2020, Sep
The US Food and Drug Administration has issued a new report on progress as well as next steps for its ongoing pilot program to develop a new certification framework for Software as a Medical Device (SaMD).
FDA’s updates on the agency’s Software Precertification (Pre-Cert) Program summarizes key findings from the program’s pilot phase, as well as the implications of these findings for further development efforts:
- “Mock” Excellence Appraisals of SaMD products based on remote work as well as objective evidence may effectively substitute for on-site visits;
- The program’s Streamlined Review component for qualifying SaMD requires additional examination and testing;
- Collecting and examining real-world performance data enables observation of measures including human factors engineering and usability, safety and risk management, but further testing is required to support assessing health benefits using such data.
What comes next for Pre-Cert development
Following FDA’s testing activities carried out with participating companies including Apple, FitBit, Roche, Johnson & Johnson and Samsung, the regulator plans additional iterative and revised testing approaches for the Pre-Cert program.
Among these next steps are utilizing a draft library of key performance indicators (KPIs) to further develop and test “excellence thresholds” for Pre-Cert program participants, as well as establish test scenarios for least-burdensome methods for setting safe and effective total product lifecycle processes for SaMD products.
Regarding the Streamlined Review framework whereby Pre-Cert participants obtain expedited US market access, FDA plans further analysis of data collected via Excellence Appraisals, premarket review determinations and real-world performance monitoring to establish relevant criteria.
In general, FDA is now shifting efforts toward integration of key Pre-Cert program components including Excellence Appraisals, review determinations, Streamlined Review and real-world performance as well as developing a deeper understanding of how these components function as whole.
In addition, the 2020 Update summarizes the FDA’s test activities, provides an update on our progress, shares what we have learned, and outlines next steps. For more information, see Developing the Software Precertification Program: Summary of Learnings and Ongoing Activities: 2020 Update
For additional US FDA medical device and SaMD regulatory resources, please contact us for more information on our medical device consulting services
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