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

    • FDA Launches Digital Health Center of ExcellenceSeptember 25th, 2020

      On September 22, FDA announced the creation of a Digital Health Center of Excellence (DHCoE), which has grown out of their existing Digital Health Program.  The objectives of the DHCoE include connecting and building partnerships, sharing knowledge and innovating regulatory approaches related to digital health.  …

    • FDA Pre-Cert Program Update – Good Progress but Full Launch Not Yet in SightSeptember 18th, 2020

      FDA’s Software Pre-Certification (Pre-Cert) Program is intended to create a new streamlined regulatory process for software as a medical device (SaMD) (see our earlier blog posts on the program here, here, here, here, and here).  On September 14, 2020, FDA updated the Digital Health Software …

    • Amid Concerns of Shortage, FDA Issues Emergency Use Authorization for Ventilators, Accessories and Other Respiratory DevicesMarch 31st, 2020

      You’ve seen the news about insufficient supply and availability of ventilators to treat patients with Coronavirus Disease 2019 (COVID-19).  You’ve also likely seen news of ideas to mitigate this shortage.  On March 24, 2020 FDA issued an Emergency Use Authorizations (EUA) for ventilators, anesthesia gas …

    • FDA Issues a Second Draft Guidance for Clinical Decision Support SoftwareOctober 1st, 2019

      On September 27, 2019 FDA issued several updates to advance their digital health policies.  One of these updates was a new draft guidance, Clinical Decision Support Software (“Guidance”).  This draft guidance replaces the 2017 draft guidance, Clinical and Patient Decision Support Software (“Prior Draft”), which …

    • FDA Finalizes Updates to the Special 510(k) ProgramSeptember 19th, 2019

      On September 13, 2019 FDA issued a final guidance document The Special 510(k) Program (“Guidance”).  We blogged about the prior draft guidance here.  This Guidance, along with The Abbreviated 510(k) Program, supersedes the 1998 guidance document The New 510(k) Paradigm – Alternate Approaches to Demonstrating …

    • FDA Issues Final Guidance on Postmarketing Safety Reporting for Combination ProductsAugust 5th, 2019

      FDA recently finalized the guidance document, Postmarketing Safety Reporting for Combination Products (“PMSR Guidance”).  The PMSR Guidance addresses compliance with the final rule on postmarketing safety reporting (PMSR) requirements, 21 C.F.R. Part 4, Subpart B (“PMSR final rule”), for combination products.  This is a complicated …

    • Device Manufacturer’s Criminal and Civil Penalties Deserve Closer AttentionJuly 2nd, 2019

      Today’s blog post illustrates how a company’s problems can escalate rapidly from an administrative warning letter to the full weight of the criminal system.  The unfortunate subject is ACell, a manufacturer of medical devices derived from porcine urinary bladder material.  ACell received a Warning Letter …

    • FDA Updates MDR Program in an Effort to Increase TransparencyJune 25th, 2019

      FDA recently announced new changes it is making to the Medical Device Reporting (MDR) program as part of its ongoing efforts to increase transparency on device performance, and detection of device-related safety concerns. FDA is formally discontinuing the Alternative Summary Reporting (ASR) Program, which permitted certain …

    • FDA’s Pre-Cert Program Enters its Testing PhaseMay 29th, 2019

      FDA’s Software Pre-Certification (Pre-Cert) Program is intended to create a new streamlined regulatory process for software as a medical device (SaMD) (see our earlier blog posts on the program here, here, here, and here).  In January of this year, FDA released version 1.0 of Developing …

    • FDA Finalizes Guidance on Non-Clinical Bench Performance Testing Information in Premarket SubmissionsMay 15th, 2019

      On April 26, 2019, CDRH released the final guidance, Recommended Content and Format of Non-Clinical Bench Performance Testing Information in Premarket Submissions (“Final Guidance”).  We previously blogged on the draft version (“Draft Guidance”) here.  Overall, the Final Guidance is much the same as the Draft …

    • Emerging Technology: Implanted Brain Computer Interface Devices for Patients with Paralysis or AmputationMarch 13th, 2019

      An Implanted Brain Computer Interface (BCI) device may sound like something out of science fiction, but FDA apparently believes these devices are on their way to becoming a reality.  FDA recently released a draft guidance document that provides recommendations on how to gain approval to …

    • FDA Issues Final Guidance on Least Burdensome ProvisionsFebruary 13th, 2019

      On February 5, 2019, FDA issued the guidance document The Least Burdensome Provisions: Concept and Principles (Final Guidance).  This version supersedes the prior version in place since October 2002.  FDA published a draft of the guidance (Draft Guidance) in December 2017, which we blogged on …

    • Updates to FDA’s Software Pre-Certification ProgramJanuary 25th, 2019

      On January 7, 2019, FDA released new documents related to its Software Pre-Certification (Pre-Cert) Program: Developing a Software Precertification Program: A Working Model (Working Model) Software Precertification Program: Regulatory Framework for Conducting the Pilot Program within Current Authorities (Regulatory Framework) Software Precertification Program: 2019 Test Plan (Test Plan) In …

    • Medical Device Enforcement and Quality ReportDecember 3rd, 2018

      In light of recent criticism of FDA’s oversight of medical devices, it is curious why FDA did not release a report touting the success of its enforcement activities with the same fanfare as its report on its plan to modernize the 510(k) program, which we reported …

    • Is Your 510(k) Device a Combination Product?November 19th, 2018

      Earlier this year, FDA quietly made changes to their 510(k) clearance letters related to combination products cleared via the 510(k) pathway. The letters now include the following language (new text in bold italics): Although this letter refers to your product as a device, please be aware …