RAC Candidate Guide
RAC Candidate Guide
RAC Candidate Guide
Candidate Guide
RAPS.org/RAC
EXAM OVERVIEW
100 multiple-choice questions for the RAC exams. Two hours to complete each exam. Administered by computer. Administered only in English.
Exam Fees
Application Fees Standard Deadline RAPS Member Nonmember $325 (US) $510 (US)* Late Deadline $425 (US) $610 (US)*
*Includes one year of RAPS membership (membership may be waived, however fee remains the same)
A cancellation fee of $100 (US) will be assessed on any cancelled application. No cancellations will be accepted after 8 March for the April/May exam or after 8 September for the October/November exam.
CONTACT INFORMATION
Regulatory Affairs Certification Program (RAC) 5635 Fishers Lane Suite 550 Rockville, MD 20852 Tel +1 301 770 2920, ext. 200 Fax +1 301 770 2924 Email: [email protected] RAPS.org/rac
RAPS.org/RAC
Regulatory professionals without an RAC credential, not currently involved with regulatory authorities in the US, EU or Canada
Baccalaureate degree (or equivalent) or 35 years regulatory experience Two hours, 100 multiple-choice questions, administered at locations worldwide RAPS members: $325; $425 late registration Nonmembers*: $510; $610 late registration
* Includes one year RAPS membership
RAC-credentialed professionals must accumulate 36 recertification credits every three years after initial certification to maintain RAC status.
RAPS.org/RAC
TABLE OF CONTENTS
INTRODUCTION .....................................................................................................................................................4 About the RAC Credential............................................................................................................................................... 4 RAC Exam Content .......................................................................................................................................................... 4 RAC Recognition ............................................................................................................................................................. 4 Why Get RAC-Certified? ................................................................................................................................................. 4 APPLYING FOR THE EXAM ......................................................................................................................................5 Eligibility Requirements .................................................................................................................................................. 5 RAC Application Deadlines ............................................................................................................................................. 5 Applying for the Exam .................................................................................................................................................... 5 Special Accommodations for the Exam ..........................................................................................................................5 Exam Fees and Cancellation/Refund Policy ....................................................................................................................5 Cancellation/Refunds ..................................................................................................................................................... 5 Payment Methods .......................................................................................................................................................... 6 Checking Application Status ........................................................................................................................................... 6 Incomplete Applications ................................................................................................................................................. 6 Application Refusal ......................................................................................................................................................... 6 Transferring to Another Testing Cycle............................................................................................................................. 6 Application Withdrawal ................................................................................................................................................. 6 EXAM SCHEDULING ...............................................................................................................................................7 Test Site, Date, Time Selection ....................................................................................................................................... 7 Changing Your Exam Appointment ................................................................................................................................. 7 Emergency Situations ..................................................................................................................................................... 7 No-show Candidates ...................................................................................................................................................... 7 Testing Site Cancellations ............................................................................................................................................... 7 PREPARING FOR THE RAC EXAM ............................................................................................................................8 EXAM DAY ....................................................................................................................................................................... 8 Proof of Identity ............................................................................................................................................................. 8 Test Center Rules ............................................................................................................................................................ 8 AFTER THE EXAM...................................................................................................................................................9 Test Scoring, Passing Standards ..................................................................................................................................... 9 Candidate Notification.................................................................................................................................................... 9 Listing of RAC Professionals ............................................................................................................................................ 