Examples RWE Report - 0

U.S.
FOOD & DRUG

ADMINISTRATION
Examples of Real-World Evidence (RWE)

Used in Medical Device Regulatory Decisions
Selected examples with file summaries, details on real-world
data source, populations, and descriptions of use
Center for Devices and Radiological Health

Executive Summary............................................................................................................................... 9
Introduction ........................................................................................................................................ 10
Section I. Examples of Registries as a Source of Real-World Evidence .............................................. 11
Subsection IA. Examples Leveraging National or International Registries for Real-World Data
Collection ............................................................................................................................................ 11
Subsection IB. Examples Leveraging Sponsor Registries for Real-World Data Collection ................. 12
Section II. Examples Leveraging Administrative Claims Data for Real-World Data Collection .......... 12
Section III. Examples Leveraging Both National Registries and Administrative Claims Data for Real-
World Data Collection ......................................................................................................................... 12
Section IV. Examples Utilizing Medical Records as Real-World Evidence ......................................... 13
Section V. Examples Utilizing Other Sources of Real-World Evidence .............................................. 13
Additional Consideration: Use of Real-World Evidence from Pediatric Populations ......................... 14
Section VI. Examples of Real-World Evidence Use for In Vitro Diagnostics ...................................... 14
Key Tag Definitions ............................................................................................................................. 15
Appendix Section I. Examples of Registries as a Source of Real-World Evidence .............................. 17
Subsection A. Examples Leveraging National Registries for Real-World Data Collection ................. 17
Guide to Examples Leveraging National Registries for Real-World Data Collection .......................... 17
Example 1. 510(k) - Modification to Indications for Use Statement for a Large Vessel Occlusion
Catheter Using the American Association for the Surgery of Trauma AORTA Registry [1, 2] ............... 22
Example 2. 510(k) - Modification to Indications for Use Statement for a Scalp Cooling System using
Real-world Evidence from an OUS Registry [3, 4, 5, 6]............................................................................. 23
Example 3. 510(k) - Modification to Indications for Use Statement for Da Vinci Surgical Systems
Using the American Hernia Society Quality Collaborative (AHSQC) Registry [7] ................................. 24
Example 4. 510(k) - Modification to Indications for Use Statement for Ultrasonic Pulsed Echo
Imaging System Supported by Data from an OUS Randomized Trial Embedded in a National Outside
the U.S. Registry [8] .............................................................................................................................. 26
Example 5. HDE - Approval for Spinal Posterior Ratcheting Rod System Using OUS Commercial Data
and Sponsor Registry to Satisfy Post-Approval Requirements [10, 11, 12] .............................................. 28
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Example 6. PMA - Approval and Postmarket Surveillance of a Pediatric Ventricular Assist Device
Utilizing National Registry Data [13, 14] ................................................................................................. 30
Example 7. PMA - Approval and Postmarket Surveillance for a Left Ventricular Assist Device Using
National Registry Data [15, 16, 17, 18] ........................................................................................................ 32
Example 8. PMA - Approval of a Heart Valve Replacement Using National Registry Data [12, 19] ....... 34
Example 9. PMA - Approval of a New PMA for an Endovascular System with a Post-approval Study
using the Society for Vascular Surgery Vascular Quality Initiative (VQI) Registry [20, 21] ..................... 35
Example 10. PMA - Modification to Indications for Use Statement and Postmarket Surveillance for a
Portable Normothermic Organ Perfusion, Ventilation and Monitoring Medical Device Using
National Registry Data [22, 23, 24, 25] ........................................................................................................ 37
Example 11. PMA - Postmarket Surveillance of a Total Hip Replacement Using Two OUS National
Registries [26, 27] .................................................................................................................................... 39
Example 12. PMA - Approval of an Indication Expansion for an Implanted Autonomic Nerve
Stimulator for Epilepsy Based on OUS National Registry Data in a Bayesian Hierarchical Analysis [28,
29, 30]
..................................................................................................................................................... 40
Example 13. PMA - Indication Expansions of Drug-Eluting Coronary Stents Using National Registry
Data [31, 32] ............................................................................................................................................ 42
Example 14. PMA - Indication Expansion and Postmarket Surveillance of a DCB Percutaneous
Transluminal Angioplasty Catheter Approval Using National Registry Data [33, 34, 35] ......................... 43
Example 15. PMA - Postmarket Surveillance of a Superficial Femoral Artery Stent Utilizing a
National Registry for Condition-of-Approval [36, 37] ............................................................................. 45
Example 16. PMA - Postmarket Surveillance of an Endovascular Graft for Aortic Aneurysms Utilizing
a National Registry for Condition-of-Approval [38, 39] .......................................................................... 46
Example 17. PMA - Postmarket Surveillance of an Endovascular Graft for Aortic Aneurysms Utilizing
a National Registry for Condition-of-Approval [40, 41] .......................................................................... 48
Example 18. PMA - Post-Approval Studies for an Implantable Cardioverter Defibrillator Utilizing a
National Registry, the National Death Index, and a Sponsor Registry [42, 43, 44] ................................... 50
Subsection B. Examples of Registries as a Source of Real-World Evidence ....................................... 50
Example 19. 510(k) - Clearance of a Cryosurgical Tool Using Sponsor Registry Data [45] ................... 56
Example 20. 510(k) - Clearance of a Cryosurgical Tool Using Sponsor Registry Data [47] ................... 57
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Example 21. 510(k) - Modification to Indications for Use Statement for a Neurological Stereotaxic
Instrument Supported by RWE from a Registry [48] ............................................................................ 58
Example 22. 510(k) - Modification to the Instructions for Use for a Neurovascular Mechanical
Thrombectomy Device for Acute Ischemic Stroke Treatment Using Registry Data [49, 50] .................. 59
Example 23. HDE - Approval for Vertebral Body Tethering System Using RWE from a Retrospective
Review of Medical Records and to Satisfy Post-Approval Requirements [51, 52, 53, 54, 55] ...................... 61
Example 24. De Novo - Classification of an In Vivo Cured Intramedullary Fixation Rod Using the
Medical Records from Sponsor’s OUS Registry [57] ............................................................................. 63
Example 25. PMA - Approval of a Permanent Pacemaker Electrode Following a Classification Order
Leveraging RWE from a Sponsor Registry and Device-Generated Data from Remote Monitoring [58]
............................................................................................................................................................ 64
Example 26. PMA - Approval of a Ventricular Support Device Using Supplemental Sponsor Registry
Data [59] ................................................................................................................................................ 65
Example 27. PMA - Postmarket Surveillance of a Leadless Pacemaker Using a Sponsor Registry [60, 61,
62, 63]
..................................................................................................................................................... 66
Example 28. PMA - Approval for a Total Ankle Replacement System using Outside-the-US RWE as a
Primary Source of Clinical Evidence and RWE for a Post-Approval Study [64, 65] ................................. 67
Example 29. PMA - Approval of a Coronary Drug-Eluting Stent Leveraging Supplemental OUS
Sponsor Registry Data [67, 68, 69, 70] ........................................................................................................ 69
Example 30. PMA - Postmarket Surveillance of a Ventricular Support Device Using Sponsor Registry
Data [71] ................................................................................................................................................ 70
Example 31. PMA - Approval of an Indication Expansion and Postmarket Surveillance of a

