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Regulatory guidance and standards
for
gathering medical device clinical evidence
Dr Janette Benaddi
jbenaddi@outlook.com
• How does the regulation apply to gathering clinical
evidence?
• What guidance and standards need to be followed
when gathering evidence?
• Clinical evidence for different device classes and the
procedures relative to each
• What data, when, why, how?
• Clinical definitions and terminology
Hierarchy:
• MDR and IVDR
• Standards ISO 14155, ISO 20916
• MDCG
• Meddevs MEDDEV 2.7.1
• IMDRF
Regulations and Guidance
The Medical Device Regulations
The EU Regulation on Medical Devices 2017/745 MDR
The EU Regulation on In Vitro Diagnostic Medical
Devices 2017/746 IVDR
Various National requirements per country
Article 2 MDR
• (44) ‘clinical evaluation’means a systematic and planned process to continuously generate, collect,
analyse and assess the clinical data pertaining to a device in order to verify the safety and performance,
including clinical benefits, of the device when used as intended by the manufacturer;
• (51) ‘clinical evidence’ means clinical data and clinical evaluation results pertaining to a device of a
sufficient amount and quality to allow a qualified assessment of whether the device is safe and achieves
the intended clinical benefit(s), when used as intended by the manufacturer;
MDR Chapter VI Article 61
Confirmation of conformity with relevant general safety and performance requirements set
out in Annex I under the normal conditions of the intended use of the device, and the
evaluation of the undesirable side-effects and of the acceptability of the benefit-risk- ratio
referred to in Sections 1 and 8 of Annex I, shall be based on clinical data providing
sufficient clinical evidence, including where applicable relevant data as referred to in
Annex II
MDR Chapter VI Article 61
• Manufacture to specify and justify level of clinical evidence required
• Plan, conduct and document a clinical evaluation
• Class III and IIb active devices intended to administer and/or remove a medicinal
product, prior to Clin Eval consult expert panel to review clin dev strategy
• Outlines what goes into to Clin Eval
Article 61 (3)
Chapter VI Article 61
Implantable and Class III perform CI except if;
• Device has been designed by modifications of a device already marketed by
same manufacturer
• Modified device is equivalent to marketed device (endorsed by NB)
• And the CE of the marketed device is sufficient to demonstrate safety and
performance of the modified device
• In which case NB checks PMCFU is in place and post market studies
ANNEX XIV
• Contents of a clinical evaluation plan
• Take into account both favourable and unfavourable data
• May be based on an equivalent device technical, biological, clinical
• No clinical significant difference in the safety and performance of
equivalent devices
• Sufficient access to devices claimed to be equivalent
• All documented in a CER
• All to be included in the technical documentation
• ISO 14155 - Clinical investigation of medical devices for human subjects — Good clinical practice
• The results of the clinical evaluation shall be used to determine and justify the optimal design of the
clinical investigation
• ISO 14971 – Medical devices — Application of risk management to medical devices
• Current knowledge of the material/medical device provided by scientific literature, previous clinical
experience and other relevant data should be reviewed to establish any need for additional data
• The manufacturer may gather and review data and literature to determine if the medical benefits of
the intended use outweigh the overall residual risk
Relevant Standards
• Guidance on how to conduct and document the clinical evaluation of a medical device as part of
the conformity assessment procedure prior to placing a medical device on the market as well as
to support its ongoing marketing.
• It is also intended to provide guidance to regulators and other stakeholders when assessing
clinical evidence provided by manufacturers.
European Commission MEDDEV. 2.7.1 Rev.4 - Clinical Evaluation: a guide for Manufacturers
And Notified Bodies (2016) 2.7.1 Rev.4
Applicable Regulatory and Guidance Documents
Applicable Regulatory and Guidance
Documents cont.
Applicable Regulatory and Guidance
Documents cont.
Applicable Regulatory and Guidance
Documents cont.
