WorkflowRegulatory Affairs

Submission Summary Writer

CTD Module 2 summaries drafted in weeks, every statement cited to its source page

Module 2 summaries drafted in weeks, every statement cited to its source page.

See one case, screen by screen ↓
target5weeksto a first Module 2 draft, down from about 5 months by hand
target100%of statements cited to a source page, each citation checked
demo309of 312facts matching everywhere they are stated — the other 3 flagged for their owners
demo6,894pagesfrom Modules 3, 4 and 5, read and indexed page by page
The problem

Why Module 2 takes months, and still ships with numbers that disagree

Module 2 condenses thousands of pages — the CSRs, the integrated summaries of efficacy and safety, the Module 3 specifications and stability data, the Module 4 toxicology reports — into a clinical overview, a clinical summary and a quality overall summary. Every statement has to trace to a page in Modules 3 to 5, and writing it by hand takes months.

Most of that time is not writing. It goes on pulling the right figure from the right table, checking each citation against its page, and reconciling the same number stated in 2.5, 2.7.3 and 2.7.6. One slip — a full-analysis-set count called “randomized”, an exposure figure carried over from an earlier safety update, a development limit quoted instead of the registered one — and the reviewer finds a number that disagrees with itself.

demo≈5monthsto a first Module 2 draft by hand
demo4,794statementsin one BLA’s Module 2, each one needing its source page
demo312factsstated in more than one place — sample sizes, results, doses, limits
Where one clinical summary section’s working days goestimated
By hand70 days
With the solution15 days
  • Pulling figures from CSRs and integrated summaries18 → 2 d
  • Drafting the section text24 → 5 d
  • Checking every citation against its page15 → 3 d
  • Reconciling numbers across 2.5, 2.7 and the sources8 → 1 d
  • Owner review and sign-off5 → 4 d

Estimated split for one section such as 2.7.3, by hand and with the solution. The totals follow the 14 → 3 weeks shown for 2.7.3 on the working solution’s dashboard.

How it works

How a section moves

Six specialist agents read the sources, draft each section, verify every citation and check the numbers agree; the section owner signs.

What comes in
Sources inModules 3, 4 and 5 · study reports and quality data
Agents at work
Source readerkey facts + pages
Then
Clinical summary writer2.5 · 2.7
Nonclinical summary writer2.4 · 2.6
Quality summary writer2.3
Then
Citation verifierevery page opened
Then
Consistency agentacross modules
A person decides
Section ownerapproves and signs
What comes out
Module 2 drafts
Citation map
Consistency report
One case, step by step

One section, from first draft to signed

The Veltrimab BLA is due on December 14. 2.7.3 Summary of Clinical Efficacy is on Dr. Maya Chen’s desk — with one number that does not agree. Here is what happens next, screen by screen, in the working solution.

  1. 01Morning

    Everything that needs her, on one screen

    Dr. Maya Chen · Clinical efficacy lead

    Maya opens the solution: 6 of 14 Module 2 sections approved, 69 days to the December 14 submission. 2.7.3 is ready for her signature with one consistency flag. Dr. Omar Haddad has asked her to review 2.5.4, and a new version of CSR VLT-303 — the Week 104 interim — touches 14 statements in 2.7.3.5 and 2.5.4.

    “VLT-302 sample size disagrees — 2.5.4 says 824 randomized · 2.7.3.2 says 818 · CSR Table 14.1.1.1”

  2. 02While she reads

    The section drafted, checked, then checked again

    Clinical summary writer

    On the dossier, the clinical summary writer finishes 2.7.3.5 Persistence of efficacy. The citation verifier then opens every one of the 214 cited pages, and the consistency agent compares 2.7.3 with 2.5.4 and 2.7.6. Every section of the BLA sits in its CTD place, with its owner, stage, statement count and share verified.

    “2.7.3 drafted — 214 statements, every one cited · 213 verified · 1 consistency flag”

  3. 03Opened

    Every statement with its citation — and one marked red

    Dr. Maya Chen · Clinical efficacy lead

    The draft follows the 2.7.3 headings, from 2.7.3.1 Background and overview of clinical efficacy to 2.7.3.5 Persistence of efficacy and tolerance effects. Each statement carries numbered citation chips and a tick once verified. One in 2.7.3.2 does not: “In VLT-302, 818 patients were randomized 2:1 to veltrimab (n=546) or placebo (n=272).”

