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Accomplishments: CDRH Plan of Action for 510(k) and Science

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CDRH Plan of Action for 510(k) and Science - Implementation

Recommendation Purpose Milestone/Deliverable Completion Date
Implement an "Assurance Case" Pilot Program To explore the use of an “assurance case” framework for 510(k) submissions. Start pilot program
Pilot program underway
See infusion pump website.		 Checkmark March 31, 2011
Establish a Center Science Council To: 1) oversee the development of a business process and SOP for determining and implementing an appropriate response to new scientific information; 2) promote the development of improved metrics to continuously assess the quality, consistency and effectiveness of the pre-market programs; 3) periodically audit pre-market review decisions to assess adequacy, accuracy and consistency; and 4) establish an internal team of clinical trial experts to provide support and advice on clinical trial design for Center staff and prospective IDE applicants. Post Council Charter to FDA Website Checkmark March 31, 2011
Provide Additional Information About Regulated Products To make device photographs available in a public database without disclosing proprietary information. Public Meeting * Checkmark April 7, 2011
Improve Medical Device Labeling To develop an on-line labeling repository. Public Meeting * Checkmark April 7, 2011
Improve Collection and Analysis of Postmarket
Information		 To develop better data sources, methods and tools for collecting and analyzing meaningful postmarket information, and to enhance the Center’s capabilities to support evidence synthesis and quantitative decision making. Determine system requirements and select the platform for a new adverse event database
System requirements determined 		Checkmark June 30, 2011
Improve the IDE Process To better characterize the root causes of existing challenges and trends in IDE decision making.
Assess, characterize and mitigate challenges in reviewing IDE’s.		 Complete program assessment
Assessment completed 		Checkmark June 30, 2011
Establish "Notice to Industry Letters" as a Standard Practice To clarify and more quickly inform stakeholders when CDRH has changed its regulatory expectations on the basis of new scientific information. Post SOP to FDA Website Checkmark June 15, 2011
Establish a Center Science Council See Above. Post initial results of 510(k) audit to FDA Website Checkmark June 15, 2011
Assess Center Staffing Needs To formalize the Center’s internal process for identifying staffing needs, and to enhance recruitment, retention, training, and professional development of review staff.
To create a mechanism to assemble an experienced ad hoc team to temporarily assist with unexpected surges in workload.		 Develop process for identifying, recruiting, retaining, and training needed staff
Internal SOP completed 		Checkmark July 15, 2011
510(k) Modifications Guidance To clarify which changes do or do not warrant submission of a new 510(k) and which modifications are eligible for a Special 510(k). Draft Guidance Checkmark July 27, 2011
Streamline Guidance and Regulation Development Process To provide greater clarity, predictability, and efficiency in the guidance and regulation development process. Post SOPs to FDA Website (PDF) Checkmark July 31, 2011
Clinical Trials Guidance To improve the quality and performance of clinical trials and the application of the least burdensome principle Draft Guidance Checkmark August 15, 2011
Enhance Training To train new Center staff on core competencies.
To train Center staff and industry on: 1) the determination of "intended use"; 2) the determination of whether a 510(k) raises “different questions of safety and effectiveness"; 3) the review of 510(k)s that use “multiple predicates”; 4) the development and assignment of product codes; 5) the interpretation of the “least burdensome” principles; and 6) the appropriate use of consensus standards.		 Develop and implement training on core competencies
Launched Reviewer Certification Program
Press Release		 Checkmark September 6, 2011
Evaluation of Automatic Class III Designation (De Novo) Guidance To streamline the de novo classification process. Draft Guidance Checkmark September 30, 2011
Continue Integration and Knowledge Management  To improve knowledge management across the Center. Complete evaluation of methods used to integrate device information into a dynamic format so that it can be more readily used by staff to make regulatory decisions
Internal Assessment completed 		Checkmark October 4, 2011
Leverage External Experts To develop a network of external experts to appropriately and efficiently leverage external scientific expertise. Also, to assess best-practices and develop SOPs for staff engagement with external experts. Post SOP to FDA Website Checkmark October 4, 2011
Multiple Predicate Analysis To conduct additional analyses to determine the basis for the apparent association between citing more than five predicates and a greater mean rate of adverse event reports. Complete analysis and make results public Checkmark October 14, 2011
510(k) Paradigm Guidance To provide greater clarity regarding: 1) when clinical data should be submitted in support of a 510(k); 2) the submission of photographs or schematics for internal FDA use only; 3) the appropriate use of multiple predicates; 4) the criteria for identifying "different questions of safety and effectiveness" and technological changes that generally raise such questions; 5) resolving discrepancies between the 510(k) flowchart and the Food, Drug, and Cosmetic Act; 6) the characteristics that should be included in the concept of “intended use”; and 7) the development of 510(k) summaries to assure they are accurate and include all required information. Draft Guidance Checkmark December 27, 2011
Appeals Guidance To clarify the process for appealing CDRH decisions by external persons. Draft Guidance Checkmark December 27, 2011
Product Code Guidance To more consistently develop and assign unique product codes. Draft Guidance Checkmark December 30, 2011
Implement a Unique Device Identification (UDI) System To permit the rapid and accurate identification of devices, to facilitate and improve adverse event reporting and identification of device-specific problems. Issue proposed regulation Checkmark July 3, 2012
Pre-Submission Interactions Guidance To supplement available guidance on pre-IDE meetings and enhance the quality of pre-submission interactions between industry and Center staff. Draft Guidance Checkmark July 13, 2012
Clarify and Improve Third-Party Review To develop a process for regularly evaluating the list of device types eligible for third-party review and to enhance third-party reviewer training. Post SOP to FDA Website Started
Due September 30, 2011
Standards Guidance To clarify the appropriate use of consensus standards. Draft Guidance Started
Due October 31, 2011
Improve Medical Device Labeling To clarify the statutory listing requirements for the submission of labeling. Issue proposed regulation Started
Due December 31, 2011
Draft 510(k) Transfer of Ownership Regulation To better identify 510(k) transfers of ownership. Issue proposed regulation Started
Due December 31, 2011

