The Clinical Evaluation Plan defines methods for creating and updating the Clinical Evaluation Report. This plan is updated later by the post-market clinical follow-up, e.g., to include new search criteria for the literature search.
While the content of the Clinical Evaluation is simple, writing it, coming up with the right structure and forming a sensible line of reasoning (equivalence) can be a bit tricky.
These are the guidance documents on Clinical Evaluation. If you’re the person writing it, you should read them:
- MDCG 2020-1, 2020-5, 2020-6
- MDCG 2020-13: Quite helpful as it gives you an idea of the structure.
- MEDDEV 2.7/1 Rev. 4. (mostly for MDD, but still a good starting point; especially the list of proposed headings for a report at the end of the document).
Optionally: * IMDRF/SaMD WG/N41 FINAL:2017 * IMDRF MDCE WG/N55 FINAL:2019 * IMDRF MDCE WG/N56 FINAL:2019 * IMDRF MDCE WG/N57 FINAL:2019
A list of the sections is presented below. You have to update this manually when you edit headings as this is a markdown file (sorry - guilty dog face).
Responsibilities 1. Scope of the Clinical Evaluation 2. Device
2.1. Device Description
2.2. Clinical Benefits, Outcome Parameters
2.3. Clinical Safety, Methods for Analysis
2.4. Acceptability of Benefit-Risk-Ratio 3. Type of Evaluation 4. Literature Search
4.1. Literature Search Methods
4.2. Literature Appraisal Criteria
4.3. Additional Databases 5. References
Describe the roles of people who will be doing the Clinical Evaluation. * Author * Literature search * Evaluation of complaints, customer feedback * Review
|Review / Approval|
Note: This section will be copy-pasted into the Clinical Evaluation Report
Based on MEDDEV 2.7/1 rev. 4, the Clinical Evaluation is performed in five logical procedural stages in order to evaluate the performance and safety data of the medical device:
Copy-paste your Device Description here, which includes the Intended Use but also, User Profile, Precautions/Safety Instructions, Contraindications, Use Environment, Operating Principle, Variants/Accessories, Novelty, Design Requirements. If it’s not done yet, remember to do it later :)
Describe the clinical benefits you expect from your product. Define how you’ll measure those (i.e., outcome parameters). You’ll probably be planning to do a literature search to prove them. As you know the literature, it makes sense to select outcome parameters which were already established in prior studies. For example, if your website claims that your device cures back pain in 50% of patients after 14 days, here’s the place to list that claim and show and explain how you’ll prove it.
Also, describe the product claims as stated by MEDDEV 2.7/1 Rev. 4: Medical device claims results from general requirements on safety and performance. These claims are part of materials (e.g. IFU, marketing material and other accompanying documents). These product claims will be checked within the clinical evaluation and evidence are made. Performance-related product claims: * Claim 1, e.g., diagnosis for better treatment decision (performance) * Claim 1, e.g., xy % accuracy, xy % sensitivity, xy % specificity
Describe your safety parameters, i.e., which things should your product fulfil so that you consider it safe? And your methods, i.e., how will you prove that your product fulfils those safety parameters? A method could be a literature search for past studies, but you could additionally do a Post-Market Clinical Follow-Up to double-check whether that’s actually true for your device.
For MD class I: does it replace the medical care chain? Is the case that only a doctor can diagnose causes or concomitant diseases in the case of occurring complaints and prescribe necessary therapies if needed? Are there any side effects expected? If however any side effects occur during the use, can the patient interrupt the process any time?
Also, make sure to mention that a risk management plan, risk assessment and risk management report were undertaken according to the EN ISO 14971:2019 to evaluate all the known and foreseeable risks related to the product.
Safety-related product claims: * Claim 1, e.g., temporary worsening * Claim 2, e.g., placebo effect
After you’ve defined your benefits and safety parameters, which combination of those is acceptable to you? In the case of most software devices (and apps), you’ll probably have subtle benefits (e.g., better disease management, early detection of relapses) while low safety concerns (e.g., disease progression unlikely, not killing anyone).
Describe the type of Clinical Evaluation you’ll be doing. Most probably, you’ll be doing a literature search to come up with adequate clinical data.
Describe your literature search methods, the databases you’ll be using (PubMed, Google Scholar, Cochrane, Embase), the keywords you’ll be entering and how you plan to document it (you’ll be creating a table, I suppose).
Comment if systematic search and review methods such as the following have been used: * PICO (patient characteristics, type of intervention, control, and outcome queries). * Cochrane Handbook for Systematic Reviews of Interventions. * PRISMA (The Preferred Reporting Items for Systematic Reviews and Meta-Analyses) Statement. * MOOSE Proposal (Meta-analysis Of Observational Studies in Epidemiology). * Other (specify or describe).
I blindly copy-pasted some semi-helpful bullet points from guidance documents here: * The adequacy of search terms: for example, it should be sufficiently broad to establish benchmarks, determine the general state of the art, determine potential risk, adverse events, undesirable side effects, etc. * Note that a search which is restricted to the manufacturer’s own product or the name of their chosen equivalent could miss important information and therefore is not acceptable. * Databases used (to minimize bias multiple databases should be used). * Acceptability of inclusion and exclusion criteria. * Both favourable and unfavourable data are included. * Strategies for avoiding duplication of data (for example, across different publications or between the manufacturer and published data). * Literature search and review protocol (i.e., how did the manufacturer test this protocol to ensure comprehensive identification of relevant data / demonstrate that all relevant data has been retrieved?). * Any deviations from the manufacturer’s literature search protocol. * Overall conclusions regarding the adequacy of search methods, the likelihood of having retrieved all relevant data, and methods used to avoid bias.
It makes sense to differentiate between “context” and “pivotal” data: * Context data describes the state of the art (commonly the introduction / literature part of papers) * Pivotal data is used for the appraisal, i.e., that’s the data describing the actual study and outcome(s). In the best case, the pivotal data is about the device(s) you’re claiming similarity to.
Describe your criteria for clinical data which you deem acceptable for your clinical evaluation. Firstly, the information should be relevant. Secondly, you’ll probably have some additional hard criteria, like requirements for the study design etc.
Also, how will you weigh the information from multiple studies?
You can evaluate the appraisal of pivotal data by considering the equivalence of the described device literature (e.g., material & methods part, algorithm, models); the level of evidence can be taken from different sources (LoE of American Heart Association or quality of clinical data according to MDCG Guideline 2020-6).
You can also check out additional databases for relevant data and mention how you search them: * Clinical trials: clinicaltrail.gov, DRKS, WHO, ANZCTR * Adverse events: EUDAMED (if it works), FDA MAUDE, FDA Medical Device Recalls
Papers and other references which you cite can go here.
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