ALERT. FDA Guidance for Industry and FDA Staff: Mobile Medical Applications. Health & FDA Business November 2013

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1 ALERT Health & FDA Business November 2013 FDA Guidance for Industry and FDA Staff: Mobile Medical Applications On September 25, 2013, the Food and Drug Administration (the FDA ) released final guidance on the regulatory requirements regarding the introduction of mobile medical applications into the marketplace (the "Final Guidance"). The purpose of the Final Guidance and its Appendices is to assist manufacturers with determining if a product is a mobile medical app and if so the FDA s expectations for that product. This Alert summarizes some the key components of the Final Guidance. I. Summary of the Guidance This Final Guidance informs manufacturers, distributors and other entities on how the FDA intends to apply its regulatory authorities to select software applications intended for use on mobile platforms (mobile applications). 1 Some mobile applications may meet the definition of a medical device under section 201 of the Federal Food, Drug, and Cosmetic Act (FD&C Act)), but because some may pose a lower risk to the public, FDA intends to exercise enforcement discretion. A majority of mobile applications either do not meet the definition of the FD&C Act or are in a category where the FDA intends to exercise enforcement discretion. The FDA intends to apply its regulatory oversight on those mobile applications that are medical devices and whose functionality could post a risk to a patient s safety if the mobile application does not function appropriately. The Final Guidance is intended to provide clarity and predictability for manufacturers of these mobile applications. 1 While many have suggested that this guidance provides similar views on software, the Agency has taken a more formalized position on certain software requirements and the classification of such products. For example, the FDA has previously clarified that when stand-alone software is used to analyze medical device data, it has traditionally been regulated as an accessory to a medical device or as medical device software. Medical Devices; Medical Device Data Systems Final Rule (76 FR 8637) (Feb. 15, 2011). GREENBERG TRAURIG, LLP ATTORNEYS AT LAW

2 The Final Guidance provides lengthy definitions of the following terms: > Mobile Platform > Mobile Application > Mobile Medical Application > Regulated Medical Device > Mobile Medical App Manufacturer The above-referenced definitions can be found in the full guidance below: II. Scope The Final Guidance explains the FDA s intent to focus its oversight on a segment of mobile apps. III. Regulatory Approach for Mobile Medical Apps The FDA intends to apply its regulatory oversight to only those mobile apps that are (1) medical devices; and (2) whose functionality could pose a risk to a patient s safety if the mobile app were to not function as intended. The FDA believes that if it fails to function as intended, this subset of mobile medical apps poses potential risks to the public health as currently regulated devices. The FDA strongly recommends that manufacturers who fall within the scope of this guidance follow the Quality System 2 regulation (which includes good manufacturing practices) in the design and development of their mobile medical apps and initiate prompt corrections to their mobile medical apps, when appropriate, to prevent patient and user harm. Manufacturers of mobile medical apps must meet the requirements associated with the applicable device classification. A. Mobile medical apps: Subset of mobile apps that are the focus of the FDA s regulatory oversight The FDA currently intends to apply its regulatory oversight to only the subset of mobile apps. 3 Of major importance, mobile apps can transform a mobile platform into a regulated medical device by using attachments, display screens, sensors, or other such methods. In spite of the transformation, FDA considers such mobile apps to be mobile medical apps. The following are mobile apps that the FDA considers to be mobile medical apps that are subject to regulatory oversight: > Mobile apps that are an extension of one or more medical devices by connecting 4 to such device(s) for purposes of controlling 5 the device(s) or displaying, storing, analyzing, or transmitting patient-specific medical device data. > Mobile apps that transform the mobile platform into a regulated medical device by using attachments, display screens, or sensors or by including functionalities similar to those of 2 See 21 CFR part See Appendix C. 4 To meet this criterion, the mobile medical apps need not be physically connected to the regulated medical device (i.e. the connection can be wired or wireless). 5 Controlling the intended use, function, modes, or energy source of the connected medical device. GREENBERG TRAURIG, LLP ATTORNEYS AT LAW 2

