Companion Diagnostics IVD Consultancy within the EMA Framework: Comprehensive Guidance

The field of companion diagnostics IVD (CDx) represents a confluence of technological innovation, regulatory compliance, and patient care. As personalized medicine becomes an integral part of healthcare, the regulatory framework governing CDx, including the In Vitro Diagnostic Medical Devices Regulation (IVDR), has become more complex. This scenario calls for a specialized companion diagnostics consultancy. MDx CRO is at the forefront of this arena, offering expertise and guidance in the process for CDx consultation with the European Medicines Agency (EMA), Notified Body preparation and IVDR compliance within the European Union (EU).

Companion Diagnostics IVD and their Role

CDx are in vitro diagnostic (IVD) tests designed to provide information that is essential for the safe and effective use of a corresponding medicinal product. Their applications could include:

  • Identifying patients who are most likely to benefit from a particular therapeutic product.
  • Determining patients’ suitability for specific treatments.
  • Monitoring responses to ongoing treatments.

The Impact of IVDR on Companion Diagnostics

The IVDR sets out robust legal requirements for in vitro diagnostic medical devices, including CDx. Key aspects include:

  • Enhanced Patient Safety: Ensuring the quality and reliability of CDx IVDs.
  • Stricter Oversight: Increased scrutiny of the CDx development and approval process. Unlike the previous directive, CDx now require conformity assessment by a Notified Body, an independent organization designated to assess the compliance of medical devices and in-vitro diagnostics. In addition, CDx are also assessed by a medicines authority, most likely the EMA (European Medicines Agency), but a competent authority could also be involved .
  • Comprehensive Technical Documentation: Increased clinical evidence requirements are particularly notable in the IVDR. MDx CRO can help CDx manufacturers and their drug partners gather the necessary data to support their CDx application. This data may include clinical trial data (clinical performance data), analytical data, and safety data. Manufacturers must provide robust clinical evidence to demonstrate the performance, safety, and clinical utility of the CDx.

There are a number of other factors that can affect the approval process for CDx in the EU. These factors include:

  • The availability of data: Both the Notified Body and the EMA will need to have access to data from clinical trials that demonstrate the safety and effectiveness of the CDx.
  • The complexity of the CDx: The more complex the CDx, the more difficult it will be to assess its safety and effectiveness.
  • The novelty of the CDx: If the CDx involves new technologies or indications, the EMA and the Notified Body will need to take a more cautious approach to its approval. Different scenarios will play a role on the extent of scrutiny involved, including co-developed CDx scenarios, follow-on CDx, and CDx already on the market under the old IVD directive.

Understanding the EMA Companion Diagnostics Consultation Procedure

The consultation procedure is initiated by the notified body when it receives an application from a CDx manufacturer. The medicinal product involved could be a medicine already authorised for marketing in the EU or a medicine undergoing approval. Aligning drug and diagnostic development processes can help to ensure that the results of the clinical trials are accurate and reliable, and that the medicine is safe and effective when used with the CDx.

Aligning timelines in the drug and diagnostic (CDx) development process can help to ensure that the clinical trials for the medicine are conducted in a way that is consistent with the intended use of the CDx.

Upon application for a CDx IVD approval, the notified body will submit a letter of intent to the EMA, along with a technical dossier that describes the CDx and the medicinal product.

The EMA will then appoint a rapporteur, who will be responsible for reviewing the technical dossier and issuing a scientific opinion on the suitability of the CDx for use with the medicinal product. The rapporteur will also consider the views of any other interested parties, such as the applicant for the medicinal product, the manufacturer of the CDx, and patient groups.

The EMA will provide its scientific opinion on the CDx aspects that relate to the medicine to the notified body. The notified body will then use the EMA’s opinion to make a decision on whether to grant the CE mark to the CDx, in accordance with the regulatory requirements of the in vitro diagnostics regulation (EU IVDR).

EMA procedure timetables play a major role in the success of the consultation and turn around times for responses can be extremely short. Manufacturers should factor this in as they plan for their CDx submissions. There is the possibility to request a pre-submission meeting which will include representatives from Notified Bodies, EMA and could also include the drug manufacturer – this is used strictly to align on procedural and timing considerations (it is not used to provide feedback on study design or the content of the technical documentation).

One of the key documents used in the consultation and submitted by the notified body to the EMA is the SSP (Summary of Safety and Performance). The EMA expects manufacturers to use the SSP template provided in MDCG 2022-9. A lot more detail is expected in the SSP when compared to the information provided in the IFU. For example, detail on concordance studies is needed, particularly for co-developed CDx when different versions of a diagnostic have been used throughout the clinical development program.

MDx CRO: Your Partner in Companion Diagnostics Consultancy

Our companion diagnostics consultancy services encompass every stage of development, approval, and post-market surveillance:

  • Guidance on IVDR Requirements: In-depth support in understanding and meeting the specific demands of IVDR as they relate to CDx. MDx CRO can help a diagnostics company identify the specific requirements that apply to its CDx. For example, the requirements for a CDx that is intended to assess a patient’s suitability for treatment may be different from the requirements for a CDx that is intended to be used to monitor a patient’s response to treatment.
  • Preparation for Notified Body Assessment: Tailored strategies for successful assessment of a CDx under the IVDR: Assistance with compiling and submitting the necessary technical documentation and quality related documents.
  • Providing training to the manufacturer’s staff: MDx CRO can provide training to the manufacturer’s staff on the EMA’s requirements for CDx, as well as the notified body’s assessment process and expectations. This training will help to ensure that the manufacturer’s staff are prepared to answer any notified body questions and increase chances of success.
  • Stakeholder Communication: Facilitating communication with all relevant parties.
  • Global Perspective: Navigating international considerations for CDx in multi-country studies.
  • Post-Market Support: Focused on maintaining the highest standards through ongoing compliance monitoring with IVDR and other regulatory requirements. This includes implementing strong post-market surveillance processes and Post-Market Performance Follow-up (PMPF) evaluations, monitoring the CDx’s performance in real-world clinical settings, tracking and analyzing adverse events related to CDx usage, and conducting ongoing studies to evaluate the long-term impact and effectiveness of the CDx.

Why MDx CRO for Companion Diagnostics IVD Consultancy?

  1. Expertise: Our in-depth knowledge of CDx, IVDR, and EU regulations offers unparalleled support.
  2. Collaboration: Working closely with clients, we tailor our approach to meet specific needs.
  3. Efficiency: Our insights and guidance save valuable time and resources, simplifying complex regulatory pathways.
  4. Commitment: Our dedication to excellence, patient safety, and innovation sets us apart.

Navigating the multifaceted world of companion diagnostics in the EU, with the added complexity of IVDR, requires a dedicated and skilled partner. MDx CRO stands ready to be your guide in this critical journey, ensuring alignment with all regulatory standards. Reach out to explore how our companion diagnostics consultancy can be the key to unlocking your CDx potential in the EU’s dynamic regulatory environment.

Frequently Asked Questions on COmpanion Diagnostics Consultancy

What is a co-developed Companion Diagnostics in the context of EMA consultation?

A co-developed CDx is a device developed alongside a medicinal product for either initial authorization or a change of indication. This can include development during a pivotal clinical trial or a bridging study, with sufficient documentation to ensure performance alignment.

How does a follow-on CDx differ from a co-developed CDx?

A follow-on CDx seeks the same indication as the original CDx but is not developed in parallel with the medicinal product. The follow-on CDx targets the same biomarker but may not be based on the same technology. It should be highly comparable to the original in performance, safety, and effectiveness.

What documentation is required for a follow-on CDx?

Sufficient documentation must be provided for a follow-on CDx to prove that its analytical performance is comparable to the original CDx and that there’s no impact on clinical performance incompatible with the safe and effective use of the medicinal product.

How are devices transitioning from IVDD to IVDR handled?

Devices initially marketed under Directive 98/79/EC (IVDD) that transition to IVDR fall under the co-developed or follow-on scenarios, depending on how they were initially developed.

Is it possible to proceed with a single CDx consultation procedure for multiple authorized medicinal products and indications?

Yes, if a device’s intended purpose includes several authorized medicinal products and indications, it’s recommended to proceed with one single CDx consultation procedure. All concerned medicinal products should be listed in the intention to submit a letter by the Notified Body and in the application form.

Written by:
Carlos Galamba

Carlos Galamba

CEO

Senior regulatory leader and former BSI IVDR reviewer with deep experience in CE marking high-risk IVDs, companion diagnostics, and IVDR implementation.
Industry Insights & Regulatory Updates

IVD Consultancy: Balancing Expertise & Cost-Efficiency with MDx CRO

Striking a balance between expertise and cost-efficiency in IVD consultancy can be a tricky task, especially within the European Union’s context, where there’s a notable dearth of specialized consultants. Recognizing this challenge and its impact on your business’s success is what we do at MDx CRO. This article offers a deep dive into the crucial factors to bear in mind when picking your IVD consultant and how MDx CRO combines expertise and cost-effectiveness smoothly.

Selecting a consultant should be a process that considers a variety of factors aligned with your company’s unique needs and budget. Here’s a look at some of the most important aspects, including domain expertise, relevance to the industry, cost-effectiveness, and cultural fit.

Depth of Expertise

At the heart of a successful IVD consultancy engagement is a consultant’s profound and extensive knowledge. This is especially important in a specialized area like IVD, where the regulatory terrain is complex and quite different from general medical devices. Scrutinize potential consultants’ qualifications, industry experience, and roles within IVD companies, regulatory bodies, and regulators to ascertain they possess the necessary domain expertise. At MDx CRO, we value expertise and consider its cost justified by the immense value it brings to your project. Our consultants are not just well-versed in the IVD sector; they are seasoned professionals with a wealth of practical experience. A common error is opting for a consultancy firm with a general understanding, perhaps in areas like pharma or general medical devices. If you’re not engaging with a partner and consultants with a deep understanding of your specific IVD technology, you’re essentially laying down hurdles in your own path.

