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Special Access Scheme (SAS): Online system guidance

28 September 2018

Online System overview

In July 2018, the Therapeutic Goods Administration (TGA) implemented an online system (the system) to enable the electronic submission and management of Special Access Scheme (SAS) applications and notifications to the TGA. The recommendation to develop and deploy this system was accepted by the Australian Government's response to the Review of Medicines and Medical Device Regulation.

Use of the system is expected to reduce administrative burden and provide health practitioners and organisations such as hospitals with additional reporting and management functions to assist in the management of their SAS applications and notifications.

It is important to note that use of the system to submit applications and notifications has not been mandated and the TGA will still accept paper SAS forms as a means of submission.

The TGA are planning to transition away from paper forms and move towards the submission of all SAS applications and notifications via the online system from 1 July 2019.

This document provides users of the system with guidance about how to use the system.

Terminology and definitions

Terminology Definition
Account Upon successful registration in the system, each user will have created an 'account' which is accessible using their credentials (username and password) selected as part of the registration process.
Affiliation Where a user has successfully been accepted by a Site Administrator to affiliate with a site providing ability to 1) share submissions with the site; and 2) view submissions shared with the site by other users in their dashboard.
Affiliated Site Creation of a site of practice within the system (such as a hospital or pharmacy department) to which system users may affiliate (by way of request or invitation from a Site Administrator). Once users become affiliated, they will then have the ability to share submissions with that site.
Outcome letter The Approval or Rejection letter provided by the TGA in response to SAS Category B applications.
Receipt A copy of the SASA or SASC notification form which can be downloaded via a user's dashboard.
Request for Information (RFI) The process by which the TGA requests additional information to be provided by the user after submission of an application.
Share Upon being affiliated with a site, a user has the option to make the SAS submission visible to other users who are also affiliated with that site. Sharing submissions will result in other users of the affiliated site to see that submission in their dashboard.
Site Administrator A system user who initially registered a site. The user will have the ability to invite other users to affiliate with that site, accept/reject requests to affiliate with that site; remove a system user's affiliations from that site, and invite other affiliated users to become Site Administrators.

Features of the SAS Online System

  • Users of the system will be required to register an account before they are able to begin drafting and submitting online SAS applications and notifications to the TGA.
  • As is the current process with the paper based SAS process, the system will allow other health practitioners (other than the prescribing health practitioner) to submit on behalf of the prescribing health practitioner.
  • Users will be able to draft and submit SAS applications and notifications to the TGA by navigating through an interactive workflow which contains a series of questions (further details provided under the 'Submitting SAS Applications and Notifications' section).
  • The interactive workflow is programmed to guide users down the correct SAS pathway based on the information provided (rather than relying on the user having to know which pathway is appropriate to access the unapproved good).
  • A searchable database of products (medicines, medical devices and biologicals) will be available for users to select the unapproved therapeutic good being sought. This will reduce administrative burden in having to manually transcribe this information and improve the quality of data received by the TGA, ultimately resulting in fewer Requests for Information (RFIs).
  • Users will also have a dashboard within their account where they will be able to:
    • Track the status of their application (in the case of SAS Category B).
    • Search previously submitted applications and notifications for reporting purposes using parameters such as patient details, product, prescriber, submission date and status (i.e. approved, rejected, withdrawn, completed).
    • Download a PDF copy of the application or notification to be saved locally.
    • Identify applications and notifications that are expiring (i.e. duration of supply is running out) or that have expired, prompting health practitioners to conduct a review of the patient's condition and resubmit SAS applications/notifications as required.
    • Download a copy of the TGA decision letter in the case of SAS Category B applications.
    • Clone (copy) previously submitted SAS submissions.
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Account registration

All users of the system are required to register a personal account. As part of this registration process, users are required to provide the following information to successfully register an account:

  • A new, unique username; password; email address (for the purposes of account registration).
  • Personal information such as full name; health practitioner type (if applicable); contact details (this will be used to populate the user's profile).