    “Says 818 randomized. The cited table shows 824 randomized and 818 in the full analysis set — and 2.5.4 states 824.”

  4. 04One click

    The source page, open at the table

    Dr. Maya Chen · Clinical efficacy lead

    Maya clicks the citation. CSR VLT-302 opens at page 112 of 2,140 — Table 14.1.1.1 Subject Disposition. Randomized: 549 and 275, total 824. Received at least one dose (full analysis set): 546 and 272, total 818. The draft gave the full-analysis-set count and called it randomized.

  5. 05Not yet

    A section with a disagreement cannot be signed

    Dr. Maya Chen · Clinical efficacy lead

    She presses Approve section anyway. The solution stops her: 2.7.3 cannot be signed while a statement disagrees with its source. It offers to open the flag.

    “Agents can propose the fix; you decide.”

  6. 06The consistency board

    Every figure stated in more than one place, side by side

    Consistency agent

    312 facts tracked, 309 matching everywhere, 3 open flags. The VLT-302 count sits next to two others: patients exposed to veltrimab (1,942 in 2.5.5, 1,947 in 2.7.4.1) and the drug product protein concentration (100 ± 10 mg/mL in 2.3.P.5, 95–105 mg/mL in 3.2.P.5.1). For each, the board shows where it is stated and the source of truth.

    “2.7.3.2 uses the full-analysis-set count (818) but calls it ‘randomized’. The final CSR and 2.5.4 both give 824 randomized.”

  7. 07Fix with agent

    A tracked change that keeps both populations

    Consistency agent

    The agent opens Table 14.1.1.1, compares the populations, and proposes a tracked change to 2.7.3.2: 824 randomized (549 and 275), with 818 receiving at least one dose and forming the full analysis set. It re-checks 2.5.4 and 2.7.6 — both already say 824, so no change there.

    “You decide — nothing changes until you apply it.”

  8. 08Applied

    Re-verified against the page

    Dr. Maya Chen · Clinical efficacy lead

    Maya applies the change to 2.7.3. The statement goes green, marked “Edited by the consistency agent · applied by Dr. Maya Chen · re-verified against the cited page”. The section moves to version 0.7, with 214 of 214 statements verified.

    “Verified. The citation verifier opened the cited page; every figure in this statement matches.”

  9. 09Sign

    Her signature, with its meaning

    Dr. Maya Chen · Clinical efficacy lead

    The signing screen sums up the section: 214 statements, every one cited; 214 of 214 verified against source pages; all figures match 2.5.4, 2.7.6 and the sources; one tracked change, in 2.7.3.2. She signs as section owner — meaning “Approved as section owner”, with her password.

    “Your signature is recorded with date, time and meaning. The section is locked as version 1.0 and goes to the eCTD build.”

  10. 10Signed · version 1.0

    Locked, with its whole history

    Dr. Maya Chen · Clinical efficacy lead

    2.7.3 is approved and locked as version 1.0. The history shows every step in order — each agent’s draft and verification, the flag, Maya’s accepted correction and her signature. Any change from here opens version 1.1, with a reason.

Who it’s for

Built for everyone who owns a Module 2 section.

The same submission, seen by four of the people who write and sign it — what their weeks looked like, and what they look like now.

MC
Dr. Maya ChenClinical efficacy lead
Section owner
Before
Checks her own efficacy numbers against the CSR tables, line by line.
Now
Starts from a cited draft with every page already opened; spends her time on the one statement that needs her judgement, then signs.
OH
Dr. Omar HaddadClinical lead · Clinical overview
Section owner
Before
Writes 2.5 from the same studies as 2.7, and finds out in review that the two disagree.
Now
Sees his 2.5.5 exposure count flagged against the final Integrated Summary of Safety, and 2.5.4 wording on body-weight subgroups checked against the figure it cites.
LO
Lena OrtizCMC regulatory lead
Section owner
Before
Re-reads Module 3 for every limit and shelf life she quotes in 2.3.
Now
Has specifications and shelf life quoted exactly as registered, with the Module 3 page — and the development limit in 2.3.P.5 flagged against the registered specification.
DO
Dana OkaforSubmission lead
Submission lead
Before
Chases 14 sections and six owners toward one submission date.
Now
Sees weeks to first draft, citation status by section, flags found and resolved, and what is due soon, against the target of all 14 sections approved by Nov 27.
Built on the engine

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

Six specialist agents read the sources, draft each section, verify every citation and check the numbers agree; the section owner signs.