9 Re-examination .............................................................................................................................................................. 9 Use of the RAC Credential .............................................................................................................................................. 9 MAINTAINING PROFESSIONAL CERTIFICATION .....................................................................................................10 CERTIFICATION PROGRAM ADMINISTRATION ..............................................................................................................10 Release of Information ................................................................................................................................................. 10 Nondiscrimination ........................................................................................................................................................ 10 Due Process Appeals .................................................................................................................................................... 10 OVERVIEW OF RAC CONTENT OUTLINES ..............................................................................................................11 Appendix A: RAC (US) Detailed Exam Content Outline............................................................................................... A-1 Appendix B: RAC (EU) Detailed Exam Content Outline............................................................................................... B-1 Appendix C: RAC (CAN) Detailed Exam Content Outline ............................................................................................ C-1 Appendix D: RAC (General Scope) Detailed Exam Content Outline ............................................................................ D-1
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INTRODUCTION
About the RAC Credential
Regulatory Affairs Certification, known as the RAC, is the only post-academic professional certification specifically for regulatory professionals in the healthcare product sector. The RAC exams are developed based on the actual work of regulatory professionals in the field. The RAC credential is a professional distinction that denotes commitment to excellence, pursuit of knowledge and career advancement. RAC-credentialed professionals are among the current and rising leaders in the regulatory profession. They work in all parts of the world and in many settings, including industry, government and academic organizations. To date, nearly 6,000 individuals have earned the RAC, some holding multiple credentials. Four different certifications are available: RAC (US): knowledge of US regulations RAC (EU): knowledge of European Union regulations RAC (CAN): knowledge of Canadian regulations RAC (General Scope): knowledge and critical thinking skills related to the general scope of practice of regulatory professionals throughout the product lifecycle, with reference to global standards from ICH, GHTF, WHO and ISO. The RAC credential initially is earned by passing one of the four examinations, US, EU, CAN or General Scope. Candidates may take multiple RAC examinations. The RAC is maintained through continuing professional development.
RAC Recognition
Candidates who pass the RAC (US), (EU), (CAN) or (General Scope) examination may use the RAC designation after their names. All RAC credentialed professionals are listed on the RAPS/RAC website at RAPS.org/rac, and a listing of newly certified RACs is published twice annually in Regulatory Focus, the monthly, flagship magazine of RAPS.
Average based on RAPS 2010 Scope of Practice & Compensation Report for the Regulatory Profession (US respondents).
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Applications from individuals who do not meet these basic requirements will not be accepted.
*Includes one year of RAPS membership (membership may be waived however, the fee remains the same)
Cancellation/Refunds
A cancellation fee of $100 (US) will be assessed on any cancelled application. No cancellations will be accepted after the final application deadline for the exam cycle (i.e., 8 March or 8 September).
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Payment Methods
Exam fees are due at the time of application submission. Applicants may pay by credit card (Visa, MasterCard or American Express) or by check or money order. Checks and money orders should be made payable to RAPS. Candidates names must appear on all payments made by money order, certified or cashiers check, personal check or organizational check. If fees for more than one candidate are paid by a single check or money order, a list of all candidates names and primary contact telephone numbers (including area codes) must be included with the check and the application materials. Checks and money orders received without proper candidate identification may be returned to the senders unprocessed.
Incomplete Applications
Candidates submitting incomplete applications will receive email notification from the RAC Program office detailing the additional information needed to complete the application. To become eligible to take the exam, candidates must submit the required information by the final application deadline and pay a $20 (US) resubmission fee. Payment instructions will be provided in the incomplete notification email. Candidates who do not rectify the application deficiencies by the date indicated will be deemed ineligible and issued a refund of their examination fees, less a nonrefundable $100 (US) application fee.
Application Refusal
Applications for the RAC exams may be refused due to one or more of the following: failure to meet eligibility requirements or deadlines, or submit a complete application falsification of application information use of fraud or deception in an attempt to obtain certification and/or knowingly assisting another person in obtaining or attempting to obtain certification by fraud or deception illegal use of the credential certificate or falsification of credentials unauthorized possession or distribution of any official RAC examination materials, including copying or reproduction of any part of the exam exhibiting unethical or inappropriate behavior during prior examinations conviction of a felony or a crime of moral turpitude in a court of law revocation of a professional license debarment under state, federal or territorial laws There is no appeal process for candidates who do not meet the minimum eligibility requirements. Applicants refused due to any of the above reasons will be refunded exam fees, less the nonrefundable $100 application fee. Applications postmarked after the late deadline will be returned unprocessed.
