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.

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