Group performing research and development in a lab environment

What Are Clinical Investigations?

Clinical investigations for medical devices are systematic studies in one or more human subjects, undertaken to assess the clinical performance, effectiveness, and/or safety of a medical device (ISO 14155). In this way, the clinical investigation of a device ensures that the final device design meets user needs, intended uses, and any other requirements.

Investigational Device Exception (IDE) allows the device to be used in a clinical study to collect safety and effectiveness data in the United States. Clinical investigation studies are often conducted to support a PMA, De Novo or, in some cases, 510(k) submissions. All medical device clinical investigations require an approved IDE before initiating the study unless exempt.

Good Clinical Practices (GCP) refers to the regulations and requirements that must be adhered to while conducting a clinical study. The FDA defines GCP as “a standard for the design, conduct, performance, monitoring, auditing, recording, analysis, and reporting of clinical investigations in a way that provides assurance that the data and results are credible and accurate and that the rights, safety, and well-being of subjects are protected.” The primary regulations that govern clinical study conduct are included in 21 CFR part 812. This regulation is consistent with the other FDA related regulations (21 CFR parts 50, 56, and 812), as well as international ethical and policy standards for clinical trials. These international standards include ICH E6, the International Conference on Harmonization of Technical Requirements for Registration of Pharmaceuticals for Human Use – Good Clinical Practice: Consolidated Guideline, and ISO 14155, the Clinical Investigation of Medical Devices for Human Subjects—Good Clinical Practice.

Ethical Considerations for Clinical Investigation

Clinical investigations should be developed, initiated, and executed with the highest level of ethical consideration. Ethical principles are outlined in the guidance document ISO 14155:2020. However, key concepts include protecting the participant’s subjectivity, fairly compensating the participant for their time, and ensuring that study plan is reviewed by an independent ethics committee (EC) such as the Institutional Review Board (IRB), which will and provide independent review to protect the rights and safety of human subjects. Also, participants involved with the clinical investigation study must be informed of any applicable risks from their participation in the study and freely volunteer to participate noting their consent by signing an informed consent form.

The IRB and other ethics committees protect the rights and welfare of human research subjects through review of the clinical investigational plan (CIP) and related materials, such as the informed consent form, recruitment documents, and other written information that will be provided to subjects. Such reviews can result in approval, modifications requirements, or disapproval of the research.

Clinical investigations should not be conducted using vulnerable populations unless it is designed to address the specific needs of that population. Additionally, clinical investigation should offer the possibility of direct health-related benefit to the vulnerable population. In these cases, additional EC procedures may be required per national regulations surrounding the specific vulnerable population.

Clinical Investigational Plan and Report

The purpose of the clinical investigational plan (CIP) is to clearly outline the objectives of the clinical investigation. The CIP and all subsequent amendments to the CIP should be prepared by the sponsor in consultation with the biostatistician when relevant, agreed upon between the sponsor and the coordinating investigator, and accepted by all principal investigators. Additionally, the CIP should include a summary of the investigation and a description of the device and clearly state the objective and hypothesis of the clinical investigation study.

After the completion and close-out of the clinical investigation, a report of the clinical investigation shall be completed, even if the clinical investigation was terminated prematurely. The purpose of the clinical investigational report (CIR) is to record the data captured and the methods used during the study. The CIR also includes any results or conclusions that could impact future research, device development, and/or medical treatment.

For more information on the CIP or CIR requirements, please see the guidance document ISO 14155:2020.

Types of Clinical Investigations

There are two types of clinical investigations: pre-market and post-market. Both studies assess the clinical performance, effectiveness, and/or safety of a medical device, but at different stages of the product’s lifecycle.

Pre-market investigations are executed prior to regulatory market approval and commercial availability. These pre-market investigations are intended to substantiate the device’s performance according to its intended use. Post-market investigations are conducted after the product has been approved for use and is on the market. These post-market investigations are intended to evaluate how the product is being used in the real world and are intended to gain additional information relating to clinical performance, effectiveness, or safety of a medical device when used in accordance with its approved labeling.

Clinical Investigation Design Stages

1

Pilot Stage

During a pre-market investigation, a pilot stage may be required to generate hypotheses to be confirmed in subsequent clinical investigations. If a pilot stage is necessary, one or more smaller scale clinical investigations could evaluate potential limitations and advantages of the medical device. A pilot stage investigation is commonly used to capture preliminary information on a medical device at an early stage of product design, development, and validation. This information can be used to adequately plan further device development steps, including potential need for design modifications or parameters prior to a pivotal clinical investigation.

2

Pivotal Stage

In the pivotal stage, one or more confirmatory clinical investigations can be conducted to provide the information necessary to evaluate the clinical performance, effectiveness, and/or safety of the investigational device. A confirmatory clinical investigation should be adequately designed with a pre-defined hypothesis for the primary endpoint(s) and pre-specified powered statistical analysis methods described in the CIP.

3

Post-Market Stage

The post-marketing stage can include additional confirmatory clinical investigations to establish clinical performance or effectiveness of the medical device in a broader population of users and subjects. Observational clinical investigations for better device safety understanding, such as rare adverse events and long-term outcomes, are also included in the post-marketing stage.

The Role of Clinical Experts in Clinical Investigation

Clinical experts such as physicians, nurses, and other healthcare professionals play a crucial role in the clinical investigation process for medical devices by interacting with the device and providing input on the device’s safety and effectiveness. These clinical experts are involved throughout the process from design and development to post-market surveillance and provide valuable insights on the device’s intended use, user needs, and clinical performance. Involving clinical experts helps ensure the device is safe, effective, and user-friendly for the intended population and meets the needs of healthcare professionals and patients.

Clinical Investigation and Risk Management

The decision to conduct or continue a clinical investigation requires that the risks to the subjects, based on the risk of the medical device and the study procedures, be balanced by the anticipated benefits to the subjects. These risks are identified, and assessed, to mitigate risks where possible. Risk management principles should be applied to the clinical investigation to ensure safety for the subjects and a collection of quality data.

Why Choose Innovenn for Clinical Investigation?

At Innovenn, we understand the importance of clinical investigation in the medical device development process. Our team of experts has experience in driving clinical investigations for a wide range of medical devices. We provide comprehensive, high-quality clinical investigation management that is tailored to the specific needs of each device and regulatory requirements. We are committed to providing our clients with the best possible support throughout the clinical investigation process.

To learn more about Innovenn’s Clinical Investigation consulting services, contact us to discuss your specific needs.