🔊 𝗢𝗿𝗽𝗵𝗮𝗻 𝗗𝗲𝘃𝗶𝗰𝗲𝘀: 𝗡𝗲𝘄 𝗱𝗲𝗳𝗶𝗻𝗶𝘁𝗶𝗼𝗻 𝗮𝗻𝗱 𝗴𝘂𝗶𝗱𝗮𝗻𝗰𝗲 📑
Yesterday, the MDCG released its latest guidance document, #MDCG2024-10, defining #OrphanDevices (ODs) and providing guidance on the #ClinicalEvaluation of these devices.
After reading this 33-page document (it seems the MDCG is developing quite a taste for lengthy guidance documents…), it’s clear that many of the considerations provided in the guidance apply to all devices, not just ODs. However, here are some 𝗸𝗲𝘆 𝘁𝗮𝗸𝗲𝗮𝘄𝗮𝘆𝘀:
⚡️ An OD is defined as a device intended to treat, diagnose or prevent a disease or condition that presents in no more than #12000 individuals in the EU per year as long as there are insufficient alternative options OR the device offers expected #ClinicalBenefits compared to the existing alternatives. The document also defines orphan subpopulations and orphan indications.
⚡️ ODs can be placed on the market with #AcceptableLimitations in the amount and quality of pre-market #ClinicalData, provided certain conditions are met, including a PMCF plan to collect long-term data.
⚡️ Robust and high-quality #NonClinicalData is of increased importance for ODs with limitations in clinical data.
⚡️ #Users of the OD need to be informed of the OD status and its known limitations in clinical data.
⚡️ The #CEP for devices claiming OD status should include disease—and device-specific factors to justify their status.
⚡️ #Legacy ODs should also follow MDCG 2020-6 and 20223-7. In some cases, clinical data from #OffLabel use can be used to provide clinical evidence.
⚡️ When designing a #ClinicalInvestigation for ODs, recruitment challenges and sample size implications should be considered.
⚡️ If available and appropriate, data from the device's use in other non-orphan populations/indications may be partially or fully #extrapolated for clinical evaluation.
⚡️ The #PMCF process is even more important in these devices, as limitations in clinical data should be filled through appropriate PMCF activities. The PMCF plan for ODs should include the limitations in clinical data, a justification of how the chosen activities will address specific limitations and an explanation of how the data will be generated (time frame, milestones, etc).
⚡️ #NBs should check the OD status as soon as possible and consider it when reviewing the #ClinicalEvaluation. NBs can evaluate issuing certificates with specific conditions or provisions (as detailed in MDCG 2022-14) for ODs. NBs should, in this case, monitor compliance with these conditions/provisions.
⚡️ Manufacturers or NBs may consult #ExpertPanels regarding the OD status and the clinical data needed for the clinical evaluation of certain devices. Depending on the situation, advice should be provided within 60-120 days.
#MedTech #MDR #OrphanDevices #Healthcare
Sr. Director of Marketing—Preceptis Medical | Hummingbird® Tympanostomy Tube System (TTS)
1wSo fun!