February 4, 2012

FDA CDRH to Hold Series of Webinars on Electronic Medical Device Reporting

We recently blogged about electronic medical device report (eMDR) submissions to CDRH setting new records in 2010. Looks like the FDA would like to get more medical device companies on the bandwagon by offering a series of monthly interactive Webinars. An email sent today from Eugene Reilly states:

Many MDR reporters are already submitting MDRs electronically, but many still have not taken the plunge. If you’re one of those, why wait?  Find out all you need to know to take the mystery out of electronic reporting at one of our upcoming interactive webinars and meet CDRH’s eMDR Team:

Friday, April 29, 2011
1:00 PM–5:00 PM EDT (1:00–1:30: Technical webinar issues/questions handled.)

Friday, June 03, 2011
1:00 PM–5:00 PM EDT (1:00–1:30: Technical webinar issues/questions handled.)

Friday, August 05, 2011
1:00 PM–5:00 PM EDT (1:00–1:30: Technical webinar issues/questions handled.)

Friday, September 30, 2011
1:00 PM–5:00 PM EDT (1:00–1:30: Technical webinar issues/questions handled.)

Friday, November 18, 2011
1:00 PM–5:00 PM EDT (1:00–1:30: Technical webinar issues/questions handled.)

CDRH’s Webinar Connection Information:
We encourage participants to test your connection prior to the webinar. Participants will not be able to enter the actual meeting until the host has logged in on the day of the event.

To join the meeting (Please use your email address to join the Adobe Connect session. We will use this email address to send follow-up information.):
https://collaboration.fda.gov/cdrhemdr/

To test your connection: https://collaboration.fda.gov/common/help/en/support/meeting_test.htm

To get a quick overview:
http://www.adobe.com/go/connectpro_overview

Questions? Please feel free to e-mail us at eMDR@fda.hhs.gov

No news yet on a mandate.

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare

Electronic Medical Device Report (eMDR) Submissions to CDRH in 2010 Sets New Record

As we predicted a few months ago, 2010 proved to be a record setting year for CDRH electronic submissions. The pace of submissions picked up significantly in the 2nd half of 2010, with October being the highest submission month (18,096).  Several years ago the device industry was criticized for not embracing electronic submission technology, but now is in a commanding lead over the rest of FDA’s divisions including CDER.

CDRH 2010 Monthly Statistics

Source: FDA

Looking at the numbers from 2006 – 2010 below, it looks like the device industry has embraced this paperless technology and will continue to grow as the mandate looms in 2011.

CDRH 2006 - 2010 ESG Submission Totals

Source: FDA

It will be interesting to see if the rate of growth will continue at this rapid pace, or will level off. We’ll keep you posted.

More information about electronic medical device reporting solutions.

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare

Device Makers Smash Record in 2010 with eMDR Submissions to FDA

In July of this year, we blogged about how the mid-year electronic medical device reporting submissions had soared to record levels. Now it looks like it’s actually going to be a record breaking year. The FDA has seen record breaking submissions by CDRH, for the first time being outpaced by CDER by almost twofold. In the past few years, CDER submissions to FDA far exceeded those by CDRH.

As you’ll see in the chart below, submissions to CDRH  have grown significantly in 2010.

But what’s even more eye-popping is the comparison of electronic submissions to CDRH for 2009 vs. 2010 (through October) shown in the chart below.

So what’s driving this surge? Many contributing factors can play into these numbers. Many companies have embraced FDA’s options for electronic submissions, and many have implemented commercial off-the-shelf electronic medical device reporting (eMDR) software as part of their overall complaint handling and quality management system. Other factors could include increased vigilance over reportable submissions, numerous new devices that have come to market, anticipation of electronic submissions mandate by FDA, as well as increased device scrutiny from FDA, health professionals and the public at large. Even though we didn’t see the expected mandate on eMDR in 2010, it is listed on CDRH’s priorities for 2011.

Some industry analysts say that device makers, generally smaller entities than pharmaceutical companies, had been slower to embrace eMDR because they didn’t have the same money or staff. But those days are clearly over.

We’ll revisit the 2010 numbers again in January 2011.

