approvals), industrials, scientists and cliniciens, and
for sure patients.
5.1 A Device without Assess to Market
Approval
In our practice, we had the case on which the strategy
of market acess was different depending of the
country/area of the world on which the manufacturer
would like to apply, which underlined different
procedures, but also lectures by authorities
concerning the way a device need to bring proofs.
5.2 A Software without Assess to
Market
The european regulation address specific sections for
software, that could have strong impact in the
diagnosis or care of the patients.
We can meet the case on which industrials
selected the strategy to play on some edges (or
adaptations?) in the lecture of the regulations, that
permit them to diffuse an “inoffensive observational”
version of their device onto hospitals and clinics on
very early phases; in that way, the aim consists in
aggregation of data, without any intervention on
patients. The data accumaleted need for sure to comply
with General Data Protection Regulation (GDPR
https://gdpr-info.eu/), but could help the manufacturer
to adapt its future device (especially in machine
learning/artificial intelligence considerations), and to
feed his future FDA or CE mark with in fact data
provided by the real life.
Another example relies on a software for which
we were involved since its very early stage for
development; the manufacturer had no experience
and was not structured for medical devices field. In
order to well understand the context, as well as giving
time to adapt the device and securize the things before
going on patients, we structured a two sequences
study, the first one being dedicated to observe the
current practices (without the software) and to define
the scenarii of use, the second one introducing the
software in simulation experimentation.
The regulatory positionning could then go on a
software first dedicated to training of caregivers,
before going on a high risk / class III medical device
- if enough proofs accumulated in these simulated
envirmnements.
5.3 A Device with a CE Mark
On medical devices already on the market since years,
we had to provide specific medico-economic
evaluations, taking into account these efficiency
considerations, in terms of duration of
hospitalization, back to work time, quality of life…
And in fact impacting the way the care and the
evaluations need to be arranged, with sometimes a
strong gap between what imagine the industrial at the
very beginning, and the proposed organization.
5.4 Use of Real Data
More and more and with the available big amount of
data, it is possible to imagine some “virtual”
controlled group, with possible pairing between a real
patient prospectively enrolled in a study, and his pair
selected onto database. This need strong thoughts on
criteria of inclusion (pairing), as well as available data
linked to the criteria of judgements. And then even if
it’s seems quite interesting (reducing the number of
patients involved in a research, gaining time, reducing
cost of a study…), it is not possible in many cases and
must not make forget to respect the chronological
steps of testing.
5.5 Implementation of a Device along
the Trial
For a very diruptive innovation involving not only
technology, but also organizations around patient and
its environment, we can pay attention to a tracker trial
that in fact allowed different phases introducing
implemented version of a prototype, each phases
turning profit from the previous ones, and feeding the
next ones (in term of adaptation of the device, but also
for the evaluations).
6 CONCLUSION
Considering our results, we plan to extend analysis
and to in end build recommendations, illustrating and
guiding the skateholders on the pathway to the
selection of a relevant methodology, depending of the
device, its level of risk but also its destination, its use,
or its stage of development. We will also think about
a “bottom up” approach by starting from the
methodology/design point of view.
We built a working group constituted of
methodologist, medical doctors, specialists in
medical devices evaluations, usability experts, in
order to set up this identification and study of cases.
Our results will be confronted to different actors of
the field, disseminated and adapted along the
feedbacks we’ll received, and finally to provide better