Industry Relevance and Recommendations

It’s crucial to check how up-to-date and applicable the consultant’s knowledge is. Review their published works, evaluate their communication style, and verify if their insights align with your needs. Moreover, consider seeking industry colleagues’ recommendations or checking professional networks like LinkedIn. A reputable consultant should be able to give a rundown of their services, providing a clear view of their value proposition and balance of cost and benefits.

Comprehensive Service Offering and Cost-Efficiency

Depending on your market entry strategy, you might require a consultant with expertise in your target regions. Consultants adept in navigating both EU and US regulatory landscapes can deliver significant value, providing cost-efficiency by producing uniform documentation for multiple markets. This saves time and eliminates redundant tasks. At MDx CRO, we take pride in offering such comprehensive and cost-effective services, positioning ourselves as your all-in-one solution for IVD regulatory needs.

Cultural Compatibility

While often overlooked, a strong cultural fit plays a crucial role in a successful collaboration. An open conversation with potential consultants can help you gauge this compatibility in terms of language, time zone, and communication style. A good cultural fit promotes better collaboration, yielding more bang for your buck.

In conclusion, choosing the right IVD consultancy involves a careful balance of expertise, industry relevance, cost-effectiveness, and cultural fit. At MDx CRO, we embody this balance, providing comprehensive, cost-effective IVD consultancy services without compromising on value. Our goal is not only to deliver expert solutions but to do so at fair and transparent prices, distinguishing us in the IVD industry.

Feel free to contact us today to discuss your IVD consultancy needs. It’s where our IVD Consultancy Expertise and Cost-Efficiency come into play, ensuring that you receive the best possible value for your investment.

Written by:
Carlos Galamba

Carlos Galamba

CEO

Carlos spent several years of his career at BSI, where he developed a global network of relationships with top EU Notified Bodies. As the first in-house clinician for IVDs at BSI, he led the implementation of the BSI clinical oversight process, providing hundreds of CE marking recommendations for IVDs and supporting IVDR Notified Body designations.
Industry Insights & Regulatory Updates

Clinical Molecular Genetics (CMG) Under the Lens of the EU IVDR, MDCG and MEDDEV.

At the crossroads of healthcare and technology, Clinical Molecular Genetics (CMG) emerges as a keystone, bridging molecular biology and genetics to comprehend and diagnose a plethora of diseases. Implementing the European Union’s In Vitro Diagnostic Medical Device Regulation (IVDR) heralds a transformative shift, bringing considerable changes to CMG and the broader landscape of in vitro diagnostics (IVD). This article seeks to demystify the implications of the IVDR for CMG and provide insights into the way forward.

Understanding Clinical Molecular Genetics (CMG)

CMG lies at the heart of modern healthcare, harnessing the transformative power of molecular biology and genetics. The field provides critical insights into a multitude of diseases, from single-gene disorders to complex multifactorial illnesses, thereby informing diagnosis and therapeutic decisions. Rapid advancements, such as next-generation sequencing (NGS) and genomics, continue to drive the evolution of CMG, heralding a promising future of personalized medicine.

The IVDR: A New Regulatory Era

In response to the sweeping advancements in CMG and other IVD fields, the European Union launched the IVDR (EU) 2017/746, which became effective in May 2022. The IVDR offers a comprehensive regulatory framework aiming to ensure patient safety and the accuracy of diagnostic results across all EU member states.

IVDR and Clinical Molecular Genetics: A New Relationship

With the IVDR, several substantial changes are impacting CMG-related IVDs, from manufacturing processes to distribution and usage. The regulation emphasizes post-market surveillance and vigilance requirements, sets rigorous standards for quality management systems, and demands comprehensive technical documentation.

Importantly, genetic tests and high-throughput NGS devices are classified under Class C or D, indicating a higher risk level. This classification necessitates a thorough review by a Notified Body, making IVDR compliance an integral part of CMG operations.

CMG, MEDDEV and MDCG: Guiding Lights in the Regulatory Landscape

EU’s guidance documents for CMG, MEDDEV and MDCG, serve as a valuable reference for manufacturers to understand and implement the IVDR requirements. Although not legally binding, adherence to MEDDEV is often seen as an indicator of commitment to regulatory compliance.

The Medical Device Coordination Group (MDCG), comprising representatives from all EU member states, ensures uniform application and interpretation of the new regulations across the EU. The MDCG has issued several guidance documents to aid IVDR implementation, offering practical guidance and tools.

The Medical Device Coordination Group (MDCG) has issued several guidance documents to facilitate a smooth transition to the IVDR. Here’s a summary of some of the most recent MDCG guidelines relevant to IVDs:

  • MDCG 2022-20: Guidelines on Substantial modification of performance study under the IVDR.
  • MDCG 2022-19: Guidance on Performance study application/notification documents under the IVDR.
  • MDCG 2022-15: Guidance on appropriate surveillance regarding transitional provisions under Article 110 of the IVDR.
  • MDCG 2022-10: Q&A on the interface between Regulation (EU) 536/2014 on clinical trials for medicinal products for human use (CTR) and the IVDR.
  • MDCG 2022-9: Guidelines on the Summary of safety and performance template.
  • MDCG 2022-8: Guidelines on the application of IVDR requirements to ‘legacy devices’ and to devices placed on the market prior to 26 May 2022.
  • MDCG 2022-6: Guidelines on significant changes regarding transitional provision under Article 110(3) of the IVDR.
  • MDCG 2022-3: Guidelines on the Verification of manufactured class D IVDs by notified bodies.
  • MDCG 2022-2: Guidelines on general principles of clinical evidence for IVDs.
  • MDCG 2021-4: Guidelines on Application of transitional provisions for certification of class D IVDs.

The CMG Road Ahead

As we navigate this era of stringent regulatory requirements, proactive and conscientious compliance with the IVDR becomes paramount for all involved in CMG. Staying updated with the latest MEDDEV and MDCG guidance documents and understanding the implications of IVDR is crucial. Nevertheless, the collective goal remains unaltered: ensuring patient safety and maximizing the potential of Clinical Molecular Genetics in revolutionizing healthcare. Manufacturers are encouraged to regularly consult the European Commission’s website or engage with a Notified Body or a regulatory consultant for the most recent and accurate guidance.

Frequently Answers and Questions

Q: What is Clinical Molecular Genetics (CMG)?

A: Clinical Molecular Genetics (CMG) is a discipline that merges the profound understanding of molecular biology and genetics to decipher the genetic basis of a myriad of diseases. Spanning from single-gene disorders to intricate multifactorial diseases, CMG offers critical insights necessary for diagnosis and therapeutic decisions. Leveraging advancements such as next-generation sequencing (NGS) and genomics, CMG is a constantly evolving field, paving the way for a future of personalized medicine.

Q: How does the IVDR influence CMG?

A: In May 2022, the European Union implemented the IVDR (EU) 2017/746, which heralds a comprehensive regulatory framework designed to assure patient safety and the precision of diagnostic results across all EU member states. The IVDR has brought about a multitude of changes that significantly impact CMG-related IVDs, including those about manufacturing processes, distribution, and usage. The regulation places a pronounced emphasis on post-market surveillance and vigilance requirements, mandates stringent standards for quality management systems, and requires exhaustive technical documentation. Of note, genetic tests and high-throughput NGS devices are classified under Class C or D, denoting a higher risk level. This categorization calls for a comprehensive review by a Notified Body, thereby making IVDR compliance an indispensable aspect of CMG operations.

Q: Are there specific CMG MEDDEV or MDCG guidances applicable?

A: The MDCG and MEDDEV that European Commission has issued several general guidance documents to aid the transition from the In Vitro Diagnostic Directive (IVDD) to the IVDR. These documents offer invaluable insights and clarifications on the key facets of the new regulations, thus serving as crucial references for manufacturers striving to understand and implement the IVDR requirements.

Industry Insights & Regulatory Updates

How to Prepare Your Clinical Evaluation Plan Template in 5 Key Steps

In this article, we will delve into the intricacies of developing a robust Clinical Evaluation Plan using expert regulatory terminology, equipping you with the knowledge to navigate this essential aspect of your MedTech product development.

As the medical device industry evolves and regulatory requirements become more stringent, the need for a well-defined Clinical Evaluation Plan (CEP) has become paramount.

The CEP plays a crucial role in assessing the safety and performance of medical devices, ensuring their compliance with Annex XIV of the Regulation (EU) MDR 2017/745 (MDR), MDCG 2020-6, and MEDDEV 2.7.1. Rev.4.

In this article, we will delve into the intricacies of developing a robust Clinical Evaluation Plan using expert regulatory terminology, equipping you with the knowledge to navigate this essential aspect of your MedTech product development.

The clinical evaluation of a medical device must be thorough and objective. Manufacturers should consider both favourable and unfavourable clinical data when developing the Clinical Evaluation Plan.

The depth and extent of the clinical evaluation must remain proportionate to the device. This includes its nature, risk class, intended purpose, manufacturer claims, and associated risks.

Manufacturers may base a clinical evaluation on clinical data from an equivalent device when they can demonstrate equivalence. The demonstration of equivalence must cover technical, biological, and clinical characteristics. Notified Bodies strongly recommend claiming equivalence against only one equivalent device.

Under MDR Article 61(1) and Annex XIV, manufacturers must plan, conduct, and document the clinical evaluation. The planning phase must be documented in a Clinical Evaluation Plan. The outcomes of the evaluation and the supporting clinical evidence must then be documented in a Clinical Evaluation Report.