Application Withdrawal
Candidates must submit written request for withdrawal of their application by the final application deadline date to receive a refund, less the $100 nonrefundable fee. Candidates who do not submit a written notification of withdrawal by the final registration deadline date will not receive a refund but may submit a new application for a future testing window.
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EXAM SCHEDULING
Eligible candidates will receive a confirmation of acceptance via email within 10 business days after receipt of a completed application by the RAC Program Office. Candidates should review the information in the confirmation email to ensure accuracy of name and key contact information as this information will be used to access examination scheduling websites and for testing site confirmation. Candidates should immediately notify the RAC Program office to correct any information ( +1 301 770 2920, ext. 200, or email [email protected]).
Emergency Situations
Candidates who experience a documented severe medical emergency or have a death in their immediate family may request to transfer to the next testing window. Appropriate documentation must be received at the RAC Program Office within 60 days of the original RAC examination date. Candidates may reschedule the exam once due to emergency situations. A $79 rescheduling fee applies.
No-show Candidates
Candidates who fail to schedule an exam appointment within the testing cycle for which they applied, who do not appear for their scheduled exam appointment, who arrive more than 15 minutes late for their appointment, who appear with improper ID or who cancel their appointment later than 12:00 pm (US Eastern Time) five business days before the scheduled exam without a documented personal or medical emergency will be considered no-shows and will forfeit all fees. No-show candidates must submit a new application for a future testing window.
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EXAM DAY
Candidates should arrive at the testing location at least 30 minutes before their scheduled appointments and must adhere to the requirements listed below.
Proof of Identity
All candidates must present proof of identity by providing an unexpired government-issued photo ID with a signature, such as a drivers license with a photograph, a military photo ID, a passport or valid national identification card. Credit cards with photos and Social Security cards are not acceptable forms of identification. Candidates who cannot present an unexpired government-issued photo ID should contact the RAC Program Office at least 10 business days before the exam. The candidates name on the identification must match the name appearing on the exam-scheduling notification. Candidates with hyphenated last names whose photo IDs show only one of the last names may be admitted if the single name matches part of the hyphenated name and the signature and photograph clearly match. Candidates whose middle names are spelled out on their ID but are listed with an initial on the application may be admitted as long as the initial matches the first letter of the middle name and the signature and photograph match. This also applies to candidates who use their middle name instead of their first name on their application but their ID displays their first, middle and last name.
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Candidate Notification
RAC examination results typically are available four weeks after the end of the testing cycle (i.e. 31 May or 30 November). Candidates will receive an email notification when RAC examination results are processed and available. Candidates will be notified of instructions for accessing a special secured website with their examination results. This personal site will include a notice presenting their pass/fail status and a summary report of their performance. Results, including scores are released only to candidates. No results will be reported over the telephone or by fax. No information is released or accessible on candidates who do not pass the examination except to the candidate.
Re-examination
Candidates who do not pass the RAC examination are eligible to retake the exam. To apply for re-examination, candidates must submit a new application. There is no limit on the number of times a candidate can take an examination.
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Release of Information
The RAC Program maintains strict procedures for ensuring the confidentiality of candidates records. Information on prospective candidates is not released to anyone other than the candidates themselves. Candidates scores are only released to the candidate and are not released by telephone or fax. The RAC Program reserves the right to publish a listing of individuals who successfully earn the RAC designation. However, under no circumstances will information be released on individuals who have not earned the RAC credential.
Nondiscrimination
The RAC Program does not discriminate among candidates on the basis of age, gender, race, religion, national origin, disability, sexual orientation or marital status.
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Question types
The RAC examinations consist of 100 multiple-choice questions. There are three types of questions included on the RAC examinations: Recall Application Analysis Recall questions ask for specific information, typically about regulations and guidance that are important aspects of the regulatory process. These questions may relate to any stage of product development and may relate to regulations specific for product types. Approximately 2533% of the exam questions will be recall. Application questions require relating specific knowledge to a situation that may be encountered in the scope of practice of a regulatory professional. Approximately 3345% of RAC exam questions are considered application type questions. Analysis questions may be described as a small case or example requiring the candidate to read and assemble information in order to identify and evaluate various solutions. Approximately 3035% of the examination will contain analysis.