Note: users who have registered with other systems hosted by the TGA should login (rather than register) using the username and password to which they registered with the first TGA system.

Health practitioners

Upon registration of an account, health practitioners will have the ability to draft and submit SAS applications and notifications to the TGA. In the account registration process, users will be presented with the following question to determine their health practitioner status:

screenshot of SAS Online welcome page

Health practitioners registering an account in the system will be asked to provide their AHPRA registration number. The AHPRA registration number should be entered exactly as it appears in the AHPRA public register, including the three letter prefix (i.e. MED1234567890).

Note: Those health practitioners able to submit SAS applications and notifications to the TGA are defined in the Therapeutic Goods Act 1989. This definition is as follows:

"health practitioner means a person who, under a law of a State or internal Territory, is registered or licensed to practice in any of the following health professions:

  • Aboriginal and Torres Strait Islander health practice;
  • dental (not including the professions of dental therapist, dental hygienist, dental prosthetist or oral health therapist);
  • medical;
  • medical radiation practice;
  • nursing;
  • midwifery;
  • occupational therapy;
  • optometry;
  • pharmacy;
  • physiotherapy;
  • podiatry;
  • psychology."

Non-health practitioners

Upon registration of an account, non-health practitioners will not be able to draft or submit applications to the TGA. This is in accordance with the relevant provisions of the Therapeutic Goods Act 1989 (the Act) and associated regulations relevant to the SAS. However, non-health practitioner users will be able to affiliate with a site to view the progress of submissions made to the TGA in their user dashboards (see 'Affiliated Sites' section for further information).

Health practitioners

Have the ability to draft and submit SAS applications and notifications to the TGA, including the submission of applications and notifications on behalf of prescribing health practitioners.

Non-health practitioners

Do not have the ability to draft and submit SAS applications and notification to the TGA however may have oversight of applications and notifications being made by their affiliated site.

Password resets

  1. Select the 'Change password' option from the dropdown menu in your user profile. Alternatively, this can also be done when attempting to login to the system:
    screenshot showing location of Change password option
  2. Enter your username:
    screenshot showing username field
  3. A password reset email will be sent to the email address associated with your username:
    screenshot showing Confirm password reset
  4. Click on the hyperlink provided to reset your password (note this link will expire in 24 hours after receiving this email):
    screenshot showing link in email
  5. Enter your new password:
    screenshot showing Reset password

Note: Passwords cannot be reset or changed more than once in a 24 hour period.

Updating account information

Once an account has been registered in the system, users will be able to update the information associated with their account (such as name and contact details) by updating their user profile:

screenshot showing location of Profile option

Purpose

To enable better oversight and management of applications and notifications submitted via the SAS, the system allows users to share applications and notifications with other users who are affiliated under a Site (such as those working at a particular hospital or pharmacy). In sharing applications and notifications with a particular Site, other affiliated users are able to then identify those submissions and access any documentation that may be relevant to the procurement of the good (such as copies of approval letters).

Site registration

Any user may register a Site in the system. It is important to note that the user who registers a Site will automatically become the Site Administrator. Site Administrators have the ability to:

  • Send invitations to affiliate with the Site via email.
  • Accept or reject requests to affiliate with the Site.
  • Edit the details of the affiliated Site (Site name, location information etc).
  • Assign other users as Site Administrators (assuming they have successfully affiliated).

To register a new site in the system, follow the below instructions:

  1. Select the 'My affiliated sites' tab:
    screenshot showing locatino of My affiliated sites tab
  2. Select 'Register a new site':
    screenshot showing location of Register a new site option
  3. Read and acknowledge the following declaration:
    screenshot showing Declaration for Register new affiliated site
  4. Select the lookup icon to search for the organisation you wish to register the Site against:
    screenshot showing Organisation name lookup field
  5. The information contained in this lookup function is drawn from the Australian Business Registry (ABR). You can search for the organisation by using the registered, trading or business name as well as the organisation's ABN:
    screenshot showing lookup results

    Note: The data included in this organisation look-up is drawn from the Australian Business Register (ABR) and is current as of 7 September 2017. There may be cases where users are unable to identify their organisation via this look-up function. If an organisation cannot be identified, please email SAS@health.gov.au with the Organisation Name and ABN so that it can be added to the look-up function. Once complete, this will allow users to then select that organisation and register an Affiliated Site(s).