Additional CDRH Actions Taken in Support of 510(k) and Science Report Recommendations

Action Purpose Milestone/Deliverable Completion Date
Analysis of Pre-market Review Times Under the 510(k) Program To determine factors affecting total review time and the number of review cycles. Post results of the analysis Checkmark July 19, 2011
Making Benefit-Risk Determinations in Medical Device Pre-market Review To provide greater clarity regarding the factors FDA considers when making benefit-risk determinations during the pre-market review process. Final Guidance Issued March 28, 2012 Checkmark August 15, 2011
(Draft Guidance)
Corrective and Preventive action (CAPA) system To assure identification and resolution of pre-market review issues. Corrective actions and, where appropriate, preventive actions, needed to correct identified issue and prevent recurrence of the problem will be recorded in a CAPA system. Start pilot program
Pilot program underway 		Checkmark October 1, 2011
International Device Regulators Forum To establish a new forum to accelerate international medical device harmonization and convergence. Hold preparatory meetings with other countries Checkmark February 15-17, 2011
October 6-7, 2011

Hold first meeting of the forum

http://www.imdrf.org/

Started
Due in 2012
SOPs for Requesting Additional Information To provide an SOP that clarifies the level of sign off or concurrence required for requesting additional data for premarket reviews. Internal SOP with training to staff Checkmark November 9, 2011
Early Feasibility Medical Device Clinical Studies Guidance To provide greater clarity regarding the development and review of Investigational Device Exemptions (IDE) applications for early feasibility studies of significant risk devices, including first-in-human studies, Draft Guidance
 		 Checkmark November 10, 2011
IDE Decisions Guidance To provide clarification regarding the types of decisions FDA may make to approve an IDE and to provide a general explanation of the reasoning and implications of those decisions. To provide an SOP that clarifies the level of sign off or concurrence required for requestion additional data for pre-market reviews. Draft Guidance Checkmark November 10, 2011
Change in Reviewer To establish procedures to assure greater consistency in the review of pre-market documents (e.g., IDEs, PMAs, 510(k)s) when review staff change during the review. Internal SOP with training to staff Checkmark December 27, 2011
Innovation Pathway To formally develop and implement the Innovation Pathway for important medical devices and apply new approaches developed to other pre-market pathways Begin implementing Innovation Pathway 2.0 Checkmark April 9, 2012
Triage of Pre-market Submissions To increase submission review efficiency and better manage the pre-market review workload. The initial management review (triage) will help determine the level of review required for each submission. Start pilot program
Pilot program underway		 Checkmark April 2, 2012
Foreign Clinical Studies To clarify the circumstances under which we would rely on clinical studies conducted in and for other countries. Proposed regulation Started
Due 2012

* Both actions were discussed at the April 7, 2011.

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