Source reader

Reads study reports and Module 3 documents page by page, and records every key fact — sample sizes, endpoint results, exposure, doses, specification limits, shelf life — with its population and exact page, table or figure.

  • Records only printed values — never infers a number
  • Every fact keeps its page anchor
Clinical summary writer

Drafts 2.5 Clinical Overview and the 2.7 Clinical Summary from the CSRs and integrated summaries, in the order set by ICH M4E(R2) and the company template.

  • No statement without a citation
  • Numbers only from the key facts register
  • Never approves its own draft
Nonclinical summary writer

Drafts 2.4 Nonclinical Overview and the 2.6 written and tabulated summaries from the Module 4 study reports, building the tabulated summaries from the report tables.

  • No statement without a citation
  • Doses and NOAELs quoted exactly as printed
Quality summary writer

Drafts the 2.3 Quality Overall Summary — drug substance, drug product and appendices — summarising each 3.2.S and 3.2.P section under its matching 2.3 heading.

  • Limits and shelf life quoted exactly as registered
  • No statement without a citation
Citation verifier

Opens every cited page and checks the statement says what the page says — every number, the population and the direction of the claim — then marks it verified, to check, or disagrees.

  • Cannot change text — proposes only
  • Every verdict keeps the page it read
Consistency agent

Finds every figure stated in more than one section and checks they agree with each other and with the source of truth; when they do not, it opens a flag with the values, the pages and a proposed correction.

  • Corrections are proposals until the owner signs
  • Source of truth: final, signed reports
Section owner

Approves and signs. The agents propose; a named person decides.

Ask in plain words

Ask about any section, statement or source

Section owners and writers can ask in plain words — or tell it what to change. Every answer comes with its page.

Where else do we state the VLT-302 sample size?

Three places. 2.5.4 and 2.7.6 say 824 randomized, which matches the final CSR. 2.7.3.2 says 818 randomized — that is the full analysis set, not the randomized count. The flag is open on the consistency board.

Which statements still need attention?

Four across the dossier: three numbers that disagree with their source — the 2.7.3.2 sample size, the 2.5.5 exposure and the 2.3.P.5 protein concentration — and one wording check in 2.5.4 on body-weight subgroups.

Does response differ by body weight?

Yes. PASI 75 response was seen in every subgroup but was lower above 100 kg: 61.0% versus 75.9%. Population PK explains it — steady-state exposure is 32% lower above 100 kg. 2.5.4 calls the response “consistent” across subgroups; the verifier suggests “seen in all subgroups, with a lower rate above 100 kg”.

Add a rule: cite final study reports, never topline memos

Added to the citation rules. The citation verifier now rejects any statement that cites a topline memo or draft report. Every statement in the dossier already cites a final or signed version.

Every screen

The working solution, as it ships.

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

HomeWhat needs the section owner today: sections waiting for signature, numbers that disagree, new source versions and the days to submission.
The dossierEvery Module 2 section in its CTD place, with owner, stage, statements, share verified, flags and due date — and the agents at work.
The section draftThe outline, the draft with a citation chip on every statement, and the source passage beside it.
The source pageAny citation opens the study report at its page and table, with the cited figures highlighted.
Signing, blockedA section cannot be signed while one of its statements disagrees with its source.
The consistency boardEvery figure stated in more than one place, where it is stated, and its source of truth in Modules 3 to 5.
A proposed fixThe agent’s steps, then the tracked change: the text now, and the text proposed with its source page.
Applied and re-verifiedThe corrected statement, marked with who proposed it, who applied it, and that it was checked against the page.
Electronic signatureStatements, verification, consistency and tracked changes summed up; the owner signs with the meaning of the signature and a password.
Signed and lockedVersion 1.0 locked, with the section’s full history of agent steps and human decisions.
SourcesThe study reports and quality documents the summaries cite, by CTD location, version and the number of statements citing each.
The dashboardWeeks to first draft by section, consistency flags found and resolved each week, citation status and what is due soon.
SettingsSection owners, citation rules and writing style — p-values, decimal places and the Module 2 template.
Governance

Built for regulatory writing: cited, verified, signed.

