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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€‹

  1. Define scope โ€” device description, intended purpose, clinical claims
  2. 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)
  3. Appraise data quality โ€” assess relevance, methodological quality, and risk of bias
  4. Analyse and conclude โ€” evaluate whether the data supports the safety and performance claims
  5. Document residual uncertainties โ€” and how they are addressed (e.g., by PMCF)

CER Depth by Classโ€‹

ClassCER Depth
Listed/IAbbreviated review may suffice for well-established technologies
IIaLiterature-based CER with systematic review methodology
IIbComprehensive CER; clinical data from investigations may be required for novel technologies
IIIRobust 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€‹

ParameterDescription
Analytical sensitivityLimit of detection and limit of quantification
Analytical specificityCross-reactivity and interference testing
PrecisionRepeatability and reproducibility
Accuracy / truenessComparison to reference method
Linearity/measuring rangeFor quantitative assays
StabilityShelf 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

For the reliance pathway, the reference NRA's clinical assessment is a key part of the reliance evidence package, and NMRA may accept the reference NRA's clinical conclusions as part of the reliance review.

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