Ventricular Support Device Leveraging Sponsor Registry Data [72, 73] ................................................. 71

Ventricular Support Device Leveraging Sponsor Registry Data [74, 75] ................................................. 73
Example 33. PMA - Indication Expansion and Postmarket Surveillance of a Drug-Eluting Peripheral
Transluminal Angioplasty Catheter Leveraging OUS Sponsor Registry Data [76, 77] ............................. 75
Example 34. PMA - Indication Expansion and Postmarket Surveillance of an Endovascular Graft for
Aortic Aneurysms Leveraging Sponsor Registry Data [78] .................................................................... 77
Example 35. PMA - Postmarket Surveillance of a Ventricular Assist Device Leveraging a Sponsor
Registry [79] .......................................................................................................................................... 79
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Example 36. PMA - Modification to Indications for Use Statement for a Vascular Hemostasis Device
Using the Sponsor’s Registry Study [80] ............................................................................................... 80
Example 37. PMA - Modification for Indications for Use Statement for Two Coronary Drug-Eluting
tents Using Sponsor Registry Data and a Post-Approval Study [81, 82, 83, 84].......................................... 81
Appendix Section II. Examples Leveraging Administrative Claims Data for Real-World Data
Collection ............................................................................................................................................ 83
Example 38. PMA - Approval for a Daily Wear Soft Contact Lens to Reduce the Progression of
Myopia Using Retrospective Review of Medical Records and RWE for a Post-Approval Study [85, 86, 87]
............................................................................................................................................................ 84
Example 39. PMA - Postmarket Surveillance of a Multifocal Intraocular Lens Utilizing Data from
Medicare Beneficiary Encrypted Files (CMS) [88] ................................................................................. 86
Appendix Section III. Examples Leveraging Both National Registries and Administrative Claims Data
for Real-World Data Collection ........................................................................................................... 87
Example 40. PMA - Postmarket Surveillance of a Left Atrial Appendage Closure Device Utilizing a
National Registry and Claims Data for Condition-of-Approval [89, 90] .................................................. 90
Example 41. PMA - Postmarket Surveillance of a Transcatheter Heart Valve Utilizing a National
Registry for Condition-of-Approval [91, 92, 93, 94] .................................................................................... 91
Example 42. PMA - Postmarket Surveillance of an Implantable Cardioverter-Defibrillator Utilizing

National Registries and Claims Data for Condition-of-Approval [95, 96, 97, 98] ........................................ 92
Example 43. PMA - Indication Expansion and Postmarket Surveillance for a Transcatheter Heart
Valve Using a National Registry [99, 100, 101, 102] ...................................................................................... 94
Valve with National Registry Data [104, 105, 106] ...................................................................................... 96
Registry and Claims Data for Condition-of-Approval [94, 107, 108] .......................................................... 98
Registry and Claims Data for Condition-of-Approval [94, 109, 110] .......................................................... 99
Registry and Claims Data for Condition-of-Approval [111] ................................................................. 100
Registry and Claims Data for Condition-of-Approval [94, 112, 113] ........................................................ 101
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Example 49. PMA - Postmarket Surveillance of a Mitral Valve Repair Device Utilizing a National
Registry and Claims Data for Condition-of-Approval [114, 115] ............................................................ 102
Example 52. Continued-Access Program Leveraging National Registry and Claims Data for Data
Collection [45, 118] ................................................................................................................................ 106
Appendix Section IV. Examples Utilizing Medical Records as Real-World Evidence ....................... 107
Example 53. 510(k) - Clearance of New Robotically Assisted Surgical Device Using a Retrospective
Review of Medical Records [119] ........................................................................................................ 110
Example 54. 510(k) - Clearance of a New Adjunct to Multiparameter Patient Monitor Using Data
from Electronic Medical Records for Validation [120, 121, 122, 123] ......................................................... 111
Example 55. 510(k) - Modification to Indications for Use Statement for a Hemodialysis Catheter End
Cap Using a Cluster-Randomized Trial with Data Abstracted from Electronic Health Records and
National Healthcare Safety Network (NHSN) Dialysis Event Forms of Patients [124, 125, 126, 127] ......... 113
Example 56. 510(k) - Modification to Indications for Use Statement for a Robotic Surgical System
Using Retrospective Reviews of Medical Records [128] ...................................................................... 115
Example 57. 510(k) - Modification to Indications for Use and Labeling for Magnetic Surgical
Instrument System Using a Retrospective Review of Medical Records [129] ..................................... 116
Example 58. 510(k) - Clearance of an Updated Percutaneous Catheter with Active Tip Using a
Retrospective Review of OUS Medical Records [130] ......................................................................... 117
Example 59. 510(k) - Modification to Indications for Use Statement and Labeling for 510(k) Dilation
Catheter Using a Retrospective Review of Medical Records [131, 132, 133] ........................................... 118
Example 60. 510(k) - Modification to Indications for Use Statement for Embolic Protection System
Using a Retrospective Review of Medical Records [134] .................................................................... 119
Example 61. De Novo - Classification of High Velocity Nasal Insufflation Device for Neonates Using a
Retrospective Review of Medical Records [22, 135, 136] ........................................................................ 120
Example 62. De Novo - Classification of a Hemostatic Device for Intraluminal Gastrointestinal

