Simplifying the challenges posed by the new EU MDR
Our CEO Dr Paul Hercock was invited to speak on a Kaizen Life Sciences podcast about the challenges posed by the new EU MDR.
An introduction to Clinical Evaluation and the pivotal role it plays in medical device safety and performance under the EU MDR.
Clinical Evaluation is a systematic and planned process to assess the safety and performance of a medical device. The objective of Clinical Evaluation is to demonstrate conformity with the relevant Annex I General Safety and Performance Requirements (GSPRs) and to prove that the device’s benefit-risk profile continues to be acceptable.
In simple terms, Clinical Evaluation answers the question “does this device work as intended, and is it safe?” through the constant production, assessment and systematic analysis of clinical evidence.
A Clinical Evaluation is fed by information from multiple sources and processes. It can be thought of as a ‘bringing together’ of clinical data accumulated through systematic literature reviews, Post-Market Surveillance (PMS), Post-Market Clinical Follow-up (PMCF) and Vigilance systems, as well as conclusions drawn from Risk Management and Quality Management Systems (QMS).
The MDR requires that Clinical Evaluation is a constant process that proceeds throughout the entire lifetime of every medical device. Clinical Evaluation of each medical device is summarised periodically in a Clinical Evaluation Report (CER), with the periodicity determined by the risk class of the device.
MDR Annex XIV Part A contains detailed requirements for Clinical Evaluation under the MDR.
In May 2021 the new Medical Device Regulations (MDR) (EU) 2017/745 will be fully in force. The MDR replaces the Medical Device Directive 93/42/EEC (MDD) and represents a significant overhaul of all aspects of medical device regulation. All medical devices and medical device manufacturers within the EU will need to comply with the new MDR regulations in order to trade and sell in the EU market.
As a consequence of the enhanced requirements imposed by the MDR, many existing medical device Clinical Evaluation processes may fail to meet the required standard, even if they successfully met expectations under the MDD.
Specific changes to Clinical Evaluation introduced by the MDR include:
Market-leading Clinical Evaluation services for EU MDR compliance of your medical devices.
Guidance on how to perform a medical device Clinical Evaluation can be found in MDR Annex XIV Part A. The Annex requires that manufacturers:
In addition to information in Annex XIV Part A, further guidance on performing a Clinical Evaluation can be obtained from MEDDEV 2.7/1 rev 4, one of a series of advisory documents published by the European Commission. It is important to be aware that MEDDEV 2.7/1 rev 4 (as of June 2020) has yet to be updated to reflect changes introduced by the MDR.
Medical device Clinical Evaluation is a complex process requiring a high degree of clinical and regulatory expertise. Mantra Systems offers the opportunity for you to benefit from the expertise of our team of specially-trained medical professionals, bringing their clinical knowledge and acumen to your MDR Clinical Evaluation.
A medical device Clinical Evaluation draws together information from a range of sources and processes. Individually, all these processes are essential in ensuring safety and performance of medical devices. Clinical Evaluation aims to make an holistic assessment of the overall picture produced by the results of each of the individual processes. The MDR encourages manufacturers to make these processes inter-dependent and the correct approach to Clinical Evaluation ensures that results are utilised in this way.
Some of the processes that contribute data to Clinical Evaluation include:
The Quality Management System (QMS) is a formalised system that ensures and continually improves the quality of all business activities. It is a composite of post-market surveillance activities that focus specifically on the performance of a medical device following release onto the market, and broader company quality control measures that govern the wider activities of the organisation.
Article 10 MDR requires that all manufacturers establish, document, implement, maintain, keep up to date and continually improve a QMS. The QMS itself determines processes for performing a Clinical Evaluation, including roles and responsibilities for individuals and departments whose activities contribute to clinically evaluating medical devices.
Post-Market Surveillance (PMS) is a structured system that monitors the safety and performance of a medical device following its release onto the market. It involves the collection and detailed review of data relating to real-life clinical experience with the device. PMS is comprised of two elements:
Data from PMS is a crucial component of Clinical Evaluation for every medical device. PMS data is also used in numerous other regulatory activities, including to update the device’s benefit-risk analysis and to inform improvements to risk management processes.
Post-Market Clinical Follow-up (PMCF) is a component of PMS and Clinical Evaluation that has attained greater importance under the MDR. PMCF is the continuous process of proactively collecting and evaluating clinical data on the safety and clinical performance of a medical device. Effective PMCF systems generate Real World Evidence (RWE) that demonstrates the real-life performance of a medical device throughout its entire lifetime.
Because Clinical Evaluation under the MDR is a continuous process, PMCF systems need to be prospective and capable of delivering data on an ongoing basis. PMCF data must also genuinely reflect real use of the device. Standard clinical investigations will not be suitable because they are normally time-limited and recruit patients within comparatively narrow criteria. An ideal structure for generating real world evidence for PMCF under the MDR is a Medical Device Registry. Registries offer a number of advantages over alternative methods and, properly implemented, will secure a PMCF system that will stand the test of time.
MEDDEV guideline 2.12/2 focuses on requirements for designing and conducting PMCF studies. Results of PMCF are compiled in a technical document known as a PMCF Report and a dedicated section of the CER.
Vigilance systems collect data on any serious incidents, complaints, and adverse events relating to the use of a medical device. Vigilance systems also concern the monitoring of trends of frequency and severity of side-effects, as well as detailing processes for the handling of Field Safety Corrective Actions (FSCAs). A distinction must be made between serious incidents and expected side-effects that are clearly documented in product information and technical documentation.
