May 17, 2012

FDA Moves to Mandate eMDR by February 2011; Will Device Firms be Ready?

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

UPDATE 2: (July 2010): FDA: eMDR Guidance Probably Won’t Happen This Summer.

UPDATE 1: (June 2010): Please see our updated blog on the new timeline here.

Well, they finally did it.

After more delays and internal intrigue than your typical Hollywood Blockbuster, the FDA today unveiled their proposed guidance for ultimately mandating electronic submission of mandatory adverse event reports.

It’s going to save time (paper submissions take up to two weeks to process at FDA HQ) and money for both industry and the agency.

But will device firms be ready?

A telling stat that came out of today’s press teleconference announcing the draft guidance: While about 80% of the nearly 500,000 submissions CDER gets already come in electronically, on the CDRH device side it’s only about 15%.

“We have some work to do” on the device side, David Buckles, Ph.D., director of the Division of Postmarket Surveillance at the FDA’s Center for Devices and Radiological Health (CDRH), observed mildly at today’s press conference.

Why are pharma firms so far ahead of device firms here? It’s odd because in many ways device firms are viewed as more tech savvy and more of the early adopter type. But the fact that pharma companies are generally much bigger, with much deeper pockets, probably explains some of why they have such a big electronic jump on their device brethren.

Device companies have also complained that the FDA hadn’t made its eMDR expectations clear. But that excuse won’t really hold now that the agency has issued a pretty straightforward guidance.

Industry has 90 days to comment on the draft guidance. After that, the agency will take a few months maximum to digest and perhaps take advice from those comments. Then they’ll issue a final rule that will mandate esubmissions for mandatory reporting (such as adverse events) a year from then.

So, mark your calendar for sometime around February 2011 for a mandate from the agency.

Will device firms be ready? There’s no excuse not to get with the program now.

Download the PDF version of the draft guidance here.

More information about AssurX’s eMDR solution here.

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Webinar: eMDR & the New Electronic FDA – June 24, 2009

eMDRThe FDA is spending billions of dollars on IT modernization and standardization, so could this finally be the year they mandate eMDR?

The pace of eMDR adoption is also starting to pick up steam. Medical device manufacturers are typically considered early technology adopters but during 2006-2007 (see chart below), eMDR submissions stayed relatively unchanged year over year. However, starting in 2008 electronic submissions more than doubled, and will most likely at least triple this year. At the end of 2008, 11% of MDRs came via eMDR.

emdrchart

So is it time to start thinking about transitioning to eMDR? Most likely say experts from the FDA. According to Indira Konduri, “Get an early start now. We’re here to help and give personalized attention. Assistance from the FDA will be easier now — before it’s mandatory — and you’ll be ready to go when when eMDR is mandated.”

About the Webinar:

AGENDA:

  • Understanding Electronic Medical Device Reporting (eMDR)
  • What the FDA is saying about eMDR and the options available to you today
  • Making the switch from manual to fully automated electronic reporting
  • The FDA’s ESG and how it works for both low and high volume submitters
  • The FDA’s $2.5 billion commitment to IT modernization (and standardization)
  • The FDA’s push for eMDR with the implementation of their new unified electronic system — FAERS
  • A closer look at MedWatch Plus Portal
  • The benefits of true eMDR and developing an effective strategy

TRUE eMDR IN ACTION LIVE DEMONSTRATION

Q&A SESSION

  • Get your eMDR questions addressed by the experts in a Q&A forum

WHO SHOULD ATTEND:

  • Regulatory Affairs and Compliance
  • Quality Management
  • Product Surveillance
  • Information Technology

To request recorded viewing of this event: http://www.assurx.com/eMDRJune09Webinar.html

eMDR eBook 3rd EditionAll attendees will also receive the newly updated 3rd Edition of the eMDR eBook “Leveraging the Benefits of eMDR: A Guide to Improved Operations with Electronic Medical Device Reporting”.

Click here to learn more about AssurX’s eMDR solution.

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Still think eMDR isn’t going to be mandatory? Think again.

fda-logoToo many medical device companies have the view that electronic medical device reporting (eMDR) won’t be mandated by the FDA anytime soon. That’s a pretty unrealistic view to take these days considering the amount of effort and money that’s being spent at the FDA to modernize their IT facility.  Look at the facts: The FDA’s systems are over 10 years old, and each center within the FDA maintains their own data center that can’t perform cross-departmental queries or has any real analytical tools – a key issue these days for combination products – recently exemplified with deaths related to Heparin coated devices.