Bleeding Using Medical Records from OUS Postmarket Studies [15, 137]............................................ 122
Example 63. De Novo - Classification of a Temporary Coil Embolization Assist Device Using Real-
World Evidence from Retrospective OUS Case Series [138]................................................................ 123
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Example 64. De Novo - Classification of a Radiological Computer-Assisted Triage and Notification
Software Using A Secondary Analysis of Medical Records and Real-world Literature [139, 140] ......... 124
Example 65. PMA - Approval for Automated External Defibrillator Using Device-Generated Data and
for a Post-Approval Study After Call for PMA [141, 142, 143, 144] ............................................................. 126
Example 66. PMA - Modification to Indications for Use Statement for a Drug-Eluting Peripheral
Transluminal Angioplasty Catheter Supported by a Retrospective Review of Medical Records from
the Sponsor’s Database [145] .............................................................................................................. 128
Example 67. PMA - Approval of an Indication Expansion for a Transcatheter Pulmonary Valve Using
Medical Record Data [146] .................................................................................................................. 129
Appendix Section V. Examples Utilizing Other Sources of Real-World Evidence ............................ 130
Example 68. De Novo - Classification of an Endoscopic Electroscopic Clip Cutting System Using OUS
Compassionate Use Data [147]............................................................................................................ 134
Example 69. De Novo - Classification of an Esophageal Cooling Device Using OUS Clinical Case
Summaries and Temperature Charts [148] ......................................................................................... 135
Example 70. De Novo - Classification of a Scalp Cooling System Using Supplemental RWE from OUS
Postmarket Surveillance Study [149] ................................................................................................... 136
Example 71. De Novo - Classification of a Percutaneous Catheter for Creation of an Arteriovenous

Fistula for Hemodialysis Access Using OUS Commercial Use Data [150] ............................................ 137
Example 72. De Novo - Classification of a Web and Mobile-Based Software Application for
Contraception Using Real-World Evidence from a Software Application with Patient-
Entered/Patient-Generated Data [151, 152] .......................................................................................... 138
Example 73. PMA - Postmarket Surveillance of an Intervertebral Disc Prosthesis Using an Explant
Retrieval Study [153]............................................................................................................................ 139
Example 74. PMA - Approval for Automated External Defibrillator Using Device-Generated Data as a
Primary Source of Clinical Evidence After Call for PMA [154, 155, 156, 157] .............................................. 140
Primary Source of Clinical Evidence After Call for PMA [158, 159, 160, 161] .............................................. 141
Primary Source of Clinical Evidence After Call for PMA [162, 163] ........................................................ 142
Example 77. PMA - Approval of an Indication Expansion of a Superficial Femoral Artery Drug-Eluting
Stent Using Supplemental OUS Postmarket Surveillance Data [164, 165] ............................................. 143
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Example 78. PMA - Approval of an Indication Expansion and Postmarket Surveillance for a
Wearable Automated External Defibrillator Using Device-Generated Data, Sponsor Database, and
Real-World Literature [166, 167, 168, 169, 170, 171]........................................................................................ 144
Example 79. PMA - Postmarket Surveillance of Implantable Cardioverter Defibrillators Using

