This document provides an overview of the regulatory requirements for registering the Vivace VX-1 medical device in Australia and Singapore. Key points include:
- Vivace VX-1 is a transcatheter mitral valve implantation device classified as high-risk Class D in Singapore and Class III in Australia.
- Risk management documentation must follow ISO 14971 standards for both countries.
- English language labeling is required, though GMDN codes are only mandatory for registration in Australia.
- A sponsor/registrant is needed in each country to register the device and facilitate the application process.
- Submission documents for Australia include design examination and declaration of conformity, while Singapore requires a Common Submission Dossier Template
This document discusses the different categories that medical devices can be grouped into for listing in the Medical Device Register: single, family, system, set, IVD test kit, and IVD cluster. It provides examples and definitions for each category. The key rules for grouping are that devices must be from the same manufacturer, have a common intended purpose, and share proprietary name, risk classification, design, and manufacturing process. Flowcharts are also included to help determine which category a group of devices falls under.
- The document provides a history of medical device regulation in the United States, European Union, and India.
- It outlines key milestones and developments in legislation and regulatory bodies governing medical devices in each region from the early 1900s to present day.
- Major acts and directives established regulatory frameworks and agencies to oversee safety and efficacy of medical devices, with increasing oversight and standards over time.
This presentation provides a KEY for classifying In Vitro Diagnostic Devices per FDA and EU In-Vitro Diagnostic Regulation EU 2017/746
EU Conformity Assessment information is also provided
The UDI system was created, developed and maintained by the device manufacturer based on global device identification standards. Today, it also helps with procurement and reimbursement. The Regulations allow for random inspections of producers’ facilities after devices have been placed on the market.
The document discusses medical device adverse event reporting requirements, including definitions of reportable events and timelines for submitting reports to regulatory agencies. It provides an overview of the classification system for medical devices and regulations around reporting malfunctions, deaths and serious injuries caused by devices. Reporting requirements and challenges involving software as a medical device are also reviewed.
Japan Medical Device Regulatory Approval ProcessKate Jablonski
Before deciding to sell your device in the Japanese market, it is important to understand how the regulations apply to your device, which steps to take, and what resources are required to complete the process. In this presentation, Ann Marie Boullie, Vice President of Business Development for EMERGO, outlines some of the most complex aspects of the Japanese registration process, including:
JMDN codes: device classification and predicates
Clinical data requirements and PMDA pre-submission meetings
Registration routes (Todokede, Ninsho, Shonin)
QMS (Ordinance 169) requirements
Role of the Marketing Authorization Holder (MAH)
This document discusses the different categories that medical devices can be grouped into for listing in the Medical Device Register: single, family, system, set, IVD test kit, and IVD cluster. It provides examples and definitions for each category. The key rules for grouping are that devices must be from the same manufacturer, have a common intended purpose, and share proprietary name, risk classification, design, and manufacturing process. Flowcharts are also included to help determine which category a group of devices falls under.
- The document provides a history of medical device regulation in the United States, European Union, and India.
- It outlines key milestones and developments in legislation and regulatory bodies governing medical devices in each region from the early 1900s to present day.
- Major acts and directives established regulatory frameworks and agencies to oversee safety and efficacy of medical devices, with increasing oversight and standards over time.
This presentation provides a KEY for classifying In Vitro Diagnostic Devices per FDA and EU In-Vitro Diagnostic Regulation EU 2017/746
EU Conformity Assessment information is also provided
The UDI system was created, developed and maintained by the device manufacturer based on global device identification standards. Today, it also helps with procurement and reimbursement. The Regulations allow for random inspections of producers’ facilities after devices have been placed on the market.
The document discusses medical device adverse event reporting requirements, including definitions of reportable events and timelines for submitting reports to regulatory agencies. It provides an overview of the classification system for medical devices and regulations around reporting malfunctions, deaths and serious injuries caused by devices. Reporting requirements and challenges involving software as a medical device are also reviewed.
Japan Medical Device Regulatory Approval ProcessKate Jablonski
Before deciding to sell your device in the Japanese market, it is important to understand how the regulations apply to your device, which steps to take, and what resources are required to complete the process. In this presentation, Ann Marie Boullie, Vice President of Business Development for EMERGO, outlines some of the most complex aspects of the Japanese registration process, including:
JMDN codes: device classification and predicates
Clinical data requirements and PMDA pre-submission meetings
Registration routes (Todokede, Ninsho, Shonin)
QMS (Ordinance 169) requirements
Role of the Marketing Authorization Holder (MAH)
medical device regulatory approval in USASuraj Pamadi
The document discusses the approval process for medical devices in the United States, including an overview of the classification system for medical devices (Class I, II, III), the requirements for each class (e.g. 510(k) notification or premarket approval), and the components required for a 510(k) premarket notification application to the FDA.
Digital therapeutics are software-based interventions used to prevent, manage, or treat medical disorders. They are clinically validated and work independently or with other treatments like medications. The digital therapeutics market is growing rapidly and was estimated at $1.8 billion in 2018, expected to reach $7.1 billion by 2025. Digital therapeutics can help change patient behavior, enable remote monitoring, and add value to healthcare delivery. Major barriers include distinguishing digital therapeutics from general health apps and obtaining reimbursement. The future of digital therapeutics includes reforming drug development and significantly impacting healthcare delivery models.
This document provides guidelines on when carcinogenicity studies of pharmaceuticals are needed. It outlines several factors to consider, including the maximum duration of patient treatment, intended patient population, prior assessment of carcinogenic potential, extent of systemic exposure, and similarity to endogenous substances. The guidelines specify that carcinogenicity studies are generally needed for continuous patient exposures of 6 months or longer, or intermittent exposures equivalent to 6 months, but may not be needed for short-term exposures or if there is no cause for concern about carcinogenic potential.
The document discusses the medical device registration process in Canada. It outlines the key steps, which include determining the device classification, obtaining necessary licenses for manufacturers and distributors, implementing quality systems according to ISO 13485, undergoing regulatory audits, and preparing required documentation for premarket review. The process varies depending on the risk class of the device and whether the applicant is a manufacturer, distributor or importer.
The document summarizes FDA regulation of medical devices in the United States. It discusses that many medical devices must undergo premarket review by the FDA to be legally marketed. Devices are classified based on risk, and moderate and high-risk devices must receive FDA clearance or approval prior to marketing, usually via the 510(k) or premarket approval (PMA) processes. Concerns have been raised about FDA's device review processes and oversight of marketed devices based on reports of device problems causing injuries.
Decentralized clinical trials (DCTs) allow patients to participate remotely with data captured using advanced equipment instead of visiting sites often. India can contribute significantly to DCTs by developing analytical tools to update clinical teams, training monitors remotely, managing documentation and helplines from India, and customizing roles like data access and quality control reviewers. DCTs have the potential to transform healthcare by improving access to trials, providing more comprehensive patient data to researchers, and opening up new areas for disease prevention and treatment evaluation using large datasets.
In pharmacovigilance, cases or reports of adverse drug reactions (ADRs) and other drug-related problems can originate from various sources. Here are the primary sources of cases in pharmacovigilance
The document discusses medical device regulations from various agencies like the FDA and EU, which classify devices based on risk into Classes I to III. It also covers quality management systems like ISO 13485 that are important for product development and design controls. The key elements of design control as required by regulatory agencies are also summarized, including design planning, input, output, review, verification, and validation.
Telemedicine shows promise for improving emergency response during trauma, disasters and other chaotic situations. It allows remote experts to assist on-site healthcare providers in real-time. Studies have demonstrated its safety and cost-effectiveness. However, telemedicine is still vastly underutilized for these situations due to lack of infrastructure, policies, protocols and standards. Ongoing work is being done to establish these frameworks and continue demonstrating telemedicine's ability to save lives in extreme conditions around the world. With further development, telemedicine could transform emergency response for both rural and disaster settings.
This document provides an overview of the key aspects of the Medical Device Directive 93/42/EEC as amended by 2007/42/EC. It defines important terms like medical device, manufacturer, intended purpose and conformity assessment routes. It describes the classification of devices based on duration of contact and degree of invasiveness. It outlines the conformity assessment procedures under Annexes II, III, IV, V and VI and notes when they are applicable based on device class. Guidance documents from the EU Commission are also referenced.
COMMON REGULATORY AFFAIRS JOB INTERVIEW QUESTIONS WITH ANSWERS-Updated in 2022!Pristyn Research Solutions
This document provides a summary of common regulatory affairs job interview questions and answers. It begins with defining regulatory affairs and its goals of protecting human health, ensuring drug safety and efficacy, and ensuring accurate product information. It then discusses the roles of regulatory affairs professionals in interacting with regulatory agencies, preparing submissions, and ensuring compliance. The rest of the document provides answers to common interview questions about regulatory submissions, guidelines, authorities, and key concepts and legislation related to drug approval.
GHTF group 1 is about pre market evaluation .This ppt includes brief about the group 1 , about ghtf , what it includes , study groups , definitions , classification and its rules
The document discusses the FDA's regulatory pathways for medical devices. The FDA uses a risk-based classification system to categorize devices as Class I, II, or III based on risk, with Class III devices posing the highest risk. Class I devices face the fewest regulatory requirements while Class III devices require a rigorous premarket approval process. The key pathways are 510(k) clearance for Class II devices and premarket approval (PMA) for Class III devices. The FDA aims to evaluate devices throughout their lifecycle from premarket through postmarket surveillance to ensure safety and effectiveness.
