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MDR - Clinical Evaluation Reports

  • 1.  MDR - Clinical Evaluation Reports

    This message was posted by a user wishing to remain anonymous
    Posted 05-Apr-2019 11:38
    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.


  • 2.  RE: MDR - Clinical Evaluation Reports

    Posted 05-Apr-2019 14:13
    Please refer to MEDDEV 2.71 revision 4 for Clinical Evaluation guidance. It is true that experience matters which most RA consultants have. But that is not to say it can't be written internally. Anyone with the degree/experience in the guidance can potentially write a CER and it is valid as long as meets the guidance requirements.

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    Vidyalakshmi Jayaraman
    RA Specialist
    Marlborough MA
    United States
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  • 3.  RE: MDR - Clinical Evaluation Reports

    Posted 06-Apr-2019 08:44
    I agree with Vidyalakshmi in that the MEDDEV provides, just as FDA does with guidances, the "current thinking" about what is expected.  In this case, it is not necessary that a clinical evaluation be authored by, but should be reviewed and signed off by an appropriate medical professional.

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    James Bonds J.D.
    Director Regulatory Affairs
    Atlanta GA
    United States
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  • 4.  RE: MDR - Clinical Evaluation Reports

    Posted 06-Apr-2019 05:18
    As Vidyalakshmi has already pointed out it's in the MEDDEV 2.7/1 version 4 guidance at Clause 6.4 on pages 14-15.  Copy of guidance is attached below.

    The authorship of reports has always been a tricky issue down here in Australia, where for many years TGA has already had the requirement that CER are written by, or at least endorsed by a clinician experienced in the device use (See TGA guidance which is shorter than. MEDDEV but also based around the same principles, with some useful additional chapters on specific devices.  Copy also attached below).  It used to be that Europe under MDD/prior versions of MEDDEV 2.7/1 accepted CERs written by product specialists from the design team.  So CERs originating in Europe have frequently been required to be upgraded for Australian approvals.

    Now that has all changed.  The new MEDDEV actually goes further.  it requires that the CER be prepared by a team of experts - including product experts, biostatistician, medical writer, librarian as appropriate to the scope and scale of the report.

    We published a training video on CERs to meet global requirements this month - you may want to review - click here to view 

    Arthur

    ------------------------------
    Arthur Brandwood PhD FRAPS
    Founder and Principal Consultant
    Brandwood Biomedical
    Sydney, Australia
    Arthur@brandwoodbiomedical.com
    ------------------------------

    Attachment(s)



  • 5.  RE: MDR - Clinical Evaluation Reports

    Posted 06-Apr-2019 17:32
    Thx Arthur for the detailed responses and Dan's clarifying details which you expanded on.  I agree as the <g class="gr_ gr_58 gr-alert gr_spell gr_inline_cards gr_run_anim ContextualSpelling ins-del multiReplace" id="58" data-gr-id="58">NBs</g> are still auditing to the MDD  MEDDEV 2.7/1 rev 4 needs to be met currently to meet MDD requirements.

    ------------------------------
    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
    ------------------------------



  • 6.  RE: MDR - Clinical Evaluation Reports

    Posted 06-Apr-2019 11:22

    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
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  • 7.  RE: MDR - Clinical Evaluation Reports

    Posted 06-Apr-2019 15:35
    Dan thanks for your thoughtful post.  You are right that the MDR goes far beyond the Clinical Evaluation Report.  

    Version 4 was written as a kind of transitional step. Which is why it includes some things (like the extended qualifications and team approach ) which are not in the MDD.

    I understand that there are already plans for a version 5 as the MDR comes in to force.

    But meanwhile, Notified Bodies are all auditing to version 4 as they continue operating to MDD.  So it needs to be more than background reading in the here and now.

    ------------------------------
    Arthur Brandwood PhD FRAPS
    Founder and Principal Consultant
    Brandwood Biomedical
    Sydney, Australia
    Arthur@brandwoodbiomedical.com
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  • 8.  RE: MDR - Clinical Evaluation Reports

    Posted 07-Apr-2019 06:31
    IMDRF recently published this. 

    Proposed update to Clinical Evaluation documents



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    Sam Lazzara
    Principal Consultant
    Fremont CA & Las Vegas NV
    United States
    https://mdqc.blog/
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  • 9.  RE: MDR - Clinical Evaluation Reports

    Posted 07-Apr-2019 10:37
    Edited by Julie Omohundro 07-Apr-2019 10:45
    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
    ------------------------------



  • 10.  RE: MDR - Clinical Evaluation Reports

    Posted 07-Apr-2019 11:10

    Julie,
    The EU-MDR is quite clear in the terminology. The manufacturer writes the Clinical Evaluation Report. The NB writes the Clinical Evaluation Assessment Report.

    As part of the pre-market activities the manufacturer implements the clinical evaluation process. One process output is the Clinical Evaluation Report. The manufacturer includes the clinical evaluation process documentation and the Clinical Evaluation Report in the Annex IX application to the NB. For the Clinical Evaluation Plan see Annex IX(2.1, tenth indent). For the Clinical Evaluation Report see Annex IX (2.2(c), fourth indent) and Annex IX(4.4).

    The NB assesses the manufacturer's Clinical Evaluation Report and writes a Clinical Evaluation Assessment Report. The NB provides a copy of the Clinical Evaluation Assessment Report to the manufacturer who includes it in the Annex II technical documentation. See Annex VII(4.6)for the NB part and Annex II(6.1(c)).

     

     



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 11.  RE: MDR - Clinical Evaluation Reports

    Posted 07-Apr-2019 11:57
    Dan, thanks for the clarification.  That makes sense.

    Its also potentially a very good idea.  In the past, the only response received after submitting a Class III design dossier to one of the major NBs was crickets, even after several efforts to get a reply.  Eventually it issued the CE certificate, so apparently this was its unhelpful way of (not) saying there were no deficiencies.  In the meantime, the company had other CERs to write and no clue if it was going about it a way that the NB would find acceptable.  Perhaps by elevating the assessment to an "official" document, the MDR will encourage NBs to reliably follow through.​

    ------------------------------
    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
    ------------------------------



  • 12.  RE: MDR - Clinical Evaluation Reports

    This message was posted by a user wishing to remain anonymous
    Posted 08-Apr-2019 13:20
    This message was posted by a user wishing to remain anonymous

    Thank you all for this very valuable feedback.


  • 13.  RE: MDR - Clinical Evaluation Reports

    Posted 07-Apr-2019 10:40
    Just have to ask...

    What is it that makes you think these people are "regulatory professionals"?  Is it something other than because they said so?​

    ------------------------------
    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
    ------------------------------