Need • Limitation of current EEG measurement capabilities • Researching the physiology of eight seizure types • Capturing contextual data - Seizure event: Type, duration, frequency, responsiveness and cognition
Need • Limitation of current EEG measurement capabilities • Researching the physiology of eight seizure types • Capturing contextual data - Seizure event: Type, duration, frequency, responsiveness and cognition - Correlation factors: Triggers, medication adherence and side effects
Contextual Data Gathering Correlation Factors Type, Duration and Frequency Responsiveness and cognition Triggers Triggers Seizure Event http://bit.do/epiwatch
Contextual Data Gathering Correlation Factors Type, Duration and Frequency Responsiveness and cognition Triggers Triggers Medication Adherence Seizure Event http://bit.do/epiwatch
Contextual Data Gathering Correlation Factors Type, Duration and Frequency Responsiveness and cognition Triggers Triggers Medication Adherence Emergency Care Delivery* SMS Alert Seizure Event http://bit.do/epiwatch
as a “mobile medical application” • Avoid “diagnosis, cure, mitigation, treatment, or prevention” • Leverage user-initiated activities only (disease tracking) http://bit.do/FDA
as a “mobile medical application” • Avoid “diagnosis, cure, mitigation, treatment, or prevention” • Leverage user-initiated activities only (disease tracking) Medical Device Any instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or similar or related article, including any component, part, or accessory intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment or prevention of disease http://bit.do/FDA
as a “mobile medical application” • Avoid “diagnosis, cure, mitigation, treatment, or prevention” • Leverage user-initiated activities only (disease tracking) Medical Device Any instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or similar or related article, including any component, part, or accessory intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment or prevention of disease Mobile Medical Application Is a medical device when it is intended: • to be used as an accessory to a regulated medical device; or • to transform a mobile platform (smartphone, tablet, etc.) into a regulated medical device http://bit.do/FDA
enforcement discretion as a “low risk” device • Avoid medical intervention - do not diagnose or treat • Do not replace an existing medical device (e.g., electronic stethoscope) • Do not control an existing medical device (e.g. iPhone infusion pump settings app) http://bit.do/FDA
enforcement discretion as a “low risk” device • Avoid medical intervention - do not diagnose or treat • Do not replace an existing medical device (e.g., electronic stethoscope) • Do not control an existing medical device (e.g. iPhone infusion pump settings app) http://bit.do/FDA
enforcement discretion as a “low risk” device • Avoid medical intervention - do not diagnose or treat • Do not replace an existing medical device (e.g., electronic stethoscope) • Do not control an existing medical device (e.g. iPhone infusion pump settings app) Enforcement Discretion Apps that are medical devices, but pose lower risk to the public, and are therefore not subject to FDA regulation “at this time”: • Apps that help asthmatics track inhaler usage, asthma episodes experienced, location of user at the time of an attack, or environmental triggers of asthma attacks • Apps that use a checklist of common signs and symptoms to provide a list of possible medical conditions and advice on when to consult a health care provider • Apps that allow a user to collect, log, track and create trend data, such as blood glucose, blood pressure, heart rate, weight or other data from a device to eventually share with a health care provider, or upload it to an online (cloud) database, personal or electronic health record http://bit.do/FDA
regulates certain data ▸ “Protected health information” - has to touch an insurance transaction in its lifecycle ▸ Academic studies often not regulated; ResearchKit can be used for private studies or products
users log in? ‣ Access Controls ‣ Is there an admin dashboard? ‣ Do researchers have different levels of access? ‣ Audit Controls ‣ Integrity + Business Continuity ‣ Data backup ‣ Storage encryption ‣ Transmission Security ‣ Encryption
for electronic consent process • ResearchKit framework for e-consent has achieved significant review and support ‣ Guided by Sage Bionetworks review http://sagebase.org/e-consent/ ‣ HHS support in developing electronic research consenting process
for electronic consent process • ResearchKit framework for e-consent has achieved significant review and support ‣ Guided by Sage Bionetworks review http://sagebase.org/e-consent/ ‣ HHS support in developing electronic research consenting process Seek expedited IRB review for minimal risk research • Try to establish an “early and often” informal check-in throughout design/development • Prepare supporting documentation ‣ Full description of the app, it’s functionality and potential risks • App copy manuscript, technical flows, designs and diagrams, scientific literature ‣ Full description of the consent process ‣ Fully-developed data security plan that has been approved by appropriate institutional officials
interest, commercial interests to IRB up front • Many research efforts have algorithm aspirations ‣ Are you validating/refining your algorithm hypothesis with the intention to make money?
interest, commercial interests to IRB up front • Many research efforts have algorithm aspirations ‣ Are you validating/refining your algorithm hypothesis with the intention to make money? Consider patent, copyright, and trademark protection • Patent protection requires innovation: can’t be just “X + computers” • Limited protection for apps • You can’t simply implement an existing concept in software Do a search to make sure you don’t infringe on someone else’s patent