FDA classify Medical Devices and how to report device problems A Systematic R...Pubrica
The typical time it takes to get a device to market is 3 to 7 years, compared to 12 years for pharmaceuticals. However, there are concerns that the Food and Drug Administration's Systematic Review Writing methods may not be adequate to satisfy the required guarantees of safety and efficacy.
Learn More : https://pubrica.com/services/research-services/systematic-review/
Reference: https://bit.ly/3xNHUsC
Why Pubrica:
When you order our services, we promise you the following – Plagiarism free | always on Time | 24*7 customer support | Written to international Standard | Unlimited Revisions support | Medical writing Expert | Publication Support | Bio statistical experts | High-quality Subject Matter Experts.
Contact us:
Web: https://pubrica.com/
Blog: https://pubrica.com/academy/
Email: sales@pubrica.com
WhatsApp : +91 9884350006
United Kingdom: +44-1618186353
FDA classify Medical Devices and how to report device problems A Systematic R...Pubrica
The typical time it takes to get a device to market is 3 to 7 years, compared to 12 years for pharmaceuticals. However, there are concerns that the Food and Drug Administration's Systematic Review Writing methods may not be adequate to satisfy the required guarantees of safety and efficacy.
Learn More : https://pubrica.com/services/research-services/systematic-review/
Reference: https://bit.ly/3xNHUsC
Why Pubrica:
When you order our services, we promise you the following – Plagiarism free | always on Time | 24*7 customer support | Written to international Standard | Unlimited Revisions support | Medical writing Expert | Publication Support | Bio statistical experts | High-quality Subject Matter Experts.
Contact us:
Web: https://pubrica.com/
Blog: https://pubrica.com/academy/
Email: sales@pubrica.com
WhatsApp : +91 9884350006
United Kingdom: +44-1618186353
medical device regulatory approval in USASuraj Pamadi
The document discusses the approval process for medical devices in the United States, including an overview of the classification system for medical devices (Class I, II, III), the requirements for each class (e.g. 510(k) notification or premarket approval), and the components required for a 510(k) premarket notification application to the FDA.
Digital therapeutics are software-based interventions used to prevent, manage, or treat medical disorders. They are clinically validated and work independently or with other treatments like medications. The digital therapeutics market is growing rapidly and was estimated at $1.8 billion in 2018, expected to reach $7.1 billion by 2025. Digital therapeutics can help change patient behavior, enable remote monitoring, and add value to healthcare delivery. Major barriers include distinguishing digital therapeutics from general health apps and obtaining reimbursement. The future of digital therapeutics includes reforming drug development and significantly impacting healthcare delivery models.
This document provides guidelines on when carcinogenicity studies of pharmaceuticals are needed. It outlines several factors to consider, including the maximum duration of patient treatment, intended patient population, prior assessment of carcinogenic potential, extent of systemic exposure, and similarity to endogenous substances. The guidelines specify that carcinogenicity studies are generally needed for continuous patient exposures of 6 months or longer, or intermittent exposures equivalent to 6 months, but may not be needed for short-term exposures or if there is no cause for concern about carcinogenic potential.
The document discusses the medical device registration process in Canada. It outlines the key steps, which include determining the device classification, obtaining necessary licenses for manufacturers and distributors, implementing quality systems according to ISO 13485, undergoing regulatory audits, and preparing required documentation for premarket review. The process varies depending on the risk class of the device and whether the applicant is a manufacturer, distributor or importer.
The document summarizes FDA regulation of medical devices in the United States. It discusses that many medical devices must undergo premarket review by the FDA to be legally marketed. Devices are classified based on risk, and moderate and high-risk devices must receive FDA clearance or approval prior to marketing, usually via the 510(k) or premarket approval (PMA) processes. Concerns have been raised about FDA's device review processes and oversight of marketed devices based on reports of device problems causing injuries.
Decentralized clinical trials (DCTs) allow patients to participate remotely with data captured using advanced equipment instead of visiting sites often. India can contribute significantly to DCTs by developing analytical tools to update clinical teams, training monitors remotely, managing documentation and helplines from India, and customizing roles like data access and quality control reviewers. DCTs have the potential to transform healthcare by improving access to trials, providing more comprehensive patient data to researchers, and opening up new areas for disease prevention and treatment evaluation using large datasets.
In pharmacovigilance, cases or reports of adverse drug reactions (ADRs) and other drug-related problems can originate from various sources. Here are the primary sources of cases in pharmacovigilance
The document discusses medical device regulations from various agencies like the FDA and EU, which classify devices based on risk into Classes I to III. It also covers quality management systems like ISO 13485 that are important for product development and design controls. The key elements of design control as required by regulatory agencies are also summarized, including design planning, input, output, review, verification, and validation.
Telemedicine shows promise for improving emergency response during trauma, disasters and other chaotic situations. It allows remote experts to assist on-site healthcare providers in real-time. Studies have demonstrated its safety and cost-effectiveness. However, telemedicine is still vastly underutilized for these situations due to lack of infrastructure, policies, protocols and standards. Ongoing work is being done to establish these frameworks and continue demonstrating telemedicine's ability to save lives in extreme conditions around the world. With further development, telemedicine could transform emergency response for both rural and disaster settings.
This document provides an overview of the key aspects of the Medical Device Directive 93/42/EEC as amended by 2007/42/EC. It defines important terms like medical device, manufacturer, intended purpose and conformity assessment routes. It describes the classification of devices based on duration of contact and degree of invasiveness. It outlines the conformity assessment procedures under Annexes II, III, IV, V and VI and notes when they are applicable based on device class. Guidance documents from the EU Commission are also referenced.
COMMON REGULATORY AFFAIRS JOB INTERVIEW QUESTIONS WITH ANSWERS-Updated in 2022!Pristyn Research Solutions
This document provides a summary of common regulatory affairs job interview questions and answers. It begins with defining regulatory affairs and its goals of protecting human health, ensuring drug safety and efficacy, and ensuring accurate product information. It then discusses the roles of regulatory affairs professionals in interacting with regulatory agencies, preparing submissions, and ensuring compliance. The rest of the document provides answers to common interview questions about regulatory submissions, guidelines, authorities, and key concepts and legislation related to drug approval.
GHTF group 1 is about pre market evaluation .This ppt includes brief about the group 1 , about ghtf , what it includes , study groups , definitions , classification and its rules
The document discusses the FDA's regulatory pathways for medical devices. The FDA uses a risk-based classification system to categorize devices as Class I, II, or III based on risk, with Class III devices posing the highest risk. Class I devices face the fewest regulatory requirements while Class III devices require a rigorous premarket approval process. The key pathways are 510(k) clearance for Class II devices and premarket approval (PMA) for Class III devices. The FDA aims to evaluate devices throughout their lifecycle from premarket through postmarket surveillance to ensure safety and effectiveness.
FDA classify Medical Devices and how to report device problems A Systematic R...Pubrica
The typical time it takes to get a device to market is 3 to 7 years, compared to 12 years for pharmaceuticals. However, there are concerns that the Food and Drug Administration's Systematic Review Writing methods may not be adequate to satisfy the required guarantees of safety and efficacy.
Learn More : https://pubrica.com/services/research-services/systematic-review/
Reference: https://bit.ly/3xNHUsC
Why Pubrica:
When you order our services, we promise you the following – Plagiarism free | always on Time | 24*7 customer support | Written to international Standard | Unlimited Revisions support | Medical writing Expert | Publication Support | Bio statistical experts | High-quality Subject Matter Experts.
Contact us:
Web: https://pubrica.com/
Blog: https://pubrica.com/academy/
Email: sales@pubrica.com
WhatsApp : +91 9884350006
United Kingdom: +44-1618186353
FDA classify Medical Devices and how to report device problems A Systematic R...Pubrica
The typical time it takes to get a device to market is 3 to 7 years, compared to 12 years for pharmaceuticals. However, there are concerns that the Food and Drug Administration's Systematic Review Writing methods may not be adequate to satisfy the required guarantees of safety and efficacy.
Learn More : https://pubrica.com/services/research-services/systematic-review/
Reference: https://bit.ly/3xNHUsC
Why Pubrica:
When you order our services, we promise you the following – Plagiarism free | always on Time | 24*7 customer support | Written to international Standard | Unlimited Revisions support | Medical writing Expert | Publication Support | Bio statistical experts | High-quality Subject Matter Experts.
Contact us:
Web: https://pubrica.com/
Blog: https://pubrica.com/academy/
Email: sales@pubrica.com
WhatsApp : +91 9884350006
United Kingdom: +44-1618186353
“CFDA Registration – Market Access Before Investment” delivered by Tim Lin, T...ulmedical
Due to a large population, increasing middle class and government plans to build tens of thousands of hospitals, there is a lot of demand for high quality medical devices in China. For many foreign medical device manufacturers, the regulatory barriers are still significant obstacles.
The medical device regulation in China is less harmonized and generally unique from other major markets. The primary challenges tend to be: actual testing, drafting standards, language barriers and license parking. These additional requirements create a delay in the registration process.
Foreign manufacturers need to specifically understand the Chinese medical device regulation in advance, and then are able to determine appropriate strategies aimed at successful China market entry.
This is the content for a live webinar, "CFDA Registration, Market Access before Investment...Solving the CFDA Challenge" delivered by UL's Tim Lin. Tim is the Senior Technical Consultant working in the Greater China Region. He majored in public health and medical device engineering, and worked as a reviewer in the Taiwan FDA for high and moderate-risk medical device and clinical trial protocol for over 5 years; and also drafted guidance for industry. He is now responsible for risk management file, usability engineering, software validation and CE MDD technical documentation.