A Clinical Evaluation Plan (CEP) is a documented strategy that defines a systematic and planned approach to assess the safety and performance of a medical device throughout its lifecycle.

This clinical evaluation plan template provides the framework for collecting, appraising, and analyzing clinical data. Its purpose is to demonstrate conformity with the General Safety and Performance Requirements (GSPRs) set out in Annex I of the MDR.

According to Part A, Section 1 of Annex XIV of the MDR, the manufacturer must establish and regularly update the Clinical Evaluation Plan. This ensures that the clinical evaluation remains planned, continuously performed, and properly documented.

Annex XIV defines the minimum requirements that every Clinical Evaluation Plan must address.

Minimum Requirements of a Clinical Evaluation Plan

The CEP must include:

  • A clinical development plan outlining the progression from exploratory investigations to confirmatory clinical investigations and PMCF activities, including milestones and acceptance criteria.
  • Identification of GSPRs that require support from relevant clinical data.
  • Specification of the intended purpose of the device.
  • Clear definition of target groups, including indications and contraindications.
  • Description of intended clinical benefits with defined clinical outcome parameters.
  • Methods for evaluating qualitative and quantitative aspects of clinical safety, including residual risks and side effects.
  • Parameters used to assess the acceptability of the benefit-risk ratio based on the current State of the Art.
  • An explanation of how benefit-risk issues related to specific components, such as medicinal substances or animal or human tissues, are addressed.

3.1. Clinical Data from Systematic Scientific Literature Reviews

Manufacturers should conduct a systematic scientific literature review to identify relevant clinical data for the device and its intended purpose.

The review should also identify gaps in the available clinical evidence. This supports a complete and transparent understanding of the existing data landscape.

Using structured methodologies such as PRISMA and PICO is recommended, as these approaches improve the systematic nature and reproducibility of the literature search.

3.2. Clinical Data from Clinical Investigations

Manufacturers should design and conduct clinical investigations in line with the Clinical Development Plan.

These investigations should generate new or additional clinical data when existing evidence does not sufficiently demonstrate safety and performance. The generated data should directly support the objectives of the Clinical Evaluation Plan.

3.3. Clinical Data Appraisal and Suitability

Manufacturers must appraise all relevant clinical data to determine their suitability for demonstrating device safety and performance.

This appraisal should consider data quality, reliability, and relevance. It should also follow the hierarchy of clinical evidence described in Appendix III of MDCG 2020-6 when assessing conformity with MDR GSPRs.

3.4. Clinical Data Analysis and Conclusions

Manufacturers must analyze all relevant clinical data, including literature data, existing clinical studies, and newly generated clinical investigation data.

The analysis should support clear conclusions on safety, clinical performance, and clinical benefits. This process includes data interpretation, statistical analysis, and benefit-risk assessment. The outcome must support robust, evidence-based conclusions within the Clinical Evaluation Plan.

The MDCG 2020-6 guidance, “Regulation (EU) 2017/745: Clinical evidence needed for medical devices previously CE marked under Directives 93/42/EEC or 90/385/EEC”, provides detailed direction on how to perform a clinical evaluation under the MDR. It supports both manufacturers and Notified Bodies in assessing clinical evidence for legacy medical devices.

This guidance is particularly relevant when preparing a clinical evaluation plan template that complies with MDR requirements.

4.1. Clinical Evaluation Plan Documentation Requirements

MDCG 2020-6 confirms that manufacturers must document a Clinical Evaluation Plan in accordance with MDR Annex XIV. The guidance also provides practical recommendations to support compliance with Annex XIV, Section 1(a).

A compliant Clinical Evaluation Plan should include:

  • Identification of the applicable General Safety and Performance Requirements (GSPRs).
  • A clear definition of the intended purpose, target patient groups, indications, and contraindications.
  • A detailed description of the intended clinical benefits, supported by defined clinical outcome parameters.
  • Specification of qualitative and quantitative aspects of clinical safety and clinical performance.

4.2. Sources of Clinical Data

According to MDCG 2020-6, the Clinical Evaluation Plan must clearly identify all relevant sources of clinical data. These sources may include pre-market, post-market, and newly generated clinical data.

Pre-market clinical data may consist of:

  • Clinical investigation reports for the device under evaluation.
  • Clinical investigations or studies published in scientific literature for equivalent devices.
  • Peer-reviewed literature reporting other clinical experience with the device or an equivalent device.
  • Additional pre-market data, such as case reports related to device use.

Post-market clinical data may include:

  • Post-Market Surveillance (PMS) clinical data.
  • Complaint handling and vigilance reports.
  • Post-Market Clinical Follow-up (PMCF) studies and investigations.
  • Independent clinical studies, device registries, and relevant literature data.

Newly generated clinical data should also be included when available and justified.

The Clinical Evaluation Plan must also describe the system used to appraise and analyze all clinical data sources.

4.3. Minimum Content of a Clinical Evaluation Plan for Legacy Devices

Appendix II of MDCG 2020-6 defines the minimum content required for a Clinical Evaluation Plan for legacy devices. This minimum content includes:

  • Identification of GSPRs that require support from clinical data.
  • Specification of the intended purpose of the device.
  • Clear definition of target groups, including indications and contraindications.
  • Description of intended clinical benefits with defined clinical outcome parameters.
  • A strategy to identify, analyze, and assess alternative treatment options.
  • Methods for evaluating qualitative and quantitative aspects of clinical safety, including residual risks and side effects.
  • Defined parameters to assess the acceptability of the benefit-risk ratio based on the current State of the Art.
  • An explanation of how benefit-risk issues related to specific components, such as medicinal substances or animal or human tissues, are addressed.
  • A strategy and methodology to identify, analyze, and appraise all relevant clinical data under the MDR definition of clinical data.
  • Evidence supporting equivalence when clinical data from an equivalent device is used.
  • A justification of the required level of clinical evidence based on device characteristics and intended purpose.
  • A strategy for the systematic collection, analysis, and assessment of post-market surveillance data to demonstrate continued safety and performance of legacy devices.

4.4. Hierarchy of Clinical Evidence Under MDCG 2020-6

Appendix III of MDCG 2020-6 introduces a hierarchy of clinical evidence to support conformity with MDR GSPRs. This hierarchy ranks different types of clinical data from strongest to weakest.

Manufacturers should consider this hierarchy when defining the appraisal methodology in their clinical evaluation plan template. Applying the suggested hierarchy supports a robust and transparent assessment of clinical evidence and strengthens the overall Clinical Evaluation Plan.

MEDDEV 2.7.1. Rev.4 refers to the fourth revised version of the Medical Device Vigilance Guidance Document.

This document encourages the adoption of a standardized approach to clinical evaluation for medical devices that fall under the regulation of directives 90/385/EEC and 93/42/EEC.

MEDDEV 2.7.1 Rev.4 continues to be used even after the implementation of MDR since it offers additional interpretive guidance and practical recommendations that complement the MDR requirements.

Section 7 of MEDDEV 2.7/1 rev. 4 addresses the definition of scope of the clinical evaluation, which constitutes the Stage 0 of a clinical evaluation, and, according to MDR and MDCG 2020-6, states that the manufacturer should set up a Clinical Evaluation Plan for the device under evaluation. 

Recognizing the wide range of technologies employed in medical devices, along with their diverse histories and associated risks, is crucial.

Therefore, Section 7 of MEDDEV 2.7/1 rev. 4 also examines the different aspects to be considered for setting up a CEP depending on the stage in the lifecycle of the product and its regulatory status (i.e., before CE-marking, For CE-marked devices).

Moreover, Appendix A3 of MEDDEV 2.7/1 rev. 4 lists information that can be relevant for planning clinical evaluations. It is paramount that the manufacturer ensures that input for the Clinical Evaluation Plan shows alignment with the device’s “label, instructions for use, promotional or sales materials or statements” and with the device’s updated risk management documentation.

Must have considerations for your Clinical Evaluation Plan Template MDR-based

At MDx CRO, we recognize the significance of a well-structured Clinical Evaluation Plan (CEP) in ensuring the safety and performance of medical devices.

The design of a Clinical Evaluation Plan (CEP) template according to the Medical Device Regulation (MDR) 2017/745 should be tailored to the specific typology of the manufacturer’s device.

This customization is critical as every medical device has unique attributes, different indications for use, target populations, and risk profiles.

Therefore, the use of a generic template for all devices is not recommended. Although it might be tempting to use a “one-size-fits-all” approach for efficiency reasons, such practice could overlook the MDR’s specific requirements for each individual device, potentially leading to non-compliance with established safety and efficacy standards.

Additionally, lack of specificity could lead to erroneous or inappropriate conclusions in the clinical evaluation, jeopardizing the device’s approval for marketing. In summary, it is essential that each Clinical Evaluation Plan is designed and tailored specifically for the device being evaluated, in line with the guidelines of the MDR 2017/745.

Despite the unique considerations required for each device’s Clinical Evaluation Plan (CEP) under the MDR 2017/745, we understand the value of having a general framework to start from. Therefore, we will provide a template that serves as a starting point for the development of a Clinical Evaluation Plan.

This template will include essential elements required under the MDR 2017/745 such as:

  • Plan rationale
  • Device description
  • Clinical background
  • Identification of pertinent data sources
  • Clinical evaluation method
  • Plan for the appraisal of clinical data.

Remember, this is a guide to help initiate the process and not a final document. You will need to tailor the template to fit your specific device, its indications, target population, risk factors, and other device-specific attributes.

Our intention is to help streamline the process, providing structure while also emphasizing the importance of customization to meet the regulatory requirements.