  6. Once the organisation has been selected, provide the additional details associated with the Site you wish to register. It is important to note that the 'Site Name' is different from that of the organisation name. Multiple Sites may be registered under a single organisation (for example, a hospital may wish to register individual departments under the single organisation, resulting in various Sites). Once the Site name has been entered, the system will validate the uniqueness of the name to ensure no other Sites exist that also use that name.
    screenshot showing site details fields
  7. Review the details before registering the Site:
    screenshot showing Site details review
  8. Once the Site has been registered, it will appear under the 'My affiliated sites' tab:
    screenshot showing Sites under My affiliated sites tab

Adding a Site Administrator(s)

The role of a Site Administrator is automatically assigned to the user who first registers that site into the system. It is important to ensure that the user registering the site for the first time is appropriate person to do so as they will be granted rights to invite other users via email and also approve or reject any requests made by users to affiliate with the site (explained below) to also affiliate with that site (noting that users who are invited to and accept such an invitation will then have visibility of all SAS applications and notifications shared with that site). Site Administrators may invite other users who are affiliated with that site to become Administrators.

  1. To invite another user to become an Administrator, select the 'View details' button on the site:
    screenshot showing location of View details option
  2. Select the user you wish to invite to become an Administrator and select the 'Edit' button:
    screenshot showing location of Edit option
  3. Under 'Site Administrator', select 'Yes':
    screenshot showing Edit User fields
  4. The user will now be listed as a Site Administrator:
    screenshot showing Administrators

Sending invitations to affiliate

  1. Site Administrators are able to invite others to affiliate with a site by clicking the 'Invite Users' button:
    screenshot showing location of Inviite Users option
  2. Invites to affiliate with the site will be sent via email. Email addresses can be entered individually:
    screenshot showing Email field
  3. Or email addresses can be entered in bulk (each email address will need to be on a new line as shown below):
    screenshot showing inviting bulk emails
  4. The system will identify those users who do not yet have a personal account registered in the system. In the below example, the 5 email addresses are not registered in the system. Upon opening the email containing the invitation to affiliate with the site, the user will be required to register a personal account in the system. Once this has been registered, they will be presented with the option to accept or decline the invitation to affiliate:
    screenshot showing Non-existing users

Requesting to affiliate with a site

  1. Once a site has been registered in the system, users may request to join a site (rather than having to be invited by a Site Administrator). Select 'Request to join a site':
    screenshot showing location of Request to join a site option
  2. Select the look-up icon to search for the organisation to which the site is registered under:
    screenshot showing searching for a site
  3. Search for the organisation by using the organisation name or ABN:
    screenshot showing search results
  4. Once an organisation has been selected, users will be able to search all the sites registered under that organisation. Select the look-up icon to search through the registered sites:
     screenshot showing searching for a site
  5. In the below example, only a single site has been registered against that organisation. In the case multiple sites have been registered (such as different hospital departments), identify and select the desired site:
    screenshot showing example of search result
  6. Once selected, a confirmation message will be presented and the request will be sent to the Administrator(s) or the site for review:

Approving or rejecting a request to affiliate with a site

  1. Site Administrators will be notified in their user dashboard when a request to affiliate with a site has been made. Site Administrators can review this request by clicking the link provided:
    screenshot showing Dashboard message
  2. Select 'View details':
    screenshot showing location of View Details option
  3. Site Administrators should ensure that the user requesting to affiliate is appropriate to view the information that is contained in submissions that will be viewable upon accepting the request:
    screenshot showing Request Details

All users who have registered an account in the SAS system will have a personal dashboard that displays information specific to SAS applications and notifications they have drafted or submitted via the system. These dashboards differ between health practitioners and non-health practitioners.

