Infusion Pumps & Accessories Guidance
Navigating the Regulatory Pathway during a Global Pandemic
What are the motivations for the COVID-19 Infusion Pumps and Accessories guidance?
- COVID-19 patients may require continuous infusion of medications, nutrition, and/or other fluids.
- It is necessary to increase access to an adequate supply of devices to treat these patients.
- New technologies help protect providers by maintaining the physical distance from the patient.
What medical device types are covered by the guidance?
- Four Infusion pumps and their accessories. Some infusion pumps have the potential to wireless connect and transmit a patient’s data directly to their health care provider.
- Eleven infusion pump accessories when use with covered infusion pumps.
What type of modifications to indications or functionality are permitted?
- Remote infusion pump monitoring/control without provider entering patient’s room.
- Wireless transfer of electronic drug library information.
- Infusion pump use for ground/air transport not indicated in original labeling.
- Infusion pump use for patient populations not explicitly reference in original labeling.
What type of modifications to indications or functionality are not permitted?
- Change labeling for device’s use in a magnetic resonance (MR) environment;
- Implementation of physiological closed loop control systems.
What type of hardware, software and materials changes are permitted?
- Hardware/software changes for remote/centralized infusion parameter monitoring/adjustment.
- Changes to increase battery capacity of the device.
- Increase distance between patient and provider through administration set changes.
- Hardware/software/material changes accommodating alternate accessory/component supplier.
What permitted changes around shelf life and duration of use?
- The devices are used according to healthcare institutional protocols.
- The device is not distributed or used if there is evidence of malfunction or visible soiling.
What is envisioned validation of COVID-19 changes?
- Designing, evaluating, and validating changes made to hardware, software, materials or duration of use should be done according to FDA recognized standards.
What COVID-19 labeling updates does the FDA recommend for modified devices?
- Describe device, performance and potential risks for new indications or functions.
- Provide adequate instructions for use by intended user in indicated environment(s), including mitigation of any known risks associated with differences from FDA-cleared operation.
- Distinctly delineate FDA-cleared indications and claims from those that are not FDA-cleared.
What needs to be submitted for Emergency Use Authorization of international devices?
- Manufacturer contact information and copy of the product labeling.
- Whether the device currently has marketing authorization in another regulatory jurisdiction.
- A summary of performance data available for long term use of the device.
- Whether the device is designed, evaluated, and validated by FDA recognized standards.
- Whether the device is designed with a U.S. compatible power supply.
- Whether device manufacture complies with FDA Medical Devices Quality Management Systems.
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Gregory House, PhD
Gregory House spearheads innovation and technology at Syncro through exciting new initiatives. Greg earned a PhD in Electrical and Computer Engineer from Carnegie Mellon University and has a 20-year track record of commercializing digital technologies. He was Principal Investigator for $2 million in biomedical funding, awarded 14 US patents, and published 8 peer reviewed journal articles. His hands-on experience includes driving intellectual property strategy, building multi-disciplinary engineering and operation teams, and collaborating with research and medical institutions. Greg launched innovative products for health care and sports media into demanding real-world environments. He enjoys outdoor nature activities and serving the elderly and the community.
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