Clinical Evaluation Plan Template Guidance

To streamline the development process and support compliance with regulatory requirements, this clinical evaluation plan template outlines the recommended structure and content of a Clinical Evaluation Plan (CEP). It helps manufacturers document clinical evidence in line with applicable regulations and guidance.

  • SECTION 1. SUMMARY
  • SECTION 2. REFERENCES
  • SECTION 3. ACRONYMS AND DEFINITIONS
  • SECTION 4. RESPONSIBILITIES
  • SECTION 5. SCOPE OF THE CLINICAL PLAN AS PART OF THE CLINICAL EVALUATION

This section defines the scope of the Clinical Evaluation Plan within the overall clinical evaluation process. It addresses the applicable General Safety and Performance Requirements (GSPR). It also references previous clinical evaluations and the current CEP.

The section explains any deviations from the CEP and justifies them when needed. In addition, it covers the Instructions for Use (IFU), device labeling, and related risk management activities.

SECTION 6. DEVICE DESCRIPTION

This section provides a clear and structured description of the medical device. It includes the device name, classification, and a brief technical overview. It also lists device components, materials, sizes, and available models.

The manufacturer name, generic device group, and device lifecycle stage must be stated. The section also explains the intended purpose of the device and how it achieves that purpose.

In addition, it defines the clinical condition, target patient population, and target user group. Contraindications, warnings, cautions, precautions, and known undesirable effects are documented to support the clinical evaluation.

SECTION 7. CLINICAL BACKGROUND AND STATE OF THE ART

This section describes the clinical background relevant to the device. It identifies the sources used for the clinical evaluation, including applicable standards and guidance documents.

The State of the Art analysis outlines current medical knowledge. It includes benchmark devices and other available treatment options. This comparison supports the assessment of safety and performance.

SECTION 8. EVALUATION OF THE DEVICE

This section explains the type of clinical evaluation performed. It defines the safety and performance parameters assessed during the evaluation process.

When applicable, the section describes how device equivalence is demonstrated. It also identifies the sources of clinical data. These sources may include manufacturer-generated data, data from systematic literature reviews, and post-market surveillance or vigilance activities.

SECTION 9. ANALYSIS OF CLINICAL DATA

This section outlines the methods used to analyze clinical data. It evaluates safety in accordance with GSPR 1 to 8 and performance in line with GSPR 1.

The section also assesses the benefit-risk profile and the acceptability of undesirable side effects, as required by GSPR 8. Any additional clinical claims are reviewed and supported with appropriate evidence.

SECTION 10. CLINICAL DEVELOPMENT PLAN

SECTION 11. ADDITIONAL ITEMS FROM APPENDIX II OF MDCG 2020-6 (LEGACY DEVICE)

This section describes planned or ongoing pre-market and Post-Market Clinical Follow-up (PMCF) investigations, when applicable. It explains how these activities support the clinical evaluation over the device lifecycle.

SECTION 12. PMS AND PMCF PLANS
SECTION 13. FREQUENCY OF CLINICAL EVALUATION UPDATES
SECTION 14. DATES AND SIGNATURES
SECTION 15. ANNEXES

This clinical evaluation plan template provides a structured guide to the essential elements of a CEP. It supports consistent documentation of device description, clinical data requirements, benefit-risk analysis, and post-market clinical follow-up activities.

Why use this Clinical Evaluation Plan Template?

This clinical evaluation plan template provides a structured and practical framework for preparing a compliant CEP. It supports consistent documentation of device description, clinical data requirements, benefit-risk analysis, and post-market clinical follow-up activities. As a result, it helps manufacturers meet regulatory expectations and maintain clinical evidence throughout the device lifecycle.

If you need help preparing your clinical evaluation plan template or developing a compliant Clinical Evaluation Plan, contact us to discuss your project and regulatory needs.

Industry Insights & Regulatory Updates

Clinical Investigation Report for Medical Devices (2023/C 163/06): Preparing your CIR template

What is the Clinical Investigation Report for medical devices, and how to prepare it to comply with the European regulation? Continue reading to learn more.

Following the end of a clinical investigation and irrespective of its outcome, the Regulation (EU) 2017/745 (MDR) and the International Organization for Standardization (ISO) 14155:2020, the Sponsor shall prepare a Clinical Investigation Report (CIR) or sometimes also called the Clinical Study Report for medical devices.

The CIR is a document that provides a comprehensive description and evaluation of the conduct and results of a clinical investigation. The Clinical Investigation Report should be signed by the investigator and shall contain a critical evaluation of all the data collected during the clinical investigation, including any negative findings.

Icing on the Clinical Investigation: The Clinical Investigation Report according (2023/C 163/06)

According to the MDR, the CIR shall be accompanied by a summary presented in terms that are easily understandable to the intended user.

According to Section 7, Chapter III of Annex XV of the MDR, the summary of the CIR should at least cover the title, purpose of the investigation, description of the investigation, investigational design and methods used, the results of the investigation and conclusion of the investigation. Moreover, the completion date of the investigation, and details of early termination, temporary halts, or suspensions of investigations, should also be included.

Considering until recently this was the main requirement for the development of the Clinical Investigation Report, lack of consistency among the summaries presented by different sponsors and, frequently, missing information were common. To address this issue, on May 8th 2023, the European Commission has made available a Commission Guidance (2023/C 163/06) that provides clear instructions and guidance on the content and structure of the clinical investigation report summary, aimed at promoting harmonization, ensuring completeness, and improving the quality of clinical data provided by manufacturers.

Shedding light on the summary of the CIR: Commission Guidance (2023/C 163/06)

The European Commission recently released the “COMMISSION GUIDANCE on the content and structure of the summary of the clinical investigation report (2023/C 163/06)”, which aims to ensure that the summary of the clinical investigation report presents information about the design, conduct, analysis, and results of the clinical investigation in terms and format that are easily understandable to the intended user of the medical device.

The main points outlined in the Commission Guidance are:

  • The guidance is in accordance with Article 77(6) of Regulation (EU) 2017/745, which specifies the requirements of the clinical investigation report.
  • The summary must be concise, avoid copying text from the full report, and be free of promotional content. It should consider the health literacy and numeracy of the intended user(s) of the device.
  • The summary should include the following sections:
  • Cover page with basic information about the clinical investigation, including date of summary, title of clinical investigation, entities sponsoring and funding the study, the single identification number, and the CIP number.
  • Title of the clinical investigation and summary information, including brief and full study titles, start and end date of the clinical investigation, location and reason for temporary halt or early termination, if relevant.
  • Purpose of the clinical investigation, including brief rationale for the clinical investigation, current standard of care and other possible interventions.
  • Description of the investigation device, clinical investigation, and methods used, including eligibility criteria, comparators (if any), procedures to use the device, study design description and justification, objectives and endpoints, sample size, randomization and blinding, follow up duration, concomitant treatments, statistical analysis methods, and substantial modifications of the CIP.
  • Results of the investigation, including participant flow, baseline demographic and clinical characteristics, outcome of the intervention, safety outcomes (adverse events, adverse device effects and device deficiencies), and deviations to CIP.
  • Conclusion of the clinical investigation, including description and discuss of results related to assessment of benefits vs risks, added value of the clinical investigation to the current scientific knowledge, limitations, and potential for future studies.

Clarifications provided by the Commission Guidance (2023/C 163/06)

The Commission Guidance also explains that, prior to the full functioning of EUDAMED, the single identification number is the Clinical Investigation Identification (CIV-ID) number provided by the authorizing Competent Authority. Once EUDAMED is functional, the single identification number should be included.

The Commission Guidance provides orientation on the reasons for temporary halt or early termination expected. These may include positive active findings, positive control findings, safety findings, futility, slow recruitment, or external evidence, among others.

To ensure a clear summary is presented, the Commission Guidance explicitly indicates not to include any results, analysis, conclusions, or discussion points in the description of the investigation device, clinical investigation, and methods used section.

Regarding the description of the investigational device, the Commission Guidance indicates the version/variant and intended purpose including the different components required for the medical intervention(s) involving the device under investigation should be detailed.

The Commission Guidance highlights that a clear definition of the primary and secondary objectives, the hypothesis tested, and the primary and secondary endpoints is crucial for ensuring a good understanding of the clinical investigation.

The Commission Guidance recommends including a table describing any substantial modifications to the CIP, where the relevant versions of the CIP, dates of these modifications, and confirmation of approval of these modifications from an ethics committee should be clearly indicated.

Moreover, the Commission Guidance provides a participant flowchart, and encourages manufacturers to use the provided flowchart or a similar one. It should be considered the flowchart is for randomized two arm studies, and therefore,  it should be adapted to the corresponding study design.

When presenting results, the Commission Guidance recommends the use of absolute numbers instead of percentages directly (e.g., 10/20, not 50%). The type of analysis conducted should be clearly identified: intention-to-treat or per protocol. The adverse events, adverse device effects and device deficiencies should be presented in a listed table in order of most to least frequent, including absolute numbers (X out of YX subjects), percentage (X% of subjects) and whether the events were expected or unexpected. Moreover, only aggregated information related to these events/effects should be presented. If any, the number of subjects withdrawn and reasons, as well as list of subject deaths, should be also included.

In line with the increasing presence of the risk-based approach in regulatory documents, the Commission Guidance indicates that the conclusions of the clinical investigation should be related with a benefit-risk assessment of the intervention in light of the investigation, as well as with a benefit-risk assessment of the investigational medical device in the context of current evidence.

With this new Commission Guidance, entities involved in medical device clinical investigations are expected to improve the quality and consistency of summaries of Clinical Investigation Reports, ultimately enhancing transparency and promoting informed decision-making.

Relationship between Commission Guidance (2023/C 163/06) and other regulatory documents

In the recently released guidance on the summary of clinical investigation reports, there are notable connections to the MDR and ISO 14155:2020. Understanding these relationships can provide better context and improve compliance with both the regulations and the standards.

