the new eu ivd regulation 2017/746
TRANSCRIPT
The New EU IVD Regulation 2017/746: opportunities & threats for in-vitro diagnostics
Prof. Dr. C.M. CobbaertChair EFLM Task Force on European Regulatory AffairsEC observer to MDCG IVD groupApril 22, 2021
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Diagnostic medicine´s contribution to Health Care
Clinical Chemistry & Laboratory Medicine
Microbiology
Virology
Human Genetics
Histopathology/molecular Pathology
Imaging
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Creation of added value through “SCIENCE”IN AN ACCREDITED LAB SETTING
S
C
I
E
N
E
C Raison d’ être
Standardisation/Harmonisation
ClinicalEffectiveness
Innovation
Evidence-basedPractice
Education of Others
CostEffectiveness
NovelApplications
Professional responsibilities of laboratory specialists
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Adding value to laboratory medicine: a professional responsibility. Beastall GH. CCLM, 2013, 51:221-7.
Role of Laboratory Medicine
Goal: improving patient management & patient outcome Tools: medical tests (CE-marked and in-house developed tests)Mechanism: supporting medical decisions
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I. Scope enlargement & (Re)Classification
II. Clinical Evidence Requirements
III. Notified bodies and Conformity Assessment for 85% of commercial tests (classes B and C);
IV. “In house” developed tests
Readiness of medical lab sector is for commercial tests fully dependent on timely test certification through EU Regulatory System, as intended in the IVDR (notified bodies, expert panels, reference labs, guidance documents, ….).
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Source: European Commission Survey on IVDR preparedness coordinated by MedtechEurope; survey results from 27 Jan-16 Febr 2021. By courtesy of Medtech Europe.
22 NBs 4 NBs
85-90% of routine medical tests (class B & C) are affected by the HARD STOP date of May 25, 2022
Auto Immunity
Endocrinology
Clinical Chemistry
Metabolic diagnostics
Infectious disease
Microbiological culture
Allergy diagnostics
Oncology
Therapeutic Drug
Monitoring
IVDR timelines: implications for CE-marked tests?
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With courtesy to Volker Franzen
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P. Vermeersch et al., CCLM, 2020
922 different medical tests • 42% commercially available• 47% in-house developed test (LDT)• 11% other tests
Call for action on degrees of freedom laboratories need to use in house tests
to improve patient care
IVDR impact FOR IN HOUSE TESTS: UZ Leuven case study
For 72% of 537 in house developed/ other tests there is no alternative on the market.
Compliance with IVDR will require a huge investment of time and effort, without directly enhancing the benefit of patient care.
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Downstream Risks for Patients
Threats/exceed opportunities
Commercial testsfrom IVD-industry
In-house developed testsfrom academia
Concerns aboutcontinuity/availability of extensivelyused tests
X X
Concerns about increasing costswithout ROI
X X
Nullify innovations, niche tests, tests for rare diseases, …, harmingpatients
X X
Precision Diagnostics endangered X
Flexibility hampered – essentialduring pandemics
X
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Medical Laboratories perspective: ready for IVDR implementation per May 2022?
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Painting from Margaret Mulder
Reflections on “READINESS” for IVDR implementation per May 2022
IVD Regulation is intended to improve patient safety and test effectiveness ….
• Multiple essential CE-marked tests may not be available per DoA.
• Some specialty tests may also be unavailable (for genetics, virology, moleculardiagnostics..).
• This will cause serious harm to patients.
• A transparent contingency plan or a moratorium is ESSENTIAL.
• The IVDR should allow rapid innovation and EU-wide flexibility for derogationsand during pandemics.
• First COVID-19 tests available within weeks were in-house developed tests.
• Urgent ACTIONS are NOW needed to prevent UNACCEPTABLE CLINICAL RISKS.
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