Clinical literature is another crucial component of Clinical Evaluation. Clinical literature includes both data that has been published independently of the company in medical or scientific journals, as well as data produced internally by the manufacturer. An important step in assessing conformity of the overall dataset for a device with the Annex I GSPRs is to perform a structured systematic literature review. This can often help to address any apparent gaps in the clinical evidence portfolio that would otherwise require significant investment to overcome.
Performing a systematic literature review to the necessary standard requires a high level of clinical acumen and appraisal skills. Our team of specially-trained medical professionals combine their knowledge of MDR requirements with extensive clinical expertise to deliver the highest available standard in MDR compliant systematic literature reviews.
Risk Management concerns processes for identifying, analysing, monitoring and controlling risk. The MDR accepts that risks cannot be entirely eliminated from the use of medical devices, and instead requires that manufacturers provide evidence that the benefit-risk profile of the device is objectively acceptable. ISO 14971:2019 outlines an internationally-recognised standard for medical device risk management, and unlike many ISO standards has been updated to reflect changes introduced by the MDR.
Demonstrating an acceptable benefit-risk profile is a major objective of medical device Clinical Evaluation.
Clinical Evaluation is a continuous process that is constantly fed by data from the sources identified above. Periodically, however, the results of Clinical Evaluation must be summarised in a technical document known as a Clinical Evaluation Report (CER). The CER must be an extensive summary of the findings of Clinical Evaluation, written objectively and carefully structured. Writing a CER is a demanding, technical task that requires a high level of regulatory expertise and clinical acumen.
MEDDEV 2.7/1 contains guidance on structuring a CER but has not been updated to reflect changes introduced by the MDR.
Our clients come from across the industry and range from pre-start businesses to stockmarket-listed multinationals. We aslo have key strategic partners based in the UK and Denmark.
It was a pleasure working with you. We are completely satisfied with your service and look forward to working with you again in future.CEO, EU medical software company
Your service surpassed our expectations and added value across our organisation. We now feel much better placed to prepare for the MDR.Chief Executive, MedTech pre-start
A comprehensive, detailed and highly professional service.Regulatory Manager, UK device manufacturer
We work with medical device manufacturers based in the UK, Europe, the US and Asia, developing MDR strategies for both physical devices and software as a medical device.
Working with us gives you access to our growing international team of MDR-trained healthcare professionals from a wide variety of clinical backgrounds.
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Our CEO Dr Paul Hercock was invited to speak on a Kaizen Life Sciences podcast about the challenges posed by the new EU MDR.
Working with the MDR requires knowing how to work with clinical evidence. Medical doctors are perfectly positioned to meet this requirement.
Unless you have spent time working with medical device legislation in the past, the idea that software could be a medical device may be rather unexpected.
We have compiled some of our frequently asked questions. If you'd like to know anything else about what we do, feel free to ask us a question.
We can work with the majority of medical device manufacturers seeking compliance of their devices in accordance with Regulation (EU) 2017/745, including both hardware and software devices. We also offer a free, no-obligation consultation, so please feel confident about discussing your requirements with a member of our team.
No. We will work with you to produce systems and to support your EU MDR compliance, but we do not conduct research ourselves. We will provide tools for you to conduct your own Post-Market Surveillance. Our range of services are designed to assist you in this matter.
Yes. We adhere to the highest standards of professionalism and regard maintaining confidentiality and data security as a cornerstone of our practice. We also comply fully with the requirements of GDPR.
Our services are built around a strict quality framework and we only work with clients who share this commitment to quality. Our CEO is a medical doctor with years of experience in the medical device industry and assumes personal responsibility for every project. Our product development process integrates client feedback throughout product production, ensuring a constant focus on your needs.
We work with clients of all sizes and at all stages of their regulatory compliance journey. Our team are here to help and are happy to respond to general enquiries, even if you don't feel like you know where to start. We are experts at 'tuning in' to your requirements and will guide you through the entire process. Our free MDR Compliance Guide and suite of MDR downloads stand as proof of our commitment to help you understand your obligations under the MDR.
Yes. Software as a medical device is an increasingly-important segment of the medical device market. We have extensive experience in building regulatory systems for medical software and offer a special application of all our MDR services for software products. We also offer unique downloads and white papers that focus specifically on software as a medical device.
At its core, working with the MDR is about working with clinical evidence. Whether you need to generate evidence for PMCF, analyse data for writing a CER, or build an MDR-ready PMS system, our medical experts have the clinical acumen to ensure that your clinical evidence is produced and interpreted with the highest levels of professionalism. Medical professionals work with clinical evidence all day. We bring their specialist capabilities directly to your MDR strategy.
We believe in transparency and aim to build long-term relationships with our clients. This commitment is demonstrated by our customer-focused pricing strategy. You pay a small deposit upfront, only paying the balance when the work has been completed to your total satisfaction. For higher-value projects we offer flexible payment packages on an individual basis — please contact a member of our team to find out more.
Yes. Our unique business model allows us to scale to accommodate almost any amount of work. Many of our medical professionals remain clinically active, meaning that we have trained more than we presently need. This system allows us to have ready availability of redundant capacity that can be called upon in the event of a surge in demand. Whatever your requirements, our unique business model allows us to step in faster than any of our competitors.
Yes. We run a number of events throughout the year focusing on specific aspects of MDR compliance. We also offer a limited number of free webinars on a limited basis — subscribe to our newsletter to be notified early when we publish new events. Of course, we also have our extensive MDR Compliance Guide and free MDR downloads suite, both of which offer extensive training on all aspects of MDR compliance.