AdvaMed Urges Prioritized Work on Guidances

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AdvaMed has identified guidance documents that FDA should prioritize in its fiscal year 2019 plan on proposed documents to be developed. In comments to the agency, AdvaMed recommends that FDA finalize several of the draft guidances that it has issued within the last year. For example, the group says the following guidances should have the highest priority:

  • The Least Burdensome Provisions: Concept and Principles
  • Requests for Feedback and Meetings for Medical Device Submissions: The Q-Submission Program
  • Breakthrough Devices Program
  • Expansion of the Abbreviated 510(k) Program: Demonstrating Substantial Equivalence through Performance Criteria
  • Changes to Existing Medical Software Policies Resulting from Section 3060 of the 21st Century Cures Act
  • Clinical and Patient Decision Support Software
  • Content of Premarket Submissions for Cybersecurity of Medical Devices of Moderate and Major Level of Concern
  • Multiple Function Device Products: Policy and ConsiderationsThe Special 510(k) Program
  • Select Updates for Recommendations for Clinical Laboratory Improvement Amendments of 1988 (CLIA) Waiver Applications for Manufacturers of In Vitro Diagnostic Devices

Additionally, AdvaMed said the top two draft guidance documents that should be developed are Nonbinding Feedback After Certain FDA Inspections of Device Establishments and Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices. The group says the inspection feedback guide is important because device firms face significant sanctions if they do not correct observations identified during these audits. “Consequently, they often invest massive time and resources in corrections without confidence that these measures meet FDA expectations,” it says. “The nonbinding feedback mechanisms better assures that proposed corrections align with FDA’s view of the remediation that should occur.”

 

Regarding the software submission draft guidance, AdvaMed contends that the current guidance is over 13 years old (2005) and software practices have changed significantly. “Updating this guidance document would reflect current software development life cycle practices and documentation,” it says.

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