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B.
Regulatory Pathways and Operations Determine requirements (local, national, international) and options for regulatory submissions (NDA/ BLA/PMA/510k, electronic/paper, 505(b)(2), etc.), approvals (priority review, user fees, etc.), and compliance activities (registration, listings, etc.). ii. Advise management on timelines, benefits/risk assessment and financial implications of the proposed regulatory strategy. iii. Investigate and communicate to management the availability of incentives (pediatric, orphan, fast track, HDE, etc.) to support product development. iv. Develop optimal strategy for Agency interactions during product development and life cycle management. v. Advise internal stakeholders (marketing, manufacturing, R&D, etc.) regarding current/pending guidances, regulations, Agency/industry initiatives, etc. to ensure regulatory strategy is in alignment with company objectives. vi. Consult with marketing/project team to develop intended use and claims (target product profile). vii. Assess quality systems (e.g., CE marking, ICH, GMP/QSR, ISO, etc.) by performing audits to determine compliance to Quality System Regulations (QSR) and Drug GMP, assuring compliance to established SOPs for QSR and drug GMPs [e.g., failure investigations, etc], and making recommendations for improvement of quality systems, based on audit findings and QSR or GMP requirements. viii. Develop/deliver/assure in-house training programs for all company personnel for regulatory compliance (Refers to GXP). ix. Assure implementation and documentation of training programs including identification of training needs (job-specific and general GMP training) and training schedules. x. Provide trainers with updated information on regulatory requirements to incorporate in on-going training programs. Interaction With Other Companies Conduct regulatory due diligence and advise senior management during product or company acquisitions and collaborations. ii. Ensure regulatory obligations are met for in- and out-licensing of products. iii. Ensure regulatory obligations are met for contract activities (manufacturing, complaint handling, regulatory operations, consultants, etc.). i.
C.
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A-1
B.
Clinical Development i. Determine requirements with regard to clinical safety and efficacy (GCPs). ii. Ensure compliance with all clinical standards (GCPs, clinical trial monitoring and auditing), IRBs, safety reporting, informed consent, financial disclosure, etc.). iii. Advise project team of regulatory recommendations for ongoing aspects of clinical trials/investigations (amendments to protocol, etc.). iv. Identify non-US country specific requirements for impact to US submissions (IND/IDE, annual report, etc.). v. Prepare and/or review information included in IND/IDE submission such as label, clinical investigation plan/protocol, case report form, investigators brochure, informed consent, etc. vi. Ensure that any identified safety risks have been appropriately addressed with the clinical development program. vii. Ensure that CFR requirements for adverse event reporting are established and being followed. viii. Evaluate need for and contribute to the development of Pediatric Development Plan and/or waivers/ deferrals, Orphan Designation Applications, etc. CMC/Device Design and Manufacturing Determine regulatory requirements for manufacturing /quality system certifications (clinical trial supplies, manufacture, dosage forms, device classification, DMFs, etc.). ii. Ensure compliance with cGMPs and QSR (SOPs, record retention, calibration, etc.). iii. Verify device Design History File complies with regulatory requirements including risk management. iv. Ensure regulatory compliance of manufacture and release of investigational products for clinical use. v. Review completeness of documentation to support IND/IDE submissions. vi. Ensure specifications for testing of API/drug substance/drug product and documentation of raw materials (novel excipients, animal derived materials, etc.) comply with regulatory requirements. vii. Ensure specifications for device components, manufacturing process, and product have been defined and meet regulatory requirements (including product and quality system software). viii. Evaluate manufacturing changes for compliance with appropriate change control systems/process and determine regulatory filing strategy. ix. Review and monitor regulatory compliance for suppliers (contract manufacturers, CROs, etc.). i. Agency Interaction i. Prepare pre-market submissions (IDE/IND) and master files for drugs/biologics/devices including investigational labeling. ii. Ensure that the project is in compliance regarding submission format (CTD/eCTD, etc.). iii. Review application for completeness according to refuse-to-file guidelines. iv. Negotiate/interact as appropriate with Agency during development/submission process (Pre-IDE/IND, End of Phase 2, Meetings, Respond to Agency comments, etc.). v. Monitor and maintain ongoing IDE/IND applications (e.g., amendments, annual reports, updates). vi. Determine requirements for export/import of investigational products (customs, USDA, etc.). vii. Ensure that the identified risks have been appropriately flagged and monitored. viii. Initiate process to obtain non proprietary (USAN) and proprietary names.
