ISSUES
PRODUCT APPROVAL
Entities
Entity Approval status – How to make the renewal process for entities more practical.
Background:
Concerns raised by entities: “Out of business” while pending
Current Status:
1. Renewal – Without changing restricted fields. The only approval required is
the approval of the Accreditation Entity. Under this option entities can come into the system and renew their status to “approved” as soon as their accreditation entity approves them.
Expiration Date Note
2. Renewal with Revision or Revision – Edit restricted fields
1. System limitation – During their revision process, Entities lose approval status in the BCIS while new revisions are pending FBC approval. In the BCIS these require two approvals. One from the Accreditation body and one from the commission. In this pending status Entities are Unselectable in Manufacturer application dropdown.
Staff recommendation:
With regard to item Number 2 above, change BCIS to rely on the approval/affirmation of the accreditation entity for changing the status of the entities on the system, then affirm approval at the next commission meeting.
3. Renewals that went through after last meeting need to be reviewed to see if they need more material or a revision.
BCIS System enhancements for consideration and approval–
Note 1:
Automated email sent to A&A or DCA when an Entity Renews or Revises, depending on if the restricted fields were edited or not (determines who receives the fee $).
Note 2:
Upon entity renewal or revision, set the new Expiration Date to 1 year from the previous
Expiration Date, not 1 year from the Date of Approval.
Manufaturers
Editorial Changes – What are considered editorial changes to an application? Background:
Currently the BCIS system does not differentiate between editorial change or technical change. Determination is being left to the applicant and Arnold and Associates. This has caused confusion and additional costs to the applicant who selects that their changes are editorial to later find out from Arnold and Associates that their change is technical. This cost is $100 for the editorial change and another $300 for a technical revision.
Staff recommendation:
Discontinue editorial revisions and continue the $300 fee for any technical or editorial change made.
Continue to allow the editorial change, however enhance the system to allow for interaction with Arnold and Associates. i.e. a note can be added under the editorial change to require the applicant to contact Arnold and Associates to determine whether or not the changes are editorial or technical. On the BCIS, this can be done with a warning.