Remote Monitoring [172, 173] ............................................................................................................... 146
Example 80. PMA - Postmarket Surveillance of a Glucose Sensor Using Device-Generated and
Patient-Reported Data [174, 175] .......................................................................................................... 148
Example 81. PMA - Approval of an Indication Expansion for an Excimer Laser System Using
Supplemental Real-World Literature [176, 177, 178] ............................................................................... 149
Supplemental Real-World Literature [179, 180, 181] ............................................................................... 150
Appendix Section VI. Examples of Real-World Evidence Use for In Vitro Diagnostics .................... 152
Example 83. 510(k) - Clearance of an IVD Using a Publicly Maintained Next Generation Sequencing
Database [182, 183, 184] ........................................................................................................................... 154
Example 84. 510(k) - Clearance of an IVD Using a Publicly Maintained Next Generation Sequencing
Database [183, 184, 185] ........................................................................................................................... 155
Example 85. De Novo - Classification of a Newborn Screening IVD Using Clinical Evidence from a
Pivotal Trial Leveraging Real-World Data Collection in a State Public Health Laboratory [186, 187] .... 156
Example 86. De Novo - Classification of an IVD Using Clinical Evidence from a Pivotal Trial
Leveraging Real-World Data Collection from an International Biobank and Medical Records [135, 188]
.......................................................................................................................................................... 158
Example 87. De Novo - Classification of an IVD Using Peer-Reviewed Real-World Literature [189] .. 159
Example 88. De Novo - Classification of a Next Generation Sequencing Based Tumor Profiling Test
Using an Analysis of Medical Records [190, 191, 192] .............................................................................. 160
Example 89. PMA - Additional Postmarket RWE Data Collection Through Sponsor Database for
Condition-of-Approval [193] ................................................................................................................ 161
Example 90. PMA - Approval for a Placental Alpha Microglobulin-1 Immunoassay using
Observational Study with Follow-up Data Collection from Medical Records [194, 195, 196, 197] ............. 162
References ........................................................................................................................................ 164
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Executive Summary
Real-world data (RWD) can be collected from a diverse array of sources, such as electronic health
records, registries, administrative claims, pharmacy data and feedback from wearables and mobile
technology. These data offer opportunities to generate evidence and better understand clinical outcomes.
In support of the U.S. FDA’s Center for Devices and Radiological Health (CDRH) mission to protect and
promote public health by ensuring the safety and effectiveness of medical devices, while assuring patients
have timely access to them, CDRH aims to foster the use of real-world evidence (RWE) to support
regulatory decision-making. To further this goal, by developing a more complete understanding of RWE
usage, CDRH has reviewed a sample of past decisions to identify examples leveraging RWE in premarket
and postmarket decisions. We selected a set of 90 examples of submissions that illustrate the broad
spectrum of RWE usage in support of regulatory decision-making from fiscal years 2012 through 2019.
The 90 examples come from the full continuum of clinical and device areas throughout all seven Offices
of Health Technology in CDRH and across the medical device total product life cycle. These examples
represent:
• 18 premarket notification (510(k)) submissions
• 14 De Novo classification requests
• two humanitarian device exemptions (HDE) applications
• 20 premarket approval (PMA) original applications
• 37 PMA panel track supplements.
This report is organized into six sections separated by device type (therapeutic devices, in vitro
diagnostics) and RWD source (Registries, Administrative Claims Data, Medical Records, Other
Sources).
The examples demonstrate a diversity in the usage of RWE, where:

• RWE served as the primary source of clinical evidence in submissions for new devices and
expanded indications for currently marketed devices
• Prospective, randomized trials were nested within RWD sources
• Control arms and objective performance goals were generated for evaluating performance of the
next generation of devices
• Registry infrastructure addressed important premarket and postmarket needs
• Diverse RWD sources were, at times, combined to generate RWE
This report also includes examples from areas where innovative device technologies are being developed.
• Three examples of digital health devices are included, demonstrating the validation of software as
a medical device product using RWD.
• Two examples utilize patient-generated data and nine examples leverage device-generated data
for both premarket and postmarket requirements.
Finally, four studies leveraged RWD sources to abstract radiographic imaging data to address endpoints,
and one example is included for a peripheral vasculature imaging device that utilized a clinical trial
embedded in a national registry, with enrollment, randomization, and data collection conducted through
the registry platform to support a premarket decision.
CDRH strongly encourages the continued and expanded use of RWE to provide new insights into the
performance and clinical outcomes associated with medical device use over the total product lifecycle.
Manufacturers planning to seek marketing authorization for devices are encouraged to consider RWE
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early on and communicate with FDA, as needed, to understand how to best utilize the RWE to support the
marketing claims. Successful applications of RWE are most often achieved when principles of relevance
and reliability are considered, as detailed in our guidance on Use of Real-World Evidence to Support
Regulatory Decision-Making for Medical Devices. We are actively engaged with the medical device
stakeholder community to address challenges and advance the science of RWE generation, through the
establishment of the National Evaluation System for health Technology, or NEST, which is integrating
data from clinical registries, electronic health records, and medical billing claims to gather more
comprehensive evidence of medical device safety and effectiveness while seeking to reduce the time and
cost of RWE generation.
Introduction
The FDA currently defines real-world data (RWD) as the data relating to patient health status and/or the
delivery of health care routinely collected from a variety of sources. RWD can be derived from a variety
of different sources, including electronic health records (EHRs), claims and administrative data, data from
product and disease registries, patient-generated data, and device-generated data. Real-world evidence
(RWE) is the clinical evidence regarding the usage, and potential benefits or risks, of a medical product
derived from analysis of RWD.
RWD on patients’ experiences with medical devices are regularly collected for non-regulatory purposes
during routine care and treatment. FDA recognizes that this resulting wealth of RWD can be leveraged to
deliver further understanding of the performance, clinical outcomes, and benefit-risk profiles related to
medical device use and to reduce the resources required to generate the necessary clinical evidence to
support medical device submissions and fulfill postmarket surveillance requirements. If RWD are reliable
and relevant to the regulatory question at hand, they may be considered valid scientific evidence
supporting both premarket and postmarket regulatory decisions made by the FDA. To foster the use of
RWE in device submissions, FDA issued the guidance document Use of Real-World Evidence to Support
Regulatory Decision-Making for Medical Devices in 2017 to explain how FDA assesses RWD to
determine if they are sufficient for generating RWE that can be utilized in support of the FDA’s
regulatory decision-making.
In continued support of its goal to increase both access to and use of RWE to support regulatory decision-
making, CDRH has undertaken a retrospective review of past decisions to catalog and better understand
examples of the use of RWE to support regulatory decisions. This review covered submissions with final
decision dates from fiscal years 2012 through 2019, and initially encompassed De Novo Requests,
original PMA applications and panel-track supplements, humanitarian device exemption applications,
post-approval studies, and 522 postmarket surveillance studies. Beginning in 2018, 510(k) clearances
were included in our retrospective review, while post-approval studies and 522 postmarket surveillance
studies were omitted.
In our retrospective review, all submissions with final decisions in the date range, fiscal years 2012
through 2019, were selected for triage, although only those 510(k) submissions that included a clinical
review were selected. The submissions were triaged to identify those in which the sponsor submitted
RWD, with a more detailed review conducted of those submissions in which the RWD was considered
important in supporting the final regulatory decision. The submissions identified from that review are
included in this report. This effort resulted in a total of 90 examples of RWE used to support the final
premarket or postmarket regulatory decision. These examples also demonstrate that the number of
submissions and variety of device types supported by RWE have increased over time. The examples
included in this report are not inclusive of all submissions or regulatory decisions that used RWE, but is
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intended to provide a small sample that can showcase the various uses of RWE as valid scientific
evidence.
These examples represent 18 premarket notification (510(k)) submissions, 14 De Novo classification

