Ophthalmic Digital Health Areas

Similar documents
National Coordinated Registry Network (CRN) Think-tank

National Medical Device Evaluation System: CDRH s Vision, Challenges, and Needs

The State of CDRH and Future Directions. Jeff Shuren Center for Devices and Radiological Health U.S. Food and Drug Administration

FDA REGULATION OF DIGITAL HEALTH

Deciding When to Submit a 510(k) for a Software Change to an Existing Device Draft Guidance for Industry and Food and Drug Administration Staff

WANT TO PARTICIPATE IN RESEARCH? THERE S AN APP FOR THAT!

Software as a Medical Device (SaMD)

& Medical Tourism. DIHTF - Dubai 20 th -21 st Feb 2018 V S Venkatesh -India

Medical Devices cyber risks and threats

CENTER FOR DEVICES AND RADIOLOGICAL HEALTH. Notice to Industry Letters

Prof. Steven S. Saliterman. Department of Biomedical Engineering, University of Minnesota

4/8/2018. Prof. Steven S. Saliterman Department of Biomedical Engineering, University of Minnesota

Implementing Quality Systems

FDA s Evolving Approach to Pharmaceutical Quality

Health Informatics Principles - Excerpt -

January 8, Licensing Requirements for Implantable Medical Devices Manufactured by 3D Printing; Draft Guidance. Dear Sir or Madame:

Wearable Computing Technologies and Regulations

New methods, how could Norway speed up Health Technology Assessment (HTA) to the benefit of health industry, policy-makers, clinicians and patients?

Written Submission for the Pre-Budget Consultations in Advance of the 2019 Budget By: The Danish Life Sciences Forum

clarification to bring legal certainty to these issues have been voiced in various position papers and statements.

Disclosure: Within the past 12 months, I have had no financial relationships with proprietary entities that produce health care goods and services.

Security and Risk Assessment in GDPR: from policy to implementation

Digital Medical Device Innovation: A Prescription for Business and IT Success

Trends Report R I M S

Keeping up with the times Tensions between workflow, status quo, and technology

Advancing Health and Prosperity. A Brief to the Advisory Panel on Healthcare Innovation

E5 Implementation Working Group Questions & Answers (R1) Current version dated June 2, 2006

EMA experience with the review of digital technology proposals in medicine development programmes

A Brief Introduction to the Regulatory Environment of Medical Device Supervision. CFDA Department of Legal Affairs Liu Pei

A Case Study on the Use of Unstructured Data in Healthcare Analytics. Analysis of Images for Diabetic Retinopathy

Digital Health: Emerging Legal, Regulatory and Ethical Issues. January 16, 2019

Supporting Innovation through Regulation and Science

CDRH PMA Critical to Quality (CtQ) Pilot

Office of Pharmaceutical Quality: Why, What, and How?

Can the Innovation Watchdog Innovate? FDA s Recent Proposals to Streamline the Medical Device Clearance Process

The FDA: Merging Innovation and Opportunity to Impact Public Health

Human Factors Points to Consider for IDE Devices

USTGlobal. Internet of Medical Things (IoMT) Connecting Healthcare for a Better Tomorrow

TGA Discussion Paper 3D Printing Technology in the Medical Device Field Australian Regulatory Considerations

Reflection Paper on synergies between regulatory and HTA issues. DG SANTE Unit B4 Medical products: safety, quality, innovation

Health Care Analytics: Driving Innovation

Global harmonization of short-range devices categories

Standing Committee on the Law of Patents

Adopting Standards For a Changing Health Environment

Convergence and Differentiation within the Framework of European Scientific and Technical Cooperation on HTA

IN VITRO DIAGNOSTICS: CAPITA EXOTICA

ITGS Areas of Impact Revision. By Panagiotis Kafkarkou

The Health Information Future: Evolution and/or Intelligent Design?

Bringing Technology and Product Development Best Practices Together for Successful Innovation

Progress in FDA s Drug Product Quality Initiative. Janet Woodcock, M.D. November 13, 2003

Ministry of Justice: Call for Evidence on EU Data Protection Proposals

Medical Robotics. Part II: SURGICAL ROBOTICS

Research with Digital Health Methods 2.0 version date: 03/06/18

SUCCESSFULLY IMPLEMENTING TRANSFORMATIONAL TECHNOLOGY IN HOSPITALS AND HEALTH SYSTEMS

1005 Longworth HOB 2111 Rayburn HOB Washington, D.C Washington, D.C

Evidence for Effectiveness

Combination Products Verification, Validation & Human Factors Sept. 12, 2017

Health & Social Care Industrial Innovation

Technology and Innovation in the NHS Scottish Health Innovations Ltd

'INNOVATIVE SOLUTIONS FOR RESEARCH IN HEALTHCARE' Developing a novel approach to deliver better precision medicine in Europe The EMA standpoint