Document MDR Class Article/Annex Guidance
Clinical Development
Plan
All Annex XIV Part A (1) -
Clinical Evaluation Plan All Article 61 (1) MDCG 2020-6
Clinical Evaluation Report All Article 61 (1)
Annex IX Chapter II
Annex XIV Part A
MEDDEV 2.7/1 Rev4**
MDCG 2020-5 (Equivalence)
MDCG 2020-6 (Legacy Devices)
PMCF Plan All Annex XIV Part B MDCG 2020-8
PMCFR All Article 61 (11) (12)
Annex XIV Part B
MDCG 2020-8
PMS Plan All Article 84
Annex III (1.1)
-
Summary of safety and
clinical performance
Class III
and
implantabl
e
Article 32 MDCG 2019-9
Periodic safety update
report
IIa, IIb, III Article 86
Annex III (1.2)
In progress
Document IVDR Class Article/Annex Guidance
Performance Evaluation
Plan
All Article 56
Annex XIII Part A
MDCG 2020-6
Performance Evaluation
Report
All Article 56
Annex XIII Part A
MEDDEV 2.7/1 Rev4**
MDCG 2020-5 (Equivalence)
MDCG 2020-6 (Legacy Devices)
PMPFU Plan All Annex XIII Part B MDCG 2020-8
PMPFU Report All Article 61 (11) (12)
Annex XIII Part B
MDCG 2020-8
PMS Plan All Article 79
Annex III
-
PMSR A, B Article 80
Summary of safety and
performance
Class C, D Article 29 MDCG 2019-9 Summary of safety and
clinical performance a guide for
manufacturers and notified bodies
Periodic safety update
report
Class C, D Article 81
Annex
In progress spring
WHY?
Which Annex of the MDR is applicable to clinical evaluation
a) Annex I
b) Annex XVI
c) Annex XIV
Which of the following devices are clinical investigations a
requirement according to MDR
a) Class I
b) Class IIb
c) Class III and implantable
Which standard is sued to conduct clinical investigaitons of
medical devices
a) ISO14155
b) ISO20916
Which standard is sued to conduct clinical performance
studies of IVDs
a) ISO14155
b) ISO20916
Educo Life Science [gathering clinical evidence] [module 1]
Educo Life Science [gathering clinical evidence] [module 1]

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Educo Life Science [gathering clinical evidence] [module 1]

  • 1. Regulatory guidance and standards for gathering medical device clinical evidence Dr Janette Benaddi jbenaddi@outlook.com
  • 2. • How does the regulation apply to gathering clinical evidence? • What guidance and standards need to be followed when gathering evidence? • Clinical evidence for different device classes and the procedures relative to each • What data, when, why, how? • Clinical definitions and terminology
  • 3. Hierarchy: • MDR and IVDR • Standards ISO 14155, ISO 20916 • MDCG • Meddevs MEDDEV 2.7.1 • IMDRF Regulations and Guidance
  • 4. The Medical Device Regulations The EU Regulation on Medical Devices 2017/745 MDR The EU Regulation on In Vitro Diagnostic Medical Devices 2017/746 IVDR Various National requirements per country
  • 5. Article 2 MDR • (44) ‘clinical evaluation’means a systematic and planned process to continuously generate, collect, analyse and assess the clinical data pertaining to a device in order to verify the safety and performance, including clinical benefits, of the device when used as intended by the manufacturer; • (51) ‘clinical evidence’ means clinical data and clinical evaluation results pertaining to a device of a sufficient amount and quality to allow a qualified assessment of whether the device is safe and achieves the intended clinical benefit(s), when used as intended by the manufacturer;
  • 6.
