Manufacturers: time to shape up your CERs
Clinical Evaluation Report (CER) makes a strong case for
your device and its intended use backed by impactful scientific evidence. The
aim of a CER is to reduce the risk that the users and patients are exposed to
when using a medical device.
Clinical evaluation is an essential prerequisite for risk
management. It justifies the assumptions made in the risk management file, with
respect to the benefits and thus the acceptance of a certain risk-benefit
ratio.
When looking at the clinical evaluation of a new device, the
available data will typically be limited. The evaluation will be based on the
best available data at the time; however, the best indication of safety and
performance will only be obtained once the device is in use. With the
increasing lifespan of devices on the market, there will be increased need for
clarity regarding the risk/benefit profile of the device.
IZiel completes the Clinical Evaluation Report (CER) as per
the following changes in revision Med-Dev Rev. 4 with focus on detailing and
clarity on every step of the clinical evaluation process that has been
conducted by the manufacturers and evaluators.
- Frequent
updates: For all devices, every time there is change in the information
available on the device based on post-marketing surveillance (PMS) that
affects the evaluation or conclusion of the device, the CER needs to be
updated. For high-risk devices, CERs need to be updated annually at the
minimum, while low-risk and well-established devices can update CERs every
2-5 years.
- Demonstrate
scientific accuracy: Greater emphasis has been placed on
establishing the scientific validity of the data for each stage of the
entire process of clinical evaluation: weighting the data, literature
search, retrieval methods, data appraisal, its analysis and weighting
it,
- Qualifications
of evaluators: A higher education degree and 5 years of professional
experience, or 10 years of professional experience where the degree is not
a prerequisite has been introduced as a pre-requisite. Deviations from
these need to be document justifiably. A declaration of interest for all
evaluators is a must as well.
- Measurable
objectives for CER: The objectives of the CER must be clearly
linked to specific endpoints on the safety, performance, and risk-benefit
aspects.
- Establishing
equivalent: Risks-benefits, safety and performance of the claimed
equivalents need to be established in greater detail.
In line with the expectations of the European Authorities,
clarity and structure are at the core of everything we do at IZiel. Ensuring
thoroughness and scientific accuracy at every step of collating data and
presenting it in the CER are our prime objectives, and receiving approval is
the clear endpoint for every report we create. EU MDR identifies the use of
clinical investigations as a method of assessing the benefit-risk ratio of
medical devices. Additionally, risk assessment is useful to justify any
foreseeable risks to trial subjects when weighed against the benefits. These
should be well-documented in the clinical investigation plan. The plan is also
required to include an ongoing monitoring strategy for the risks and the
benefit-risk ratio.
Comments
Post a Comment