Post on 15-Jan-2016
Weaving regulations into sound value analysis processes
Barbara Strain, MA, SM(ASCP)Director Value Management
University of Virginia Health System
Learn key healthcare agency resources
Understand the importance of the relevant guidance documents
Apply resource information to value analysis processes
Know the role of the VAP in patient safety
ObjectivesObjectives
Documentation
Safety
Quality
New Devices
New Devices&Drugs
Healthcare Agency Healthcare Agency ResourcesResources US FDA – Food and Drug Administration
◦ http://www.fda.gov/
Master guidance resource for devices, drugs, radiation emitting sources, other
Expert assistance
Incident follow up
Healthcare Agency Resources CDC Centers for Disease Control & Prevention
◦ http://www.cdc.gov
◦ NIOSH National Institute of Occupational Safety & Health http://www.cdc.gov/niosh/ http://www.cdc.gov/niosh/topics/bbp/ http://www.cdc.gov/niosh/topics/bbp/sharps.html http://www.cdc.gov/niosh/npptl/topics/respirators/dis
p_part/n95list1.html http://www.cdc.gov/niosh/topics/latex/
Healthcare Agency Resources OSHA Occupational Safety & Health
Administration – US Dept of Labor; code of regulations (CFR)
http://www.osha.gov/ Federal Register e.g. 29CFR Part 1910 Blood Borne
Pathogens
What Value Analysis professionals need to know about medical devices Introduction of new devices
◦ evaluations, ◦ use, ◦ research,◦ manufacturer discussions,◦ physician discussions
Assuring Quality
Creating/Maintaining a culture of Safety
What Value Analysis professionals need to know about medical devicesA Medical Device is:
"an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory”
They range from simple tongue depressors and bedpans to complex programmable pacemakers with micro-chip technology and laser surgical devices as well as in vitro diagnostic products, such as general purpose lab equipment, reagents, and test kits, which may include monoclonal antibody technology.
certain electronic radiation emitting products with medical application and claims meet the definition of medical device. E.g. diagnostic ultrasound products, x-ray machines and medical lasers.
Medical Device Classes
Device Classes and Regulatory Controls Class I General Controls
◦ With Exemptions ◦ Without Exemptions
Class II General Controls and Special Controls ◦ With Exemptions ◦ Without Exemptions
Class III General Controls and Premarket Approval
Determining Device Classes and Actions
Classification is risk based, that is, the risk the device poses to the patient and/or the user is a major factor in the class it is assigned. Class I includes devices with the lowest risk and Class III includes those with the greatest risk.
The class to which a device is assigned determines the type of premarketing submission/application required for FDA clearance to market. If your device is classified as Class I or II, and if it is not exempt, a 510k will be required for marketing. All devices classified as exempt are subject to the limitations on exemptions. For Class III devices, a premarket approval application (PMA) will be required unless the device is has been on the market prior to 1976 which in that case, a 510k will be the route to market.
Device classification depends on the intended use of the device and also upon indications for use. For example, a scalpel's intended use is to cut tissue. A subset of intended use arises when a more specialized indication is added in the device's labeling such as, "for making incisions in the cornea". Indications for use can be found in the device's labeling*.
* on label use
Class I/II Exempt Devices FDA has exempted almost all class I devices
premarket notification requirement, It is important to confirm the exempt status and any limitations that apply with 21 CFR Parts 862-8927.
If a manufacturer's device falls into a generic category of exempted class I/II devices as defined in 21 CFR Parts 862-8928, a premarket notification application and FDA clearance is not required before marketing the device in the U.S. However, these manufacturers are required to register their establishment and list the generic category or classification name.
Class I/II Non-exempt Devices510(k) process
A new 510(k) submission is required for changes or modifications to an existing device, where the modifications could significantly affect the safety or effectiveness of the device or the device is to be marketed for a new or different indication for use.
Class III DevicesPMA Class III devices are those that support or sustain
human life, are of substantial importance in preventing impairment of human health, or which present a potential, unreasonable risk of illness or injury. Due to the level of risk associated with Class III devices, FDA has determined that general and special controls alone are insufficient to assure the safety and effectiveness of class III devices.
Premarket approval (PMA) is the FDA process of scientific and regulatory review to evaluate the safety and effectiveness of Class III medical devices.
Examples of devices by class Class I exempt
Class I non-exempt
Class II exempt
Class II non-exempt
Class III
Cotton tip applicator
Heel warmer; transport media
Wheeled stretcher
IV pump accessories; antigen reagents
Defibrillator, biologics, hemodialysis catheters
IDE – Investigational Device Exemption An investigational device exemption (IDE) allows the
investigational device to be used in a clinical study in order to collect safety and effectiveness data.
Clinical studies are most often conducted to support a PMA. Investigational use also includes clinical evaluation of certain
modifications or new intended uses of legally marketed devices. All clinical evaluations of investigational devices, unless exempt,
must have an approved IDE before the study is initiated. Clinical evaluation of devices that have not been cleared for
marketing requires:◦ an IDE approved by an institutional review board (IRB). If the study
involves a significant risk device, the IDE must also be approved by FDA;
◦ informed consent from all patients; ◦ labeling for investigational use only ◦ monitoring of the study and; ◦ required records and reports.
Process for Introduction of New Devices Evaluation, Research/IRB or Use User facility must know what is in use
◦ Safety◦ FDA approvals◦ Device/Tissue tracking
http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm071756.htm
Joint Commission: TS03.01.01 - .03◦ Issue reporting◦ Recalls
Assure in-service education Keep a log
Quality: Safe Medical Device Act Problem reporting
◦Internal- equipment, supplies, accessories Before use: foreign body in sterile packaging During use: bovie does not fire After use: observe brown liquid in basin
leaching out of a blue OR towel How to report: manually/electronically Saving the effected item Assess seriousness, trends, lot#, serial# Communicate Educate
Safe Medical Device Act, cont’d
◦ External Contact quality department at manufacturer Follow instructions Document Communicate
◦ FDA reporting: Manufacturer and User Facility Device Experience (MAUDE) “You are encouraged to report all serious adverse
events and product quality problems to FDA MedWatch at www.fda.gov/medwatch/report.htm”
MedSunhttp://www.fda.gov/MedicalDevices/Safety/
MedSunMedicalProductSafetyNetwork/default.htm
Creating and Maintaining a Culture of Safety
Recalls, Market Withdrawals and Safety Alerts
Where to find the most up to date info?◦ http://www.fda.gov/Safety/MedWatch/
SafetyInformation/SafetyAlertsforHumanMedicalProducts/default.htm
◦ Subscription services: examples RASMAS, ECRI
Institutional Recall/Alerts Process Who, what, when, where, why & how Institutional policy Key process owners Well defined Automated or manual Centralized Accountable Log Reporting up through institutional
committee structure
Examples
Knowledge+Effective Processes
Safe Environment
Documentation
Safety
Quality
New Devices
New Devices&Drugs