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare

Mid-year Electronic Medical Device Report (eMDR) Submissions to CDRH Soar to Record Levels

In January of this year, we took a look at the overall numbers for electronic medical device reporting (eMDR) submissions to the CDRH/FDA. As we predicted, those numbers have risen significantly in the first half of 2010, even though the final rule still has not been published, and probably won’t happen before the end of the summer. Comparing the first six months of 2009 vs. 2010 [see chart below], electronic submissions are up dramatically.

eMDR Submissions 2010 vs. 2009 - First Six Months - Source: FDA

The all-time monthly record was set in June 2010 with 7,755 electronic submissions, and for the first six months of this year they’re up 74% over total submissions in 2009 (21,296 total in 2009 vs. 36,962 first six months of 2010). Even without the eMDR final rule published, companies are taking advantage of paperless electronic submissions to FDA. As Indira Konduri, CDRH eSubmissions Program Manager once told us, it’s better to get on board with the FDA now, rather than wait. I’d take that advice and get it done now, before the final rule is published and everyone rushes to get on board.

It will be interesting to see what happens for the rest of the year.

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare

FDA: eMDR Guidance Probably Won’t Happen This Summer

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

“Check back in August,” FDA spokesman Dick Thomspon told us this week when we asked if the eMDR guidance was coming out anytime soon. “The guidance is not yet complete,” Thompson said. “At this point, I would not expect this to be issued before the end of the summer.”

The FDA has missed several unofficial deadlines for the guidance, others in and close to the agency have told us in recent months. The latest missed deadline was June, when several folks inside the agency told us and others off the record that it was going to be issued that month.

Well, that didn’t happen.

It’s unclear exactly what the cause of the delay is; we’ve heard from those inside the agency who say it’s more about workload and shifting priorities than any guidance content issue, e.g. the eMDR guidance gets shoved off someone’s desk when something else “more important” comes up. More ominously, we’ve also heard some rumblings that the eMDR process is getting a little political much like the Part 11 process did.

At any rate, the agency asked us to check back in August.

Have a nice summer.

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare

Mixed Reviews by Medical Device Companies on FDA's 'Free' eMDR Option

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

Remember that old expression “you get what you pay for”? Well, it’s a cliché, but most of the time these oft-used phrases are oft-used because they have an underpinning of truth. This brings us to the FDA’s free eMDR options for low and high-volume submissions.

In the past few days we’ve connected with a number of folks who either tried it and liked it, tried it and hated it, and/or were afraid to try it because of all the horror stories they heard.

None wanted to speak on the record, but if you are considering going the free route, their comments are, to use another cliché, food for thought.

“We talked to people from several companies and they found creating the files was still considerably more challenging than it should have been,” a medical device QA official told us. Her bottom-line: “We evaluated eMDR in 2009 and were strongly encouraged by others NOT to utilize” it.

On the other side of the ledger (there’s another cliché, for those keeping score), we heard from at least some medical device companies that said the experience was fine. Example: One told us they’d recently filed their first eMDR, and the report was posted on the FDA’s MAUDE database just under a month later.

And it appears the FDA is at least working to improve its eMDR offerings. Earlier this week, for example, the agency issued a bulletin aimed at high volume submitters in its eMDR user group . The agency told those using a gateway to gateway connection using AS2 or thinking of using a high volume solution in the future that the Implementation Specification found in the Health Level Seven (HL7) Individual Case Safety Reporting (ICSR) files has been updated with some important information.

They boiled down to this:

1) Under the section titled “How do I know my submission reached CDRH?” where the 3 acknowledgments sent via the ESG are discussed, they added the following: “For those reporters using a B2B account (i.e. a gateway to gateway connection) using AS2, you should not rely on the “Content-Type” header for determining how the acknowledgments are processed.  Acknowledgments should be processed based on the file extension and actual content, and your systems should be programmed accordingly.”

This was added to address the issue where the content type sent by the Electronic Submissions Gateway (ESG) in test and production differ, the agency explained.

2) Under the section titled “Can I submit attachments?”  the FDA added an instruction:  “Please limit each attachment to 50 MB in size.”