  • 7. MDR Chapter VI Article 61 Confirmation of conformity with relevant general safety and performance requirements set out in Annex I under the normal conditions of the intended use of the device, and the evaluation of the undesirable side-effects and of the acceptability of the benefit-risk- ratio referred to in Sections 1 and 8 of Annex I, shall be based on clinical data providing sufficient clinical evidence, including where applicable relevant data as referred to in Annex II
  • 8. MDR Chapter VI Article 61 • Manufacture to specify and justify level of clinical evidence required • Plan, conduct and document a clinical evaluation • Class III and IIb active devices intended to administer and/or remove a medicinal product, prior to Clin Eval consult expert panel to review clin dev strategy • Outlines what goes into to Clin Eval
  • 10. Chapter VI Article 61 Implantable and Class III perform CI except if; • Device has been designed by modifications of a device already marketed by same manufacturer • Modified device is equivalent to marketed device (endorsed by NB) • And the CE of the marketed device is sufficient to demonstrate safety and performance of the modified device • In which case NB checks PMCFU is in place and post market studies
  • 11. ANNEX XIV • Contents of a clinical evaluation plan • Take into account both favourable and unfavourable data • May be based on an equivalent device technical, biological, clinical • No clinical significant difference in the safety and performance of equivalent devices • Sufficient access to devices claimed to be equivalent • All documented in a CER • All to be included in the technical documentation
  • 12.
  • 13. • ISO 14155 - Clinical investigation of medical devices for human subjects — Good clinical practice • The results of the clinical evaluation shall be used to determine and justify the optimal design of the clinical investigation • ISO 14971 – Medical devices — Application of risk management to medical devices • Current knowledge of the material/medical device provided by scientific literature, previous clinical experience and other relevant data should be reviewed to establish any need for additional data • The manufacturer may gather and review data and literature to determine if the medical benefits of the intended use outweigh the overall residual risk Relevant Standards
  • 14. • Guidance on how to conduct and document the clinical evaluation of a medical device as part of the conformity assessment procedure prior to placing a medical device on the market as well as to support its ongoing marketing. • It is also intended to provide guidance to regulators and other stakeholders when assessing clinical evidence provided by manufacturers. European Commission MEDDEV. 2.7.1 Rev.4 - Clinical Evaluation: a guide for Manufacturers And Notified Bodies (2016) 2.7.1 Rev.4
  • 15. Applicable Regulatory and Guidance Documents
  • 16. Applicable Regulatory and Guidance Documents cont.
  • 17. Applicable Regulatory and Guidance Documents cont.
  • 18. Applicable Regulatory and Guidance Documents cont.
  • 19.
  • 20. Document MDR Class Article/Annex Guidance Clinical Development Plan All Annex XIV Part A (1) - Clinical Evaluation Plan All Article 61 (1) MDCG 2020-6 Clinical Evaluation Report All Article 61 (1) Annex IX Chapter II Annex XIV Part A MEDDEV 2.7/1 Rev4** MDCG 2020-5 (Equivalence) MDCG 2020-6 (Legacy Devices) PMCF Plan All Annex XIV Part B MDCG 2020-8 PMCFR All Article 61 (11) (12) Annex XIV Part B MDCG 2020-8 PMS Plan All Article 84 Annex III (1.1) - Summary of safety and clinical performance Class III and implantabl e Article 32 MDCG 2019-9 Periodic safety update report IIa, IIb, III Article 86 Annex III (1.2) In progress
  • 21. Document IVDR Class Article/Annex Guidance Performance Evaluation Plan All Article 56 Annex XIII Part A MDCG 2020-6 Performance Evaluation Report All Article 56 Annex XIII Part A MEDDEV 2.7/1 Rev4** MDCG 2020-5 (Equivalence) MDCG 2020-6 (Legacy Devices) PMPFU Plan All Annex XIII Part B MDCG 2020-8 PMPFU Report All Article 61 (11) (12) Annex XIII Part B MDCG 2020-8 PMS Plan All Article 79 Annex III - PMSR A, B Article 80 Summary of safety and performance Class C, D Article 29 MDCG 2019-9 Summary of safety and clinical performance a guide for manufacturers and notified bodies Periodic safety update report Class C, D Article 81 Annex In progress spring
  • 22. WHY?
  • 23.
  • 24.
  • 25. Which Annex of the MDR is applicable to clinical evaluation a) Annex I b) Annex XVI c) Annex XIV
  • 26. Which of the following devices are clinical investigations a requirement according to MDR a) Class I b) Class IIb c) Class III and implantable
  • 27. Which standard is sued to conduct clinical investigaitons of medical devices a) ISO14155 b) ISO20916
  • 28. Which standard is sued to conduct clinical performance studies of IVDs a) ISO14155 b) ISO20916