3 currently regulated medical devices. Mobile apps that use attachments, display screens, sensors or other such similar components to transform a mobile platform into a regulated medical device are required to comply with the device classification associated with the transformed platform. > Mobile apps that become a regulated medical device (software) by performing patient-specific analysis and providing patient-specific diagnosis, or treatment recommendations. These types of mobile medical apps are similar to or perform the same function as those types of software devices that have been previously cleared or approved. B. Mobile Apps for which the FDA intends to exercise enforcement discretion (meaning that FDA does not intend to enforce requirements under the FD&C Act) The Final Guidance illustrates the FDA's exercise of enforcement discretion for mobile apps that: (i) Help patients (i.e., users) self-manage their disease or conditions without providing specific treatment or treatment suggestions; (ii) Provide patients with simple tools to organize and track their health information; (iii) Provide easy access to information related to patients health conditions or treatments; (iv) Help patients document, show, or communicate potential medical conditions to health care providers; (v) Automate simple tasks for health care providers; or (vi) Enable patients or providers to interact with Personal Health Record ( PHR ) or Electronic Health Record ( HER ) systems. It is important to note that some mobile apps listed above and below may be considered mobile medical apps, and others might not. The following examples represent mobile apps for which the FDA intends to exercise enforcement discretion: IV. > Mobile apps that provide or facilitate supplemental clinical care, by coaching or prompting, to help patients manage their health in their daily environment. > Mobile apps that provide patients with simple tools to organize and track their health information. > Mobile apps that provide easy access to information related to patients health conditions or treatments (beyond providing an electronic copy of a medical reference). > Mobile apps that are specifically marketed to help patients document, show, or communicate to providers potential medical conditions. > Mobile apps that perform simple calculations routinely used in clinical practice. > Mobile apps that enable individuals to interact with PHR systems or EHR systems. Regulatory Requirements Manufacturers of mobile medical apps are subject to the requirements described in the applicable device classification regulation. 6 6 Class I devices: General Controls, including: Establishment registration, and Medical Device listing (21 CFR Part 807); Quality System (QS) regulation (21 CFR Part 820); GREENBERG TRAURIG, LLP ATTORNEYS AT LAW 3

4 Our team will continue to provide you with updated information on various aspects of this Final Guidance. This GT Alert was prepared by Nancy Taylor and Chad Ehrenkranz. Questions about this information can be directed to: > Nancy Taylor > Chad Ehrenkranz > Any member of Greenberg Traurig s Health & FDA Business team > Or your Greenberg Traurig attorney Labeling requirements (21 CFR Part 801); Medical Device Reporting (21 CFR Part 803); Premarket notification (21 CFR Part 807); Reporting Corrections and Removals (21 CFR Part 806); and Investigational Device Exemption (IDE) requirements for clinical studies of investigational devices (21 CFR Part 812). Class II devices: General Controls (as described for Class I), Special Controls, and (for most Class II devices) Premarket Notification. Class III devices: General Controls (as described for Class I), and Premarket Approval (21 CFR Part 814). GREENBERG TRAURIG, LLP ATTORNEYS AT LAW 4

5 Albany Denver New York Silicon Valley Amsterdam Fort Lauderdale Orange County Tallahassee Atlanta Houston Orlando Tampa Austin Las Vegas Philadelphia Tel Aviv^ Boca Raton London* +44 (0) Phoenix Tysons Corner Boston Los Angeles Sacramento Warsaw~ Chicago Mexico City San Francisco Washington, D.C Dallas Miami Seoul West Palm Beach Delaware New Jersey Shanghai White Plains This Greenberg Traurig Alert is issued for informational purposes only and is not intended to be construed or used as general legal advice nor as a solicitation of any type. Please contact the author(s) or your Greenberg Traurig contact if you have questions regarding the currency of this information. The hiring of a lawyer is an important decision. Before you decide, ask for written information about the lawyer s legal qualifications and experience. Greenberg Traurig is a service mark and trade name of Greenberg Traurig, LLP and Greenberg Traurig, P.A. *Operates as Greenberg Traurig Maher LLP. **Greenberg Traurig is not responsible for any legal or other services rendered by attorneys employed by the strategic alliance firms. +Greenberg Traurig s Mexico City office is operated by Greenberg Traurig, S.C., an affiliate of Greenberg Traurig, P.A. and Greenberg Traurig, LLP. Operates as Greenberg Traurig LLP Foreign Legal Consultant Office. ^Greenberg Traurig's Tel Aviv office is a branch of Greenberg Traurig, P.A., Florida, USA. ~Greenberg Traurig s Warsaw office is operated by Greenberg Traurig Grzesiak sp.k., an affiliate of Greenberg Traurig, P.A. and Greenberg Traurig, LLP. Certain partners in Greenberg Traurig Grzesiak sp.k. are also shareholders in Greenberg Traurig, P.A. Images in this advertisement do not depict Greenberg Traurig attorneys, clients, staff or facilities. No aspect of this advertisement has been approved by the Supreme Court of New Jersey Greenberg Traurig, LLP. All rights reserved. GREENBERG TRAURIG, LLP ATTORNEYS AT LAW 5

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