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  • 1.  Reporting cclinical investigation results in a Clinical Evaluation Report

    This message was posted by a user wishing to remain anonymous
    Posted 12-May-2023 08:15
    This message was posted by a user wishing to remain anonymous

    Dear All,

    I am wondering when a manufacturer-sponsored clinical investigation resulted in a publication, does the manufacturer besides reporting the publication which will show up in a literature search, need to also discuss the clinical investigation itself within a Clinical Evaluation Report? I assume both need to be included in the CER, especially since the clinical investigation plan/report contains more details on the study conduct as compared to published article.
    Thanks!



  • 2.  RE: Reporting cclinical investigation results in a Clinical Evaluation Report

    Posted 12-May-2023 12:00

    The word 'sponsored' is a bit ambiguous here. It could mean that the manufacturer is the sponsor, as defined in the regulations. In that case, these would be manufacturer-owned investigation results and they should be discussed in the appropriate section. The publication should also be listed, but the results should only be counted once for the final evaluation. If you mean that the manafucturer helped for example an investigator initiated study by providing devices for free (this could be seen as 'sponsoring' as well), I would treat this publication as any other publication, with a note that the devices were provided for free. 



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    Ronald Boumans
    MDR Expert
    Super PRRC
    Netherlands
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  • 3.  RE: Reporting cclinical investigation results in a Clinical Evaluation Report

    Posted 14-May-2023 08:08

    Good day Anon,

    The simple answer is yes, you would want to clearly identify clinical investigations which are under the prevue/control/management of the company and those which get published in clinical literature or journals.  Usually what I do is in the Clinical Evaluation Report (CER) have a separate section for "clinical investigations" where these are clinical investigations managed by the company.  You are correct, usually the clinical investigation protocol and clinical investigation report can then be referenced by the CER (kept these in the document control system as well) providing much more detail.  Then during the clinical literature search, the journal which is reporting the clinical investigation can show up again or the company may already know the publication information.  What I do then is make a clear indication in the analysis section that these two are related.  Meaning, in the clinical investigation summary make a note the trial was published as "Title" by Author, et. al., etc.  Then in the clinical literature summary make a note Article # is the published part of Clinical Investigation 999.  Strongly recommend putting these put in the CER and linking them together in some way.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: Reporting cclinical investigation results in a Clinical Evaluation Report

    Posted 15-May-2023 03:15

    Dear Anon

    Further to those previous comments with the EU perspective....
    All clinical data - published or non-published data - will be expected to be included in the CER by the notified bodies. 
    All data addressing the safety and effectiveness of the medical device including a short summary of the performed V&V and their results will assist in getting the approval of your device. 
    Generally, for completeness, we give a short synopsis of the Clinical Investigation Protocol (CIP) and of course include the results, discussion, conclusions and highlight the limitations. 

    Best Regards,
    Stephanie



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    Stephanie Grassmann
    Founder & Managing Director of MedTechXperts Ltd
    Biberstein
    Switzerland
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  • 5.  RE: Reporting cclinical investigation results in a Clinical Evaluation Report

    Posted 15-May-2023 09:10

     

     

    Hi Anon,

     

    Based on experience from something like a hundred CERs written at MED, I agree with the advice you got from Richard and Stephanie, as well as your posted thinking: the company's internal data is almost certainly more detailed than what is in the publication, and those details (as applicable) should be included in the CER.  As both advisors noted, the overlap should also be described, to the extent you can determine it.

     

    For what it's worth, here's a link to a blog post on CERs that may be of interest...

     

    https://medinstitute.com/download/clinical-evaluation-plan-cep-6-content-considerations/

     

    Best regards,

     

    Ted

     

    --

    Theodore (Ted) Heise, PHD, RAC

    Vice President Regulatory and Clinical Services

     

    MED Institute Inc.

    1330 Win Hentschel Blvd.

    West Lafayette, IN  47906-4149 USA

    765.340.7819

    http://medinstitute.com

    theise@medinstitute.com