Clinical evaluation report cer in a more stringent regulatory- Pepgra HealthcarePEPGRA Healthcare
European regulatory framework has established rules that govern the development, manufacturing, and marketing of medical devices in the European market. Both European and non-European medical device manufacturer’s fall under the purview of the regulatory framework, which is established to
provide condence to the clinicians and the patients that the medical devices and the implantable devices used in the region have been validated for their potential benets and certied as safe for usage.
This document defines combination products and medical devices and discusses their classification and regulatory requirements. Combination products involve two or more regulated products combined in a single package. Medical devices are instruments or articles used for diagnosis, prevention, monitoring or treatment of disease. The document outlines the classification of medical devices into Classes I-III based on risk and the regulatory pathways of 510(k), reclassification, product development protocol, de novo review, and premarket approval.
The use of low quality in vitro diagnostics (IVDs) in resource poor countries poses serious risks. While standards for IVD registration exist in developed nations, many developing countries lack regulatory processes and infrastructure to ensure IVD quality. As a result, substandard diagnostic kits are often marketed and used without formal evaluation, adversely impacting patient care and public health. There is a need for comprehensive regulatory frameworks in developing nations, similar to those governing pharmaceuticals, to increase access to good quality diagnostics through guidelines for IVD standards, testing, and enforcement against non-compliant products. Establishing effective regulatory oversight can help address this important issue, just as the mice in Aesop's fable eventually solved their "cat
The document provides guidance for regulatory audits of medical device manufacturers' quality management systems. It discusses the Global Harmonization Task Force (GHTF), which aimed to harmonize medical device regulations internationally. GHTF established 5 study groups, including Study Group 4 which focused on auditing strategies and developed guidance documents. The guidance covers establishing auditing procedures, auditor competencies, and conducting and documenting audits in a harmonized manner. It provides a framework for consistent regulatory audits of medical device quality systems across countries.
Complying with Wearable Health Device RegulationTGA Australia
The document discusses regulations for wearable health devices in Australia. It provides an overview of the Therapeutic Goods Administration (TGA), which regulates medical devices to ensure safety, quality and performance. The TGA evaluates devices before and after market access. It also outlines what classifies a device as medical and subject to regulation, and the process for including a device on the Australian Register of Therapeutic Goods (ARTG). Higher risk devices receive more scrutiny. Manufacturers must comply with essential principles for design and safety, and report any issues with devices.
The document provides an overview of clinical trials for medical devices. It discusses definitions of medical devices according to FDA and Indian regulations, and classification of devices into classes based on risk level. The key phases of medical device clinical trials are pilot/feasibility studies and pivotal/confirmatory studies. Other topics covered include premarket notification (510k), investigational device exemption (IDE), premarket approval (PMA), differences between device and drug trials, and the global and Indian medical device markets.
This document provides an overview of biomedical instrumentation and the medical device regulatory process. It discusses how biomedical instrumentation systems work by measuring physiological parameters, conditioning signals, and displaying outputs. It also describes the classification of medical devices based on risk, and the FDA approval pathways of 510(k) clearance for lower-risk devices and premarket approval (PMA) for higher-risk Class III devices. PMA requires clinical evidence that devices are safe and effective.
Safety monitoring and reporting of adverse events of medical devices national...Vivek Nayak
This document outlines safety monitoring and adverse event reporting for medical devices from national and international perspectives. It defines medical devices and their classification system. Approval processes in India are discussed, along with the Materiovigilance Program of India for post-marketing surveillance. Adverse events must be reported within defined timeframes. International regulatory bodies like the FDA and MHRA also have mandatory reporting requirements. The limitations of current monitoring and reporting are noted.
Decision No. 2426/QD-BYT : Issue together with this Decision the ASEAN Common Submission Dossier Template (CSDT) for medical devices, applied to applications for registration of medical devices of class B, C, D.
Presentation: Software as a Medical Device: Regulatory insights and Q & ATGA Australia
The document provides an overview of the Therapeutic Goods Administration (TGA) in Australia, which regulates medical devices and software. It discusses:
- The TGA evaluates medical devices before and after market to ensure safety, quality and performance.
- Medical devices are classified based on risk from Class I to III, with Class III requiring the most oversight and pre-market evaluation.
- All medical devices must comply with the Essential Principles which address design, safety and intended use. Higher risk devices require more regulatory procedures.
- Software can be regulated as a medical device (Software as a Medical Device or SaMD) if it meets the definition and new rules are being proposed for SaMD in Australia
The FDA’s Breakthrough Devices Program is for certain medical devices that provide treatment or diagnosis of life-threatening or irreversibly debilitating diseases or conditions.1 This particular pathway is reserved for devices with unique and other-wise unavailable treatments to serious conditions, but what about devices associated with conditions less serious than those eligible for the Breakthrough Devices Program? The answer to this question is the FDA’s Safer Technologies Program or STeP.
STeP is targeted at medical devices that treat or diagnose conditions that are milder than what is eligible for the Breakthrough Devices Program, and even includes conditions that are non-life-threatening or reasonably reversible.2 There are two eligibility factors for STeP...
A Survey on Current Applications for Tracking COVID-19EMMAIntl
The document summarizes current applications for tracking COVID-19 around the world and discusses regulatory requirements for such applications. It outlines several prominent COVID-19 tracking tools used by countries like Australia, China, India, UK, Germany and USA. It also discusses the FDA regulatory process for medical devices and software-as-a-medical device (SaMD), including requirements for registration, clinical testing, labeling, quality management and reporting issues. The document emphasizes that COVID-19 tracking applications must comply with FDA regulations to be legally marketed in the US.
Device registration and listing of medical devices on the US marketttopstart B.V.
We provide an overview of the regulations and legislations with regard to commercialisation of medical devices in the US. The product category of medical devices ranges from class I devices up to class III devices. In the US, market approval is granted by the FDA (Food and Drug Administration) upon assessment of quality, safety and effectiveness.
The information provided here informs start-ups, spin-offs and biotech companies about the differences in regulatory procedures for specific classes of medical devices. By summarising the procedures for each class of medical device, we, ttopstart, aim to offer a guide through this dense regulative and legislative landscape. These insights can be used to design the optimal market introduction strategy for your medical device.
Devices Sponsor Information Day: 0 - Developments in medical device regulationTGA Australia
Presentations by TGA and Industry (combined) to help sponsors and manufacturers better understand the regulation of medical devices and in-vitro diagnostic medical devices
Presentation: Proposed Reforms to the Regulation of Software, Including Softw...TGA Australia
The document summarizes the results of a consultation on proposed reforms to the regulation of software as a medical device in Australia. It discusses key points from international approaches to classifying and regulating software, proposed new classification rules and essential principles for software in Australia, and the results of the consultation which found general agreement with the proposals among respondents.
6 medical device registration in singaporeandaman2015
The document discusses medical device registration requirements in Singapore. The Health Sciences Authority (HSA) regulates medical devices and requires all devices to be registered prior to placement on the Singapore market, except for some low-risk Class A devices. Medical device dealers must be registered with the Accounting and Corporate Regulatory Authority (ACRA). Devices are classified from Class A to D based on risk, with higher classes facing more stringent registration requirements including longer processing times and higher fees.
Similar to Academic Report on Singapore HSA Class D and Australia TGA Class III Medical Device Regulatory Overview & Strategy (20)
Academic Report on Singapore HSA Class D and Australia TGA Class III Medical Device Regulatory Overview & Strategy
1. Academic Report on
Singapore HSA Class D and Australia TGA Class III Medical Device Regulatory Overview & Strategy
Introduction
This chapter is a modified literature review on the overview of Australia Therapeutic Goods Administration (TGA) and Singapore
Health Sciences Authority (HSA) with their respective medical device regulatory route and requirements pertaining to the product
known as Vivace VX-1 a Transcatheter Mitral Valve Implantation (TMVI).
Background
Due to the fact that both TGA and HAS developed, published and update their medical devices guidance documents that are
available to the public for general applicability to interpret and plan according to the agency’s rules and regulations. This chapter
relies heavily on the extracted information (a part or a whole portion) obtained from the respective guidance documents and reports
for comparison purpose. All the source and referencing are available in the footnote. This format of presentation was chosen
because the author is using the actual, updated and transferrable regulatory information to discuss and try to put into practice in the
‘real’ workplace. The author (Edwin) is hoping to build up similar comparison review so as to benefits the various small and
medium enterprise in the medtech industry in Singapore and Australia lacking of full-time medical device regulatory staffs to
navigate the regulatory map and to made better regulatory decisions.
Product Assessment on Vivace VX-1
The Vivace VX-1 is a Transcatheter Mitral Valve Implantation (TMVI) that involves minimally invasive procedure treatment.
Currently MitraClip is another medical device that serves similar intended purpose and is being supplied in both Australia and
Singapore. With the acceptance of MitraClip in both countries, Vivace VX-1 will be register in Australia first and after gaining TGA
issued conformity assessment certification, the market access to European and obtain CE certification can be faster. Even though
after the US FDA and Australia TGA approval status of Vivace VX-1 registration, the Vivace VX-1 is not exempted for product
registration in Singapore. The regulatory reason to register in Singapore is because the medical device approval by either one of the
reference agencies (US FDA or Australia TGA), may qualify for abridged evaluation which is a quicker route of assessment with
lower registration fees and charges.
The registration documents are required by Singapore HSA to be structured and submitted with the Common Submission Dossier
Template (CSDT) which is also adopted by the various South-East Asia (SEA) countries and therefore the successful registration of
Vivace VX-1 in Singapore may path the way into South East Asia (SEA) markets.
