Here is a document of links pointing to FDA guidance documents and other forms of communication. It was compiled by googling CDRH regulatory buzz words. We hope this document is useful. Caveat to all: You won't know what's required for your submission until you ask, try, and succeed. === Pre-submission meeting === In CDRH, the best advice is to know about pre-submission meetings. * [https://www.fda.gov/downloads/Training/CDRHLearn/UCM387291.pdf Slides: Pre-Submissions and Meetings with FDA Staff] * [https://www.fda.gov/downloads/medicaldevices/deviceregulationandguidance/guidancedocuments/ucm311176.pdf Guidance document: Requests for Feedback on Medical Device Submissions: The Pre-Submission Program and Meetings with Food and Drug Administration Staff] === IFU: Indications for Use === Part of the definition of your medical device are the indications for use. * [https://www.fda.gov/RegulatoryInformation/Guidances/ucm080275.htm Webpage: Indications For Use.] It's never to early to start thinking about, researching, and crafting an IFU for your device. === Comprehensive Regulatory Assistance === * [https://www.fda.gov/medicaldevices/deviceregulationandguidance/ Webpage: Comprehensive Regulatory Assistance] === 510k program === * [https://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/UCM284443.pdf Guidance Document: The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications 510(k). Guidance for Industry and Food and Drug Administration Staff.] A Premarket Notification [510(k)] is a submission made to FDA to demonstrate that the device to be marketed is safe and effective by proving substantial equivalence (SE) to a legally marketed device (predicate device). * [https://www.fda.gov/regulatory-information/search-fda-guidance-documents/deciding-when-submit-510k-change-existing-device Guidance Document: Deciding When to Submit a 510(k) for a change to an Existing Device.] * [https://www.fda.gov/regulatory-information/search-fda-guidance-documents/deciding-when-submit-510k-software-change-existing-device Guidance Document: Deciding When to Submit a 510(k) for a Software Change to an Existing Device.] === de Novos === * Special controls accompany all de Novo classifications. * Special controls outline submission requirements for medical devices with similar IFU. * Special controls are defined for a device type that can be broad or narrow. * [https://www.fda.gov/medicaldevices/deviceregulationandguidance/overview/generalandspecialcontrols/default.htm#special Webpage: Special Controls] If you can't find a de Novo or existing 510k that is a perfect predicate for your device type: Then find and learn about the closest one or two. It's a way to start. === PMA === Pursuing a pre-market authorization ('''PMA''')is a regulatory pathway for medical devices that have a higher risk profile than a 510(k). PMAs are not covered here. * Google [https://www.google.com/search?ei=j3meXPLPB4i2ggeXyLmoBA&q=fda+cdrh+pma&oq=fda+cdrh+pma&gs_l=psy-ab.3..0i22i30.324912.329012..330133...0.0..0.82.699.12......0....1..gws-wiz.......0i71j0i67j0i131j0j0i10i67.sJO-LkkaM "fda cdrh pma"]. === Mock Submission === * [https://mdic.org/event/computational-modeling-simulation/ Webpage: MDICx webinar that includes '''a presentation on mock submissions to FDA/CDRH.]''' * [http://mdic.org/wp-content/uploads/2014/05/CMS-Summit-Myers.pdf Slides: Mock Submissions to FDA/CDRH: History and Lessons Learned:] by Kyle Myers, Director DIDSR/OSEL/CDRH/FDA. This presentation was made as the agency was working with MDIC to pursue a mock submission about, "Augmenting a Clinical Study with Virtual Patient Models." * [https://webcache.googleusercontent.com/search?q=cache:C2Ru6HlIKEAJ:https://mdic.org/project/virtual-patient-vp-model/+&cd=7&hl=en&ct=clnk&gl=us&client=firefox-b-1-d Webpage: All the '''mock submission documents''' to and from the MDIC team and FDA.] Actually, this cached web link seems to now point to the updated Virtual Patient Page at MDIC which is missing the FDA submission feedback. * The mock submission was followed quickly by actual submissions. * Slides, Mock Submissions updated [[File(20190412-HTTMockSubmissions.pdf)]] * [https://mdic.org/project/virtual-patient-vp-model/ Updated Virtual Patient Page at MDIC] * The virtual patients mock submission was preceded by [http://clinchem.aaccjnls.org/content/56/2/165 "Protein-Based Multiplex Assays: Mock Presubmissions to the US Food and Drug Administration"], Regnier et al. * [http://www.clinchem.org/content/vol56/issue2 Supplementary Materials] * Future Archive of mock submission content === Medical Device Development Tools (MDDT) program === The FDA's Medical Device Development Tools (MDDT) program is a way for the FDA to qualify tools that medical device sponsors can use in the development and evaluation of medical devices. It is a way for the broader community (academia, health providers, and government scientists, not just industry) can impact the regulatory process. * [https://www.fda.gov/medicaldevices/scienceandresearch/medicaldevicedevelopmenttoolsmddt/ Webpage: FDA page, "Medical Device Development Tools (MDDT)"] === Computer Aided Detection and Diagnosis: CADe, CADx === * [https://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm524904.pdf Guidance document: Software as a medical device] * Computer aided detection (CADe) guidance - Radiology''' * [https://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm187294.pdf Guidance document: Non-clinical=Stand-alone=No human in the loop:] * [https://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm187315.pdf Guidance document: Clinical=Reader Study=Human in the loop:] === Quantitative Imaging === [https://www.fda.gov/regulatory-information/search-fda-guidance-documents/technical-performance-assessment-quantitative-imaging-device-premarket-submissions Guidance Technical Performance Assessment of Quantitative Imaging in Device Premarket Submissions] === Adaptive Algorithms, continuous learning === * [https://www.fda.gov/medical-devices/software-medical-device-samd/artificial-intelligence-and-machine-learning-software-medical-device Webpage, Artificial Intelligence and Machine Learning in Software as a Medical Device] * [https://www.fda.gov/media/122535/download White paper, Proposed Regulatory Framework for Modifications to Artificial Intelligence/Machine Learning (AI/ML)-Based Software as a Medical Device (SaMD)] === Digital Pathology and AI === * Device type Whole Slide Imaging System * Philips !IntelliSite Pathology Solution (DEN160056: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfPMN/denovo.cfm?ID=DEN160056). * Classification Product Code: PSY * Record includes special controls * "Digital Pathology Regulatory Considerations" * Presentation by Cheng Cui at Pathology Informatics Summit 5/9/19 * [[File(PathologySummit2019_Pittsburgh_ChengCui_FDA.pdf)]] === CAD Examples === * Device type: Radiological computer-assisted diagnostic (CADx) software for lesions suspicious for cancer. * !QuantX (DEN170022: https://www.accessdata.fda.gov/cdrh_docs/reviews/DEN170022.pdf). * Classification Product Code: POK * Device type: Radiological Computer Assisted Detection and Diagnosis Software" (CADe ''+'' CADx). * Imagen !OsteoDetect (DEN180005: https://www.accessdata.fda.gov/cdrh_docs/pdf18/DEN180005.pdf). * Classification Product Code: QBS * Device type: Radiological computer aided triage and notification software. * Viz.AI !ContaCT (DEN170073: https://www.accessdata.fda.gov/cdrh_docs/reviews/DEN170073.pdf). * Classification Prodcut Code: QAS * Device type: Retinal diagnostic software device * IDx IDx-DR (DEN180001: https://www.accessdata.fda.gov/cdrh_docs/reviews/DEN180001.pdf). * Classification Prodcut Code: PIB === Presentations in this space === * "Evaluating Artificial Intelligence Devices at the FDA and Related Collaborations and Initiatives" * Brandon Gallas, !PhD, Research Physicist and Mathematician, Division of Imaging, Diagnostics, and Software Reliability OSEL, CDRH, FDA * ACR Informatics Summit, October 5-6, 2019, Washington, DC. * [[File(20191005ACRinformaticsSummit_BDG-6-FINAL.pdf)]] * * Jennifer Segui, Lead Medical Device Reviewer, Division of Radiological Health, FDA * [[File(J.A.Segui.ACR.Informatics.2019.Slides.FINAL.pdf)]]