FDA Multifunctional Device Guidance Explained
An FDA 7/29 final guidance on the regulation of medical devices with multiple functions is largely similar to an earlier draft but with further clarification about the agency’s expectations for the device manufacturer risk assessment processes, including new language on assessing cybersecurity risks associated with non-device functions, according to an online FDA Regulatory Alert prepared by Ropes & Gray attorneys. They write that the final guidance also provides additional information on the agency’s expectations for premarket submissions for multiple function device products, including information on labeling claims addressing non-device functions. And it includes a new flow chart illustrating how FDA will assess the impact of non-device functions on device functions when reviewing premarket submissions, and a new discussion of modifications to previously approved or cleared multiple function device products.
“Companies that seek to develop multiple function device products should consider designing their product with a clear demarcation between the device and other functions and ensuring that they have robust cybersecurity procedures in place,” the attorneys conclude. “Additionally, companies should carefully document any impact of the “other function” on the safety and effectiveness of the device function. Even if FDA does not require disclosure of all positive impacts in the premarket submission, this information will be important to ensure quality compliance.”