Advances and Perspectives in Health Information Standards

Medical Technology Association of NZ. Proposed European Union/New Zealand Free Trade Agreement. Submission to Ministry of Foreign Affairs & Trade

EU MDR Deep Dive: Software/Digital Health Implications for Manufacturers/Developers. 19 JUNE 2018 ASQ RAPS MASSMEDIC Waltham Woods

Medical Device Usability Engineering. Product and Service Design Innovation Consultancy

The New World of. Virtual Reality

China: Managing the IP Lifecycle 2018/2019

Office of Pharmaceutical Quality Key Quality Initiatives

CEOCFO Magazine. Pat Patterson, CPT President and Founder. Agilis Consulting Group, LLC

CMC Topics and PMDA s activities Yoshihiro Matsuda, Ph.D.

Digital Health Dilemma: Regulators Struggle to Keep Pace with Health-Care Technology Innovation

Introduction to Computational Intelligence in Healthcare

AIMed Artificial Intelligence in Medicine

Justice Select Committee: Inquiry on EU Data Protection Framework Proposals

Contributing to Society through Business

ehealth : Tools & Methods Dr. Asif Zafar

EN Official Journal of the European Union L 117/176 REGULATION (EU) 2017/746 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL.

Model Based Design Of Medical Devices

September November 2010

Meet the Human Factors Premarket. Office of Device Evaluation

Industrial Strategy Challenge Fund. Dr Jon Wood Manager for

UNIT 2 TOPICS IN COMPUTER SCIENCE. Emerging Technologies and Society

IEEE IoT Vertical and Topical Summit - Anchorage September 18th-20th, 2017 Anchorage, Alaska. Call for Participation and Proposals

Third Century Initiative: Global Challenges

Protecting Software as a Medical Device With Patents, Design Patents and Trade Secrets

INTEGRATING HUMAN FACTORS AND USABILITY TESTING INTO MEDICAL DEVICE RISK MANAGEMENT

CDRH INNOVATION INITIATIVE. February 2011 Center for Devices and Radiological Health U.S. Food and Drug Administration

envision workshop Designing for Change The Exam Process in 2030 American Academy of Ophthalmology 2015

Challenge AS3: Utilise Recent Developments in IT, Computing & Energy Storage Technology to Transform the Analytical Operations

The HL7 RIM in the Design and Implementation of an Information System for Clinical Investigations on Medical Devices

CDER s Office of Pharmaceutical Quality (OPQ): Delivering on the 21 st Century Quality Goals

The TRC-NW8F Plus: As a multi-function retinal camera, the TRC- NW8F Plus captures color, red free, fluorescein

GE Healthcare. Precision 500D. Digital radiography and fluoroscopy system

Mario Maniewicz Deputy-Director, Radiocommunication Bureau Commonwealth Spectrum Management Forum London, October 2017

2. Evidence themes and their importance along the development path

Standards and privacy engineering ISO, OASIS, PRIPARE and Other Important Developments

A FRAMEWORK FOR RISK CATEGORISATION AND CORRESPONDING CONTROLS FOR SaMD

Jim Mangione June, 2017

FDA Centers of Excellence in Regulatory and Information Sciences

Human factors and design in future health care

Improving Safety in Medical Devices from Concept to Retirements

Transcription:

FDA Perspectives on Ophthalmic Mobile Medical Applications and Telemedicine Ronald Schuchard Center for Devices and Radiological Health Office of Device Evaluation Ophthalmic Digital Health Areas Software as a Medical Device Mobile Medical Application s Interoperability Advanced Analytics Wireless - Cybersecurity Cloud - Fog/Edge Artificial Intelligence Medical Device Data Systems Implement consistent regulatory strategies and policies for ophthalmic digital health technologies 1

Types of Digital Health Devices in as Software in a Medical device Software as a Medical device SaMD 3 Rapidly Evolving Landscape Many ophthalmic devices rely heavily on digital technology Software diagnostics (CADx) and advanced analytics (CADe) are rapidly emerging Greater connectivity (interoperability) of devices has lead to new/greater risks Software development practices are evolving rapidly Changes to digital technology are more frequent (including after market clearance/approval) 4 2

Telemedicine in Ophthalmic Health Care Telemedicine (e.g., teleophthalmology) systems Telemedicine health care is part of the practice of medicine and not regulated by FDA Telemedicine is likely to have Medical Device Data Systems (MDDS) functionality which transfers, stores, or displays medical device data without controlling or altering the functions or parameters of a medical device 21 st Century Cures has removed the MDDS functionality from the definition of a medical device (Section 3060) Telemedicine in Ophthalmic Digital Health Telemedicine systems (continued) Devices used in Telemedicine are regulated by FDA (some of them are Digital Health Devices) Ophthalmic Cameras At Home Vision Testers (e.g., Visual Acuity & Amsler Grid) Telemedicine and Digital Health Devices can be Class I or Class II 510(k) exempt devices Perimeters with databases Group 1 Light Source Ophthalmic Cameras vrs Group 2 Light Source Ophthalmic Cameras 3