Worth noting: The FDA said anything larger might cause its loading programs to stall.

3) The FDA also added a new question/answer in the FAQ section:
Q:“Electronically submitted adverse event reports do not have all the fields found in the 3500A form able to be mapped. How should we send information that is not able to be mapped to a 3500A field?”

A: “Correct. Some fields such as G5’s check boxes for combination product, pre-1938, and OTC product are not available for mapping. If you would like to indicate this information or any information that is not mapped, please use section H10 (manufacture narrative) to indicate this information.”

Apparently many reporters already have noticed this, but the agency felt it was helpful to have it noted in the implementation file.

The FDA also tried to deal with some other eMDR issues, too, for WebTrader users.

“The FDA Electronic Submissions Gateway (ESG) has heard from trading partners, industry submitters, and ESG account holders about difficulties logging in to the WebTrader portal. The ESG team has been troubleshooting the issue and has found that the large size of some WebTrader inboxes has been causing login difficulties,” the FDA said.

Because many users have left large numbers of old messages in the WebTrader inbox, the FDA ESG staff announced it would delete all messages other than the most recent 20 messages on Monday, June 14th, 2010 at 1PM EDT.

If you haven’t read your messages or if you might want to save them because they have important information from the FDA, you need to open your WebTrader inbox this week and save them to your own computer or a network location your company defines, the agency said. Otherwise, if you don’t read and save your messages before the deadline, all messages beyond the last 20 will be deleted.

The FDA’s other helpful hint: In order to ensure good WebTrader performance in the future, please save a copy of the receipt and acknowledgment files immediately upon receipt and delete copies from your WebTrader inbox or ensure that the WebTrader inbox has a reasonable number of past messages (i.e. <20).

Direct questions/concerns to the FDA ESG staff at esgreg@gnsi.com.

And if you’ve got any great or horrific eMDR experiences to share with us (off the record, if you prefer) please contact me at mcausey@edataintegrityreport.com

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare

Surprise Surprise: FDA Internal Deadline on eMDR Slides to June 2010

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

UPDATE! (July 2010): FDA: eMDR Guidance Probably Won’t Happen This Summer.

Lucy of “Peanuts” fame liked to ask Charlie Brown to come kick that football, only to yank it away at the last minute. That’s kind of how I feel waiting for the FDA to release its final eMDR rule.

Officially, the FDA isn’t saying much publicly. But well-placed sources within the agency have told us in the past that it was “coming soon,” even going so far as to say many months ago that it would be released February 2010.

Guess what? The agency missed that deadline, too. We’re hearing it’s been delayed for a slew of reasons; and few, if any, have to do with the content in the rule itself. Indeed, the agency has been surprised how little comment the eMDR rule proposal received. It’s no longer very controversial, and industry realizes that it is going to happen.

And I feel like Charlie Brown again, but here goes: FDA inside sources told us yesterday that it will be released next month. If that new deadline holds, it is also likely to be mandated within a year of its release, so mark June or July 2011 on your calendar for that.

Indeed, CDRH even placed eMDR at #4 on its top priorities list for 2010.

But the FDA has had its hands full and not enough hands to juggle it all. So, chalk the eMDR delay up to internal FDA issues, e.g. lack of staff, other “higher priorities” knocking the eMDR rule off a person’s desk while they put out another fire, etc.

The agency is committed to eMDR, and industry should be too. Once it is up and humming, it will improve productivity, reduce errors, and cut some compliance costs, too.

Watch this space for the latest developments.

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare

FDA CDRH Electronic Submissions Up Significantly in 2009

fda-logoNumbers don’t lie. Reviewing the year-end numbers for FDA’s CDRH electronic submissions (AS2 Electronic Submissions Gateway) provides some eye popping stats.  This is an early indicator that electronic medical device reporting submissions have significantly increased over 2008, and certainly suggests they’ll rise even faster this year after the final rule is published.

Comment period on the draft guidance ended November 2009. The final ruling is expected within weeks. According to some FDA insiders, many were relieved the agency wasn’t overwhelmed with comments (slightly over two dozen comments were filed), and the ones received were definitely “workable”.

