[sergers]

My company software is considered a Class 2 medical device.

We have to go through so many crippling hurdles with FDA it's almost not worth it.

You are spot on.

To add though, In atleast the diagnostic imaging space, radiologist reading groups/practices are selecting their own systems more and more nowadays.

Individual doctors? Likely not.

[616c]

So why do you need FDA regulation in your situation? I know people handling security regulation in the defense industry and I'm curious how you know the FDA has to approve you as opposes to CMS and what it entails.

[sergers]

For diagnostic imaging (x-rays, CTs etc) which we make software for, alot of equipment is FDA regulated.

We chose to go for class 2 designation in FDA terms as it shows you comply with uptmost regulations, which is a selling point. Some hospitals depending on state gets rebates for meeting compliance.

It depends on what space you are going into. If it touches a patient, more than likely FDA regulated in the USA.

Other countries have similar orgs ( Canada has... Health Canada).

We also work with DoD/VA... Don't get me started on compliance with them.(the security stuff is a plus though, while initially challenging to meet, it has us pushing the code into commercial space products, everyone benefits from the extra security hardening. )

[Thriptic]

What it entails depends on the product. FDA has 2 regulatory classes which require a premarket notification, class 2 and class 3. Class 2 submissions generally require you to comply with a set of software development standards governing testing and validation, requirements generation at multiple levels, interface design, risk management, traceability, design, and actual development. You are required to handle customer complaints, safety problems, and maintenance in specific ways. You are required to produce customer facing documentation in specific ways, have installation plans, etc. Finally, you need to register yearly with the FDA and have all sorts of training and infrastructure planning. Proof of all of this is to be constantly generated (think every test report) and it all gets put into a massive file for FDA review. There are also some writeups you need to do explaining why you are class 2 as opposed to class 3. This generally involves finding a class 2 piece of software which resembles yours and saying your software is basically doing the same thing. This is typically referred to as a 510(k) submission.

There is also a pathway you can apply for if there is no existing device with a class 2 designation which resembles yours, but you believe your device is still fairly low risk. That is called a de Novo submission.

A class 3 submission generally involves even stricter requirements for development plus a clinical trial to prove efficacy and safety. The most common one if these is called a PMA which stands for premarket approval.

Also, if you are FDA regulated you still have to comply with CMS regs. It is an extra layer of regulatory scrutiny.