Back in September 2008, the FDA announced it planned to spend $2.5 billion to upgrade its technology to better track the safety of drugs, devices and food. The funds will be rewarded to 10 contractors as the agency prepares to transfer their data tracking operations to two new systems.

One of those systems is the FAERS (FDA Adverse Event Reporting System). The FDA says this electronic system will be used for receiving, processing, evaluating and analyzing adverse event reports and other safety information for all FDA-regulated products. The new system, MedWatch Plus, will provide a single point of entry for all FDA regulated products and will combine all the various reporting processes and systems into a single repository. The FDA’s goal is to get away from a center-centric system, and combine it all into a unified adverse event environment.  FAERS will have advanced analytical tools and data mining capability to enable the FDA to standardize the reporting process, analyze thousands of safety reports, and efficiently identify and respond to safety issues.

InfoFlow_Diagram_Final_CS3

For medical device companies, the FDA’s plan is to replace the current CDRH’s low volume CeSub (eSubmitter JAVA Applet based program) and implement the Web-based MedWatch Plus Portal. This system will be based on the HL7 ICSR messages that are currently in use by higher volume manufacturers for direct eMDR submissions using the FDA’s AS2 Gateway.

The MedWatch Plus Portal, dubbed the “Rational Questionnaire”, is a joint effort between the FDA and the NIH, and will be a Web-based system for use by consumers, health professionals, investigators, sponsors and other parties for electronic submission of AE reports. This is specifically designed for small device companies with low volume submissions.

The FDA plans to roll out the new FAERS system in phases, with CDRH slated for early 2010. That suggests that the guidance documents for eMDR are due out in the first half of this year, and will most likely require manufacturers to implement eMDR within a year or two.

Think this isn’t important to the FDA? Listen to them talk about it:

“For the first time, we will be able to collect and track safety information from virtually anyone who touches a particular FDA product throughout its life cycle—from manufacturing through initial marketing to its wide-spread use,” explained Dr. Rachel Behrman, FDA Associate Commissioner for Clinical Programs/ Director, Office of Critical Path Programs, the office supporting the effort.  “This will be a key component in an improved, nationwide surveillance system that will strengthen our ability to protect the Nation’s public health.”

For more information about eMDR and the future of the FDA including FAERS, request the 3rd edition of the eMDR eBook here.

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FDA Shows it’s Backing eMDR with Revised User Guide

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

Michael Causey, Editor & Publisher, eDataIntegrityReport.com

The FDA is anxious for eMDR to be formally launched with a full-blown regulation. It’s been delayed, (mostly for internal reasons having more to do with a change in Administration than the actual contents of the reg, we hear) but it’s ultimately a matter of “when, not if,” an eMDR guidance will arrive.

Savvy medical device and drug manufacturers are getting ahead of the curve and embracing eMDR. Others are waiting to be ordered to do it.

Don’t wait too long. You risk losing a competitive advantage, for starters. Did you realize that 11% of MDRs came via eMDR in CY 2008? Or that thirty manufacturers are currently submitting electronically via eMDR?

Yep, it’s the companies that view this as a way to improve efficiency, speed approvals, and improve overall product quality that will ultimately thrive in the marketplace, experts stress.

The FDA just did a nice job updating its user guide to its Electronic Submissions Gateway (ESG). It’s available here at http://www.fda.gov/esg/userguide/WebHelp/default.htm

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Still No Definitive Timeline for eMDR Guidance Documents from the FDA

fda-logo

Back in October 2008, we posted this on our eMDR Updates page on our website:

No definitive release date for eMDR draft guidance documents from the FDA

In a recent Webcast, Indira Konduri of the FDA indicated that they were still working on the proposed rule making for electronic medical device reporting (eMDR). No specific time line has been released. However, she did hint that the time frame to implement (if mandated) would most likely be one year. As with any other proposed guidance, there will be an open public comment period.

Another FDA insider told us that the guidance documents would either be released at the end of this year, or early 2009. Original scheduled release date was 2Q of 2008. We’ll keep you posted as soon as we find out.

According to FDA officials we spoke to a couple of weeks ago, there is still no time-line for releasing the guidance documents to the industry. Apparently, everyone is waiting on the new administration’s leadership team for the FDA to be put in place before proceeding any further. However, considering the significant IT investments that the FDA committed to in 2008, mandating electronic medical device reporting is not a matter of if, but when. We’ll keep you posted.

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