So, what did 2009 numbers look like?

Source: FDA

Source: FDA

As the chart shows, early 2009 got off to a slow start, but picked up significantly in the fourth quarter of the year.

CDRH Year over Year Submissions Stats

Source: FDA

But when comparing 2008 vs. 2009, total submission numbers jumped from 4,619 to 21,296. It’s apparent that the device industry has picked up the pace when it comes to electronic submissions to FDA. And if this isn’t a wake up call for device companies to move away from paper 3500A submissions to eMDR, we don’t know what is.

We’ll be keeping a close eye on this through 2010.

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare

Tobacco, Food, eMDR, Transparency, More Staff Add Up to a Big 2009 for FDA – and 2010 Looks Even Bigger

fda-logoThe early part of the 21st century was a tough time for the FDA. Its budget was curtailed, it lost some important personnel, and the word “acting” kept appearing on people’s business cards.

But 2009 just might be going down in history as the Year of the FDA Turnaround.

In October, the agency announced a long-overdue hiring binge that signals an even stronger FDA is on tap for 2010.

Watch for the agency to get a bigger budget in the coming years – though much of that emphasis will be on the food side and perhaps less on the drug and device side. For FY 2010, the FDA requested a total budget of $3.2 billion. This amount is $511 million more than FY 2009 and represents a 19 percent increase — the largest ever in FDA history. They won’t get it all, but they’ll probably come close.

Here are some other FDA highlights in a big year:

FDA Finally Gets Tobacco

It took years of lobbying and a new President, but in June 2009 the FDA was given the power to regulate tobacco products. This is a huge victory for the agency. It remains to be seen how the FDA will use this new power, but its surge of activity in the second half of 2009 suggests they want to seize the initiative.

Lawrence Deyton, M.S.P.H., M.D., joined the U.S. Food and Drug Administration (FDA) on Sept. 14, 2009, as director of the agency’s new Center for Tobacco Products. He hit the ground running.

“Our objective is to use the best available science to develop and put into action effective public health strategies to reduce the enormous toll of illness and death caused by tobacco products,” Deyton said .

Deyton was also asked how the tobacco regulation differs from FDA’s regulation of drugs or medical devices?

“FDA’s regulatory role for drugs and medical devices is usually based on a safety and effectiveness standard. The tobacco act establishes a new standard: to regulate tobacco products based on a public health and population health standard.

Deyton noted that when FDA gets an application for a new drug to treat a disease, the agency normally considers studies of patients who have the disease. ”But when we get an application for a new tobacco product, the law tells us we have to consider whether permitting the product’s marketing protects the public health and we have to evaluate the effects of the product on the population as a whole. We’re directed to consider both users and nonusers, and whether our action might encourage people who don’t use tobacco products to begin using them, or encourage people who might otherwise quit to continue using them.”

Bottom-line: It was a huge turf battle victory for the FDA and increases the agency’s overall regulatory clout.

Risk Communications

The agency also took big strides forward in how it gets the word out to industry and the public regarding risk. In its Strategic Plan the agency spelled out its perceived role in communicating the risks of regulated product use, defining risk communication anew for a 21st century in which evolving technologies have enabled increased patient and consumer involvement in managing their health and well-being. The document defines the three key areas (science, capacity, and policy) in which strategic actions, in collaboration with relevant domestic and international stakeholders, can improve the generation, dissemination, and regulation of risk communication about regulated products. It also identifies and details 14 specific strategies.

“FDA is showing its commitment to the goals of the plan not just by identifying the strategies it will implement, but also by identifying over 70 actions the agency plans to take within the next few years to improve risk communication,” it says in the Strategic Plan. The document also identifies 14 of those actions that FDA plans to accomplish within the next 12 months.

Clearing Up Transparency

Echoing an Obama campaign promise to make government more open and accountable to taxpayers, the FDA also walked the walked and talked the talk with its new “transparency”  initiative with public meetings in June and November. The agency also opened a blog that, so far, has had a fair amount of uncensored comment both pro and con about agency performance.