Potential Use
The Vivace VX-1 TMVI is targeted to benefit patients with moderate to severe mitral regurgitation without undergoing open heart
surgery. The Vivace VX-1 aims to further serve patients who were previously denied of surgery. In Singapore, National University
Hospital (2016) reported with the introduction of procedure treatment by Vivace VX-1, a majority of old age and multiple co-
morbidities patients will now have another options for palliative treatment.
Target Population
In Singapore, National Heart Centre Singapore (2011) estimated 12 per cent of patients over the age of 75 will be affected in the
coming years and 50 patients every year will be expected to receive the procedure treatment based on MitraClip procedure in. In
Australia, Medical Services Advisory Committee Australia (2012) estimated 2,127 patients every year based on the figure populated
from MitraClip procedure.
Do Vivace VX-1 Qualifies As A Medical Device ?
To better understand whether Vivace VX-1 qualifies as a medical device. There is a need to find out the qualified answer from the
respective country’s Competent Authorities and their enacted legislation act that are regulating the medical devices industry.
In Australia, the Therapeutic Goods Administration (TGA) Medical Devices Branch is part of the Australian Government
Department of Health and is responsible for regulating therapeutic goods including medical devices. TGA basics (No Date) The
Health Sciences Authority (HSA) Medical Device Branch is entrusted with the responsibility of regulating medical device products
placed on the Singapore market. HSA (2015
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 1
2. As reported by TGA Regulation impact statement (2013) and HSA Regulatory Framework (2015), the current regulatory framework
for both Australia TGA and Singapore HSA are based on the model endorsed by the Global Harmonisation Task Force (GHTF) now
known as International Medical Device Regulators Forum (IMDRF).
As a result, both of the countries issued their legislation act incorporating similar definition of a medical device, namely:
a medical device is any instrument, apparatus, appliance, material or other article (whether used alone or in combination, and
including the software necessary for its proper application) intended, by the person under whose name it is or is to be supplied, to be
used for human beings for the purpose of one or more of the following:
a) diagnosis, prevention, monitoring, treatment or alleviation of disease;
b) diagnosis, monitoring, treatment, alleviation of or compensation for an injury or handicap;
c) investigation, replacement or modification of the anatomy or of a physiological process;
d) control of conception;
and that does not achieve its principal intended action in or on the human body by pharmacological, immunological or metabolic
means, but that may be assisted in its function by such means; or an accessory to such an instrument, apparatus, appliance, material
or other article. Therapeutic Goods Act Section 41BD (1989)
In Singapore, Health Products Act Chapter 122D (2007) modified and included the following two points to suit the Singapore
context:
a) disinfection of medical devices;
b) providing information for medical or diagnostic purposes by means of in vitro examination of specimens derived from the
human body,
In conclusion, the Vivace VX-1 qualifies as a medical device and fall within the definition of being used on humans and for the
purpose of treatment of disease known as mitral valve disease and degenerative diseases.
Medical Device Risk Classification
Both Australia TGA and Singapore HSA apply risk-based classification rules to determine the risk classes.
According to HSA Regulatory Framework (2015), there are four risk classes and risk level, namely, Class A for Low Risk, Class B
for Low-moderate Risk, Class C for Moderate-high Risk and Class D for High Risk medical devices. The classification of a medical
device will depend upon a series of factors, including:
a) How long the device is intended to be in use;
b) Whether the device is invasive;
c) Whether the device is implantable;
d) Whether the device is active;
e) Whether the device contains a drug or biologic component
According to the Australian regulatory guidelines for medical devices TGA ARGMD Part 1 (2011), the classification levels are
Class I for Low Risk, Class IIa for Low-medium Risk, Class IIb for Medium-high risk and Class III for High Risk medical devices.
The manufacturer is responsible for determining the classification of a device using a set of classification rules based on:
a) Manufacturer’s intended use of the device;
b) Level of risk to patients, users and other persons (the probability of occurrence of harm and the severity of that harm)
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 2
3. c) Degree of invasiveness in the human body
d) Duration of use
How Vivace VX-1 Will Be Classified
As both Australia TGA and Singapore HSA classification rules are adopted from the guidance developed by the Global
Harmonization Task Force. The assessment and classification of the risk class of Vivace VX-1 will be based on their respective set
of rules in their published regulatory guidelines. The Australia TGA issued Australian regulatory guidelines for medical devices
TGA ARGMD Part 1 (2011) and Singapore HSA published the guidance document on the Risk Classification of General Medical
Devices. (HSA GN-13 2014)
There will be more than one rule that apply as the intended purpose and features of Vivace VX-1 includes implantable, surgically
invasive, long-term use, for more than 30 days, with direct contact with the heart and contains non-viable animal tissues.
For Singapore, the classification rules that apply under the HSA GN-13 (2014) are as follow:
a) Rule 8: All implantable devices, and long-term surgically invasive devices intended to be used in direct contact with the
heart.
b) Rule 14: All devices manufactured from or incorporating animal tissues and rendered non viable are Class D.
c) The Singapore HSA allows self-assessment with their Online Medical Devices Risk Classification Tool (2016) and after 3
online questions the result computed Rule 14 Class D which is an easier option than to go through the guidance documents.
For Australia, the classification rules that apply under the TGA ARGMD Part 1 (2011) are as follow:
a) Rule 3.4(4)(a) A surgically invasive device for long-term use to be used in direct contact with the heart, the central
circulatory system or the central nervous system is Class III.
b) Rule 5.5(1)(a) Devices that contain animal tissues or derivatives that have been rendered non-viable are Class III.
In conclusion, when there may be more than one rule, the highest classification will apply. In the case of Vivace VX-1, all the rules
pointed toward the highest spectrum. Therefore, the allocated risk classification will be Class D and Class III for Singapore and
Australia respectively.
Risk assessment: What Is Required In A Risk Management Plan
For risk assessment, the Singapore guidance document HSA GN-17 (2014) Guidance on Preparation of a Product Registration
Submission for General Medical Devices using the ASEAN CSDT stipulated the following information to be submitted:
a) Compulsory submission of a risk management report with the risk management activities conducted according to ISO
14971. A risk management report will contain details of the risk analysis, risk evaluation, risk control conducted for the medical
device. The risks and benefits associated with the use of the medical device should be described.
b) This risk analysis should be based upon international or other recognized standards, and are appropriate to the complexity
and risk class of the device.
c) A list of possible hazards for these devices must be prepared.
d) Indirect risks from device-associated hazards, such as evaluation of these risks against the claimed benefits of the device
and the method(s) used to reduce risk to acceptable levels must be described.
e) The technique used to analyze risk must be specified, to ensure that it is appropriate for the medical device and the risk
involved.
In Australia, the TGA have the TGA ACSMD (2016) Advisory Committee on the Safety of Medical Devices to seek further advise
on the safety, risk assessment, risk management and performance of medical devices being supplied.
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 3
4. TGA ARGMD Part 1 (2011) stated that the Risk Management report have to follow the format of ISO14971 so as to comply with
Essential Principles, Schedule 1 of the Regulations and section 3 of the Essential Principles with the following information for
submission:
a) Risk Management Report to include the Essential Principles that would require a manufacturer to conduct a risk analysis to
evaluate the known and foreseeable risks of using a device and ensuring that any undesirable side-effects are minimized and
acceptable, when weighed against the benefits of the intended performance of the device
In conclusion, both Australia TGA and Singapore HSA accept the risk management process as defined in ISO 14971 with the
overarching principle of applying the concept of risk-based approach to regulation and risk management to ensure that the level of
regulation is proportional to the degree of risk involved and the benefits offered in using a medical device.
Labelling Requirements- Identification Of Device Labeling
In Australia, the use of Global Medical Device Nomenclature (GMDN) term and code as the device identification is required by the
manufacturer as part of the conformity assessment procedures stated in TGA ARGMD Part 1 (2011). The GMDN structures consist
of a single five-digit code, device category, template and preferred terms and device name. The five-digit code will have to be stated
on labelling of Vivace VX-1.
The reasons for selecting and adhering the appropriate GMDN term and code are as follow:
a) Used by TGA to describe medical devices;
b) Assist in consistent assessment of devices before they are approved for supply;
c) Assist in ongoing monitoring of devices once they are available for supply
To obtain the correct GMDN term and code for Vivace VX-1.There is a need to join as a paying member and subscribe to the
GMDN agency to access the database or even pay for creating a new term and code. For a company with annual medical device
sales of less than 0.5 Euro million, the membership fee is 200 Euro with subsequent annual fee at 100 Euro GMDN Agency (No
date).
In Singapore, the GMDN term and code is not mandatory for medical device product registration. However it is an added-values to
Singapore HSA to include any given GMDN code or the Unique Device Identification (UDI) during reporting of adverse event.
Labeling Requirements- Translation Requirements
In Australia, under the Therapeutic Goods Order No. 37 (1991) the general labelling requirements have to be fulfilled in English
language. This is aligning to Singapore HSA GN-23 (2014) labeling requirement for medical devices that product labeling and such
must be in English.
In conclusion, the English language labeling requirements will apply across the board for Australia TGA and Singapore HSA
labeling and label definitions, in which the HSA GN-21 (2015) Guidance on Change Notification for Registered Medical Devices
defines label as:
a) Label (as set out in the Health Product Act): in relation to a health product or an active ingredient, means any written,
printed or graphic representation that appears on or is attached to the health product or active ingredient or any part of its packaging,
and includes any informational sheet or leaflet that accompanies the health product or active ingredient when it is being supplied.