C.
D.
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B.
C.
D.
Approximately 8 recall Questions, 8 application questions, and 7 analysis questions for a 100-question examination (percent of items on exam: 23%) A. Postmarketing/Maintenance Submit required licensing fees, drug and device listings, periodic reports and updates (e.g., PSURS, master files, etc.). ii. Comply with product post-marketing approval requirements/condition of approval studies (Phase IV Studies). iii. Prepare, implement and monitor strategy for alerts/notifications/recalls/market withdrawal. iv. Advise management on alerts/notifications/recalls. v. Provide regulatory input on post-approval change management. vi. Assess documentation to support product and process changes and determine regulatory category of change (PAS, CBE, Annual Reports, etc). vii. Prepare and submit supplements/design change applications and notifications to NDA, BLA, PMA. viii. Maintain and record changes to the technical file/design dossier or NDA/BLA. ix. Ensure compliance with Risk Evaluation and Mitigation Strategy (REMS). i. Postmarketing Surveillance/Vigilance i. Evaluate reports of product complaints. ii. Ensure that appropriate systems are in place to document and track product complaints and ADR reports. iii. Ensure implementation of necessary corrective actions based on results of inspections, audits, failure analysis and consent decrees. iv. Report product safety issues/failures to regulatory agencies as required [e.g., ADEs]. v. Review adverse drug reaction reports and medical device reports.
B.
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C.
Advertising/Promoting/Labelling Review and approve revised labelling and claims, public communications, press releases, advertising, and promotional items for regulatory compliance. ii. Evaluate data to support comparative claims in advertising and implications of off-label use. i. Distribution Ensure compliance with regulatory requirements for supply, handling, storage, distribution, import, and export of materials. ii. Ensure compliance with applicable requirements/regulations for distribution of controlled substances. iii. Review regulatory aspects of contracts for product distribution (e.g., product complaints, product tracking, etc.). iv. Advise on the issues related to drug/product/lot releases (Annual Product Review, Device History Record). i. Crisis Management i. Advise management regarding the regulatory impact of a crisis event. ii. Develop regulatory plan to address the crisis event. iii. Advise management on regulatory implications of proposed crisis resolution strategies. Agency Interaction Facilitate coordination of outside consultants and company personnel in response to Agency comments (PAI, 483 responses, conduct of clinical studies, etc.). ii. Negotiate with Agency wording of inspection findings. iii. Manage/accompany/chaperone inspection teams or auditors. iv. Advise internal functional groups regarding regulatory compliance (e.g., FDA 483s, warning letters, and consent decrees) and communicate corrective follow-up actions to management. v. Prepare strategy/briefing documents for panel hearings and informational meetings (Advisory Committee). vi. Communicate/refer external requests for information. vii. Develop Freedom of Information Act strategy regarding confidentiality and protection of proprietary information and document requests. i.
D.
E.
F.
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B.
C.
D.
E.
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B-1
B.