Filtering dashboard information

  1. Dashboards allow users to search and filter submissions based on the fields shown below:
    screenshot showing filter options
  2. Users can also apply a uniform search across all available data fields by typing in the below text box:
    screenshot showing the location of the search field

Exporting submission data

  1. Selection of submissions and selecting the 'Save list as CSV' link will download a local .csv copy of the available data fields contained in the dashboard for those selected submissions as shown below:
    screenshot showing selecting submissions and resulting CSV file

Cloning submissions

All SAS submissions visible in a user's dashboard, including those submissions shared by another user via an Affiliated Site, can be cloned. The purpose of this function is to reduce the administrative burden of re-entering identical information into renewal submissions, or submissions for frequently used unapproved goods.

Upon cloning a submission, previously entered information will be used to prepopulate a new draft SAS submission. It is the responsibility of the submitter to review the information copied into the cloned submission to ensure that the correct information is provided to the TGA.

Please be aware that the following information will not be prepopulated into the new draft by the cloning function, and will need to be provided before submitting to the TGA:

  1. Answer to whether the patient's condition meets the SAS Category A definition ('yes/no')
  2. Intended date of supply
  3. Any attachments uploaded with the original submission
  4. Answer to the privacy statement on the Summary step ('yes/no')

Note: The information specific to the State or Territory Health Department for medicinal cannabis submissions will not be copied in the new draft submission. If State or Territory Health Department approval is required, this information will need to be provided in Step 5 before submitting.

Identify the submission that needs to be cloned by filtering in the user dashboard; click the 'Actions' tab and select 'Clone' from the dropdown:

screenshot showing location of Clone option

Navigate through the workflow and provide/update any relevant information specific to the new SAS application or notification before submitting to the TGA.

Draft submissions are saved when a user has entered information as part of a new SAS application or notification but has not yet submitted this to the TGA. A draft submission saves information already entered into the application or notification which can then be accessed from the dashboard for completion at a later date. Draft submissions appear under the 'Drafts' tab of the dashboard and do not display the 'submitted date' field.

screenshot showing location of Drafts option

Non-health practitioners

Dashboards for non-health practitioners will not include the 'Draft Submissions' tab as they are unable to submit SAS applications or notification to the TGA as per the provisions of the Act and associated regulations.

Saving as 'Draft'

The system does not include a 'save as draft' button to be selected. A draft submission is saved automatically when a user 1) closes their browser prior to submitting; or 2) navigates to another part of the system outside of the workflow.

Status of completed submissions

All SAS applications and notifications that have been submitted via the system will appear under the 'submitted tab' and will each be accompanied by a 'status'.

screenshot showing location of Submitted option

A list of the status terminology can be found below:

Status Description
'TGA Approved' Reflects TGA's approval of a SAS Category B (SASB) application.
'TGA Completed' Completion of a compliant SAS Category A (SASA) or SAS Category C (SASC) notification.
'TGA Non-compliant' Completion of a SASA or SASC notification where 1) the notification was submitted greater than 28 days after supply; or 2) an incorrect type of health practitioner has supplied the good.
'TGA Rejected' Reflects TGA's rejection of a SASB application.
'Under TGA Investigation' When a SASA or SASC notification has been submitted and the TGA is investigating the compliance of the notification with the SASA regulatory requirements or SASC Rules.
'Under TGA Review' Completion of a successful SASB application to the TGA to which a decision is yet to be made on that application.
'TGA Withdrawn' Reflects the status of a SASB application that has been submitted via the system and subsequently withdrawn at the request of the applicant.

