Dan, it's an RA truism that it is prudent to use the same terminology as the regulators.
This can be difficult when regulators themselves are not so good with terminology. The MDR refers to both a clinical evaluation assessment report (?!?) and a clinical evaluation report. It also refers to clinical evaluation documentation. However in Article 62, which describes the requirements for a clinical evaluation, it says that the clinical evaluation, its results, and the associated clinical evidence must be documented in a clinical evaluation report. I don't see much wisdom in referring to a report that has been issued to meet this requirement as anything other than a clinical evaluation report.
It is also useful for clarity of communication, because the EU clinical evaluation report is not the only type of clinical report required across all jurisdictions. One of the first things I ask someone who says they want me to write a clinical evaluation report is whether they are referring to the report that is required to support CE certification.
In any case, good luck with words and thought processes. Neither the MDD nor the MDR make any reference to a technical file, some NBs have gone so far as to emphasize this in their training, all to no avail.
As for your concern that following the clinical evaluation process in the MEDDEV will not assure compliance with the EU-MDR clinical evaluation process, assuring compliance is not the purpose of the MEDDEV. It's purpose is to provide useful guidance to those seeking to conduct a meaningful clinical evaluation. Assuring compliance is a very different activity, done by different people, at a different time, for a different purpose. When people talk about pursuing compliance over quality, this is what they mean. That's fine for auditors. It's their job, after all. It is not fine for people who are doing the work to be audited.
------------------------------
Julie Omohundro, ex-RAC (US, GS), still an MBA
Principal Consultant
Class Three, LLC
Mebane, North Carolina, USA
919-544-3366 (T)
434-964-1614 (C)
julie@class3devices.com------------------------------
Original Message:
Sent: 06-Apr-2019 11:22
From: Dan O'Leary
Subject: MDR - Clinical Evaluation Reports
The EU-MDR does not specify the qualifications or organizational requirements for the author of a clinical evaluation report.
There are a few issues that I wish to raise.
I recommend that we stop using the term clinical evaluation report, CER, when referring to the process required by the EU-MDR Article 61. Under the MDD, the result was the CER and it became a shorthand. However, under the EU-MDR there is a more defined process which requires plans, reports, and updates. I think it would be better to refer to the clinical evaluation process rather than one output, the CER.
I'm concerned about using MEDDEV 2.71 revision 4 for the EU-MDR. The MEDDEV is written for the MDD and includes things that are not explicit in the MDD. The EU-MDR has many explicit requirements and they do not align with the MEDDEV. My concern is that following the clinical evaluation process in the MEDDEV will not assure compliance with the EU-MDR clinical evaluation process.
Article 8 suggests there may be harmonized standards for clinical evaluation. I don't believe there is an EN standard for clinical evaluation, let alone a harmonized standard.
Article 9 suggests there may be common specifications for clinical evaluation, but there are none yet.
Until we have clarifying documentation on clinical evaluation, my recommendation is to become familiar with the EU-MDR requirements as new requirements. Develop your company's clinical evaluation process based solely on the EU-MDR. Consider the MEDDEV as background reading and not as the EU-MDR methodology.
------------------------------
Dan O'Leary CQA, CQE
Swanzey NH
United States
Original Message:
Sent: 04-Apr-2019 10:53
From: Anonymous Member
Subject: MDR - Clinical Evaluation Reports
This message was posted by a user wishing to remain anonymous
Hello. I have been told by multiple regulatory professionals that under the MDR CERs must be written by a medical professional or CRO. I performed a search in the MDR and cannot locate anything that specifically states this. Does anyone know where I can find this information to quote? Thanks in advance.