Commission Guidance and Regulation (EU) 2017/745 (MDR)

The guidance is developed in accordance with Article 77(6) of MDR, which outlines the requirements of the CIR. The MDR aims to ensure a high level of safety and health protection for patients and users while supporting the innovation and competitiveness of the medical device industry.

The key aspects related to MDR found in the Commission Guidance (2023/C 163/06) are:

  • The sponsor of a clinical investigation must submit a study report and summary within one year of the end of the clinical investigation or within three months of the early termination.
  • The minimum requirements of the clinical investigation report are outlined in Section 7, Chapter III of Annex XV of the MDR.
  • The report and summary shall be submitted to Member States through the electronic system referred to in Article 73 of the MDR and become publicly accessible.

Commission Guidance and ISO 14155:2020

The ISO 14155:2020 standard provides guidance on the requirements for clinical investigations of medical devices involving human subjects. It aims to ensure that clinical investigations are designed, conducted, recorded, and reported ethically and scientifically.

The key aspects related to ISO 14155:2020 found in the Commission Guidance (2023/C 163/06) are:

  • The guidance integrates and adapts elements from ISO 14155:2020, particularly in the sections on participant flow, baseline demographic and clinical characteristics, outcome of the intervention, safety outcomes, and limitations.
  • The guidance also refers to ISO 14155:2020 Annex D.7, focused on the presentation of the results in the CIR, and to Annex D.8, addressing the discussion and overall conclusions of the CIR, for further information on those sections of the summary.

Commission Guidance and other MDCG Guidance Documents

MDCG 2021-6 Regulation (EU) 2017/745 – Questions & Answers regarding clinical investigation

The MDCG 2021-6 is Questions & Answers document intended for sponsors of clinical investigations of medical devices conducted within the scope of the Regulation (EU) 2017/745 (MDR).

The Commission Guidance refers to the MDCG 2021-6 to provide more clarity on definitions of the start and end date of the clinical investigations, as well as on substantial modification to the CIP. 

MDCG 2020-10/1 Rev 1 Safety reporting in clinical investigations of medical devices under the Regulation (EU) 2017/745

The MDCG 2020-10/1 Rev1 is focused on proving guidance on safety reporting in clinical investigations of medical devices according to the requirements of the MDR. This document defines Serious Adverse Event (SAE) reporting modalities (in the absence of Eudamed) and includes a summary tabulation reporting format.

Despite the Commission Guidance does not explicitly reference MDCG 2020-10/1 Rev1, the review of this MDCG to complete the safety outcomes in the summary of the CIR is strongly recommended.

In conclusion, the new guidance on the summary of clinical investigation reports is closely aligned with both MDR and ISO 14155:2020. By following the Commission Guidance, entities involved in medical device clinical investigations can ensure compliance with the relevant regulations and standards, ultimately contributing to patient safety and the advancement of the medical device industry.

Relevance of the Commission Guidance: Its Impact on Manufacturers and Clinical Investigations

The Commission Guidance on the content of on the content and structure of the summary of the clinical investigation report (2023/C 163/06) is relevant for several reasons:

  • Provides Clarity: The Commission Guidance provides clarity on the content and structure of the summary of the clinical investigation report, helping manufacturers to prepare high-quality summaries of clinical investigation reports that fulfill MDR 2017/745 and ISO 14155:2020 expectations.
  • Promotes Harmonization: The Commission Guidance promotes a harmonized approach to the content and structure of the clinical investigation report summary, reducing the inconsistencies and confusion among manufacturers, and ensuring a consistent interpretation and implementation of the regulatory requirements.
  • Improves Efficiency: The Commission Guidance provides clear instructions on how to structure and present the summary of the clinical investigation report, making it easier for sponsors to prepare, and for regulatory authorities to review and assess the data, improving the efficiency of the regulatory process.
  • Enhances Patient Safety: The Commission Guidance emphasizes the importance of providing complete and accurate information in the summary of the CIR, promoting patient safety by ensuring that the medical devices on the market have been rigorously tested and evaluated.

Overall, this Commission Guidance document will help to ensure that medical devices on the market are safe and perform as intended by the manufacturer, improving patient outcomes, and enhancing public health.

How can MDx CRO help with a Clinical Investigation Report and its summary?

MDx CRO is a regulatory consulting firm that specializes in helping medical device & IVD manufacturers comply with regulatory requirements in their clinical investigations and clinical performance studies. We offer a range of services to help manufacturers prepare for the new MDR/ IVDR requirements for clinical investigations, from the study design and submission of the clinical regulatory package to Ethics Committees and Regulatory Authorities, to monitorization of the clinical study and preparation of the clinical investigation report and summary.

Written by:
Alberto Bardají

Alberto Bardají

Head of Medical Devices

Senior med-tech expert & ex-Notified Body reviewer with deep experience in high-risk implants, orthopedics, dental & neurology.
Industry Insights & Regulatory Updates

What is the Regulatory Process for IVD in Europe?

What is the regulatory process for IVD in Europe, and which are the most important aspects of it? Continue reading to learn more.

The In Vitro Diagnostic (IVD) market in Europe is regulated by a complex framework, and understanding the regulatory process for IVD is crucial for manufacturers looking to bring their products to market. With the implementation of the In Vitro Diagnostic Regulation (IVDR) in 2022, new requirements and conformity assessment routes have been introduced.

In this article, we will discuss the regulatory process for IVD in Europe, highlighting the importance of IVD consultancy and the role MDx CRO can play in developing technical documentation and managing clinical performance studies for IVDs.

1. Overview of the In Vitro Diagnostic Regulation (IVDR)

The IVDR (EU) 2017/746 came into full effect in May 2022, replacing the In Vitro Diagnostic Directive (IVDD) 98/79/EC. The regulation aims to improve patient safety and the performance of IVDs by introducing more stringent requirements for manufacturers. Some of the significant changes introduced by the IVDR include:

  • A risk-based classification system for IVD devices
  • Strengthened requirements for clinical evidence
  • Increased scrutiny of the IVD technical documentation
  • Increased post-market surveillance (PMS) requirements

2. Risk-based Classification of IVDs

The IVDR introduces a new risk-based classification system, dividing IVDs into four classes (A, B, C, and D) based on their potential risk to patients and public health. This classification system is more aligned with the global risk-based classification approach and helps determine the appropriate conformity assessment route for each IVD device.

3. Conformity Assessment Routes

Under the IVDR, manufacturers are required to follow specific conformity assessment routes based on the classification of their IVD device. The conformity assessment routes include:

  • Self-certification for Class A non-sterile devices
  • Assessment by a notified body for Class A sterile, Class B, C, and D devices

Manufacturers must choose a notified body designated under the IVDR to assess their device’s conformity. The notified body will review the technical documentation, conduct a quality management system (QMS) audit, and issue an EU Technical Documentation Assessment Report and an EU QMS Certificate, which are essential for obtaining a CE mark.

4. Technical Documentation

Technical documentation is a crucial aspect of the regulatory process for IVD in Europe. Under the IVDR, manufacturers must maintain comprehensive technical documentation that demonstrates the safety, performance, and compliance of their IVD device. The technical documentation should include:

  • Device description and specifications
  • Information about the device’s design and manufacturing process
  • Pre-clinical, analytical and clinical performance data
  • Labelling and instructions for use
  • Risk management documentation
  • QMS documentation
  • Post-market surveillance and vigilance data

5. Clinical Evidence and Performance Studies

The IVDR emphasizes the importance of clinical evidence in demonstrating the safety and performance of IVD devices. Manufacturers must conduct clinical performance studies to generate robust clinical evidence that supports their device’s intended purpose, clinical performance claims, and overall safety. The clinical evidence should be periodically updated as part of the post-market surveillance process.

6. Post-Market Surveillance (PMS)

Under the IVDR, manufacturers are required to establish a comprehensive PMS system that monitors the safety, performance, and effectiveness of their IVD device throughout its lifecycle. The PMS system should be capable of identifying and addressing potential risks, non-conformities, and adverse events.

Manufacturers must also establish a Periodic Safety Update Report (PSUR) to provide a summary of the PMS data and any necessary corrective actions.

7. The Role of IVD Consultancy and CRO

Navigating the regulatory process for IVD in Europe can be a complex and time-consuming task. Partnering with an experienced IVD consultancy can significantly streamline the process, ensuring compliance with the IVDR and facilitating a successful market entry. IVD consultancies, such as MDx CRO, offer invaluable support in various areas, including:

  • Developing technical documentation
  • Managing clinical performance studies
  • Designing and implementing a robust QMS
  • Guiding through the risk management process
  • Assisting with post-market surveillance and vigilance activities

8. How MDx CRO Can Help

MDx CRO is a leading IVD consultancy and IVD CRO that specializes in helping manufacturers navigate the regulatory process for IVD in Europe. Our team of experts has extensive experience in developing technical documentation and managing clinical performance studies for IVDs, ensuring compliance with the IVDR.

We offer the following services:

  • Technical documentation development: Our team will work closely with you to create comprehensive technical documentation that demonstrates your IVD device’s safety, performance, and compliance with the IVDR.
  • Clinical performance study management: We design and manage clinical performance studies tailored to your IVD device, generating robust clinical evidence that supports your device’s intended purpose and clinical performance claims.
  • Post-market surveillance support: We assist manufacturers in establishing a comprehensive PMS system, ensuring continuous monitoring of the safety and performance of your IVD device throughout its lifecycle.

Regulatory Process for IVD: Conclusion

Understanding the regulatory process for IVD in Europe is crucial for manufacturers looking to bring their products to market successfully. The IVDR has introduced new requirements and conformity assessment routes that manufacturers must comply with to ensure patient safety and the performance of their IVD devices.