In the same context, the Therapeutic Goods Order No. 37 (1991) defines label as:
a) Label is a display of printed information provided on or attached to a therapeutic device;
b) if the therapeutic device is within one of more levels of packaging, that level of packaging or any of those levels of
packaging; or
c) Information that is sealed within a package, but does not include a label which is intended to be returned by the consumer
to the supplier or manufacturer as a record of purchase.
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 4
5. Registration Requirements- In-Country Representation
In Australia, medical device must be registered and included on the Australian Register of Therapeutic Goods (ARTG) before they
can be sold. A sponsor is responsible for applying to the TGA to have their therapeutic good included on the (ARTG). TGA Role of
the sponsor (2015)
The definition of a sponsor in relation to medical devices as stated by the Therapeutic Goods Act 1989 (2016) are as follow:
a) a person who exports, or arranges the exportation of, the goods from Australia; or
b) a person who imports, or arranges the importation of, the goods into Australia; or
c) a person who, in Australia, manufactures the goods, or arranges for another person t manufacture the goods, for supply
(whether in Australia or elsewhere);
but does not include a person who:
d) exports, imports or manufactures the goods; or
e) arranges the exportation, importation or manufacture of the goods;
on behalf of another person who, at the time of the exportation, importation, manufacture or arrangements, is a resident of, or is
carrying on business in, Australia.
In Singapore, higher risk medical devices must be registered and included on the Singapore Medical Device Register (SMDR). A
Registrant is responsible to register higher risk medical devices by applying for marketing clearance with HSA before placing such
device products on the Singapore market. HSA Product Registration (2014)
The definition of a Registrant as stated in HSA GN-24 (2014) are as follow:
a) A Registrant, in relation to a registered medical device, is the person who applied for and obtained the registration of the
medical device under the Health Products Act (Act);
b) A Registrant do not have to be licensed under the Act, however the registrant is required to register with HSA to facilitate
product registration applications in Medical Device Information Communication System (MEDICS) e-Services.
In Singapore, based on HSA GN-02 (2011), Product Owner means a person who sells a medical device under his own name, or
under any trade-mark, design, trade name or other name and who is responsible for designing and manufacturing, there are licensing
to be applied based on the activity performed by that person in relation to medical devices. The three type of licensees are as follow:
a) Manufacturer’s license- any person who manufactures medical device in Singapore;
b) Importer’s license- any person who imports medical device into Singapore;
c) Wholesaler’s license- any person who supplies medical devices by wholesale (which include export) in Singapore.
Registration Requirements- Documentation required for submission of a device registration application
In Australia, TGA ARGMD Part 1 (2011) pointed out that the appropriate conformity assessment procedures to register Vivace VX-
1 is the Part 1 (Full Quality Assurance Procedures) with Clause 1.6 (Examination of Design) with the Declaration of Conformity
legislative reference as Schedule 3, Part 1 clause 1.8. For Manufacturing medical devices overseas for import into the Australian
market. The overseas medical device manufacturers are required to obtain a TGA Conformity Assessment Certificate before the
medical device can be included on the ARTG, and therefore be supplied into the Australian market. TGA Manufacturing medical
devices (2016)
The summary as stated by TGA ARGMD Part 1 (2011) are as follow:
a) Part 1, Full quality assurance procedure encompasses design, production, packaging, labelling, and final inspection of a
medical device;
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 5
6. b) Manufacturer must implement a full quality management system (that is, all clauses of ISO 13485 including clauses 7.3
and 7.5.2) and arrange for the quality management system to be audited by the
TGA or EU Notified Body. The TGA or EU Notified Body also assesses the manufacturer’s technical documentation for the
medical devices, including clinical evidence.
c) This conformity assessment procedure can be applied to all devices that they manufacturer.
d) Part 1, Clause 1.6, Examination of Design Involves an examination of the design dossier for medical devices to which the
manufacturer has applied a Part 1 conformity assessment procedure.
e) The technical documentation for the Class III and AIMD device (also referred to as a design dossier) must be submitted for
examination to assess the compliance of the device with the Essential Principles.
f) This must be done in conjunction with Part 1 assessment of the quality management system; by either the TGA or the same
EU Notified Body.
The requirements as stated by TGA ARGMD Part 1 (2011) are as follow:
a) A manufacturer applies this procedure to Classes AIMD, Class III, Class IIb, or Class IIa medical devices by implementing
a full quality management system that takes into account the regulatory requirements for the: design, production, packaging,
labelling, final inspection processes and implementation of an ongoing monitoring system.
b) A certificate will be issued by the TGA or an EU Notified Body if the quality management system is satisfactory. The
certification will declare that the quality system conforms to the requirements of: Part 1 of the TGA regulatory requirements or
Annex II section 3 of the EU Medical Device Directive (MDD) 93/42/EEC or Annex 2 section 3 of the EU Active Implantable
Medical Devices Directive 90/385/EEC (AIMDD).
c) The assessment is against the requirements of the Australian legislation or the EU Directive. The assessment will include
audit of the quality management system (all clauses of ISO 13485 or equivalent standard) and an assessment of the manufacturer’s
technical documentation for the devices, including clinical evidence. The conformity assessment certification remains valid only if it
is subject to periodic and satisfactory surveillance audits. Changes to the quality system that broaden the scope of the quality system
or substantially alter the approved system, design or production arrangements may require further assessment or approval by the
conformity assessment body. Once a manufacturer has obtained conformity assessment evidence under this Part they must then
prepare an Australian Declaration of Conformity in accordance with clause 1.8 of Schedule 3 of the Regulations.
In Singapore, HSA-GN-15 (2014) documented that Vivace VX-1 (after fulfilling some criteria) are eligible for either the Abridged
Evaluation Route or the Full Evaluation Route. The Guidance documents applicable to the product registration documentation
requirement are as follow:
a) GN-17: Guidance on Preparation of a Product Registration Submission for General Medical Devices using the ASEAN
CSDT Common Submission Dossier Template
b) GN-18: Guidance on Preparation of a Product Registration Submission for In Vitro Diagnostic (IVD) Medical Devices
using the ASEAN CSDT
c) Annex 2 for GN-17 and GN-18 List of Configurations of Medical Devices to be Registered
d) GN-16: Essential Principles Checklist Template
e) GN-15: Letter of Authorisation Template
f) GN-20: Guidance on Clinical Evaluation (if applicable)
The requirements for the 2 different route are stated below:
Abridged Evaluation Route:
a) Eligibility Criteria- A medical device that has obtained at least one reference regulatory agency approval for a labelled use
identical to that intended for marketing in Singapore at the time of submission will qualify for the abridged evaluation route.
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 6
7. b) Submission Requirements for Abridged Evaluation Route: Letter of Authorisation, Annex 2 for GN-17 and GN-18: List of
configurations of medical devices to be registered, Proof of approval by reference regulatory agency, Common Submission Dossier
Template (CSDT).
c) Common Submission Dossier Template (CSDT) with the following requirements:
a) Executive Summary
b) Essential Principles Checklist and Declaration of Conformity (Refer to GN-11 for the Declaration of Conformity template)
c) Device Description
d) Summary of Design Verification and Validation Documents
− Summary of Preclinical Studies including the sterilization validation and shelf life studies, if applicable- Clinical Evidence –
Clinical Evaluation Report
e) Proposed Device Labelling
f) Risk Analysis
g) Manufacturer Information− Name and address of the manufacturing site(s)− Proof of Quality Management System – Eg:
ISO13485 Certificate, Conformity to US FDA Quality System. Regulations or Japan MHLW Ordinance 169− Manufacturing
Process – Flow Chart
Full Evaluation Routes:
a) Eligibility Criteria- A medical device that has not obtained any prior approval from any of HSA’s reference regulatory
agencies at the point of application will be subject to the full evaluation route.
b) Submission Requirements for Full Evaluation Routes: Letter of Authorisation, Annex 2 for GN-17 and GN-18: List of
configurations of medical devices to be registered.
c) Common Submission Dossier Template (CSDT) with the following requirements:
a) Executive Summary
b) Essential Principles Checklist and Declaration of Conformity (Refer to GN-11 for the Declaration of Conformity template)
c) Device Description
d) Detailed Information of Design Verification and Validation Documents − Full reports of Preclinical Studies including the
detailed sterilisation validation and shelf life studies if applicable − Clinical Evidence – Clinical Evaluation Report including
publications and full reports of the studies referenced in the clinical evaluation report
e) Proposed Device Labelling
f) Risk Analysis
g) Manufacturer Information − Name and address of the manufacturing site(s) − Proof of Quality Management System – e.g.
ISO13485 Certificate, Conformity to US FDA Quality System Regulations or Japan MHLW Ordinance 169 − Manufacturing
Process – Flow Chart
Registration Requirements- Submission Platform
In Australia, TGA Business services (2015) stated that Sponsors have to use the online services to complete the registration
applications. The Sponsors need to apply a client identification number (Client ID) and also apply to access to the online TGA:
electronic Business Services (eBS) system. Beside managing therapeutic good registration applications, the Client ID and access to
eBS system are required for the following activities:
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 7
8. a) Supply in Australia
b) Manufacture
c) Import into Australia
d) Export from Australia
e) Submit clinical trial notifications (CTNs)
f) Notify about adverse events or recalls.
g) View and cancel current Australian Register of Therapeutic Goods (ARTG) entries
h) Generate certificates online.
