Understanding the Importance of Clinical Performance Evaluation for IVDs

Understanding the Importance of Clinical Performance Evaluation for IVDS: Meeting Regulatory Expectations

Summary

In vitro diagnostics (IVD) are tests that are carried out outside the human body to diagnose a wide range of illnesses and monitor various medical conditions.
Importance of Clinical Performance Evaluation (CPE) for IVDS is essential for ensuring the accuracy and reliability of these diagnostic tools.
Meeting regulatory expectations is crucial for ensuring the safety, efficacy, and quality of these devices.
Adopting strategies like thorough research, building strong partnerships, investing in quality management systems, and staying informed about regulatory developments can navigate the regulatory process effectively and bring compliant IVD devices to the market, ultimately benefiting patients and healthcare providers alike.

Introduction

Having a detailed clinical performance evaluation for in-vitro diagnostics in India is extremely important to meet the regulatory expectations. It highlights the need for thorough research, strong partnerships, and compliance with quality management systems to navigate the regulatory process effectively.

What are In-Vitro Diagnostics?

In vitro diagnostics (IVD) are tests that are carried out outside the body to diagnose a wide range of illnesses and monitor various medical conditions. These tests involve using specialized tools and instruments such as test strips and reagents to analyse specimens like blood, tissue, or urine.

Types of IVDs

In India, the Central Drugs Standard Control Organization (CDSCO) classifies IVDs into four categories based on the potential risks associated with their use.

Risk Class	Description	Example
Class A	Low-risk	Blood smear cassette
Class B	Low to moderate risk, requires registration	Pregnancy test kits, blood glucose test strips
Class C	Moderate to high risk, requires registration	HIV test kits, Hepatitis B test kits
Class D	High risk, requires approval	Cancer diagnostic kits, genetic test kits

Table 1: Classification of IVD Medical Devices

Why Clinical Performance Evaluation is important?

Clinical Performance Evaluation (CPE) helps to assess the analytical and clinical performance of a new IVD medical device. It tests for its sensitivity, specificity, safety, accuracy, precision, and clinical validity, using human specimens systematically. It is an ongoing process that continues throughout the device’s lifecycle. Thorough clinical performance evaluations help to demonstrate the effectiveness and reliability of IVD devices, ensuring compliance with regulatory standards and suitability for diagnosing and monitoring medical conditions.

Process of Clinical Performance Evaluation

The Central Drugs Standard Control Organization (CDSCO) in India regulates the process of CPE to ensure that IVDs meet the necessary standards for accuracy, safety, and clinical validity. It includes the following steps:

Conduct of clinical investigation: It must be conducted in accordance with CDSCO rules and the permission has to be granted by the Central Licensing Authority.
Ethical Approval: Before conducting the study, approval must be obtained from an Ethics Committee registered with CDSCO. The committee ensures that the study meets ethical standards and safeguards the rights and welfare of participants.
Application for Permission: The sponsor must submit an application for permission to conduct a clinical investigation to the Central Licensing Authority in Form MD-22, accompanied by specified information.
Pilot Clinical Investigation: If conducting a pilot clinical investigation, the sponsor must pay a fee as specified in the Second Schedule and provide information as specified in the Seventh Schedule.
Grant of Permission: The Central Licensing Authority may grant permission to conduct a clinical investigation if satisfied that the requirements have been complied with. If not satisfied, the application may be rejected within ninety days.
Conditions for Permission: After grant of permission, the sponsor must comply with several conditions, including initiating the investigation after Ethics Committee approval, conducting the investigation according to approved plans and guidelines, and registering the investigation with the Clinical Trial Registry of India.
Reporting and Documentation: The sponsor must submit annual status reports of each investigation to the Central Licensing Authority and report any suspected unexpected serious adverse events within fourteen days.
Medical Management and Compensation: In case of injury or death during a clinical investigation, the sponsor must provide complete medical management or compensation as per the rules.
Inspection and Review: The premises of the sponsor and clinical investigation sites are open for inspection by the Central Licensing Authority to verify compliance with the rules. The Authority may impose or exempt any condition while granting permission for specific investigations.

Therefore, evaluation of IVDs is a systematic and rigorous process that ensures these devices meet the necessary standards for accuracy, safety, and clinical validity, as per the guidelines set by CDSCO.

Importance of Clinical Performance Evaluation for IVDS

Fig 1: Process of Clinical Performance Evaluation

Regulation of IVDs

The regulatory assessment of an IVD device involves several key steps to ensure compliance with regulatory requirements and standards.

Fig 2: Regulatory Assessment of IVDS

In India, the regulation of IVD devices is governed by the CDSCO under the Medical Devices Rules, 2017. These rules establish the regulatory framework for the registration, import, manufacture, sale, and distribution of IVD devices in the country. Meeting regulatory expectations in the context of IVD devices poses several challenges, but with the right strategies, these challenges can be overcome.

One of the key challenges in meeting regulatory expectations is ensuring compliance with the stringent requirements set forth by the CDSCO. This includes the need for CPE studies to demonstrate the analytical and clinical performance of IVD devices.

Challenges in Meeting Regulatory Expectations

Some of the common challenges faced by manufacturers in meeting regulatory expectations are:

Lack of clarity: The regulatory requirements for IVD devices can be complex and ambiguous, leading to confusion among manufacturers.
Resource constraints: Conducting CPE studies and obtaining regulatory approvals require significant resources in terms of time, money, and expertise.
Changing regulations: The regulatory landscape for IVD devices is constantly evolving, requiring manufacturers to stay updated with the latest requirements.