FDASIA Categories of Health IT Administrative Functionality* Health Management Functionality* Medical Device Functionality* Admissions; Billing and claims processing; Practice and inventory management; Scheduling; General purpose communications; Analysis of historical claims data; Determination of health benefit eligibility; Reporting communicable diseases; Reporting on quality. No Additional Regulatory Oversight Health information management; Data capture and encounter documentation; Electronic access to clinical results; Most clinical decision support; Medication management; Electronic communication (e.g. provider-patient, providerprovider, etc.); Provider order entry; Knowledge management; Patient ID and matching. Primary Focus of Proposed Health IT Framework Computer aided detection software; Remote display or notification of real-time alarms from bedside monitors; Refractive Surgery treatment planning software; High IOP detection. Primarily FDA Oversight * Examples provided are not intended to be an exhaustive list of functionalities. FDASIA Health IT Clinical Decision Support Tools intended to enhance, inform, and influence health care decisions. Health Management Functionality 1 Clinician order sets Clinician health records access Drug dosing calculations; Drug formulary guidelines; Reminders for preventative care; Access to treatment guidelines; Calculation of prediction rules. Medical Device Functionality 2 Computer aided detection (CADe) Computer aided diagnostic (CADx) Refraction treatment planning Robotic surgical planning and control Electrophysiology analytical software. 1 If a product with health management functionality meets the statutory definition of a medical device, FDA does not intend to focus its oversight on it. 2 CDS that have medical device functionality and present higher risks warrant FDA s continued focus and oversight. 4

FDA Perspective of Review Challanges Lack of experience for established device information that should be provided in applications No clear/complete description of technology or device Unclear indications for use / intended use Eye care clinical environment Non-eye care clinical environment Non-clinical environment (e.g., at home or school) Lack of a clearly appropriate predicate Risk Analysis is inadequate given risk of device use No or limited information provided for the software function relative to the risk of the device use Focusing on Higher Risk Functionality Lower Risk Functionality May not always enforce regulatory requirements Lower risks are not likely to exceed the limits of exemption ( 886.9) Higher Risk Functionality Intend to assure patient safety while encouraging advances in innovative technology and product life-cycle De Novo 510(k) PMA 10 5

Risk Assessment is key Premarket Assessments: What are the key functions of the device? What are the aspects of the device that are vulnerable? How are the key functions impacted by a vulnerability? What protections are in place? Methods of Mitigating Risks: Safeguards built into the software / hardware Methods to limit the intended users Labelling provided for patient use Training modules and tutorials Medical Mobile Apps (MMA) Final Guidance issued Feb 9, 2015 Focuses only on traditionally regulated functionality Provides users with same level of assurance of patient safety Identifies mobile app types that FDA does not intend to enforce requirements Clarifies what is not a device (Outside of FDA s Jurisdiction) MMA Mobile apps not considered medical devices Mobile Medical Apps Lower risk mobile apps that meet device definition 6

MMA & SaMD (Software as a Medical Device) Diagnostic MMAs D-EYE (886.1120 / PJZ Registered) Paxos Scope (886.1120 / PJZ) R&D in Tablet Video Field Assessment R&D in CADx for Diabetic Retinopathy Therapy MMAs R&D for Dichoptic Treatment of Amblyopia; Red/Green Glasses or Virtual Reality Glasses with Mobile Display R&D for wayfinding and object detection/localization as assistive technology devices for visually impaired MMA & SaMD Disease Progression Aids in Diagnosis/Therapy MyVisionTrack (K143211) 886.1330 Amsler Grid / HOQ Saccadometer Plus (K152890) 886.1510 Eye Movement Monitor / HLL EYE-SYNC (K152915) 882.1460 Nystagmograph / GWN Ophthalmic Image Management Systems - 892.2050 Picture Archiving and Communications System (PACS) / NFJ Retina Workplace (K170638) Huvitz Imaging System (K161829) Optos Advance Software (K162039) Synergy ODM (K151952) IRIS Intelligent Retinal Imaging Systems (K141922) 7

Interoperability Medical Device Interoperability is the ability of two or more products, technologies or systems to safely and effectively exchange and use information that has been exchanged FY 2015 FDA Draft Guidance Design Considerations and Premarket Submission Recommendations for Interoperable Medical Devices Interoperability Standards August 2013 FDA Recognized 14 standards for interoperability Nomenclature Medical device communications System / Software lifecycle process. Can be used for different levels of interoperability 8

Conclusions Ophthalmic Digital Health will lead to many new innovative devices that will provide diagnostic and therapeutic health care We hope today s workshop will foster Ophthalmic Digital Health innovation Right Cure for the Right Patient at the Right Time Thank you for your participation 17 9