In Singapore, MEDICS e-Services can be created and login either with a SingPass or HSA PIN, a CRIS company account and a
Registrant's Account. According to MEDICS e-Services (2015) the Medics allow the following transactions:
a) Dealer's Licence & Registrant's Account
b) Product registration
c) Export-Only Unregistered Medical Devices
d) Certificates
e) Withdrawal
f) Amendment for Dealer's license / Submission of update of Class A Medical Device Exemption List
g) Amendment for Registrant's account
h) Cancellation
i) Change Notification for Registered Devices
j) Change of Business Information
k) Renewal of dealer's licence
l) Retention of SMDR device listing
m) Global Update of Applicant Details
n) Assignment of Importer Wholesaler Ship and Management of View Access to Importer and Wholesaler
Costs: Fees and Charges Associated With Initial Regulatory Compliance
In Australia, the TGA operates on a 100% cost-recovery basis and collects its revenue primarily through annual charges, and
application, evaluation, audit, conformity assessment, application audit and assessment fees. Fees are charged for applications,
assessments, and audits for new medical devices. Fees are also payable when there are changes that the TGA needs to assess. TGA
ARGMD Part1 (2011)
TGA Fees and charges (2016) reported the breakdown of the costs for Vivace VX-1 (Class III medical device) as follow:
a) Application fee- $1,265 AUD to include a medical device in the ARTG
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 8
9. b) Application audit assessment fees- $1,265 AUD for a medical device that is a prosthetic heart valve
c) Application audit assessment fees- $3,700 AUD for Level 1 - verification of sponsor's application and evidence of
conformity (for application based on a Europe certificate)
d) Application audit assessment fees- $6,790 AUD for Level 2 - Level 1 activities plus review of evidence of conformity (for
application based on a Europe certificate)
e) Medical device clinical trial- $345 AUD for Clinical trial notification (CTN)
f) Medical device clinical trial- $17,600 AUD for Clinical trial exemption (CTX) evaluation
g) Application fee for conformity assessment procedures- $900 AUD for all type of conformity assessment procedures
h) Initial assessment fee of conformity assessment- $28,600 AUD for Full quality management system inspection: Schedule 3,
Part 1
i) Initial assessment fee of conformity assessment- $56,300 AUD for Design examination: Schedule 3, Clause 1.6
j) Surveillance inspection fee- $8,320 for Full quality management system surveillance inspection: Schedule 3, Part 1
In Singapore, Importers and wholesalers of medical devices in Singapore are required to meet GDPMDS (Good Distribution
Practice for Medical Devices in Singapore) requirements, the objective of which is to ensure the quality and integrity of medical
devices throughout the distribution process. The GDPMDS certificate is issued by third party certification bodies accredited by the
Singapore Accreditation Council, and is valid for three years with an annual site audit, in accordance with international ISO
practice. The cost of applying and maintaining the GDPMDS certification fees varies between third party certification. HSA About
GDPMDS certificate (2012)
The HSA Fees and Charges (2015) reported the Product Registration and Applicable Evaluation Fees for Vivace VX-1 (Class D
medical device) as follow:
a) Dealer's Licence Fees- $1,000 SGD for a new application for an Importer licence
b) Dealer's Licence Fees- $1,000 SGD for a new application for a Wholesaler licence
c) Application fee- $500 SGD payable for product registration
d) Evaluation fee- $5,700 SGD for Abridged Evaluation Route
or
e) Evaluation fee- $11,400 SGD for Full Evaluation Route
Costs: Fees and Charges Associated With Ongoing Regulatory Compliance
TGA Fees and charges (2016) reported the breakdown of the ongoing costs for a Class III medical device as follow:
a) Application audit assessment fees- $6,790 AUD for Considering submissions to the Secretary in relation to a proposed
suspension of a kind of medical device from the ARTG.
b) Application audit assessment fees- $430 AUD for Variation to an ARTG inclusion entry if the entry is incomplete or
incorrect.
c) Miscellaneous- $430 AUD for Application for consent of Secretary to importation into Australia, supply for use in
Australia, or exportation from Australia of a medical device that does not conform to the essential principles
d) Changes Fee to conformity assessment- $17,200 AUD for Full quality management system inspection: Schedule 3, Part 1
e) Changes Fee to conformity assessment- $33,900 AUD for Design examination: Schedule 3, Clause 1.6
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 9
10. f) Review of certificate of conformity assessment fee- $50,900 AUD for Design examination re-assessment: Schedule 3,
Clause 1.6
g) Annual charges of $1,200 AUD are charged to the sponsor TGA for retention of product listing in the ARTG
In Singapore, applying a Registrant's account to register medical devices on behalf of product owners do not incur charges. For the
others fees and charges, HSA Fees and Charges (2015) and HSA Target Processing Timelines (2014) reported the breakdown of the
ongoing costs and the target turn-around-time [TAT] for a Class D medical device as follow:
a) Annual Retention Fees- $120 SGD for per Class D Medical Devices listed on SMDR
b) Dealer's Licence Fee- $1,000 SGD for annual renewal for an Importer licence
c) Dealer's Licence Fee- $1,000 SGD for annual renewal for a Wholesaler licence
d) Licence amendment Fee- $150 SGD for any amendment to approved Importer licence
e) Licence amendment Fee- $150 SGD for any amendment to approved Wholesaler licence
f) Change Notification Fee- $0 (No fees applicable for Notification Changes) [TAT: Immediate]
g) Change Notification Fee- $500 SGD for Administrative Changes [TAT: 30 working days]
h) Change Notification Fee- $2,800 SGD for Technical Changes [TAT: 90 working days]
i) Change of Registrant Fees- $800 SGD for any changes of approved Registrant
Timelines Of Device Registration Process
In Australia, the TGA application instructions (2015) reported the industry-agreed time frames for assessments for conformity
assessment certification are target times only and are not legislated. While the TGA will attempt to meet target times, it may not
always be possible (e.g. when onsite inspections are required as part of a QMS certificate application assessment).
The TGA endeavours to meet industry-agreed time frames for assessments for conformity assessment certification. All time frames
are given in TGA working days and start from the date the e-Business application fee is received. A working day is any day other
than a weekend, a public holiday in the Australian Capital Territory, or when the TGA is waiting on information requested or
waiting for payment of fees.
The assessment timeframe with documentation that are of good quality, application that is well-structured, no omissions in the
submission, and that fees are paid promptly are as follow:
a) Target time frames of 90 working days for Full Quality Assurance System(QMS) certificates (for Part 1 only)
Additional of 60 working days if ACMD advice required
b) Target time frames 120 working days for Design Examination certificates (for part 1, Clause 1.6)
Additional of 60 working days if ACMD advice required
In Singapore, HSA Target Processing Timelines (2014) reported that HSA shall endeavour to meet the target processing timelines
for all submitted applications. Applicants should ensure that the dossiers are complete before submission. Incomplete submissions
and untimely responses to queries will result in unnecessary delays to the registration process and thus, will have a negative impact
on the target processing timeline . The target turn-around-time (TAT) for applications commences from the date of receipt of the
application and does not include ‘stop-clock time' due to input requests for clarifications and additional information. The
target turn-around-time (TAT) are as follow:
a) 310 Working Days for Class D Full Evaluation Route
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 10
11. b) 220 Working Days for Class D Abridged Evaluation Route (with One reference agency approval [USA FDA PMA or
Australia TGA]
c) The Vivace VX-1 is excluded from being registered via Expedited Class D Registration Evaluation Route because it is an
implantable device that is in direct contact with the central circulatory system (direct contact with the heart)
Post-market Requirements- Post-market Monitoring
In Australis, TGA have it own diligence check on the environmental scanning to collect and review of scientific and medical
literature, media reports and regulatory news to identify safety issues that require further investigation. TGA rely on primary source
of Information by Media, industry, governments, other countries regulatory bodies, academia and even consumers. In Singapore, the
HSA’s Vigilance and Compliance Branch conduct the various post-market surveillance related activities; Adverse event monitoring,
Risk assessment and management, Risk communication and regulatory research, Environmental scanning for potential issues
relating to health products’ safety, quality and efficacy, medical advertisement and compliance monitoring.
TGA ARGMD Part 3 (2011) reported that once a medical device has been included in the ARTG the device must continue to meet
all the regulatory, safety and performance requirements and standards that were required for the approval. For Post-market
monitoring, TGA mandated annual reporting of problems for Class III medical devices Sponsors have to provides three consecutive
annual reports to the TGA following inclusion of the device in the ARTG. The Annual reports are due on 1 October each year.
Reports should be for the period 1 July to 30 June. The annual report must include all complaints received by the manufacturer
relating to problems with the use of the device that have been received by them over the year. Complaints received by the
manufacturer relating to the use of the device, including its supply under a different name, in other countries where the device is
available must also be included.
In Singapore, there is no annual report of problem for Class D registered medical device. The HSA required Manufacturer/Product
owner and registrant to uses a number of post-marketing risk assessment approaches to ensure the continued safe use of medical
devices. These measures include reporting to healthcare professionals and the mandatory reporting of adverse events by
manufacturers and registrant is an important part of the post-market surveillance system.
For Singapore, the Post-market monitoring activities includes change notification on any technical/ review/ administrative change,
as defined in GN-21 Guidance on Change Notification, made to registered medical and have to require approval from the HSA prior
to supply of these medical devices. The manufacturer/ product owner shall assist the Health Sciences Authority with any request for
information on registered medical devices. The product owner shall provide post-market support and assistance to the registrant for
medical devices registered under this listing.
