Pre-Cert Working Model 1.0 Discussed
CDRH associate director for digital health Bakul Patel says the 1/7 release of version 1.0 of the Center’s pre-certification working model also included release of a test plan and regulatory framework. In a 2/7 Webinar on the releases, Patel said that in version 1.0 CDRH emphasized that the program is all about the total product lifecycle. “We are emphasizing that we are in the excellence appraisal process, and we describe what that detail looks like,” he said. “We are also looking at how we create a system where there are minimal questions on what category a product fits into, aligning with the international medical devices regulatory form or framework.”
The new version also proposes a list of review elements, Patel explained, saying the Center believes that if excellence appraisal and the redetermination happen, those are the components that are important for CDRH to review.
“These are proposals that we are going to test and I will share with you how we are going to do that,” he said.
Patel said the Center is moving from an episodic oversight to a sort of continuous oversight in which staff not only look at one point but look throughout the product lifecycle.
For the testing program, CDRH is proposing using the de novo pathway to look at the information used in the excellence appraisal, the redetermination and streamline review in totality to assure that a product’s risks are managed and controlled.