• where experts go to learn about FDA
  • Adrienne R. Lenz, Principal Medical Device Regulation Expert

    • Medical Device Notification Warns of Continued Data Integrity ConcernsMarch 26th, 2025

      Last year, FDA issued a letter to the medical device industry warning medical device firms of concerns related to fraudulent and unreliable laboratory testing data in premarket submissions, which we blogged about here.  This was followed last September with warning letters issued to two Chinese …

    • FDA Would Like to Join You in the Sandbox When Developing AI Enabled DevicesMarch 7th, 2025

      In the past three months, FDA has released two guidance documents related to artificial intelligence (AI) enabled medical devices: (1) a final guidance titled Marketing Submission Recommendations for a Predetermined Change Control Plan for Artificial Intelligence-Enabled Device Software Functions (PCCP Guidance, which we blogged about …

    • AI May Make Your Device More Efficient, but Be Prepared to Spend More Time on Design DocumentationFebruary 5th, 2025

      In early January, FDA released a draft guidance document titled Artificial Intelligence-Enabled Device Software Functions: Lifecycle Management and Marketing Submission Recommendations (Draft AI Guidance).  FDA has issued discussion papers (see our posts here and here ) and guidance on use of Pre-determined Change Control Plans …

    • FDA’s Third Party Review Program is Ready for the Next Pandemic, not the LDT Final RuleDecember 17th, 2024

      FDA recently released 510(k) Third Party Review Program and Third Party Emergency Use Authorization (EUA) Review which finalizes the draft guidance of the same title issued in December 2023.  We previously discussed the Third Party Review Program in a blog post last year when FDA …

    • How Many Hours are Really in a Day?December 3rd, 2024

      We recently blogged on FDA’s draft guidance, Chemical Analysis for Biocompatibility Assessment of Medical Devices, which describes chemical characterization methods that may be used to demonstrate biocompatibility of a medical device as an alternative to conducting certain biological testing.  We noted that the draft guidance’s …

    • New Draft Guidance Provides Detailed (and Burdensome) Recommendations for Chemical Assessments to Support Medical Device BiocompatibilityNovember 20th, 2024

      FDA recently issued a draft guidance, Chemical Analysis for Biocompatibility Assessment of Medical Devices, which describes chemical characterization methods that may be used to demonstrate biocompatibility of a medical device as an alternative to conducting certain biological testing.  Chemical characterization identifies and quantifies chemicals that …

    • Indeterminate Change: FDA Releases Draft Guidance on Predetermined Change Control Plans for Medical DevicesOctober 3rd, 2024

      A recent draft guidance on predetermined change control plans (PCCP) for medical devices continues FDA’s effort to implement Section 515C of the Food and Drug Omnibus Reform Act of 2022 (FDORA),   which Congress enacted to make it easier for manufacturers to make post-market device changes …

    • Days Go By* – Particularly When Responding to an FDA InspectionSeptember 13th, 2024

      While we hope readers of the Blog, as our clients and friends, come out of any FDA inspection with a clean bill of health, we know that based on FDA FY2024 data to date, approximately 40% of inspections of medical device companies end up classified …

    • FDA Releases Draft Guidance on Essential Drug Delivery OutputsJuly 24th, 2024

      For several years, FDA has requested that sponsors of drug or biologic led combination products identify essential performance requirements (EPRs) related to the device constituent in their applications.  EPRs were usually requested in the context of design controls, although 21 C.F.R. § 820.30 does not …

    • Power to the Patient with Patient Generated Health DataJuly 11th, 2024

      FDA’s Center for Devices and Radiological Health (CDRH) recently partnered with the Digital Medicine Society (DiMe) to host a two-day workshop to help advance the use of patient-generated health data (PGHD) to support improved clinical trials, medical device development, and regulatory science.  The workshop included …

    • PreSTAR: a New Template for Pre Submissions and 513(g) Requests for InformationJune 27th, 2024

      FDA recently released a new eSTAR template for device pre-submissions and 513(g) Requests for Information, referred to as PreSTAR.  A pre-submission provides the submitter an opportunity to obtain FDA feedback prior to a planned medical device premarket submission.  A 513(g) Request for Information is a …

    • Women’s Health a Focus for FDA and Biden AdministrationJune 2nd, 2024

      FDA’s Office of Women’s Health (OWH) recently celebrated its 30th anniversary.  This office was formed in 1994 to promote the inclusion of women in clinical trials and to provide leadership on topics related to the health of women.  Given that FDA was founded in 1906 and …

    • Can a Device Be Found Not Substantially Equivalent Because of Cybersecurity Risks? A Review of FDA’s Draft Guidance on Cybersecurity in Medical DevicesMay 7th, 2024

      FDA recently issued a draft guidance which would update the agency’s Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions guidance.  The draft guidance provides recommendations on what is required to meet cybersecurity obligations under section 524B of the Food, Drug and …

    • Feeling the Heat (or Cold) – New Draft Guidance Addresses Requirements for Devices that Produce Thermal EffectsMarch 19th, 2024

      FDA recently issued a draft guidance, Evaluation of Thermal Effects of Medical Devices that Produce Tissue Heating and/or Cooling (link), which describes information to include in a marketing application to support the evaluation of thermal effects of medical devices that produce local, regional, and/or systemic …

    • Bad Labs! Bad Labs? Whatcha Gonna Do?March 12th, 2024

      On February 20, 2024, FDA issued a letter to the medical device industry (link) warning medical device firms of recent FDA concerns related to fraudulent and unreliable laboratory testing data in premarket submissions.  Unfortunately, the letter provides little new information to guide industry conduct.  While …