3. Barrier to Market
It Comes with the Territory…
Typically attributed to product approval by regulatory agencies
(FDA, CE, AMAR etc.)
Extends to the entire lifecycle of medical device from inception
to end of life
A collective name for three disciplines:
Regulatory Affairs (RA)
Quality Affairs (QA & QC)
Clinical Affairs (CA)
What Does Regulation
Stands for? 3
4. Is my product regulated as Medical device?
What is its classification?
Which regulatory requirements apply to my product?
What is my time to market?
How much will it cost me?
Start up wisdom, innovation, leverage good regulatory science
and medicine
QRC Strategy & Work-plan
What Does Regulation
Stands for? 4
6. The Impact –Early Stage
How Does it Impact Me? 6
Betting on the “wrong horse”
Time to market
Do it right the first time:
Q: Are we developing the right product?
A: Due-dilligence; QA & CA feed the answer
Q: Are we developing the right product right?
A: Design control practice, Quality by design
Wrong doing, under doing, over doing
burn rate, dilution…diminsh ROI
7. Increase Your ROI
How Does it Impact Me? 7
Valid Regulatory strategy
Clinical strategy
Quality plan
Gates
Control
8. Bottom Up QRC Work-plan & Budget
How Does it Impact Me?
8
Harmonized with R&D WP
Manage your risk
Time to market
Burn rate
ROI
10. Tips & Pearls
How Does it Impact Me?
10
Due diligence: screen strategy – is QRC project risk
aligned with your investment strategy, are project
plan and budget valid?
Control your investment – do it right the first time
Understand that ensuring your project is handled by
competent QRC expert is in your best interest as
investor
11. Three risk classes
Risk vs. benefit
Intended use
General controls, special controls and PMA
Medical Device Regulation
11
Digital Health Regulation
Four classes driven by risk and classification rules
Loosely tied to intended use
Conformity assessment
Paradigm more established but struggling with
innovation
12. Digital Health Regulation is Challenging
• Regulation is (always) behind technology
• Booming health apps. Nd Health IT products
• Multiple stake holders (HIPPA, FD&C Act, FTC Act,
CMS)
• Multiple types (mHealth, CDS, Health IT, Personalized
Medicine, Telemedicine, wearable device (IOT))
• The demarcation between FDA regulated product vs.
nonregulated is complex and tricky at times.
• The ramifications of this demarcation are extensive!
12
13. Risk (privacy, hacking, injury, miss-diagnosis, delay
of treatment, misuse, error)
Functionality focused (administrative, medical
device etc.)
Narrowly tailored
Risk Based Approach for Regulating Digital Health
13
14. Regulation Goes Beyond FDA
FCC, RTTE
FTC
HIPPA (Privacy, Security)
EC Privacy directive (95/46/EC)
ISO/IEC Health IT Standards
Liability for defective products (1985/374/EC &1999/34/EC)
General product safety (2001/95/EC)
Sale of consumer goods (1999/44/EC)
and much more…..
16. Founded & Managed by Gadi Ginot
• Over 20 years industry experience in managing
Medical Device & Combination product regulation,
quality and clinical development
Pharma (Teva)
Medical Device
International experience (scores of relocation to
the EU, US)
• Internationally renown
• Unprecedented accomplishment in navigating precut
certification thru FDA and Notified Body
17. Full Service Solution for Medical Device
Manufacturer
• Largest vendor in Israel (over 30 experts on board)
• We cover all bases of Medical Device
• Designated Digital Health Team
Usability
FDA 513(g), 510(k), PMA
CE Mark
ISO13485, ISO9001, CMDCAS
CLIA
International registration
including AMAR, Russia, CFDA
Compliance
HW & SwQA
Design Control
Risk Management
Performance
evaluation
Clinical evaluation
Clinical Trials
HIPPA
Cybersecurity