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

    • 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 …

    • Cybersecurity Déjà VuOctober 31st, 2018

      On October 18, FDA issued a new draft guidance document, Content of Premarket Submissions for Management of Cybersecurity in Medical Devices (“Draft Guidance”). When final, it will supersede the 2014 guidance document of the same name (“Current Guidance”). The guidance comes shortly after release of …

    • Final Guidance Issued for Considering Benefit-Risk Factors in 510(k)s with Different Technological CharacteristicsOctober 5th, 2018

      On September 25, 2018, FDA issued a final guidance document: Benefit-Risk Factors to Consider When Determining Substantial Equivalence in Premarket Notifications (510(k)) with Different Technological Characteristics (“guidance”).  A draft of the guidance was issued on July 25, 2014.  When reviewing device 510(k)s, FDA’s review of …

    • FDA Proposes Updates to the Special 510(k) ProgramOctober 3rd, 2018

      On September 28, 2018 FDA issued a new draft guidance document: The Special 510(k) Program (“draft guidance”). The draft guidance was followed by the announcement on October 1, 2018 of a Special 510(k) Pilot Program. The Special 510(k) program was established in 1998 to create a …

    • Will a “Quik” 510(k) be a Quick 510(k)?September 14th, 2018

      On September 6, 2018, FDA launched the Quality in 510(k) Review Program Pilot (“Quik”). With the name “Quik,” it has a lot to live up to.  The goal of the program is to simplify the 510(k) process by providing an alternate method of preparing a …

    • Multiple Function Device Products – FDA Clarifies Its ApproachMay 8th, 2018

      On April 27, 2018 FDA released a draft guidance describing the regulatory approach and policy for multiple function device products. The draft guidance, Multiple Function Device Products: Policy and Considerations, is available here and has been issued in response to the 21st Century Cures Act section …

    • FDA Issues Final Guidance Documents on HCT/Ps, Announces a Three Year Period of Enforcement Discretion for Certain HCT/Ps for Autologous Use (Part I of “The FDA’s Comprehensive Regenerative Medicine Policy Framework”)December 6th, 2017

      On November 16, 2017, FDA released four guidance documents that, together, the Agency described as a “comprehensive policy framework” for applying existing laws and regulations governing regenerative medicine products, including human cells, tissues, and cellular and tissue-based products (“HCT/Ps”).  The policy framework is set forth …

    • FDA Updates “Least Burdensome” Guidance After 17 YearsOctober 11th, 2017

      Sponsors commonly receive a request for additional information (AI) during Food and Drug Administration (FDA) review of a 510(k) submission, de novo classification request, or premarket approval application. In some cases, a sponsor may conclude that one or more AI requests calls for information that …