Tom Nonnemaker
Experienced Project/Program Manager, NPD, Acquisitions, Supply Chain Management, Class I & Class II Medical Devices
October 2015
< 1 min reading time
I’d be curious if anyone is ‘in the know’ on awareness of any general strategy for compliance to the UDI ruling for non-sterile implantables (such as spinal implants) ? The FDA gave us an extension to Sep 2016 to implement, but there is no real clear “solution” for how or what exactly to implement. I attended FDA’s UDI Conference in Baltimore a few months ago but it did not shed much light. I know the larger players are working on certain solutions of their own, but even they did not have all the answers, nor were the solutions I saw complete, last I checked. I even wondered about possible licensing/buying of solutions, maybe from these larger players, and I was told the FDA was working on some means to manage that possibility. Request to FDA’s Help Desk have gone unacknowledged to this point. The other puzzling thing to me is it seems that the hospitals need to be in this loop as well, since whatever solutions the medical device companies come up with, one would think it would need to be harmonized with each hospital’s procedures for sterilization, etc. Last I checked with AdvaMed, I did not get much clarity, as it did not appear that they were leading any “common” resolution. Curious if anyone has any inside knowledge or suggestions. source: https://www.linkedin.com/groups/78665/78665-6061965569639403522 Marked as spam
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Private answer
Tom Nonnemaker
For those still interested in this one, with Joe's help, I was able to get the following feedback from Haley Lentz, of Reed Tech. Thank you Haley ! Here was her feedback: Regarding your question, I attended an FDA GUDID User Group Discussion last week. During the webinar, FDA noted that they are working with AdvaMed for a solution to the issue and will be releasing a letter soon providing an update. They will include possible solutions to making the UDI available at the point of implantation. FDA noted that in terms of hospital responsibility, they are hoping that once the UDIs are made available in some fashion that hospitals will utilize this information. Recently, the ONC published a final rule requiring the UDI to be included in patient EHRs which will facilitate this use further. In addition, any HER vendor who wants to be certified by ONC must provide a mechanism to capture the implant.
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Private answer
Tom Nonnemaker
To those still interested, check this out link. I spoke with the company yesterday...sure seems like they've got the solution, the best one I've seen so far anyway. http://www.prweb.com/releases/2015/10/prweb13012382.htm
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Private answer
From a labeling perspective we worked with Jay Crowley, Vice President of UDI Solutions and Services at USDM to develop a webinar on the topic in the past. We hosted another webinar today - I apologize had I seen this sooner I would've invited you all. If you'd like to check the info out it can be found here: http://www.prisymid.com/udi-compliance-webinar
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