requests, two humanitarian device exemption (HDE) applications, 20 PMA original applications, and 37
PMA panel track supplements, and include one continued access program. These examples come from the
full continuum of clinical and device areas throughout all seven Offices of Health Technology (OHT) in
CDRH and represent only a subset of regulatory submissions that utilize RWD. These examples represent
a diversity in usage of RWD. In many examples, registry infrastructure addressed important premarket
and postmarket needs. Among the examples in which RWE served as the primary source of clinical
evidence for new devices or expanded indications for currently marketed devices, there are instances
where prospective, randomized trials were nested within RWD sources. In still other examples control
arms were comprised of RWD. In at least one instance, RWD was used to generate objective performance
goals for evaluating the performance of the next generation of devices. And in some examples, diverse
RWD sources were, at times, combined to generate RWE.
Section I. Examples of Registries as a Source of Real-World Evidence

These examples use registries as the source of RWE. This section is divided into national and
international registries and study sponsor registries.
Subsection IA. Examples Leveraging National or International Registries for

Real-World Data Collection
National registries can be leveraged as sources of clinical evidence, including in support of 510(k)
submissions. An example is for a scalp cooling system (K173032) which used clinical evidence from the
Dutch Scalp Cooling Registry, as well as for robotic surgical systems (K173585) which utilized data from
the American Hernia Society Quality Collaborative Study. Additionally, for a large vessel occlusion
catheter (K170411), data from the American Association for the Surgery of Trauma AORTA Registry
were leveraged as the primary source of clinical evidence to support modification to the indication for use
statement. Another example pertains to an ultrasonic pulsed echo imaging system (K173860) for an
indication expansion to include use in the coronary arteries and vessels of the peripheral vasculature. The
clinical data submitted to support this indication expansion was derived from a clinical study embedded in
a national registry, the Swedish Coronary Angiography and Angioplasty Registry (SCAAR). Enrollment,
randomization, and collection of standard-of-care patient data were all performed through the registry at
31 coronary intervention centers in the SCAAR network. Clinical evidence from this study supported a
determination of substantial equivalence, exemplifying the use of a source of RWE as a platform for
performing multiple phases of a clinical trial. In all these examples, information from several countries’
national registries was leveraged to support modifications to the indications for use statements.
CDRH also continues to use RWE from national registries to meet post-approval requirements, including
for an indication expansion for a portable normothermic perfusion system for donor lungs
(P160013/S002). The United Network for Organ Sharing (UNOS) Registry was leveraged to perform two
post-approval studies for the device, and match-run data from the UNOS Registry were additionally used
to support premarket approval. In another example, for an indication expansion of a DCB percutaneous
transluminal angioplasty catheter (P140010/S015), SVS VQI Registry data were used as control data for a
standard-of-care cohort to compare to sponsor registry data using a propensity-score adjusted analysis
based on 20 pre-specified variables, and SVS VQI Registry data were additionally utilized for condition-
of-approval postmarket surveillance of patients up to 3 years. To support a conversion of HDE to PMA
for a pediatric ventricular assist device (P160035), national registry data from the Extracorporeal Life
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Support Organization Registry were leveraged as a historical control that was propensity-score matched
to the HDE IDE trial population, and also included RWE from post-HDE approval patients. Condition-of-
approval postmarket surveillance was conducted through an all-comers surveillance registry with a
follow-up of five years.
Subsection IB. Examples Leveraging Sponsor Registries for Real-World Data

Collection
Sponsor or manufacturer registries represent another commonly utilized source of RWE. Included in this
report are 19 examples of sponsor registries utilized as a source of premarket and postmarket clinical
evidence. For a modification of the indications for use for a neurological stereotaxic instrument
(K171257), registry data on patients treated with the device in standard practice served as the primary
source of clinical evidence supporting a decision of substantial equivalence. Sponsor registry data were
leveraged as both the primary source of clinical evidence supporting the approval of a total ankle
replacement system (P160036) and as a source for deriving performance goals for the condition-of-
approval postmarket study. For a modification of the indications for use for a vascular hemostasis device
(P960043/S097), the sponsor’s registry tracked patients who were treated with the subject device as part
of a continued access study after the conclusion of the previous randomized controlled trial of the device.
Data from this registry were the sole source of clinical evidence supporting approval of the supplement
seeking an indication expansion. Additionally, for two coronary drug-eluting stents (P160043/S012 and
P110013/S088), two bundled modifications of indications for use were submitted. Data from the
sponsor’s international registry were used to create a sub-cohort for analysis of the subject devices and
served as a secondary source of clinical evidence supporting approval.
Section II. Examples Leveraging Administrative Claims Data for Real-World

