Bob Perry Consulting

RA3F™

Regulatory Affairs AI Assurance Framework

A practical, risk-based framework for governing, assessing, assuring and managing the use of artificial intelligence within pharmaceutical Regulatory Affairs.

From AI risk to regulatory control to auditable evidence.

The Governance Gap

Enterprise AI governance is necessary. Regulatory Affairs still needs an operating layer.

Enterprise AI governance can establish organization-wide expectations for inventory, risk, responsible AI, security, privacy, human oversight and monitoring. Regulatory Affairs must translate those expectations into the actual work performed in labeling, regulatory intelligence, submissions, controlled content, regulatory data and related workflows.

RA3F™ provides the operational bridge from enterprise AI governance to defined Regulatory Affairs use cases, proportionate controls, human decision authority, measurable assurance and retained evidence.
Enterprise AI Governance
RA3F™
Regulatory Affairs Execution
The RA3F™ Approach

Four functions. One operational assurance model.

GOVERN

Establish accountability, policy, human authority, risk governance, vendor governance, documentation and traceability expectations.

MAP

Define the Context of Use, purpose, boundaries, stakeholders, technology context, risks, requirements and expected benefit.

ASSURE

Establish evidence that AI performs as intended within defined boundaries through measurement, testing, traceability, review and monitoring.

MANAGE

Prioritize and treat risk, manage incidents and change, address residual risk, escalate issues and govern continuity, suspension or retirement.

ASSURE is RA3F™'s adaptation of the NIST AI RMF MEASURE function for the Regulatory Affairs assurance context.

Signature Concept

Context of Use: define exactly what the AI is being allowed to do.

RA3F™ starts with the actual use of AI, not the technology label. The same underlying model can present very different regulatory risk depending on its purpose, users, inputs, outputs, workflow position, decision influence, human authority, boundaries and evidence requirements.

Risk follows use.
A Context of Use asks
  • What is the AI intended to do?
  • Where does it operate in the workflow?
  • Who relies on its output?
  • What decisions can it influence?
  • What must a qualified human review?
  • What uses are prohibited?
  • What evidence must be retained?
  • What changes trigger reassessment?
Risk-Proportionate Governance

Assess the regulatory consequence of the use case, then scale control intensity.

D1 Regulatory Consequence
D2 Patient / Product Impact
D3 Decision Influence
D4 AI Autonomy
D5 Human Oversight & Decision Authority
D6 Traceability Requirement
Tier 1
Limited

Lower regulatory consequence; proportionate controls and evidence.

Tier 2
Regulatory

Meaningful Regulatory Affairs influence requiring enhanced governance and assurance.

Tier 3
Significant

Higher-consequence use requiring formal control, assurance and decision evidence.

RA3F™ separates risk tier, risk priority and control intensity. Applicable controls are identified as CORE or CONDITIONAL, with Basic, Enhanced or Formal implementation intensity as appropriate.

Control Architecture

30 controls organized around the RA3F™ functions.

7
GOVERN
Governance & accountability
7
MAP
Context & risk
9
ASSURE
Testing & evidence
7
MANAGE
Risk treatment & lifecycle

RA3F™ is an integration layer. It is intended to work alongside enterprise AI governance, quality systems, security, privacy, legal, records management, vendor management, system assurance and existing Regulatory Affairs process controls rather than replace them.

Lifecycle Governance

Govern the use case from definition through change and retirement.

DEFINE
ASSESS
ASSURE
MANAGE
REASSESS

GOVERN spans the entire lifecycle.

1Register & Define
Identify the use case and establish its Context of Use.
2Assess & Specify
Evaluate risk and define applicable controls and requirements.
3Test & Assure
Evaluate performance, oversight, traceability and evidence.
4Approve & Deploy
Support authorization by the appropriate client authority.
5Monitor & Change
Monitor production use and assess material change.
6Reassess or Retire
Reevaluate risk and controls or suspend/retire the use case.
Illustrative Application

RA3F™ applied to AI-assisted pharmaceutical labeling.

Consider an AI capability that compares an approved Prescribing Information document with a proposed revision and identifies omissions, unsupported claims, differences and traceability evidence.

AI role

Identify potential differences, findings and supporting evidence for review.

Human oversight

A qualified labeling reviewer confirms, rejects, modifies or escalates AI findings.

Decision authority

Authorized Regulatory Affairs personnel determine the regulatory action. AI assists; humans decide.

From Framework to Evidence

RA3F™ creates a traceable assurance chain.

Use Case
Context
Risk
Control
Test
Evidence
Decision

The objective is to make significant conclusions explainable, reviewable and supportable with evidence. RA3F™ distinguishes assurance, authorization and residual-risk acceptance: assurance informs the decision; it does not make the decision for the accountable organization.

A practical way to begin

Start with one real Regulatory Affairs AI use case.

A focused RA3F™ pilot can define the Context of Use, assess risk, identify applicable controls, establish assurance and evidence requirements, and provide an executive roadmap before broader implementation.

Free RA3F™ Resource

Free Regulatory AI Context-of-Use Assessment

Download this complimentary working questionnaire to define how an AI capability is intended to be used within Regulatory Affairs, where it influences regulated work, what human oversight is expected, and what evidence and controls may warrant deeper assessment.

This is an initial scoping resource—not a certification, compliance determination, regulatory approval, or formal RA3F™ assurance conclusion.

The future assessment will be educational and preliminary. It will not determine regulatory compliance, certify an AI system, or replace qualified Regulatory Affairs, quality, legal, security or privacy review.

External Reference Qualification. RA3F™ incorporates concepts and practices informed by external regulations, guidance, standards and AI risk-management frameworks. References to NIST, FDA, ISO/IEC, ICH, EMA or other external organizations do not constitute endorsement, certification, approval or formal adoption of RA3F™ by those organizations. RA3F™-specific controls, risk tiers, control intensities, artifacts, terminology and assurance methodologies are defined by RA3F™ unless explicitly identified as originating from an external source.