Every statement cites a pageEvery statement in Module 2 cites a page in Module 3, 4 or 5. A statement without a citation cannot leave drafting, and one click opens the source at the highlighted passage.
Every cited page is openedThe citation verifier reads the page behind each statement and checks the numbers, the population and the wording. It cannot change text — it only proposes.
Final reports are the source of truthFigures are checked against the final, signed report — never a topline memo. When a source gets a new version, the affected statements are proposed as tracked changes.
Agents propose, people decideOnly the named section owner can approve. A fix changes nothing until a person applies it, and marking a flag “not an issue” needs a reason the owner confirms.
Signed with meaning, locked as a versionApproval is an electronic signature with its meaning, date and time. The signed section is locked, and any later change opens a new version with a reason.
Every step on the recordEach agent’s draft, verification and flag, and each person’s edit, correction and signature, is kept in the section’s history with who, what and when.
Configuration

Your writing rules, not ours

Owners, citation rules and house style are settings. Headings and order follow ICH M4 and your company style guide.

SettingDefaultChoose from
Who signs each sectionIts named section ownerAny person on the team, per section
Every statement needs a source pageOnOn · Off
Numbers must match the key facts registerOn — before owner reviewOn · Off
Flag wording that overstates a resultOnOn · Off
Re-check when a source gets a new versionOn — as tracked changesOn · Off
How small p-values are writtenp<0.001p<0.001 · p<.001 · exact
Decimal places in results text10 · 1 · 2
Your own citation rulesYour rulesAdd in plain words
Connections

Works with the documents you already have

Clinical study reportsCSRs, integrated summaries and PK reports, Module 5
Quality and CMC documents3.2.S and 3.2.P: process, specifications, stability, validation
Nonclinical study reportsModule 4 toxicology and pharmacology
Document management systemnew sources and new versions, read and indexed
Module 2 templatesICH M4 headings, your template and style guide
eCTD buildsigned, locked sections go to publishing
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
5weeks
to a first Module 2 draft
By hand≈ 5 months
With agents≈ 5 weeks
target
100%
of statements cited to a source page, each citation checked
statements cited to their page
target
312facts
kept in step across all 14 sections, rechecked when a source changes
309 match · 3 flagged for the owner

“demo” = seen in the working solution, on its sample Veltrimab BLA data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · Module numbers follow the ICH Common Technical Document (M4). People, products and studies named on this page are characters and sample data in the working solution.

Questions

What regulatory and medical writing teams ask us.

What does the Submission Summary Writer do?

It drafts the CTD Module 2 summaries — 2.3 Quality Overall Summary, 2.4 and 2.6 nonclinical, 2.5 Clinical Overview and the 2.7 Clinical Summary — from your Module 3, 4 and 5 documents. Every statement is cited to its source page, every citation is checked, and figures are kept the same across sections. The section owner reviews and signs.

How does it make sure each statement matches its source?

The citation verifier opens every cited page and checks the numbers, the population and the direction of the claim. A statement is marked verified, to check if the wording overstates or understates the result, or disagrees if a number or population differs.

How does it keep numbers consistent across 2.5, 2.7 and Module 3?

The source reader records every key fact with its page in a key facts register, and the writers take numbers only from it. The consistency agent tracks each figure everywhere it is stated and opens a flag, with a proposed correction, when two places disagree or one disagrees with the final report.

What happens when a study report gets a new version?

The new version is read and indexed page by page, the changed facts are found, and every statement that cites them gets a tracked change proposed for its owner. In the working solution, the Week 104 interim of CSR VLT-303 touched 14 statements in 2.7.3.5 and 2.5.4.

Do people stay in control?

Yes. Agents draft, cite, verify and propose — they never sign. Nothing changes until a person applies it, only the named section owner can approve, and approval is an electronic signature with its meaning, recorded with date and time.

Can we use our own template and style guide?

Yes. Headings and order follow ICH M4 and your company style guide, and settings cover how p-values are written, decimal places in results text, who owns each section and your own citation rules.

Does it work for quality and nonclinical summaries too?

Yes. The quality summary writer drafts 2.3 from Module 3, quoting specification limits and shelf life exactly as registered. The nonclinical summary writer drafts 2.4 and 2.6 from the Module 4 reports, quoting doses and NOAELs exactly as printed.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your Module 2 template, style guide and a set of study reports — and it goes live once every quality gate has passed. We will walk you through it on one of your own sections first.

See it on
your submission.

We’ll draft a Module 2 section from your own study reports and template.