Data Collection
In Section II, there are two examples of submissions leveraging administrative claims data as RWE. For a
pediatric contact lens (P180035), in order to fulfill the condition-of-approval, a post-approval study was
required to evaluate the rate of microbial keratitis (MK) against a performance goal. Due to the low-
prevalence of MK, this type of endpoint would be difficult to assess in a traditional clinical trial. Instead,
FDA is working with the sponsor on a novel approach that will nest a cohort post-approval study into an
integrated health care and coverage organization. Outcomes of interest will be extracted from electronic
health records and claims data. For an indication expansion of a multifocal intraocular lens
(P040020/S049), the post-approval study will utilize Medicare Beneficiary Encrypted Files as part of a
retrospective study of all cataract surgeries in the Medicare population from 2011 to 2013, comprising
approximately 180,000 surgeries, in order to estimate the background rate of post-surgical intraocular
inflammation to compare to the subject device.
Section III. Examples Leveraging Both National Registries and

Administrative Claims Data for Real-World Data Collection
Included in this section are 12 examples that leverage a combination of national registries and
administrative claims data. All but one of these examples leverage the Society of Thoracic
Surgeons/American College of Cardiology Transcatheter Valve Therapy (STC/ACC TVT) Registry with
linkage to administrative claims data in CMS claims database to monitor long-term outcomes through
five years after implantation of the subject devices. Two examples of transcatheter heart valves
(P140031/S028 and P130009/S034) utilized STS/ACC TVT Registry data for both condition-of-approval
postmarket surveillance and clinical evidence supporting approval of the indication expansions sought in
both devices through PMA supplements. The transcatheter heart valve in P140031/S028 additionally
relied on STS/ACC TVT Registry data as the sole source of clinical evidence in supporting expansion to
include aortic and mitral valve-in-valve replacement. Finally, for an implantable cardioverter-defibrillator
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(P110042/S077), the condition-of-approval (CoA) postmarket surveillance study utilized multiple RWE
sources to monitor the long-term performance of the subject device. The study leveraged existing national
registry data from the American College of Cardiology National Cardiovascular Data Registry (ACC-
NCDR) ICD Registry, remote-monitoring of device-generated data, public and private payer claims data
from CMS and Truven MarketScan databases, and the National Death Index.
Section IV. Examples Utilizing Medical Records as Real-World Evidence

CDRH continues to review and make regulatory decisions on all types of submissions that use medical
records as the primary or secondary source of clinical evidence. Medical records may serve as the primary
source of clinical evidence for new submissions, as for a new version of a percutaneous catheter
(K180986) which was supported solely by a retrospective medical record review of patients treated OUS,
and for a new robotically assisted surgical device (K171120) to be cleared based on a retrospective
analysis of medical records.
Utilizing medical records as a primary source of clinical evidence is common in submissions seeking an
indication expansion. Other submissions illustrate use of RWE to support modifications to the indications
for use statements for legally marketed devices. In most cases these modifications include use to treat a
new disease or use in a new patient population or anatomic location. These submissions often incorporate
systematic reviews or meta-analyses of existing literature to develop comparators or provide context for
the real-world performance of the subject device. One example is for an indication expansion of a drug-
eluting peripheral catheter (P140010/S037) to include treatment of longer lesions, primarily supported by
a retrospective analysis of medical records from the sponsor’s database. Another example is for a
modified indications for use statement for a hemodialysis catheter end cap (K180111), which FDA has
cleared to include information related to the reduction of bloodstream infections. The sponsor performed
a cluster-randomized clinical trial in 40 dialysis centers across the U.S. to compare the subject device and
a comparator device using data abstracted from electronic health records (EHRs). Both devices were
legally marketed, and dialysis centers were randomized to use one or the other device. Patients were
treated according to the local standard of care, which includes routine blood culture specimen collection
for blood infection surveillance and reporting to the Centers for Disease Control and Prevention (CDC)
National Healthcare Safety Network (NHSN). Blood culture specimens were analyzed by a central
laboratory and the results were then entered into the patient’s EHR and into NHSN Dialysis Event forms
for routine surveillance reporting. Data were then abstracted from the EHR and from the NHSN forms for
the purposes of the study.
Section V. Examples Utilizing Other Sources of Real-World Evidence

Section V is comprised of examples of other sources of RWE. Included in this section are PMAs
submitted in response to a classification order requiring premarket approval of automated external
defibrillators (AEDs). In these three examples for AEDs (P160012, P160032, and P160033), the subject
devices had been marketed in the U.S. for over 10 years, and the submissions drew on postmarket device-
generated data on out-of-hospital use in order to support their approvals. In P160012, when EMS were
called to an out-of-hospital cardiac arrest, study data collectors traveled to the scene, interviewed
witnesses, recorded data on the circumstances of the cardiac arrest, and collected data recorded by the
AEDs.
Real-world evidence is also starting to be used to support regulatory decision-making for digital health
technologies. One example is for a software platform that computes a Rothman Index score from data
extracted from patients’ electronic medical records (K172959). These RWD were used for development
and validation of the device, as well as for comparing performance of the Rothman Index to the predicate
patient status index when both were calculated from hospitals’ electronic medical record systems.
Another example is a De Novo classification request for a radiological computer-assisted triage and
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notification software (DEN170073) that analyzes CT angiogram images and notifies a specialist when a
large vessel occlusion has been identified for further image review. To support this submission, the
sponsor performed standalone performance testing which evaluated the performance of the software
against ground truth. The sponsor also performed a secondary analysis which compared the notification
time of the device against a standard-of-care notification time extracted from corresponding standard-of-
care radiologist reports. For a De Novo classification request for a mobile software application for
contraception (DEN170052), the sponsor supported their submission by analyzing outside the U.S. (OUS)
data from more than 15,000 women who had used the mobile application. RWE from this analysis was a
primary source of clinical evidence for the submission.
Additional Consideration: Use of Real-World Evidence from Pediatric