Partnering with an experienced IVD consultancy like MDx CRO can significantly streamline the process, providing invaluable support in developing technical documentation, managing clinical performance studies, and ensuring compliance with the IVDR.

Are you in need of expert guidance and support to navigate the regulatory process for IVD in Europe? Contact MDx CRO today to learn more about our IVD consultancy services and how we can help you successfully bring your IVD device to market.

FAQs

What are the key changes introduced by the In Vitro Diagnostic Regulation (IVDR) in Europe?

The IVDR has introduced several significant changes to the regulatory process for IVD in Europe. Some of the key changes include:

  • A new risk-based classification system for IVD devices, dividing them into four classes (A, B, C, and D) based on their potential risk to patients and public health.
  • More stringent requirements for clinical evidence, emphasizing the importance of conducting clinical performance studies to generate robust clinical data.
  • Increased scrutiny of the IVD technical documentation to ensure the safety, performance, and compliance of IVD devices.
  • Enhanced post-market surveillance (PMS) requirements, mandating manufacturers to establish a comprehensive PMS system that monitors the safety and performance of their IVD devices throughout their lifecycle.

How can an IVD consultancy like MDx CRO help manufacturers navigate the regulatory process for IVD in Europe?

MDx CRO, a leading IVD consultancy, offers expert guidance and support to help manufacturers navigate the complex regulatory process for IVD in Europe. Our services include:

  • Developing technical documentation that demonstrates the safety, performance, and compliance of IVD devices according to the IVDR requirements.
  • Designing and managing clinical performance studies tailored to the specific IVD device, generating robust clinical evidence to support its intended purpose and clinical performance claims.
  • Assisting with the establishment of a comprehensive post-market surveillance system, ensuring continuous monitoring and addressing any potential risks, non-conformities, or adverse events throughout the device’s lifecycle.

By partnering with MDx CRO, manufacturers can ensure compliance with the IVDR and successfully bring their IVD devices to the European market.

Industry Insights & Regulatory Updates

IVDR Compliance Made Easy: The Importance of an IVDR Pre-Submission Assessment

What are the most important things you’ll need to know when it comes to IVDR pre-submission assessment? 

The In Vitro Diagnostic Regulation (IVDR) is a new regulation that took effect on May 26, 2022, replacing the In Vitro Diagnostic Directive (IVDD) and introducing new requirements for manufacturers of in vitro diagnostic medical devices (IVDs). A major change is the increased scrutiny of technical documentation by Notified Bodies (NBs).

To prevent time-consuming and costly NB processes and avoid product rejections, manufacturers can undertake an IVDR Pre-Submission Technical Documentation Assessment with a specialised IVD consultancy like MDx CRO. This assessment comprises a completeness check, consistency check, full review, and comprehensive report.

Why is an IVDR Pre-Submission Technical Documentation Assessment crucial?

An IVDR Pre-Submission Technical Documentation Assessment is a valuable tool for manufacturers striving to comply with the new IVDR requirements. Identifying gaps in technical documentation and offering recommendations for enhancement, this assessment helps manufacturers achieve IVDR compliance, thus ensuring a predictable go-to-market strategy.

Moreover, a pre-submission documentation review prepares manufacturers for the actual Notified Body (NB) review process, enabling them to pinpoint areas needing improvement in their technical documentation and ensuring full preparedness for the NB review.

What does an IVDR Pre-Submission Technical Documentation Assessment entail? 

The review process starts with a completeness check phase. The completeness check verifies the submitted technical documentation is complete, searchable, ensuring all required documents are present and that they meet, on a high level, the requirements of the IVDR as per the specific Notified Body best practice guidance. The output is a completeness check form verified by MDx CRO and a 1st milestone meeting & presentation. 

The assessment proceeds to a full technical documentation review, which involves reviewing all technical documentation submitted by the manufacturer as if it was an actual Notified Body assessment, using our unique knowledge of Notified Body expectations and assessment skills and technique.

This includes checking that all documents meet the requirements of the IVDR and that they are consistent with each other. The output is a comprehensive report and strategic presentation to the client. The full report includes a summary of identified gaps and tracing them to the corresponding IVDR requirements.

It also includes a high-level quality plan with an outline of recommendations to achieve IVDR compliance. The solutions range from providing justifications for nonapplicable requirements to providing recommendations for documentation updates, remedial product testing, or closing clinical evidence gaps.

The final step involves conducting a consistency check, to verify the coherence of the technical documentation. This includes checking that all documents are consistent with each other and that there are no contradictions or errors, including in the intended purpose, product descriptions, codes applied, benefits and risks, among others.

Inconsistency of technical documentation is one of the top findings of Notified Bodies and with limited opportunities for product approval, this is an area manufacturers should be particularly vigilant about.  The output of MDx assessment is a redline through the technical documentation for consistency, which will serve as a remediation plan. 

What is included in our Full Technical Documentation Review?

Our assessment of IVD technical documentation includes a comprehensive evaluation of all aspects of the documentation, following a similar process of the Notified Body (NB), in compliance with Annex II and Annex III of the EU IVDR 2017/746.

Our analysis involves a comprehensive examination of the documentation’s depth, taking into account various factors such as risk classification, suitability of product claims, intended use, and current industry standards.

Moreover, we assess the device’s compliance with regulatory requirements and its traceability, from labelling to design inputs, manufacturing, design outputs, verification, validation, and post-market surveillance (PMS).

Our assessment includes a thorough evaluation of clinical evidence data and the performance evaluation process, ensuring the device’s benefit/risk acceptability is appropriate. Furthermore, we include an evaluation of post-market surveillance (PMS), including the Post-Market Performance Follow-up (PMPF), to identify any potential issues that may arise with the device’s use and ensure its continued safety and effectiveness.

In summary, our assessment covers all aspects of technical documentation review to ensure that the medical device is safe and effective for its intended use, meeting all regulatory requirements.

In addition, we provide customized solutions to our clients. One area that manufacturers often seek our expertise is in clinical evidence, which is a popular area for them to validate. As noted by Carlos Galamba, MDx CRO’s Founder and former BSI Internal Clinician, “Clinical performance alone accounts for 40% of all notified body findings

Detailed Scope​:

Our pre-submission technical documentation review can cover some or all of the following areas:

  • Device description, intended purpose, classification review and product claims
  • Declaration of conformity 
    • Regulatory requirements, review of strategy for DoCs covering multi-products​
  • Information supplied by the manufacturer, 
    • Regulatory review of labels and IFUs for compliance with regulatory and harmonized standards​
    • Review of specific requirements for self-tests and near patient tests.​
  • Design and manufacturing information
    • Design specifications, determination of critical ingredients, Notified Body methods for assessment of hazardous substances (CLP and REACH compliance), ​
    • Manufacturing processes, appropriateness of quality control testing and specifications​
    • Specific design aspects for self-testing & near-patient testing devices​
  • General Safety and Performance Requirements (GSPRs)
    • Review process, applicability and methods used for compliance. ​
  • Electrical safety and Electromagnetic compatibility where applicable
  • Software verification & validation where applicable
  • Full Risk management review: 
    • Plans, procedures, reports. ​
    • Review of technology-based risks in the areas of design, production and user/product risks.​
  • Product verification and validation: 
    • Specimen: claims, sample types, storage handling and transport conditions​
    • Stability: packaging validation, in-use stability, transport stability, shelf-life and specimen stability.​
  • Full performance evaluation and clinical evidence assessment: ​
    • Performance Evaluation Plan (PEP), Scientific Validity Report (SVR), Analytical Performance Report (APR), Clinical Performance Study Plans and Reports (CPSP and CPSR), Clinical Performance Report (CPR), Performance Evaluation Report (PER), usability study protocols and reports, Summary of Safety and Performance (SSP). Includes a review of the appropriateness of the performance strategy based on claims and patient populations. ​
  • Standards and guidelines
    • Assessment of the device against EU Common Technical Specifications, technical state of the art guidance (e.g. CLSI guidelines, WHO), harmonized standards and regulatory requirements ​
  • Post Market Surveillance: 
    • Review of complaints data, trend analysis and vigilance. Adequacy of PMS and PMPF plans for product type. Evaluation of the outputs of PMPF, PMS reports and PSURs.

What are the benefits of undergoing an IVDR Pre-Submission Technical Documentation Assessment?

Undergoing an IVDR Pre-Submission Assessment can provide several benefits for manufacturers. These include:

  • Avoiding costly Notified Body (NB) processes and product rejections: By identifying gaps in technical documentation early on, manufacturers can avoid lengthy and costly NB processes and product rejections.
  • Reducing time to market: By identifying areas where they need to improve their technical documentation early on in the development process, manufacturers can avoid costly delays later on.
  • Ensuring compliance with IVDR requirements: The IVDR introduces new requirements for clinical evidence, performance evaluation, and risk management. By undergoing an IVDR Pre-Submission Technical Documentation Assessment, manufacturers can ensure that their documentation meets all requirements and is fully prepared for NB review.
  • Improving product safety and effectiveness: By identifying gaps in technical documentation and providing recommendations for improvement, manufacturers can ensure the safety and effectiveness of their products.

How can MDx CRO help with an IVDR Pre-Submission Technical Documentation Assessment? 

MDx CRO is a regulatory consulting firm that specializes in helping medical device & IVD manufacturers comply with regulatory requirements. We offer a range of services to help manufacturers prepare for the new IVDR requirements, including pre-submission technical assessments and remediation solutions.

Our team of experts has extensive experience in scientific validity reports for EU IVDR submission, regulatory affairs, quality assurance, clinical research, and medical writing. We work closely with our clients to identify gaps in their technical documentation and provide recommendations for improvement.