Strategies for Successful Evaluation

To overcome these challenges and meet regulatory expectations, manufacturers can adopt the following strategies:

Conduct thorough research: Understand the regulatory requirements specific to IVD devices in India and seek guidance from experts if needed.
Build strong partnerships: Collaborate with local experts, consultants, and regulatory bodies to navigate the regulatory process effectively.
Invest in quality management systems: Implement robust quality management systems to ensure compliance with regulatory requirements and standards.
Stay informed: Keep abreast of the latest developments in the regulatory landscape for IVD devices in India and adapt your strategies accordingly.

Conclusion

In conclusion, meeting regulatory expectations for a CPE for In-Vitro Diagnostics in India is crucial for ensuring the safety, efficacy, and quality of these devices. While the regulatory landscape may pose challenges such as complex requirements and resource constraints, manufacturers can overcome these challenges by adopting strategies like thorough research, building strong partnerships, investing in quality management systems, and staying informed about regulatory developments. By doing so, manufacturers can navigate the regulatory process effectively and bring compliant IVD devices to the market, ultimately benefiting patients and healthcare providers alike.

References

Regulatory guidance for medical device 2017 CDSCO https://cdsco.gov.in/opencms/opencms/system/modules/CDSCO.WEB/elements/download_file_division.jsp?num_id=OTg4NQ==
GHTF (2008b) Principles of In-Vitro Diagnostic (IVD) Medical Devices Classification 2016. https://www.imdrf.org/sites/default/files/docs/ghtf/final/sg5/technical-docs/ghtf-sg5-n8-2012-clinical-performance-studies-ivd-medical-devices-121102.pdf#:~:text=The%20objective%20of%20a%20clinical%20performance%20study%20is,literature%20and%2For%20experience%20gained%20by%20routine%20diagnostic%20testing. A GUIDANCE DOCUMENT for MEDICAL DEVICES Indian Pharmacopoeia Commission National Coordination Centre-Materiovigilance Programme of India Ministry of Health & Family Welfare Government of India https://ipc.gov.in/images/mvpi/Guidance_Document.pdf
Overview on Performance Evaluation / External Evaluation of In-vitro Diagnostic Medical Device (IVDMD) 2022 Ministry of Health and Family Welfare Government of India https://cdsco.gov.in/opencms/resources/UploadCDSCOWeb/2018/UploadPublic_NoticesFiles/1Draft%20Guidance%20on%20PER%20.pdf
Manu M, Anand G. A review of medical device regulations in India, comparison with European Union and way-ahead. Perspect Clin Res. 2022 Jan-Mar;13(1):3-11. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8815674/

Frequently Asked Questions

What is FORM MD-24?

Form MD 24 is an application form to get the grant or permission to conduct a performance evaluation of a new in-vitro diagnostic kit.

Is their any timeline for initiation of clinical performance evaluation after grant of permission?

The study must be initiated within one calendar year of receiving the permission. If permission is not granted, it will need to be approved in advance. The sponsor should submit an annual status report on the study to Central Licensing Authority. If the investigation ends, it should also be reported within thirty days.

What is Form MD-25?

The permission to conduct clinical performance evaluation for a new in vitro diagnostic medical device is granted in Form MD-25 by the Central Licensing Authority.

What is the labelling requirement for medical device or a new in vitro diagnostic medical device for purpose of test, evaluation, clinical investigations?

Any medical device or new in vitro diagnostic medical device imported or manufactured, for the purpose of clinical investigation or clinical performance evaluation, test, evaluation, demonstration and training, shall be kept in containers bearing labels, indicating the name of the product or code number, batch or lot number, serial number wherever applicable, date of manufacture, use before date, storage conditions, name and address of the manufacturer, and the purpose for which it has been manufactured.

Which class of in-vitro diagnostics medical devices require clinical performance evaluation in India?

Clinical performance evaluation in India are typically only required for risky IVD (Class B, Class C and Class D) without predicates and may also be required for Class A IVD’s.

What is clinical performance evaluation of in vitro diagnostic (IVD)?

Clinical performance evaluation is the systematic performance assessment of an in vitro diagnostic medical device using a specimen taken from humans to evaluate its performance.IVD Clinical investigation is the ability of the diagnostic kit to perform its intended function as claimed by the manufacturer. It includes the analytic and, where applicable the clinical performance that supports the intended purpose.

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Understanding the Importance of Clinical Performance Evaluation for IVDS: Meeting Regulatory Expectations

Frequently Asked Questions

What is FORM MD-24?

What is FORM MD-24?

Is their any timeline for initiation of clinical performance evaluation after grant of permission?

Is their any timeline for initiation of clinical performance evaluation after grant of permission?

What is Form MD-25?

What is Form MD-25?

What is the labelling requirement for medical device or a new in vitro diagnostic medical device for purpose of test, evaluation, clinical investigations?

What is the labelling requirement for medical device or a new in vitro diagnostic medical device for purpose of test, evaluation, clinical investigations?

Which class of in-vitro diagnostics medical devices require clinical performance evaluation in India?

Which class of in-vitro diagnostics medical devices require clinical performance evaluation in India?

What is clinical performance evaluation of in vitro diagnostic (IVD)?

What is clinical performance evaluation of in vitro diagnostic (IVD)?

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