Here (Finally) Comes the eMDR Guidance

In August, the FDA unveiled their proposed guidance for ultimately mandating electronic submission of mandatory adverse event reports. It took a long time to come to fruition, and some are lobbying the agency to push it back another year or two, but the simple fact that it was released was a big deal in 2009.

Guidance on Presenting Risk Info

Before unveiling the eMDR rule, the agency also issued  in May the important draft Guidance for Industry: Presenting Risk Information in Prescription Drug and Medical Device Promotion. The guidance is important on several levels, but perhaps the most important is that it addresses factors the FDA considers when evaluating ads and promotional labeling for prescription drugs, ads for restricted medical devices, and promotional labeling for all medical devices for their compliance with the Federal Food, Drug, and Cosmetic Act and relevant regulations.

In doing so, it cleared up a lot of confusion in the industry and signaled a revitalized FDA that was on the way back.

Putting The ‘Food’ Back In Food & Drug Administration

Responding in part to pressure from Congress and consumer groups over beef and other food contamination recalls, the FDA also revitalized its food enforcement in 2009, and this is also an area where the smart money says they’ll be even more active in 2010. In September, the agency capped a number of new food initiatives by unveiling a new reporting system that gives the agency new enforcement teeth when it comes to the food chain.

Here’s a prediction: FDA historians of the future are probably going to see 2009 as the year the agency picked itself up off the ground and started to flex its regulatory muscle again.

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare

Industry to FDA: We like the eMDR initiative, except for…

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

Well, the eMDR comment period has come and gone – and I’ve got to say I’m a little surprised at the relatively low number of comments. But let’s look on the bright side: What we didn’t get in quantity we might have gotten in quality. This is generally as well-articulated and intelligent a group of comments I’ve read in years.

The overall tone of the letters can be summed up like this: Some want more time to implement the rule, while most generally support the eMDR initiative and call for some changes, mostly of a relatively minor, if probably justified, nature.

A few days before the comment period ended, I spoke with Axis Technology President Mike Logan about why there were so few comments. A handful came in after we spoke on Nov. 11, but he and I are still both a bit surprised there weren’t ultimately more comments.

His view:  “Right now I believe people are taking a ‘wait and see’ approach until more firm details are unveiled. As nice of an idea the eMDR is, there are a lot of risks involved and questions that need to be answered, such as how this impacts standards compliance and potential liabilities.” Axis is a provider of IT consulting and data security offerings for healthcare industry organizations.

Some of the comments seek the kind of clarification Logan believes some in industry need before they are fully confident in using eMDR.

From a medical device standpoint, AdvaMed’s comment is one of the most important since it speaks for so many others (its member companies produce nearly 90 percent of the health care technology purchased each year in the U.S.). It’s also worth noting that the trade association can “get away” with saying things to the FDA that an individual company might not want to risk.

At the outset, AdvaMed says it supports the initiative. But, and there’s always a but in cases like this, they want to see the time stamp issue clarified, a concern echoed by Abbott. AdvaMed also wants the agency to adopt the date and time in the first acknowledgement sent to the submitter by the FDA that the report was received. It also wants the agency to develop a grace period for companies when they have a system outage, among a few other requests.

AdvaMed also wants the final rule to take effect at least two years after publication of the final rule.

On balance, most of the changes requested by the comment letters strike me as reasonable. Industry won’t get everything it asks for here, but I suspect the FDA will work pretty hard to accommodate the most reasonable requests.

Remember, the agency is still smarting from how it mishandled 21 CFR Part 11 in 1997. Back then, it made the rule way too literal and hands-on. Its stated goal to was to advance the use of technology; instead the FDA set it back for several years.

In many ways, I think the agency is to be commended for learning from its mistakes with Part 11 and applying them to its rollout of eMDR. The eMDR guidance is not perfect for everyone, but it’s pretty good for almost all, and that kind of effective compromise strikes me as democracy at its best. Here’s hoping the FDA takes some of the best comments to heart and improves a guidance that’s pretty close to the mark.

To learn more about a COTS solution for eMDR, click here.

TwitterFacebookDiggDeliciousTechnorati FavoritesEmailPrintFriendlyShare