Nonclinical and Clinical Development i. Advise sponsor of regulatory requirements for clinical trials/investigations. ii. Determine adequacy of nonclinical data and risk analysis to support approval to conduct clinical trials/ investigations. iii. Identify national/local requirements and prepare clinical trials/investigations submissions to CA/EC. iv. Prepare or review study information such as IMPD/technical file/design dossier, label, clinical investigation plan/protocol, case report form, investigators brochure, patient information letter, and informed consent to comply with local, regional, national, European, and international regulatory requirements. v. Interact with and coordinate the use of CROs, subcontractors, test facilities, and consultants. vi. Respond to questions/comments from CA/EC. vii. Ensure regulatory compliance of manufacture and release of investigational products for clinical use. viii. Ensure that reporting procedures are in place to report adverse events that occur during clinical trials/ investigations to CA/EC. ix. Review clinical data from literature and other sources. x. Report trial/investigation results to CA/EC. xi. Maintain authorisation for on-going clinical trials/investigations (e.g., amendments, annual reports, updates). xii. Evaluate need for and contribute to the development of Paediatric Investigation Plans/waivers/deferrals. Preregistration/CE Marking Interfacing i. Evaluate need for and coordinate Protocol Assistance/Scientific Advice Meetings with CAs. ii. Liaise with project team to develop project plans including submission timelines, deliverables, etc. iii. Liaise with marketing/project team to develop target product profile and determine the claims that can and cannot be made based on available data. iv. Participate in audits/inspections by NBs/CAs and contribute to responses to audit findings as required. v. Evaluate and communicate relevant legislation and guidelines (e.g., EMA, scientific, harmonized standards, and essential requirements). i.
C.
D.
Registration/CE Marking Ensure adequate documentation to support MAA/Technical File/Design dossier. a. Proof of concept/animal model i. Nonclinical safety/biocompatibility b. Clinical safety and performance/efficacy c. Product quality/design verification and validation d. Administrative data, forms, manufacturer authorisations/certifications, declarations and essential requirements checklists e. Labeling/Product Information (including readability testing) f. Risk Management Plan/File g. Vigilance system h. Post-market surveillance plan i. Environmental risk assessment j. Compliance with other applicable directives (e.g., WEEE, ROHS, machinery, battery) ii. Prepare MAA/Design Dossier/Technical File. iii. Submit MAA (incl. eCTD requirements)/Design Dossier to CA/NB. iv. Monitor /track submission progress (procedural timelines). v. Respond to questions/comments from CA/NB. vi. Meet with CA/NB to negotiate during review process. vii. Coordinate product information (i.e. label, carton, and leaflet/IFU) translations. viii. Review approval documents/certificates.
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B-2
B.
Postmarketing Surveillance and Vigilance i. Evaluate reports of product failures and complaints ii. Write field safety notices and report product failures and recalls /field safety corrective actions to CAs iii. Maintain vigilance and ensure post-market surveillance activities are conducted. iv. Ensure that Periodic Safety Update Reports (PSUR) are compiled and submitted to CAs according to regulatory timelines. v. Ensure regulatory compliance of post-approval clinical studies vi. Ensure implementation and monitor effectiveness of safety alerts, notifications, field safety corrective actions, and recalls. vii. Consider use of information gained in the post-market phase for broadening product indications Supply Chain i. Ensure compliance with regulatory requirements for supply, handling, distribution, import and export of materials. ii. Review regulatory aspects of supplier and distributor contracts (e.g., complaints, traceability, changes, etc.) i. ii. i. ii. iii. Product-specific Crisis Management Advise management regarding the regulatory impact of a crisis event (e.g., batch failure) Advise management on regulatory implications of proposed crisis resolution strategies
C.
D.
E.
Postapproval Regulatory Compliance Advise the Management Representative/Qualified Person regarding regulatory requirements. Ensure quality system SOPs meet regulatory requirements Assess whether new or revised legislation, guidelines, monographs and harmonized standards affect certain functions, activities, or products iv. Initiate, monitor, document and submit changes where applicable to ensure compliance with new or revised legislation, guidelines, monographs, and harmonised standards v. Review and monitor contractual obligations and agreements with NBs to ensure regulatory compliance vi. Negotiate wording of audit findings
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B-3
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C-1
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C-2
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C-3
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D-1
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D-2
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D-3