Dec 3 • Katie Cooney & Breda Kearney

EU-MDR Clinical Evaluation of Software as a Medical Device (SAMD): Bringing it back to basics

What you’ll learn in this informative EU MDR SaMD webinar

The session starts with how to determine whether software is regulated under the MDR and meets the definition of a medical device in Article 2, using MDCG 2019-11 and MDCG 2020-1 as the key guidance documents for qualification and deciding whether a stand-alone clinical evaluation is required.

It then explains what the MDR means by clinical evaluation: a systematic, planned, and continuous process to generate, collect, analyse and assess clinical data to confirm the device is safe, performs as intended and delivers a clinical benefit.

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The webinar outlines the steps in this process, including preparing the clinical evaluation plan, identifying, and appraising available data, generating new data where needed and completing the clinical evaluation report.
A core part of the session covers the three elements of clinical evidence that software must demonstrate: valid clinical association, technical performance and clinical performance. It describes how to establish that the software’s output is clinically relevant, that the device reliably generates the intended technical output and what happens when it is used by the intended users in the intended clinical setting.

The webinar also addresses how to define a clear intended purpose and clinical benefit, noting that for software the clinical benefit often relates to providing information to support diagnosis, as described in MDCG 2020-1. It then walks through how to define the state of the art by looking at the clinical condition, current care pathways, alternative options and similar devices, and how this is used to set performance and safety objectives.

The differences between clinical data and non-clinical data are explained, including why retrospective testing of pre-labelled datasets is useful for technical performance but is not clinical data for demonstrating clinical performance. Case examples illustrate how evidence requirements vary depending on the device’s intended purpose, risk and novelty.

Finally, the session shows how post-market surveillance (PMS) and post market clinical follow up (PMCF) feed back into clinical evaluation, with real-world data from complaints, vigilance, feedback, literature and planned PMCF activities used to update the clinical evaluation and risk management file as part of the ongoing cycle.

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