Populations
This section examines the benefits of the use of RWE for pediatric patients, a population that has
historically been difficult to study in traditional clinical trials. From the sections organized by data source
above, examples have been selected in which RWE from pediatric patients was used to support modifying
device labeling to explicitly include use in pediatric populations. While these submissions may also
include extrapolation from adult data, the real-world pediatric use information was vital to support the
regulatory decision by assessing the totality of available data. In the submissions for AEDs (P160032 and
P160012) mentioned previously in Section VI, the sponsors utilized RWE from postmarket observational
studies of their device modifications for pediatric patients to support approval. Another example,
regarding a high velocity nasal insufflation device (DEN170001), illustrates how RWD from a pediatric
population can be used to provide supplementary clinical evidence to augment a prospective randomized
trial performed for the adult population. In addition to the adult trial, the sponsor utilized published
literature studies for the neonate population, including a retrospective cohort study of pulmonary outcome
data extracted from medical records in the Vermont Oxford Network database. Moreover, FDA approved
a vertebral body tethering system (HDE H190005) using clinical data collected from pediatric subjects
implanted with a similar device approved for use in adult patients. The pediatric subjects were
retrospectively identified from medical records, and then prospectively enrolled in a clinical study to
collect the long-term follow-up data that were used to support the HDE decision. A second pediatric
scoliosis device approved via HDE, H170001, used RWD from commercial use of the device OUS. Long-
term safety and probable benefit of this device will be assessed in post-approval study that utilizes a U.S.
registry.
Another example is for a pediatric contact lens (P180035) mentioned in Section III. The sponsor
performed a randomized controlled trial to support the effectiveness endpoint and was also required to
demonstrate that the rate of Microbial Keratitis (MK) is no higher than 0.4% per patient-year, since the
risk has not been well characterized previously for children due to the lower level of contact lens use. To
address this concern, the sponsor conducted a retrospective study investigating RWD from soft contact
lens use among children by analyzing the medical records of 782 pediatric patients wearing commercially
available soft contact lens from seven U.S. community clinics. Also, as mentioned previously, a post-
approval study was required to collect long-term safety and effectiveness data, including the rate of MK
assessed against a performance goal. The study will be conducted within integrated eyecare practices or
healthcare and coverage organization systems, with outcome data collected via health records and
administrative claims.
Section VI. Examples of Real-World Evidence Use for In Vitro Diagnostics

In addition to therapeutic devices, CDRH also reviews and makes regulatory decisions on submissions for
IVDs. IVDs represent a technological area that warrants specific attention, as there are clinical, logistical,
and technological characteristics that are unique to IVDs as compared to therapeutic devices. This report
includes eight examples of use of RWE in regulatory decisions for IVDs, including six premarket
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decisions, one postmarket decision, and one example involving both premarket and postmarket use of
RWE that spans the “total product life cycle” (TPLC). These examples include RWE from the sources
described above, including medical records, published literature, and sponsor database data. One
particularly innovative example included in this report is a newborn screening IVD utilizing dried blood
specimens (DEN150035). The pivotal trial for the device was embedded in the Missouri State Public
Health Laboratory’s routine screening program and evaluated the device performance on all samples
submitted to this state laboratory. The Missouri Department of Health and Senior Services’ active
surveillance program was also utilized to track reports of false negatives. This study served as the sole
source of clinical evidence supporting the regulatory decision to grant the De Novo classification request.
Another example is a De Novo classification request for a next generation sequencing-based tumor
profiling test (DEN170058). Clinical data for this submission came from an electronic medical record
database of advanced cancer patients with associated pathological and clinical data generated as part of
routine workflow at Memorial Sloan Kettering Cancer Center. A retrospective analysis of the electronic
medical records provided evidence to support a pan-cancer claim, to validate a test cut-off, and to provide
data on somatic mutation prevalence. The original PMA submission for an IVD to assess risk of
spontaneous preterm delivery by testing cervicovaginal secretions (P160052) is a total-product lifecycle
example with patients’ medical records serving as the primary source of clinical evidence for both the
premarket approval and post-approval study. The sponsor submitted an observational clinical study of
patients tested with the subject device for premarket clinical evidence and as a condition-of-approval, and
the sponsor will collect postmarket clinical evidence by conducting a confirmatory study in a larger
population of patients tested with the subject device. These examples demonstrate how RWD sources can
be leveraged to support clinical research and generate evidence for marketing submissions for IVDs, and
further examples can be found in Appendix Section I.
Key Tag Definitions
The tag definitions below are used for all examples:
1. Administrative claims data – Example includes (or will use) data from administrative
claims.
2. Device-generated data – Example includes (or will use) real-world data from the device
during commercial use.
3. Digital Health example – Example is for a digital health device.
4. Medical records (EHR, EMR, or chart review) – Example includes (or will use) data from
medical records (includes electronic health records, electronical medical records, and medical
chart reviews).
5. Next-generation sequencing – Example is a next-generation sequencing device.
6. Outside-the-US – Example includes RWE from outside the U.S.
7. Patient-generated or patient-entered data – Example includes patient-generated or patient-
entered RWD, such as through a mobile application.
8. Pediatric RWE – Example includes RWE from a pediatric population.
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9. Performance goal or comparator derived from RWE – Example includes a performance
goal or comparator derived from real-world evidence.
10. Registry data – Example includes (or will use) registry data.
11. RWE as a primary source of clinical evidence – Example includes RWE used as the
primary or sole source of clinical evidence for a premarket submission.
12. Total-Product Lifecycle Example – Example includes RWE for both premarket decision-
making and to support a post-approval study.
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Appendix Section I. Examples of Registries as a Source of Real-World Evidence
Subsection A. Examples Leveraging National Registries for Real-World Data Collection
Guide to Examples Leveraging National Registries for Real-World Data Collection