Post-market Requirements- Post-market Vigilance
For Post-market Vigilance activities TGA ARGMD Part 3 (2011) stated the following requirements, The purpose of medical device
vigilance is to improve the health and safety of patients, users, and others by reducing the likelihood of adverse events being
repeated. This can be achieved by:
a) Adverse event (AE) reporting- Reports regarding deficiencies in labelling, instructions or packaging, defective
components, performance failures, poor construction or design of medical devices marketed in Australia. Primary Source of
Information by Sponsors.
b) Adverse event reporting with Device Incident Report (DIR) using Incident Report Investigation Scheme (IRIS)
c) Safety Alert by sponsor voluntarily that is not considered to be a recall
d) Safety Advisory
e) Urgent Medical Device Recall for Product Correction-
• Involve temporary removal from the market or from use
• Permanent removal of deficient medical devices from the market or from use
f) Urgent Medical Device Recall
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 11
12. g) Pharmacovigilance audits- A medical device manufacturer's adverse event records are inspected as part of the Quality
Management System (QMS) assessment. Primary Source of Information by Manufacturers
h) Reporting on vigilance activities- TGA report on the monitoring and evaluation of information related to the safety and
efficacy of marketed therapeutic products through a variety of means. Information is shared with the public and with health
professionals through the Medicine Safety Updates (MSU) and through safety alerts published on HSA website. HSA have also
established mechanisms to alert the public to recalls of therapeutic products, to provide the public with adverse event data associated
with medicines and medical devices and to provide the public with an early warning communication system to advise of potential
safety issues for medicines and medical devices.
In Singapore, HSA-GN-05 (2013) reported that the mandatory reporting of Adverse Event AEs by medical device dealers is an
important part of the post-market vigilance system. The objective of AE reporting and others relevant activities are to improve
protection of the health and safety of patients, users and others by disseminating information that may reduce the likelihood of, or
prevent repetition of AEs. This can be achieved by:
a) Mandatory Reporting for Adverse event with reporting Form MDAR1 for reporting of adverse events not related to clinical
trial using the email, fax or postal mail submission to Compliance Branch Vigilance, Compliance and Enforcement Division.
b) Medical Device Alerts by HSA-The Medical Device Alert aims to increase the awareness of specific medical device safety
issues or events amongst healthcare professionals. The articles also serve to encourage medical device adverse event reporting,
which forms part of HSA’s post-market safety surveillance programme for medical devices. The alert is distributed to all physicians,
dentists and pharmacists.
c) Dear Healthcare Professional or Dear Doctor letter containing suggested actions, advisory note, recommended actions to be
taken to manage important new medical device issues such as new warnings, other safety information, or important changes to the
prescribing information (labelling). It is often issued to communicate risk to medical device users typically in response to an adverse
event or to provide additional information to enable safer and/or effective use of medical device to healthcare practitioners. HSA
GN-09 (2016)
d) Field Safety Notice (FSN) is used to communicate to device users in relation to a Field Safety Corrective Action (FSCA), it
includes the product identifier of affected units and a field for the consignee to acknowledge the understanding of the contents of the
FSN. HSA GN-10 (2016)
e) Medical Device Field Safety Corrective Action taken to reduce a risk of death or serious deterioration in the state of health
associated with the use of medical device, including the return of the medical device to its product owner, replacement or
destruction of the medical device, any action regarding the use of the medical device that is taken in accordance with the advice of
its product owner, the clinical management of any patient who has used the medical device, the modification of the medical device,
the retrofitting of the medical device in accordance with any modification to it or any change to its design by its product owner, the
making of any permanent or temporary change to the labelling or instructions for use of the medical device and any upgrade to any
software used with the medical device, including any such upgrade carried out by remote access. HSA GN-10 (2016)
f) Field Safety Corrective Action reporting with Form MDRR1 for Notification/Preliminary reporting of FSCAs that require
initiation in Singapore, with Form MDRR2 for Follow Up/Final reporting of FSCAs that require initiation in Singapore and Form
MDRR3 for reporting of medical device related post-market information. HSA GN-10 (2016)
g) Medical Device Recall notification with time frame of within 24 hours before carrying out any recall. The report required
are as follow: Preliminarily report have to be submitted containing as much of the recall detail within 24 hours from the
commencement of the recall and a final report is to be submitted to HSA within 21 days from the date of commencement of the
recall. HSA GN-02 (2015)
In conclusion, both TGA and HSA have developed agreements and documents to promote a harmonised approach to medical device
regulation around the world by modelling and customizing the various GHTF models. As a result, the timeframes for submitting
adverse event reports are similar:
a) 2 Days for serious public Health threat
b) Within 10 Days Of Becoming Aware Of A Death Or Serious Injury
c) Within 30 Days Of Becoming Aware Of An Event That Might Have Led To Serious Injury Or Death
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 12
13. Both TGA and HAS have emphasized and often shared regulatory information on implementation of Post-market surveillance
systems, adverse incident reporting programs and vigilance activities. Memorandum of Intention of Cooperation (2002). Therefore,
the best practise in methods and ways in fulfilling the Post-market requirements can be shared among TGA and HSA and to
localized to each country specific needs and then be transferred to the Manufacturer and Sponsor (TGA) and Product Owner and
Registrant (HSA) to implement them.
Insurance and Reimbursement
In Australia, according to HTA Medicare Benefits Schedule (2011) reported that where a medical device is considered for
reimbursement, the TGA approval process must be completed before the reimbursement decision is finalize. The listing, registration
or inclusion on the ARTG is generally a requirement for any medical device to enable it to be listed for reimbursement under an
Australian Government funding program known as the Medicare Benefits Schedule (MBS). During the review stage, the
Department of Health and Ageing will work with Medical Services Advisory Committee (MSAC) to undertake an assessment on
the medical devices for Medicare Benefits Schedule (MBS) listing and inclusion.
International Society for Pharmacoeconomics and Outcomes Research (ISPOR) (2016) reported that the Medical Services Advisory
Committee (MSAC) will also assist the Prostheses List Advisory Committee (PLAC) to manage the Australian Prostheses List (PL)
which comprises over 10,000 implantable devices eligible for reimbursement by private health funds. Whereas MSAC reviews and
determines the listed price of services provided in the delivery of tests or devices, the PLAC does not determine the reimbursement
benefit for the medical technology itself. Implantable medical devices are reviewed by the PLAC and a benefit is assigned for the
device itself. (Note: MSAC determines the fee for the clinician to implant the device).
TGA Administration of the Prostheses List (2016) reported that under Section 72-1 of the Private Health Insurance Act 2007 (the
PHI Act), private health insurers must pay at least the minimum benefit accorded to each prosthesis listed on the List:
a) for which an insured person has appropriate cover;
b) that are provided as part of an episode of hospital treatment or hospital-substitute treatment; and
c) for which a Medicare benefit is payable for the professional service associated with the provision of the prosthesis.
d) Medical device sponsors and suppliers apply to list prostheses on the Prostheses List so they will be reimbursed by private
health insurers. By doing so they gain access to the private health market. The activities involved in processing applications and
maintaining listings on the Prostheses List include:
TGA Administration of the Prostheses List (2016) stated that since 15 January 2009, the application fees have been $600 to apply to
list a new prosthesis, $200 to initially list a new prosthesis, and $200 each six months to maintain a listing.
Singapore is unlike Australia where there is no specific private health insurance/ Government reimbursement regarding Medical
Devices to be used by the end-customers. But Singapore Economic Development Board (2016) reported that Singapore Government
is providing universal coverage for Singaporeans with multiple layers of care.
ASEAN Briefing (2016) reported the Overview of Healthcare Plans in Singapore:
a) Medisave Medisave is a national medical savings scheme which lets individuals set aside part of their income into their
Medisave Accounts. Every employee can contribute eight to 10.5 percent of their monthly salary to cover future personal or
immediate family’s hospitalization, day surgery and certain outpatient expenses.
How much an employee can contribute depends on their age group. Savings can be withdrawn to pay the hospital bills of the
account holder and their immediate family members, in line with the financing framework.
b) MediShield Life- On November 1, 2015 MediShield was replaced was MediShield Life, which will offer the following: if a
patient is faced with a large hospital bill, the plan offers better protection and higher payouts, which will ease payment demands
(Medisave/cash) on patients Full coverage for all Singapore Citizens, including Permanent Residents, which covers aging citizens
and those with pre-existing conditions.
c) Lifelong protection- MediShield is administered by the Central Provident Fund (CPF) Board and is essentially a basic
healthcare plan. Additionally, it covers selected and expensive outpatient treatments, such as dialysis and chemotherapy.
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 13
14. d) Medifund- Medifund was set up by the Government as an endowment fund to help Singaporeans in need. It offers security
for patients who face large bills and financial difficulties in paying them after obtaining government subsidies, MediShield Life,
private Integrated Shield Plans, Medisave and cash.
e) Eldershield- The ElderShield plan was set up for people of old age and is an affordable severe disability insurance scheme
which provides basic financial protection to those who need long-term care. It takes the form of a monthly cash payout to help cover
out-of-pocket expenses that arise for the care of a severely-disabled person.
Summary Comparison
Even though the TGA required full assessment of detailed technical documentations as compared to HSA less tedious product
registration documentation and templates. The documentation required for product registrations for both HSA and TGA are very
identical mainly because Australia TGA is one of the Global Harmonization Task Force (GHTF) now known as International
Medical Device Regulators Forum (IMDRF) founding members and Singapore HSA model their regulatory framework and
requirements with the GHTF model. The ISO 13485 Quality System is accepted by both HSA and TGA. The submissions
documentations of the Technical an Design Dossier are similar in nature because HSA accept Common Submission Dossier
Template (CSDT) and TGA accept the Summary TEchnical Document (STED) which consist of identical components. There is no
country of origin approval requirement and the type testing requirements for both HSA and TGA can be conducted in-house or in an
accredited testing facilities which are only upon request by the regulatory authority.