Downloading receipts and outcome letters

Users will have the ability to download receipts and outcome letters provided by the TGA through their dashboard. This can be done on a single submission basis or a bulk download by selecting the submissions of interest as shown below:

screenshot showing selecting submissions and downloading receipts

A message box will be presented when attempting to download outcome letters if:

  1. The user is attempting to download an outcome letter for a SAS Category A or SAS Category C notification (as outcome letters are only applicable to SAS Category B applications); and
  2. The outcome letter for that SAS Category B application is not yet available.
screenshot showing message that the outcome letter is not available

The terms 'expiring and 'expired' are made in reference to the duration of supply remaining on a SAS application or notification:

  • Expiring means there are less than 14 calendar days remaining on the duration of supply of the SAS application/notification.
  • Expired means that the duration of supply approved/notified under the SAS has been exceeded.
screenshot showing location of Expiring and Expired terms

The purpose of displaying expiring and expired SAS applications and notifications in these tabs is to:

  1. Prompt health practitioners to conduct a review of the patient's condition post-treatment.
  2. Ensure continuation of patient care by accessing unapproved therapeutic goods under the SAS should the patient require further treatment.
  3. If supply of the unapproved therapeutic good is still required after the expiry date, a new SAS application/notification should be made for that patient.

The online system has been designed to guide health practitioners down the correct SAS pathway when seeking access to unapproved therapeutic goods. The online system will determine which information is required by the TGA based on the specific application/notification using internal logic.

The system will use information provided by the user about the prescribing health practitioner type, the unapproved product and its proposed use to ensure that the appropriate SAS pathway is used in accordance with regulatory requirements.

  1. To complete a SAS application or notification and submit this to the TGA via the system, go to your dashboard and select 'New SAS submission':
screenshot showing location of New SAS submission option

Step 1 – Prescriber details

  1. Users will have the ability to share a submission with a particular Site. More information on this functionality is provided under the 'Affiliated Sites' section:
    screenshot showing Share submission fields
  2. If submitting as the prescriber, the details will be automatically populated from the account which was registered through the system, as shown below. Note that contact details may be amended prior to continuing:
    showing Prescriber details fields
  3. If you are not the prescriber, the user will be asked to provide the AHPRA registration number for the prescriber. The system will then search the TGA's internal database in attempts to identify whether a profile associated with that AHPRA registration number already exists. If not, the user will be required to provide the prescriber's information before proceeding with the submission. (NB newly entered AHPRA numbers will be auto-populated with prescriber information in the system the next time they are used).

Note: The validation of this AHPRA ID does not refer to the AHPRA registry.

screenshot showing AHPRA number search

Step 2 – Product selection

  1. Select the type of unapproved therapeutic good for which access is being sought:
    screenshot showing Therapeutic good type options
  2. Upon selecting a type of therapeutic good, the user will be prompted to provide details of the product such as the active ingredient, dosage form and indication. A look-up function is available to search TGA's internal database of existing entries as shown below:
    screenshot showing active ingredient search
  3. Use the search bar to identify the active ingredient. To search on partial text, use the asterisk (*) wildcard character:
    screenshot showing search
  4. If you are unable to identify the required information via the look-up function, select the check-box below the search field. This will allow users to provide a free-text entry to support the submission:
    screenshot showing message that active ingredient could not be found
  5. If the product and indication are not able to be supplied by way of notification under the SAS Category C pathway, the user is prompted to confirm whether the patient meets the definition of a SAS Category A patient (this question will only be presented if the prescriber for the submission is a medical practitioner). The answer to the below determines whether the submission is processed as a SAS Category A notification or SAS Category B application:
    screenshot showing question whether the patient meets the SAS Category A definition

Step 3 – Product details

  1. Based on the prescriber's health practitioner type, the product/indication selection and whether the patient met the criteria of a SAS Category A patient, the workflow will determine whether the submission is to be processed as a SAS Category B application. If the product is available by way of notification under the SAS Category C pathway, the user will not be asked whether the patient's condition meets the SAS Category A criteria. Users are then required to complete the additional data fields specific to the product that is being sought as shown below:
screenshot showing the application pathway

Step 4 – Patient details

  1. Complete the patient details section and attach any supporting information via the upload function:
screenshot showing patient details fields

Step 5 – Summary

  1. Acknowledge that you have read and understood the following disclaimer to submit the SAS application or notification to the TGA:
screenshot showing privacy statement

In April 2018, the Commonwealth and State and Territory Health Departments announced they would work collaboratively to streamline access to unapproved medicinal cannabis products for Australian health practitioners. This announcement made reference to a 'single-in' application process through which medical practitioners could notify or apply to both the Commonwealth and the relevant State or Territory Health Department (where applicable) to prescribe and supply medicinal cannabis products via a single application. Historically, prescribers of unapproved medicinal cannabis products have been required to separately apply/notify the TGA and the State or Territory Health Department (where applicable) for approval/authorisation to supply these products.

