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Page 1: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

FDASIA Taxonomy Subgroup

HIT Policy Committee

FDASIA Workgroup Virtual Meeting

14 June 2013

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Drag picture to placeholder or click icon to add

Page 2: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Follow-on Activities

Reviewed/consolidated feedback and discussion points from on-site meeting

Reviewed additional materials forwarded to subgroup:— Bipartisan Policy Center Health Innovation Initiative,

Draft/Work-in-Progress: “Defining and Characterizing Risk of Health Information Technology”

Teleconference with additional group-level discussion, consensus building

Page 3: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Scope Dimensions

User Type﹣ …

Phases of product lifecycle﹣ …

Developer/ ‘Manufacturer’ Type﹣ …

Distribution Model﹣ …

Conditions of use﹣ …

Intended use﹣ …

Product Categories ﹣ …

New as of 31 May 2013

Miscellaneous- …

Page 4: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

User Types

Health Care Providers – institutional and individual

Clinical Researchers using on human subjects

Patients under care by a provider

General public user/consumer under own use/health management

In Scope Potentially Out of Scope

No Change From 31 May 2013

Page 5: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Product Lifecycle

Design phase

Implementation-Installation

Maintenance

Availability-Downtime Hazard

Recall

End-of-Life Support

Cybersecurity

In Scope Potentially Out of Scope

New as of 31 May 2013

Page 6: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Product Lifecycle

Design phase

Implementation-Installation

Maintenance

Availability-Downtime Hazard

Recall

End-of-Life Support

Cybersecurity

Methods and modes of end-user training

In Scope Potentially Out of Scope

Consensus

Page 7: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Miscellaneous

Regulation around Privacy (HIPAA)

In Scope Potentially Out of Scope

New as of 31 May 2013

Page 8: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Developer/ ‘Manufacturer’ Types

Entity who develops/markets/licenses/distributes products with commercial interest

Entity who develops/ advertises/distributes via public channel products intended for general public users, even if no commercial interest

Healthcare provider* who develops products de novo for use on patients, even if no direct or indirect commercial interest

Healthcare provider* who modifies functionality of previously licensed, ‘finished’ products

Individual who develops for personal private use

Individual who develops/distributes via private channel to limited individuals without commercial interest

In Scope Potentially Out of Scope

*institutional or individual provider

Clarification and refinement

Page 9: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Distribution Model

Marketed-licensed-distributed-sold in a restricted manner, with credentialing requirements

Marketed-licensed-distributed-sold in a restricted manner, without credentialing requirements

Made available for download via an unrestricted public channel, with or without credentialing requirements

Available under a SaaS model

In Scope Potentially Out of Scope

No Change From 31 May 2013

Page 10: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

General Conditions of Use

By prescription, recommendation or under direction of licensed/credentialed healthcare provider

Independently by general public consumer/user

For management of defined illness or chronic condition

For research purposes on human subjects

? For health maintenance or fitness

In Scope Potentially Out of Scope

New as of 31 May 2013

Page 11: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

General Conditions of Use

Intended use

Foreseeable misuse

Non-foreseeable, willful misuse

Use clearly beyond labeled intended use

In Scope Potentially Out of Scope

No Change From 31 May 2013

Page 12: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Specific Product Types - Categories

In Scope Potentially Out of Scope

Page 13: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Decision Tree ApproachIntended Use - Functionality – Potential for Harm

Page 14: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Diagram

Is use intended to inform or change decision making about:

- initiating - discontinuing - modifying

care interventions or personal health management ?

NO

YES

Out-of-scope … defer to existing regulatory framework

Potentially in-scope

Page 15: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Diagram 2

Does malfunction, foreseeable misuse have potential to cause patient injury, via:• Delay or failure to present clinical data/ information at time of need• Presentation of outdated information• Patient-data mismatch ?

YES

NO

Potentially in-scope

Potentially out-of-scope

Page 16: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Diagram 2

Is the data/information that is managed by system the sole or 1o source of data at point of care (i.e., no alternate sources of data / info that can be used for confirmation) ?

YES

NO

Potentially in-scope

Potentially out-of-scope

Page 17: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Diagram 2

Through design and intended use, is patient or provider reliant on data/information to initiate or modify prescribed intervention or treatment ?

YES

NO

Potentially in-scope

Potentially out-of-scope

Page 18: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Examples of Scoping Using Decision Tree Approach

Claims processing

Health benefit eligibility

Practice management / Scheduling / Inventory management

Healthcare provider communication tools (e.g., email, paging)

Population management tools

Software using historical claims data to predict future utilization/cost of care

Cost effectiveness analytic software

In Scope Out of Scope

Page 19: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Examples of Scoping Using Decision Tree Approach

Diseases severity scoring algorithms

Electronic guideline distribution

Disease registries

In Scope Out of Scope

Page 20: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Examples of Scoping Using Decision Tree Approach

EHRs (installed, SaaS)

Hospital Information Systems-of-systems

Decision support algorithms

Visualization tools for anatomic, tissue images, medical imaging and waveforms

Health Information Exchanges— advanced functionality

Electronic/robotic patient care assistants

Claims processing

Health benefit eligibility

Practice management / Scheduling / Inventory management

Healthcare provider communication tools (e.g., email, paging)

Population management tools

Software using historical claims data to predict future utilization/cost of care

Cost effectiveness analytic software

Diseases severity scoring algorithms

Electronic guideline distribution

Disease registries

In Scope Out of Scope

Page 21: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Diagram

Does product currently meet FDA (Act 21 CFR)

definition of Medical Device (including MDDS)

?

NO

YES

Potentially in-scope

Potentially in-scope

Page 22: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Possible revisions or re-engineering of risk assessment and regulatory framework around certain products — Currently explicitly regulated by FDA— Meet definition but through

enforcement discretion, regulatory framework is not actively enforced

Explicitly Enter Into ScopeFor Deliberation and Discussion

Page 23: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Examples:— Software only products— Archiving systems— MDDS— Calculators

Explicitly Enter Into ScopeFor Deliberation and Discussion

Page 24: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Rationale:— Boundaries very blurred— In some cases, nearly identical

functionality and risk profile for explicitly regulated and non-regulated/non-enforced products

— Examples: PACS

Explicitly Enter Into ScopeFor Deliberation and Discussion

Page 25: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Strive to:— develop a framework that is able to

meet future undefined needs— avoid a discrete, static and specific

defined list of named products

Favor the decision tree approach that emphasizes functionality as a primary scoping criterion

Final Conclusions

Page 26: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Be cautious of wide-spectrum use cases that span a risk-spectrum within a single functionality— E.g. prescribing or alerting functions, but are

used on both negligible-risk and high-risk medications/drugs

Consider that any products that relies on patient lookup/patient data retrieval/data-patient matching should be evaluated for risks of patient-data mismatch

Final Conclusions

Page 27: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

In preparation:— Matrix and formal decision tree tool

Final one-page summary of taxonomy, process and rationale

Final Conclusions

Page 28: FDASIA Taxonomy Subgroup HIT Policy Committee FDASIA Workgroup Virtual Meeting 14 June 2013

Questions and Discussion