By working with MDx CRO, manufacturers can ensure that their technical documentation meets all IVDR requirements and is fully prepared for NB review. Our services can help manufacturers avoid costly delays and product rejections while ensuring the safety and effectiveness of their products.

This proactive approach not only saves time and resources but also ensures the continued success of IVD manufacturers in the ever-evolving regulatory landscape.

FAQ

What is IVDR and why does it matter for IVD manufacturers?

The In Vitro Diagnostic Regulation (IVDR – EU 2017/746) replaced the previous IVDD framework. It also introduced stricter requirements for clinical evidence, performance evaluation, risk management, and technical documentation. One of the most significant changes is the increased scrutiny by Notified Bodies (NBs), meaning manufacturers must present more robust, structured, and consistent technical files to achieve certification.

What is an IVDR Pre-Submission Technical Documentation Assessment?

An IVDR Pre-Submission Technical Documentation Assessment is a structured review of your technical documentation before submission to a Notified Body.
It simulates the NB assessment process and helps identify:
Gaps in documentation
Missing or inconsistent data
Weak clinical evidence
Risk management deficiencies
Non-compliance with IVDR requirements
The goal is to ensure your documentation is complete, consistent, and submission-ready.

Why is a pre-submission assessment important?

Under IVDR, NB capacity is limited and rejection risks are high. A pre-submission review helps you:
Avoid costly and time-consuming NB findings
Reduce the risk of product rejection
Shorten time to market
Strengthen your regulatory strategy
Ensure predictable approval timelines
Early gap identification prevents major remediation efforts later.

What are the main phases of the assessment process?

The process typically includes three key stages:
1. Completeness Check
2. Full Technical Documentation Review
3. Consistency Check

What is included in a Full Technical Documentation Review?

A comprehensive review covers:
-Device description and intended purpose
-Risk classification and product claims
-Declaration of Conformity
-Labeling and IFU regulatory compliance
-Design and manufacturing information
-General Safety and Performance Requirements (GSPRs)
-Risk management files
-Verification and validation data
-Stability studies and specimen handling
-Software validation (if applicable)
-Electrical safety and EMC (if applicable)
-Performance evaluation and clinical evidence
-Post-Market Surveillance (PMS) and PMPF
-Compliance with harmonized standards and EU Common Technical Specifications
-Special attention is typically given to clinical evidence and performance evaluation, as these are frequent areas of NB findings.

Why is clinical evidence such a critical focus area?

Under IVDR, performance evaluation requirements are significantly expanded.
Clinical performance, scientific validity, and analytical performance must be clearly demonstrated and aligned with product claims and intended use.
Weak or incomplete clinical evidence is one of the most common causes of NB findings, making early review essential.

What common issues does a pre-submission review uncover?

Frequent findings include:
Inconsistent intended purpose statements
Unsupported product claims
Gaps in clinical performance data
Incomplete risk management documentation
Misalignment between labeling and technical files
Missing traceability between design inputs and validation outputs
Weak PMS or PMPF planning
These issues can delay certification if not addressed early.

How does this assessment reduce time to market?

By identifying documentation gaps before NB submission, manufacturers can:
Avoid iterative rounds of NB questions
Reduce major non-conformities
Prepare structured responses in advance
Align internal teams around a remediation plan
This proactive preparation significantly shortens the approval cycle.

Who should consider an IVDR Pre-Submission Assessment?

This assessment is especially valuable for:
Manufacturers transitioning from IVDD to IVDR
Class C and Class D device manufacturers
Companies with limited internal IVDR expertise
Organizations with new clinical evidence requirements
Manufacturers planning first-time NB submission

How can MDx CRO support IVDR compliance?

MDx CRO provides structured pre-submission technical documentation reviews and tailored remediation strategies.
Support includes:
Full IVDR Annex II & III documentation review
Clinical evidence validation
Performance evaluation gap analysis
Risk management alignment
PMS and PMPF strategy review
Regulatory strategy consulting
By working with experienced regulatory and clinical experts, manufacturers can strengthen submission readiness and reduce approval uncertainty.

What are the overall benefits of undergoing this assessment?

An IVDR Pre-Submission Assessment helps manufacturers:
Minimize regulatory risk
Improve documentation quality
Strengthen clinical justification
Enhance product safety and effectiveness
Avoid costly rework
Achieve more predictable regulatory outcomes

Written by:
Carlos Galamba

Carlos Galamba

CEO

Senior regulatory leader and former BSI IVDR reviewer with deep experience in CE marking high-risk IVDs, companion diagnostics, and IVDR implementation.
Industry Insights & Regulatory Updates

IVD Software Development: How to Bring IVD Software to Market in 8 Steps

The healthcare industry is undergoing a rapid transformation spurred by the advent of advanced medical diagnostic technology. IVD software development is a critical component of this revolution as it allows for testing, analysis, reporting, and communication without needing a physical laboratory or a visit to a doctor’s office.

Bringing IVD software development to the market can benefit patients and healthcare providers who can deliver quality care faster with fewer resources.

Projected size of the IVD market worldwide from 2018 to 2027 (in million U.S. dollars)

Source: Statista

The above graph shows the In-Vitro Diagnostics (IVD) market globally was estimated at 72.4 billion U.S. dollars in 2020, with a projected growth of 108 billion U.S. Dollars by 2027, showing its increased relevance in the healthcare industry today.

1. Conduct Market Research

Before starting the development process,  organizations must conduct market research and understand their target market, user needs, and potential competitors.

Market research should also help determine regulatory requirements that organizations must comply with and any current trends within the industry or technology space.

Below are some key points to consider when conducting market research for IVD software development:

  • Identify regulatory requirements: Identifying the regulatory requirements for your software is essential for bringing your product to market. They may vary depending on your target market, such as the FDA in the US or the European Union’s CE marking requirements (IVDR 746/2017).
  • Determine your target market: Identify the segments of the healthcare industry that your IVD software will serve. Consider factors such as geography, type of healthcare organization, and specialty areas.
  • Identify your competitors: Research the IVD software market to identify your competitors and their products. Analyze their strengths, weaknesses, pricing, and marketing strategies.
  • Understand your customers: Conduct surveys, interviews, and focus groups with healthcare professionals to understand their needs, preferences, and pain points. Use this information to tailor your IVD software to meet their specific needs.
  • Analyze market trends: Stay up-to-date on the latest trends and developments in the IVD software market. Monitor industry publications, attend conferences, and follow industry experts and thought leaders on social media.
  • Determine pricing strategy: Consider costs, target market & competition when determining pricing strategy, e.g., one-time fee. Subscription fee? Per-test fee?

2. IVD Software Classification

Understanding the classification of your IVD software is crucial before starting the planning and design process. Determine whether the IVD software is a standalone IVD medical device or a component of a larger system.  To be qualified as an IVD medical device software in the EU, the product must fulfil the definition of IVD according to Article 2(2) of Regulation IVDR 746/2017, as described in the Figure 1. The correct classification of IVD software should be done based on the rules described in Annex VIII of the IVDR. Relevant guidance documents, such as MDCG 2019-11 are also essentials for the qualification and classification of IVD software.

Fig. 1 – MDCG 2019-11 flowchart on qualification of Medical Device Software (MDSW)

Familiarize yourself with relevant regulatory frameworks, guidances and standards such as ISO 13485, IEC 62304, but also specific guidance documents published by regulators, which provide specifications and guidelines for developing, validating, and maintaining IVD software.

3. Plan and Design the Software

The next crucial step of a successful IVD software development is design and planning.

  • A well-documented and robust planning process can help provide a more detailed roadmap for development.
  • During this phase, design reviews, testing, and verification will ensure that the final version meets user requirements.
  • It is essential to incorporate user feedback at every stage of the design process to develop an intuitive interface that works effectively according to their needs.
  • Obtaining feedback from customers and stakeholders offers the development team opportunities to recognize potential concerns and areas for enhancement.
  • Developers can devise software solutions that fulfill customer needs and address their grievances by integrating feedback.
  • The importance of accurate documentation should not be underestimated as it helps trace back issues later on in the lifecycle of the software.
  • The development team must consider scalability and flexibility during the initial planning and design stages when creating the software.

4. Develop and Test the Software

Developing and testing the software is crucial in creating a working prototype.

  • The development phase is necessary to ensure the accuracy of the design, coding, and algorithms used in creating the software solutions.
  • Testing and quality assurance also play an essential role in ensuring the products meet all requirements before launch.
  • It is essential for companies to thoroughly assess each component of their software as part of this process. This includes ensuring they meet performance objectives concerning speed, responsiveness, scalability, security, reliability, and ease of use for their users.
  • Quality assurance checks help identify bugs or errors to release a defect-free product that meets all standards from regulatory bodies such as FDA or CE Marking.
  • When deploying IVD systems, manufacturers need to consider if their applications can be flexible enough to support new technological advances; future-proofing their products becomes increasingly necessary where customers demand longevity across upgrades or iterations over time.

5. Prepare a Regulatory Submission

Preparing a regulatory submission package is critical in bringing IVD software development to market. This step involves compiling documents to demonstrate that the software meets regulatory requirements and is safe and effective.

Here are some critical considerations for preparing a regulatory submission:

  • Gather relevant documents for the package

Understand regulations, standards, and risk classification of IVD software and the manufacturing role. Key documents to include are the device description, technical documentation, risk management file (ISO 14971), software lifecycle documentation (IEC 62304), and quality management system documentation (ISO 13485). Risk management must be applied and monitored during the IVD software development life cycle.

