What changed
The obligation applies from the first review cycle, and the deadline is fixed. Teams that batch their intake will feel this sooner.
The threshold is set out in the guidance; this reference for the detail.
- In-house teams handling supplier paper
- Anyone routing intake through a shared inbox
- Including the teams who only triage
- Map the current intake path
- Decide what a complete request looks like
The bottleneck was never the drafting. It was the queue.
An external counsel note covers the edge cases; this reference for the detail.