The following charts are the summary and comparison of regulatory requirements for Singapore HSA and Australia TGA.
Countries
Competent
Authority/Regulatory
Bodies
Classification
Quality System
Regulation
Premarket Evaluation
Common Regulatory
Areas
Singapore
HSA
Health Sciences
Authority (HSA)
Medical Device Branch
Health Products Act
(Chapter 122D) Year
2007
Health Products
(Medical Devices)
Regulations Year 2010
Class D
HSA GN-13 (2014)
Rule 8 (direct contact
with the heart)
Online Medical Devices
Risk Classification Tool
(2016) –
Rule 14 (animal tissues)
GDPMDS (Required)
Basic standard
(Submission)
(horizontal standard)
ISO 13485, ISO 14971
etc
+
Group standard
(Submission)
(semi-horizontal
standard):
ISO 10993, ISO 11135
etc
Abridged Evaluation
Route or the Full
Evaluation Route +
ASEAN Common
Submission Dossier
Template (CSDT)
Follow Closely with
GHTF [Now IMDRF]-
Pre-market Evaluation
Model
Australia
TGA
Therapeutic Goods
Administration (TGA)
Medical Devices
Branch
Therapeutic Goods Act
(Chapter 4) Year 1989
Therapeutic Goods
Regulations Year 1990
Therapeutic Goods
(Medical Devices)
Regulations 2002
Class III
TGAARGMD (2011)
Rule 3.4(4)(a)
(direct contact with the
heart)
Rule 5.5(1)(a)
(animal tissues)
Manufacturer must
Implement a full quality
management system
(all clauses of ISO
13485 and arrange for
the quality management
system to be audited by
the TGA
Part 1 (Full Quality
Assurance Procedures)
+ Clause 1.6
(Examination of Design
G
lobal Medical Device
Nomenclature (GMDN)
Codes required for
assessment of devices
before they are
approved for supply
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 14
15. Countries
Costs associated with initial and ongoing
regulatory compliance
Timelines
(After Submission
Until Approval)
Clinical trials Costs and Scheme
Singapore
HSA
Overall Cost: US$4,600 to US$8,800
Application fees: $500 SGD| Evaluation
Fees: Abridged- $5,700 SGD/ Full- $11,400
SGD| Annual Retention Fees: S$120 SGD
220 Working Days
for Abridged
|
310 Working Days
for Full
Evaluation Route
Nil
Australia
TGA
Overall Cost: US $82,000
Application fees: $1,265 AUD, Application
audit assessment fees: Level 1 - verification
of sponsor's application and evidence of
conformity- $3,700 AUD, Level 2 - Level 1
activities plus review of evidence of
conformity- $6,790 AUD, Application for
conformity assessment- Application fee-
$960 AUD, Full quality management system
inspection: Schedule 3, Part 1- $28,600
AUD, Design examination: Schedule 3,
Clause 1.6- $56,300 AUD, Surveillance
inspections - conformity assessment- $8,320
AUD | Annual Retention Fees: $1,200 AUD
330 Targeted time
frames (Working
Days)
There are two schemes under which clinical trials
involving unapproved therapeutic goods may be
conducted in Australia, the Clinical Trial Notification
(CTN) Scheme and the Clinical Trial Exemption (CTX)
Scheme.
Clinical trial notification (CTN) @ $345.00 AUD /
Clinical trial exemption (CTX) evaluation @ $17,600
AUD
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 15
16. Countries Adverse Event Reporting
Post Approval Studies (PAS by US
FDA) Example: Clinical, Animal or
Laboratory Studies
Post Market Surveillance
Compliance to QMS
(Complaint Handling and Reporting
to regulatory authorities)
Singapore
HSA
2 Days- Serious for Public Health
Threat
Within 10 Days Of Becoming Aware
Of A Death Or Serious Injury
Within 30 Days Of Becoming Aware
Of An Event That Might Have Led
To Serious Injury Or Death
TGA uses Global Medical Device
Nomenclature (GMDN) Codes for
ongoing monitoring of devices.
GMDN and UDI are added values to
Singapore HSA during reporting of
adverse event
HSA review stages are during
Pre-Market application.
Multiple Input Requests will be
issued for full clarifications and
additional information
Post-market Monitoring- Report On
Demand Basis
Adverse event (AE) reporting,
Field Safety Notices (FSN),
Medical Device Alerts,
Medical Device Recall,
Field Safety Corrective Actions
(FSCA)
Pharmacovigilance audits
Australia
TGA
Addendum Report Submission May
Be Required
TGA review stages are during Pre-
Market application.
Multiple Request for Information
(S41JA) will be issued for full
clarifications and additional
information
(Application Audits apply for High
Risk Class)
Post-market Monitoring-
(1st 3 Years After Inclusion in ARTG)
Yearly Report Monitoring
[1st October Every Year]
Adverse event (AE) reporting,
Incident Report Investigation Scheme
(IRIS),
Safety Advisory or Alert, Urgent
Medical Device Recall for Product
Correction, Urgent Medical Device
Recall
Pharmacovigilance audits
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 16
17. Key Points and Conclusion
The registration pathways for Australia will be longer than Singapore because of the lead-time to obtain a TGA Conformity
Assessment Certificate to supply in Australia. Adding further to the lead time is the substances of animal tissues that will requires
demonstration of compliance with risk-management procedures, controls on sourcing, collection and handling of animal origin
materials and validation of inactivation processes for viruses and transmissible agents. Even after the Conformity Assessment
Certificate have being issued, the TGA have the right, entry and inspection powers to enter the US manufacturing premises (outside
Australia) to check for compliance and regulatory matters. The plan to use the Class D Abridged registration route will be
depending on either US FDA Premarket Approval (PMA) or TGA approval in the event of approval is delayed or denied.
With the Unique Device Identification (UDI) going to be implemented in US FDA and China CFDA soon, the device traceability
effort and post-market surveillance effort will be more comprehensive for Singapore HSA as there is also the TGA Global Medical
Device Nomenclature (GMDN) to follow.
There are legal obligation to furnish accurate declaration during pre and post market to HSA and TGA especially in term of the
submission of the Essential Principles and Evidence of Conformity because any intentional misrepresentation constitute criminal
offences in Australia and Singapore for the manufacture/product owner and sponsor/registrant.
In Australia, there are Criminal Offences under S41MA and Civil Penalties under S41MAA of the Therapeutic Goods Act 1989, for
persons who import, supply or export medical devices that do not meet the Essential Principles for safety and performance. In
Singapore, any false declaration in Essential Principles and Evidence of Conformity is an offence under the Health Products Act
(Cap. 122D) and may result in the cancellation of registration of the above medical devices under Section 37(1) of the Act.
The device registration license validity is unlimited (lifetime) for US FDA and South Korea MFDS (KFDA), five years for China
CFDA and Australia TGA and one year for Singapore HSA. The one year validity in Singapore seemed to be a disadvantage factor
but in fact, the HSA have an auto renewal of device registration license scheme annually and looking at the cost factor, the annual
retention fees is only $120.00 SGD to maintain the medical devices listing on SMDR. Conversely, the cost of maintaining product
license and TGA Conformity Assessment Certificates required for recertification is in the range of $17,200 AUD to $33,900 AUD,
more fee will be occurred for changes to the Full quality management system inspection: Schedule 3, Part 1 or the Design
examination: Schedule 3, Clause 1.6. Conformity.
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 17
18. Because of the higher cost, there is a business objective and a need to sell more Vivace VX-1 and hopefully the Vivace VX-1 can be
approved for reimbursement under Australian Government funding program known as the Medicare Benefits Schedule (MBS).
There is a need to also get the Vivace VX-1 to be approved and listed as one of the implantable devices in the Australian Prostheses
List (PL) in order to be eligible for reimbursement by private health insurers (funds). The Government’s reimbursement model and
private health insurers’ structure together with the solid clinical evidence and demonstration of significant cost decrease and high
clinical/economic value should allow Vivace VX-1 to obtain the higher payout especially for the Medicare Benefits Schedule
(MBS).
Beside higher regulatory and compliance cost in Australia. TGA have some cost saving measure like the Annual Charge Exemption
(ACE) scheme allows for the exemption of annual charges ($1,200 AUD ) until a product first generates turnover. The scheme
allows sponsors to enter their products on the ARTG in advance of their marketing with no annual charge. Annual charge exemption
scheme (2016).
This prepared report and the recommendations were not intended to be exhaustive .During pre-market, the key to success for placing
any high risk medical devices in any countries are highly dependent on the quality and qualification of the manufacturer, it is crucial
especially in the area of design transfer in ensuring that the design of the medical device can be correctly translated into production
specifications (product development to manufacturing) The support of the local representations (sponsor and registrant) are equally
important for post-market compliance and follow up. The key ingredient is to choose the right standards, guidance and regulatory
guidelines to follow and be in touch with the regulatory bodies and authorities to address any ambiguous areas. In the course of
researching, the author depend heavily on the guidance documents and sincerely hope that the extracted portion will allow a holistic
and high level understanding for the readers.
End of Report
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 18
19. Reference
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EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 19
20. _Registration/GN-17-D1.1%20Guidance%20on%20Preparation%20of%20a%20Product%20Registration%20Submission%20for
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EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 20
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End of References
EdwinNgChunPeng_RAPS_Module 4_Individual Report_2015_2016 pg. 21