When not to use the system to submit medicinal cannabis applications

There are circumstances where the TGA's SAS online system should not be used for medicinal cannabis submissions. These circumstances include:

  • Where the prescriber of the unapproved therapeutic good is not a medical practitioner.
  • If you are submitting an application on behalf of the prescriber. The medical practitioner prescribing the medicinal cannabis product must make the submission via the system.
  • Where the prescriber is in possession of a current TGA approval and the notification/application only relates to the state or territory. A notification or application in these circumstances should be made directly to the relevant State or Territory Health Department.

Notifying or applying to a State or Territory Health Department via the system

  1. Upon selecting 'medicine' as the therapeutic good type, the prescriber will be prompted to provide details of the medicinal cannabis product such as the active ingredient. A look-up function is available to search TGA's internal database of existing entries. Please note that medicinal cannabis products are listed via trade name rather than active ingredient (as displayed below). In selecting a medicinal cannabis product from the look-up function, the prescriber will then be prompted as to whether a State or Territory Health Department should also be notified or applied to as part of the submission:
    screenshot showing question about notifying or applying to a state or territory health department
  2. If the proposed product is unable to be selected via the look-up function, prescribers will have the ability to free-text details of the product. Upon entering free-text information, the prescriber will then be asked whether the product is a medicinal cannabis product as shown below:
    screenshot showing active ingredient fields
  3. If 'Yes' is selected to the above question, the prescriber will be asked which State or Territory Health Department should receive the notification/application. If the state or territory required is not available in the system, please leave this field blank and submit a standard SAS submission to the TGA. If you need to notify or apply to a State or Territory Health Department not included in the system, this needs to occur outside of the system:
    screenshot showing field to indicate which state or territory health department to notify or apply to
  4. Determine what SAS form type (Category A or Category B) should be submitted to the TGA:
    screenshot showing selection of Category A notification
  5. When a State or Territory Health Department has been selected, an additional step will be included in the system containing the data fields relevant to the state or territory application process:
    screenshot showing Step 5
  6. Once all the information requested in the system has been completed as part of the submission, the prescriber will then submit the application/notification. In submitting the application/notification via the system, both the TGA and selected State or Territory Health Department will concurrently receive the application information. This means that prescribers do not need to then separately notify or apply to the relevant State or Territory Health Department.
  7. The TGA and relevant State or Territory Health Department will each conduct their own evaluation processes on the information submitted via the system. It is important to note that as part of these evaluation processes, the TGA and State or Territory Health Department may contact the prescriber seeking further information in support of the application.
  8. The prescriber will receive a single email from the TGA containing both the TGA and state or territory outcome letters within 48 hours (2 business days) of having received all information required to evaluate the application.

TGA contact details

Email

Special Access Scheme: SAS@health.gov.au

Medicinal Cannabis: Medicinal.cannabis@health.gov.au

Phone

Special Access Scheme: 1800 020 653; +61 2 6232 8644

Medicinal Cannabis: 1800 220 007; +61 2 6232 8866

Fax Special Access Scheme and Medicinal Cannabis: +61 2 6232 8112

Version history
Version Description of change Author Effective date
V1.0 Original publication. Experimental Products Section (EPS); Pharmacovigilance and Special Access Branch (PSAB) 31 July 2018
V1.1 Guidance updates based on system changes. Experimental Products Section (EPS); Pharmacovigilance and Special Access Branch (PSAB) 28 September 2018