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CE marking for medical apps is a delicate process, and many people who want to develop apps scare away from it. Yes, it is a lot of work, but let's explain why you shouldn't be afraid, what were our learning when we did the process for our award winning medical app iP Voiding Diary, and why you should be happy, too.
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Synappz © 2013
Why you should be happy
..with CE-marking
Synappz © 2013
Who are we?
Erik van der Zijden BSc MBA Piet Nelis DVM MBA Erich Taubert MD
One app, one life. At least.
Synappz © 2013
Meet the Synappz App Family
voidingdiary
Synappz © 2013
FIRST
MEDICAL APP
Ingredients for an awesome medical app
Synappz © 2013
Connect
APIsStandards (OpenEHR, HL7, DICOM)WearablesSensor Tech
See
Interaction DesignGraphical DesignCodingUse caseMarketing & PR
TrustCE certificationSector certificationNorms, Protocols (NEN7510, HIPAA)EncryptionConformity AssessmentAnonymization/Pseudonymization
Believe
Validation(Scientific) publications
Community Best PracticesExpert Co-Creation
Awards
Do Implementation ProgramTraining & Support
Change Management
Synappz © 2013
Why CE-marking?
Synappz © 2013
Deciding whether we need one
• Step 1 - Computer program? iP VD is made up of programming language, and depending on the input, iP performs a certain function. In addition, software applications are explicitly mentioned as an example of a computer. Step 1 is therefore affirmative (‘Yes’).
• Step 2 - Part of a medical device? If iP VDis regarded as part of a medical device, the medical device must be fully assessed and there is no place to independently assess iP. iP performs its function autonomously and can therefore be considered as stand-alone software. Step 2 is therefore negative (‘No’).
• Step 3 - Data handling? iP VD would fall outside the definition of a medical device if it did not handle the entered data or would merely save the data, communicate simple searches orcompress the data without any loss of data. But the data entered into iP VD are used to compile a report and to compare them with standard values (reference data). This implies that iP, based on its data processing properties, qualifies as a medical device. Step 3 is affirmative (‘Yes’).
• Step 4 - Individual medical care? The function as mentioned under step 3 is intended as abenefit for the individual user. That means the software is used for the evaluation of individual patient data or to support or influence medical care data to the individual patient. The reports in iP provide insight for the patient and the doctor in the patient’s water balance and give an indication to what extend this is abnormal. This implies iP VD provides individual care to benefit individual patients. Step 4 is affirmative (‘Yes’).
• Step 5 - Medical purpose? iP is intended by the manufacturer to be used for (diagnostic ortherapeutic) purposes as mentioned in the definition of a medical device. The insight into the patient’s water balance and the indication as to how far the patient’s data deviate from normal assist the doctor in setting a diagnosis regarding potential pathological conditions in that patient. In addition, the water balance is closely related to various physiological processes and therefore iP VD can be used to study such physiological processes. Synappz, the manufacturer of iP VD, has intended iP VD for the purposes of supporting the doctor’s evaluation. Step 5 is affirmative (‘Yes’).
Deciding whether we need one
Based on the above decision tree analysis, iP VD can indeed be qualified as a medical device.
Synappz © 2013
We needed a bit of help
Synappz © 2013
Our learnings
A lot of work, difficult to do alone.
MEDDEV important source, but lawyers still necessary.
Create clear ‘Intended Use’ statement (e.g. Withings).
Self-certification helps, but could be better (e.g. clinical validation).
We need also quality mark (e.g. VvAA/KNMG).
Regulations follows technology.
Synappz © 2013
Why you should be happy?
You’re a medical app developer in an exciting field.
Authorities take your business serious.
Separate the boys from the men.
Gain trust.
Taken seriously.
Good karma.
Hey! It’s fun to write technical dossiers.
Synappz © 2013
Don’tbe!
Synappz © 2013
hEyewayOphtalmology. Redefined.
Does it need
?