first pieces of a launchOn · Off
Fair balance threshold, email and digital7060 · 70 · 80
Who signs, per brandVeltrimab: Dr. Maya Chen, Omar Haddad, Lena OrtizMedical: Dr. Maya Chen or Dr. Sana Iqbal · regulatory: Omar Haddad or Dana Okafor · legal: Lena Ortiz or Ben Adler
Checks the agents run7 of 8 onEach check on or off — accessibility is off by default
Your own rulesAdd in a sentenceTurned into a check for your approval
Prescribing InformationCurrent versions, checked nightlyFrom your regulatory label store
Connections

Works with the systems you already run

Agency draftsPDF, HTML email, deck or video script, with its references
Reference librarypublications, study reports and data on file, indexed by page
Label storePrescribing Information, Medication Guides and ISI modules, versioned
Claims librarypre-approved claims with their reference, page and label section
Brand guides and channel standardsapproved phrasing, trademarks, required links
Form FDA 2253the package, ready to file at first use
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
13.5days
median from submission to approval, every piece pre-reviewed
Before29 days
With agents13.5 days
target
58%
of pieces approved in one round, the evidence beside every finding
approved in one round
target
41%
of pieces fast-tracked to one reviewer; only 16% reach the full committee

“demo” = seen in the working solution, on its sample pieces · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published MLR cycle-time benchmarks (≈ 29 business days). Regulatory context: 21 CFR 202.1 and Form FDA 2253 at first use. People named on this page are characters in the working solution; its brands, studies and companies are fictional.

Questions

What MLR teams ask us.

What is MLR pre-review?

MLR pre-review checks a promotional piece before the medical, legal and regulatory reviewers open it. The Promotional Material Pre-Review Agent extracts every claim and its reference anchor, checks the cited page supports it, compares it with the current label, measures fair balance and checks the safety information and required statements — then annotates the piece so reviewers start with the evidence.

How does it check claims against references?

The reference verifier opens each cited reference at the anchored page, finds the supporting passage and checks the value, comparator, population, endpoint type and timepoint. Verdicts are supported, overstated, not supported or wrong anchor, each with the page and passage. Exploratory and subgroup results are never marked supported as efficacy claims.

Does it check fair balance and the ISI?

Yes. The fair balance checker measures share of words, type size, contrast and placement — and words per second for audio — against your threshold for the channel. The label checker compares the safety information word for word with the current label version and names any missing warning.

Does the AI approve promotional pieces?

No. Agents propose; reviewers decide. Every finding is accepted, sent to the agency or dismissed with a reason, and named reviewers sign every piece — one on fast track, three on standard and committee — with the meaning of each signature recorded. Every step is on the piece’s record.

What happens when the label changes?

When a new label version is approved, the label checker re-checks every approved, live piece against it and proposes revise or withdraw for each. A person confirms, and the change requests go to the agency with the new text.

Does it prepare the Form FDA 2253 submission?

It builds the package once every required signature is in: the completed form fields, the final piece clean and annotated, the current Prescribing Information and the annotated references. Your regulatory reviewer downloads it or schedules the filing for first use.

Can we set our own routing and reviewers?

Yes. The fast-track and full-committee score thresholds, which pieces always go to committee, the fair balance threshold, who signs per brand and which checks run are all settings. You can add a rule by describing it in a sentence, and it becomes a check after your approval.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your reference library, label versions, claims library, brand guides and routing rules — and it goes live once every quality gate has passed. We will walk you through it on your own past pieces first.

See it on
your pieces.

We’ll run Promo Pre-Review on a sample of your own past pieces and their references.