FDA Software Functions Guidance Explained
Two medical device technical experts at Hyman, Phelps & McNamara say an 11/4 FDA draft guidance describes the recommended documentation that a sponsor should include in premarket submissions for medical device software functions. Writing in their firm’s FDA Law Blog, the two say the draft, when finalized, will replace a 5/11/2005 guidance. FDA is receiving comments on the draft until 2/22/22.
The new draft applies to both software in a medical device and software as a medical device, the post says, with a scope that is essentially the same as the 2005 guidance.
“The most obvious update to the new draft guidance is the shift from three to two categories for determining which software documentation to include in a premarket submission,” the authors write. “According to the 2005 software guidance document, FDA used Major, Moderate, or Minor Level of Concern to determine the recommended documentation for software. In the new draft guidance document, FDA introduced four risk-based factors to help determine the device’s documentation level — either Basic Documentation level or Enhanced Documentation level.”
The authors say other significant changes include FDA’s details around what is expected for system and software architecture and risk management. The agency also updated the guidance for artificial intelligence/machine learning software devices.