Development and Regulation of Connected Combined Products: Reflections From the Medtech & Pharma Platform Association

• Published in: Clinical therapeutics Vol. 44; no. 5; pp. 768 - 782
• Main Authors: Kühler, Thomas C., Schoenmakers, Marc, Shergold, Oliver, Affolter, Stephan, Bolislis, Winona Rei, Foster, Ruth, Gardner, Paul, Hruschka, Svenja, Jomini, Thierry, Kaveripakam, Sathish, Mayerhofer, Karl, Scherini, Tomaso, Swierczynska, Marta, Vandal, Gretchen, Fürst-Ladani, Shayesteh
• Format: Journal Article
• Language: English
• Published: United States Elsevier Inc 01.05.2022; Elsevier Limited
• Subjects: Artificial intelligence; Combination products; Competent authority; Conformity; connected combined products; Connectivity; Cybersecurity; digital health; Drug delivery; Drug delivery systems; Internal Medicine; Legislation; Life cycles; Medical device industry; medical devices; Medical equipment; Medical technology; medicinal products; Patients; Regulation; Regulatory approval; Smartphones; Software; Usability; Working groups; medicinal products; digital health; medical devices; software; Combination products; connected combined products
• ISSN: 0149-2918; 1879-114X; 1879-114X
• DOI: 10.1016/j.clinthera.2022.03.009

Patients taking a medicinal product in a homecare setting typically use a medical device to facilitate the injection process. Reductions in wireless connectivity costs, combined with the rapid adoption of smartphones with connectivity to cloud-based services, are enabling these drug delivery devices to now be connected to a digital ecosystem as connected combined products (CCPs). The purposes of this article are to identify the challenges in developing and releasing these products when they straddle different regulatory frameworks and standards and to highlight gaps in the European Union regulations. Industry subject matter experts from pharmaceutical, medical device, and consultancy companies, who are members of the Medtech & Pharma Platform Association, formed 4 working groups to address current best practice for developing and releasing CCPs and the different relevant regulatory frameworks. The 4 areas studied were clinical and regulatory, usability and human factors engineering, development and life cycle management, and cybersecurity. Development teams require new skills to create innovative products that have a good safety profile and are simple to use, such as design thinking to understand user needs and systems engineering to manage complexity and ensure interoperability. Risk management process should integrate cybersecurity, data privacy, and data integrity, whereas design control processes should enable asynchronous development cycles for hardware and software components. Regulatory frameworks exist for individual components within the CCP. However, for a complex product, regulatory guidance is needed when combining components with different risk and safety profiles and to ensure that the responsibilities and liabilities of companies contributing components are clear. The efficient management of software changes and product updates, as well as dealing with end-of-life hardware and backward compatibility to older software versions, needs agile approaches when it comes to regulatory updates. The regulatory uncertainties and development processes outlined in this article need to be addressed. We call for joint discussions among the various stakeholders in the fields of medicinal products, medical devices, and in vitro diagnostics, as well as standalone software, data protection, and cybersecurity experts, together with regulators and lawmakers in the European Union to meet in focused discussion groups with the aim of devising pragmatic solutions and regulations for the benefit of the sector and hence the patients it serves.