Author: William Hyman

Since connectivity runs on software, and some medically related software is a medical device, and medical devices are regulated by the FDA, those involved in connectology must pay at least some attention to what the FDA is saying about the subject of medical software that is not an inherent part of some other medical device.  In this regard the FDA speaks in multiple ways, ranging from regulations, to final guidance documents (fGD), to draft guidance documents (dDG), to more casual public comments. Recently (since October 1st) the FDA has been busy in the software space by releasing several new...

On October 25, 2017 the FDA released its guidance on "Deciding When to Submit a 510(k) for a Software Change to an Existing Device". A draft of this guidance was released in August 2016 and I commented on that draft here. The scope of what was changed is not easy to discern, especially since the draft is no longer directly available and the URL for the final guidance is the same as that for the previous draft. No doubt there are many people who have a copy of the draft and the Wayback Machine might also be explored. But such...

Software as a Medical Device (SaMD) is terminology under the aegis of a work group of the International Medical Device Regulators Forum (IMDRF) of which the FDA is a member. SaMD is distinct from software in a medical device although "in" these days may have a looser meaning closer to is a part of.  The notion that "stand alone" software, operating on a general purpose computer could be or is a medical device was at one time debated by some but this has been resolved by various regulatory bodies who declared that the discussion was now over and that software is...

A ubiquitous characteristic of software is that it often undergoes numerous changes after it is first released for general use. These changes may be to fix things that were never right in the first place, or to provide new features and/or greater security. If the software is a “medical device”, or part of a medical device, or connects medical devices, then changes may come under the FDA's regulatory processes. New Draft Guidance from FDA A recurring question for software that is a medical device and which is actively regulated is when do changes to that software require a new 510(k)...

Among the many forms of data flow that might occur from a medical device is direct to the patient. This received some notoriety when a patient wanted to access the output directly from their own implanted device. They had to do battle with the device manufacturer who claimed among other things that the FDA would not allow them to make the data available. It turns out that the "FDA won't let us" is a well known, if not necessarily correct, excuse in a different arena, that of medical device service and repair. The FDA has added some clarification in...