Third-Party Review Guidance Explained

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CDRH Office of In Vitro Diagnostics policy analyst Allen Hill says the 510(k) third-party review program explained in a 3/12 guidance enhances quality in several ways. Speaking during a 4/16 Webinar on the guidance, Hill said the quality enhancements are that the agency has the right devices eligible for the program, the agency receives quality reviews that can be verified through a supervisory review, and the agency can ensure that only quality third-party review organizations remain in the program.

Hill said CDRH wants to be sure that the “right devices” are eligible for the program. Factors that were considered in deciding which devices are eligible were lower risk, well-understood, and lack of post-market safety signals.

The 510(k) third-party review program is a voluntary alternative, Hill said. It operates in this way: (1) the submitter identifies an appropriate third-party to review its 510(k); (2) the submitter sends the eligible 510(k) to the third party; (3) the third party reviews the 510(k), resolves any differences they find, documents their review, and sends a recommendation to FDA, and (4) FDA does a supervisory-level review to make a final decision.

“It’s important to note the interactive nature of the process,” Hill said. “Everyone can be part of the conversation and talk with each other. The third party is the primary contact point.”

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