Clinical Evidence
NMRA ยท CER for general devices ยท Performance evaluation for IVDs
Why Clinical Evidence Is Requiredโ
The NMRA requires clinical evidence to establish that a device performs safely and as intended when used in patients in clinical practice. Clinical evidence is distinct from bench testing โ it addresses the device's actual clinical behaviour, not just its physical or chemical properties.
General Devices โ Clinical Evaluation Report (CER)โ
For general medical devices, the clinical evidence is compiled into a Clinical Evaluation Report (CER) following a systematic methodology:
CER Processโ
- Define scope โ device description, intended purpose, clinical claims
- Identify applicable clinical data โ from three possible sources:
- Clinical investigations of the subject device
- Equivalent device data (with justified equivalence)
- Published clinical literature (systematic literature review)
- Appraise data quality โ assess relevance, methodological quality, and risk of bias
- Analyse and conclude โ evaluate whether the data supports the safety and performance claims
- Document residual uncertainties โ and how they are addressed (e.g., by PMCF)
CER Depth by Classโ
| Class | CER Depth |
|---|---|
| Listed/I | Abbreviated review may suffice for well-established technologies |
| IIa | Literature-based CER with systematic review methodology |
| IIb | Comprehensive CER; clinical data from investigations may be required for novel technologies |
| III | Robust clinical data including clinical investigations where no equivalent device exists |
IVDs โ Performance Evaluationโ
IVD registration requires performance evaluation data rather than a clinical evaluation report:
Analytical Performanceโ
| Parameter | Description |
|---|---|
| Analytical sensitivity | Limit of detection and limit of quantification |
| Analytical specificity | Cross-reactivity and interference testing |
| Precision | Repeatability and reproducibility |
| Accuracy / trueness | Comparison to reference method |
| Linearity/measuring range | For quantitative assays |
| Stability | Shelf life and open-vial stability |
Clinical Performanceโ
- Sensitivity and specificity compared to reference method or gold standard
- Positive and negative predictive values in the intended use population
- Results from clinical studies or specimen bank evaluations
Overseas Clinical Dataโ
NMRA accepts clinical data generated outside Sri Lanka, provided:
- Device used in the overseas study is identical (or equivalence is properly justified)
- Study population is representative of the Sri Lankan patient population
- Clinical conditions and intended use are comparable
When using the reliance pathway, the reference NRA's clinical assessment and conclusions form a key component of the reliance evidence package. The NMRA may accept these conclusions as supporting evidence, though the NMRA retains the right to conduct additional review if needed.
Post-Market Clinical Follow-Up (PMCF)โ
For Class IIb and III devices, the NMRA may require a PMCF plan as part of the registration dossier. PMCF collects clinical data after registration to:
- Confirm long-term safety and performance
- Detect rare or late-emerging adverse events
- Address residual uncertainties identified in the pre-market CER
In Overseas Clinical Data section, add: 'Where clinical data is from significantly different geographic, climatic, or epidemiological regions, provide justification that the data remains applicable to the Sri Lankan patient population, or plan for supplementary local clinical data collection.'