  • Prepare a performance evaluation report (PER)

This will require a comprehensive analysis of scientific evidence showing that the product meets user needs safely and effectively. IVD software performance evaluation should be prepared in accordance with relevant guidance documents, such as MDCG 2020-1 for the EU. Other guidance such as MedTech Europe Clinical Evidence Requirements for IVD can also be a good source of  additional information.

Clinical performance studies are aimed at providing evidence of the safety and effectiveness of a product’s intended purpose to ensure that it’s able to diagnose, monitor and predict diseases and conditions accurately.

As described in MDCG 2020-1 “Validation of the clinical performance should be considered at each change of the software to a new release. If no validation is performed, a justification should be stated in the technical documentation. With a validation of clinical performance, it is demonstrated that users can achieve clinically relevant outputs through predictable and reliable use of the MDSW”.

Adherence to relevant standards and guidelines, such as ISO 20916 (Clinical Performance Studies for In vitro diagnostics) and Good Clinical Practice (CGP), are crucial for the successful execution of clinical studies.

  • Ensure data accuracy

Ensure that that any data collected from testing is presented accurately to prove safety and efficacy before submitting your application. This includes validation and verification data, performance evaluations, and, if applicable, results from clinical studies. Carefully review all information for accuracy and completeness before submitting it.

6. Obtain Regulatory Approval

You need to obtain regulatory approval to bring IVD software development to market. Successful approval enables you to market and sell your software in compliance with local laws and regulations.

  • Familiarize yourself with the applicable regulatory frameworks and guidelines for your software. These may include ISO 13485 (quality management systems), IEC 62304 (medical device software lifecycle processes), ISO 14971 (risk management), and MDCG guidance documents such as MDCG 2019-11 (qualification and classification of software in the medical device regulations) and MDCG 2020-1 (guidance on performance evaluation for IVD software under the IVDR. You should also consider guidelines from other jurisdictions depending on your market strategy. The FDA for example has issued guidance for software as a medical device (SAMD).
  • Develop a comprehensive application package that should include all the necessary documents, data, and tests required for review. Ensure your package addresses regulatory requirements, such as conformity assessment procedures, clinical evidence, and post-market surveillance.
  • Submit the application package to the relevant regulatory authorities for review, such as the FDA in the US or notified bodies in the EU under the In Vitro Diagnostic Regulation (IVDR) 2017/746.
  • Be prepared to respond quickly and accurately to any feedback or additional information requests from regulatory agencies during the review process.
  • Make recommended changes swiftly as part of your submission to obtain approval from agencies successfully.
  • Once you receive approval from regulatory agencies, you can move forward with marketing and selling your software according to local laws & regulations, ensuring ongoing compliance with any post-market requirements.

7. Developing Marketing and Sales Strategies

Creating a successful marketing and sales strategy is essential for bringing IVD software to the market, it allows for faster positioning and gaining a competitive advantage. Make sure to develop a strong brand identity with messaging that resonates with your audience.

In addition, researching customer needs and understanding key industry trends can create a more targeted approach when it comes to the marketing of IVD software solutions, increasing your likelihood for success.

Make sure to use multiple channels such as paid advertising, email campaigns, social media and webinars to reach out to potential customers from diverse segments.

And last but not least, creating effective communication strategies to engage with customers throughout the sales cycle will also be key to promoting IVD products successfully.

8. Launch and Support the Software

Launching and supporting software is a crucial element to its success. The product can be improved over time by providing regular updates and customer service, and users can get the best experience.

Here are some points to consider when launching your IVD software development:

  • Create a comprehensive support plan that puts customer needs first. Ensure you have an efficient process for handling inquiries and technical issues as they arise.
  • Ensure that all necessary software updates are completed on schedule, so users don’t experience any delay in accessing the product’s full features or bug fixes.
  • Assess the regulatory impact of changes and bug fixes, changes to your IVD software may or may not be significant. Consider whether changes impact your regulatory approvals. MDCG 2022-6 provides additional guidance on changes to design and intended purpose in the context of the new transition timelines for IVDs in Europe.
  • Set up user feedback forms or surveys so customers can share their thoughts on the product’s performance and what improvements they want to see. This will help drive further development of the software over time.
  • Offer ongoing training opportunities for new features, so users feel confident using them once released. This will also ensure that customers know how to use their investment in your IVD software development solution fully.

Revolutionizing Healthcare With IVD Software Development

In vitro diagnostic (IVD) software development has transformed the healthcare industry by providing cost-effective testing, analysis, reporting, and communication solutions without physical laboratory equipment.

Studies indicate that healthcare providers highly prioritize in vitro diagnostic (IVD) procedures, and their optimization has the potential to enhance patient outcomes. Therefore, the development of IVD software is crucial in facilitating quicker and more accurate diagnostic results, ultimately leading to the optimization of healthcare practices.

If you need a partner in IVD software development for your business, MDx CRO is an IVD consultancy that provides end-to-end solutions to accompany you at each step of the process. Our team of highly experienced CRO strategists has extensive expertise in bringing innovative medical devices and IVD technologies to market. Request your expert consultation today.

FAQs

What are the key considerations when designing IVD software?

There are several key considerations that companies should keep in mind when designing IVD software: user requirements, regulatory requirements depending on the target geographic location, data accuracy and effective data management, the software’s ability to integrate with other systems, as well as performance and usability.

What are the regulatory requirements for IVD software development in Europe?

The regulatory requirements for IVD software development in Europe are determined by the In Vitro Diagnostic Regulation (IVDR), which became applicable on May 26, 2022. They include, but are not limited to design and development, risk management, validation and verification, as well as compliance with GDPR.

What are the most common challenges in IVD software development?

The most common challenges in IVD software development include regulatory compliance (which can be complex and challenging to navigate through), ensuring integration compatibility with other systems, effective data management, and great user experience, among others.

How do you ensure the quality and reliability of IVD software?

To ensure the quality and reliability of IVD software, it’s important that companies follow all regulatory guidelines applicable to their geographical location, and use a quality management system to ensure that the development process is well-documented. Conducting testing, validation and verification processes is another essential element of software development for in vitro diagnostics.

Industry Insights & Regulatory Updates

What to Consider When Developing an IVD Clinical Performance Study for IVDR Compliance

In vitro diagnostic (IVD) devices are essential in healthcare as they provide accurate and reliable diagnostic information to healthcare providers. The development of an IVD device involves several stages, including research and development, design and prototyping, verification and validation, regulatory approval, and commercialization.

One of the critical steps in IVD development is the conduct of an IVDR clinical performance study to generate reliable and meaningful data to support regulatory approval and the device’s commercial success. In Europe, the in-vitro diagnostic regulation (EU IVDR) is now in force and all new products to market must meet very strict requirements of clinical performance.

The role of ISO 20916 in IVDR clinical performance studies

The design and execution of an IVD clinical performance study are critical to its success, and several factors must be considered to ensure that the study generates reliable and meaningful data. The International Organization for Standardization (ISO) has developed ISO 20916, a standard that provides guidance on the design and conduct of clinical studies for IVD medical devices. The standard is intended to help manufacturers, regulators, and other stakeholders ensure that IVD clinical performance studies are designed and conducted in a consistent and scientifically rigorous manner.

ISO 20916 covers several important aspects, including study design, sample size determination, selection of appropriate endpoints, statistical analysis, and reporting of study results. The standard emphasizes the importance of designing studies that are appropriate for the intended use of the IVD device and that incorporate good clinical practice (GCP) principles.

The plan should specify the study objectives, inclusion and exclusion criteria for study participants, study endpoints, and statistical analysis plan, amongst many other requirements. It should also include procedures for data management and quality control to ensure the accuracy and reliability of the data collected.

Another important aspect of ISO 20916 is the requirement to ensure the safety and well-being of study participants. The standard emphasizes the importance of obtaining informed consent from study participants and protecting their privacy and confidentiality. The standard also requires that studies be conducted in compliance with ethical principles and regulatory requirements.

Alignment with EU IVDR

In addition to ISO 20916, the implementation of the EU IVDR has increased the importance of conducting IVD clinical performance studies as they are required for regulatory compliance. The IVDR replaced the previous In Vitro Diagnostic Directive (IVDD) and introduced more stringent requirements for IVD devices, including clinical evidence requirements. IVD manufacturers are now required to demonstrate clinical evidence that supports a device’s intended purpose and its’ safety and performance. This is particularly important, because insufficient clinical evidence could ultimately lead to a product refusal at the Notified Body resulting in additional costs and delays to bringing product to market.

Amongst many requirements, an IVDR clinical performance study is designed and conducted in compliance with GCP principles. ISO 20916 has additional requirements, and both the regulation and the standard should be considered by all diagnostic manufacturers when developing clinical performance study plans or protocols.

How can MDx CRO help?

MDx is a Medical Device & IVD Contract Research Organization (CRO) that can help IVD device manufacturers with their clinical performance studies by providing a range of services, including:

  • study design
  • site selection
  • patient recruitment
  • study monitoring
  • data management
  • statistical analysis

MDx has extensive experience in conducting clinical performance studies for IVD devices and a deep understanding of the regulatory requirements for these studies. Our team of professionals is well-trained and experienced in managing all aspects of the study, from protocol development to study execution and data analysis. We work closely with our clients to ensure that their studies are designed and conducted in compliance with applicable regulations and guidelines and that they generate reliable and meaningful data.

Conclusion

Conducting an IVD clinical performance study is a critical step in the development and commercialization of an IVD device. By following best practices, working with experienced professionals, and selecting the right CRO, IVD device manufacturers can generate reliable and meaningful data that can support regulatory approval and the device’s commercial success, ultimately benefiting patients and healthcare providers. Adherence to the IVDR and the ISO 20916 standard can help ensure that the data generated is acceptable for regulatory submission and meets the safety and performance requirements for IVDs.

Industry Insights & Regulatory Updates