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Radiological Devices Advisory Committee Meeting . November 18, 2009 John A. DeLucia iCAD, Inc. Comments. CAD Guidance Informed Consent for Image Collection. CAD Guidance – General Comments. We welcome the efforts of FDA in issuing this guidance Catalyst for change

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Radiological devices advisory committee meeting

Radiological Devices Advisory Committee Meeting

November 18, 2009

John A. DeLucia

iCAD, Inc.


Comments
Comments

  • CAD Guidance

  • Informed Consent for Image Collection


Cad guidance general comments
CAD Guidance – General Comments

  • We welcome the efforts of FDA in issuing this guidance

    • Catalyst for change

    • CAD manufacturers experiencing gridlock in FDA review of submissions

    • iCAD has experienced unreasonable delays in our submissions

    • New products and improvements are not getting to market and ourpatients in timely manner

  • Areas of Concern

    • The new CAD guidance only addresses new or significantly modified 510(k) CAD devices and not Class III CAD devices

    • Lacks a robust testing and submission paradigm


Cad guidance 510 k cad devices
CAD Guidance – 510(k) CAD Devices

  • The new CAD guidance1 presents examples where modifications to cleared 510(k) CAD devices may result in new submissions

    • Focus on testing & clinical considerations and device classification

  • FDA should reference an existing guidance document in the new CAD Guidance

    • “Deciding When to Submit a 510(k) for a Change to an Existing Device (K97-1) January 10, 1997”

      • Detailed flowchart to assess modifications to 510k devices

      • The 510(k) holder is best qualified to make this assessment

        1. Draft Guidance for Industry and FDA Staff: Computer-Assisted Detection Devices Applied to Radiology Images and Radiology Device Data - Premarket Notification [510(k)] Submissions


Cad guidance class iii cad devices
CAD Guidance – Class III CAD Devices

  • No guidance (paradigm) on when to submit a PMA supplement for Class III devices as there is for 510(k) devices

  • The guidance does not answer key concerns of Class III CAD manufacturers:

    • How to handle incremental changes to Class III CAD devices?

      • E.g. Modification to a mammographic CAD software interface to accept new digital (DR/CR) images with no change to CAD algorithm


Cad guidance class iii cad devices1
CAD Guidance – Class III CAD Devices

  • For approved CAD devices that do not have reader studies, is standalone testing still acceptable for incremental changes?

  • For approved CAD devices with valid reader studies, when do incremental performance changes, demonstrated through standalone testing, trigger another reader study?

  • Industry needs a clear paradigm issued in a timely manner to move forward


  • Sample testing paradigm for approved class iii cad devices
    Sample Testing Paradigmfor Approved Class III CAD Devices

    Industry Needs a Testing Paradigm Based on Science, Safety, and Efficacy And Proportional To the Type of Change


    Informed consent
    Informed Consent

    • FDA's Investigational Device Regulations are intended to encourage the development of new, useful devices

    • Image collection is critical to CAD development

      • Development, training and testing of the software algorithm

    • There are two types of image collection:

      • Retrospective – data acquired from existing or historical clinical case records

      • Prospective – data acquired concurrently during patient evaluation & treatment


    Informed consent1
    Informed Consent

    • FDA has consistently maintained that:

      • There are no exceptions from the informed consent requirements on the grounds that specimens are not identifiable, AND

      • FDA regulations do not allow IRBs to decide whether or not to waive informed consent

    • iCAD believes that informed consent should be waived for de-identified retrospective data collection

      • No/little patient risk, no adverse affect to patient health information, impractical to collect informed consent

      • Least Burdensome approach

      • Further, in our experience there is significant confusion amongst IRBs on this issue

    • FDA should seriously consider exercising enforcement discretion as to the informed consent requirements for de-identified retrospective image collection as they do with in-vitro diagnostic leftover specimens1

      1. “Guidance on Informed Consent for In Vitro Diagnostic Device Studies Using Leftover Human Specimens that are Not Individually Identifiable”


    Summary
    Summary

    • New Guidance

      • We need clear/concise guidance for all CAD devices whether new or modified

      • Acceptable Clinical Testing & Regulatory Submission Paradigm

    • Informed Consent

      • FDA should exercise enforcement discretion for informed consent requirements during de-identified retrospective image collection



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