File (510k Sponsor Device Real-World Data (RWD) RWE Use Key Tags
Summary at Source(s)
fda.gov)
1 K170411 Prytime ER-REBOA Catheter American Association for Premarket: RWE was a primary source of clinical Registry data;
Medical the Surgery of Trauma evidence supporting modifications to the labeling RWE as a primary source
Devices, Inc. (AAST) Aortic Occlusion for and to modify the indications for use statement to of clinical evidence;
Resuscitation in Trauma add a specific indication, "patients requiring
and Acute Care Surgery emergency control of hemorrhage,” to the general
(AORTA) Registry indications for use.
2 K173032 Paxman Paxman Scalp Dutch Scalp Cooling Premarket: RWE was a primary source of clinical Outside-the-US;
Coolers Cooler Registry (OUS) evidence for this 510(k) to expand the indication of Registry data;
Limited the subject device to include all cancer patients with
RWE as a primary source
solid tumors, with data from patients in the Dutch
of clinical evidence;
Scalp Cooling Registry supporting a decision of
substantial equivalence.
3 K173585 Intuitive da Vinci Xi Surgical Americas Hernia Society Premarket: RWE was the primary source of clinical Registry data;
Surgical, Inc. System (Model Quality Collaborative data supporting modifications to the indications for RWE as a primary source
IS4000), da Vinci X (AHSQC) Registry use statement to include adding “Ventral Hernia of clinical evidence;
Surgical System Repair” under the cleared “general laparoscopic
(Model IS4200) surgical procedures.”
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4 K173860 Volcano s5/s5i/CORE/ CORE OUS randomized trial Premarket: For this 510(k) submitted to modify Outside-the-US;
Corporation Mobile Precision embedded in national the subject device’s indication, the sponsor Registry data;
Guided Therapy registries (Swedish submitted clinical evidence from three studies, RWE as a primary
System Coronary Angiography
including a randomized controlled trial embedded source of clinical
and Angioplasty Registry)
in an OUS national registry. evidence;
5 H170001 ApiFix, Ltd. Minimally Invasive Outside-the-US Premarket: OUS commercial use provided the Outside-the-US;
Deformity Correction commercial use majority of clinical use cases for this submission. Pediatric RWE;
(MID-C) System The RWE was used in combination with other
Registry data;
Postmarket registry clinical data from OUS studies.
RWE as a primary
Postmarket: The sponsor has agreed to perform a source of clinical
post-approval study (PAS) that will use registry- evidence;
based data collection. Total-Product Lifecycle
Example;
6 P160035 Berlin Heart EXCOR Pediatric Real-world data from non- Premarket: In this conversion of an HDE to a PMA, Pediatric RWE;
Inc. Ventricular Assist study patients, ELSO national registry data from the Extracorporeal Life Registry data;
Device Registry, postmarket Support Organization (ELSO) Registry was Total-Product Lifecycle
registry
leveraged as a historical control that was Example;
propensity-score matched to the HDE trial
population. RWE also served as a source of
supplemental clinical evidence in the form of post-
HDE patient data.
Postmarket: As a condition-of-approval,
postmarket surveillance will be conducted
through an all-comers registry for five years.
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7 P100047 Medtronic, HeartWare INTERMACS Registry Premarket: For this PMA, RWE from the Registry data;
Inc. INTERMACS Registry was utilized as a Total-Product Lifecycle
contemporaneous control for the sponsor's Example;
clinical trial data.
Postmarket: The INTERMACS Registry will be

leveraged to compare outcomes through two
years between patients receiving the subject
device and other LVADs.
8 P150036 Edwards INTUITY Elite Valve STS Adult Cardiac Surgery Premarket: For this PMA, data from the Society of Registry data;
Lifesciences, Database Thoracic Surgeons Adult Cardiac Surgery Database
LLC (STS ACSD) on mean aortic cross-clamp and
cardiopulmonary bypass surgical times was
leveraged as a comparison metric against data
from the sponsor’s clinical trial.
9 P180001 William Cook Zenith Dissection Society for Vascular Postmarket: As a condition-of-approval for this Registry data;
Europe ApS Endovascular System Surgery Vascular Quality PMA original application, the postmarket
Initiative (VQI) Registry surveillance study will utilize the Society for
Vascular Surgery (SVS) Vascular Quality Initiative
(VQI) Registry.
10 P160013/S002 TransMedics, Organ Care System United Network for Organ Premarket: To support this PMA supplement for Registry data;
Inc (OCS) Lung System Sharing (UNOS) Registry modifying the indications for use, the sponsor Total-Product Lifecycle
provided supplemental, match-run data from the Example;
Sponsor Registry United Network for Organ Sharing (UNOS)
(Postmarket only) database.
Postmarket: The sponsor will conduct two post-

approval studies as a condition of approval, one
that follows current clinical trial patients for five
years utilizing the UNOS database, and one that
collects postmarket data in all-comers registry
with some data collected from the UNOS registry.
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11 P070026/S004 DePuy DePuy Ceramax UK National Joint Registry, Postmarket: As a condition-of-approval, OUS data Outside-the-US;
Orthopaedics Ceramic Total Hip Australian NJRR from the UK National Joint Registry and Australia Registry data;
System Orthopaedic Association National Joint
Replacement Registry will be collected and
analyzed for device survivorship, revision, and
death rates.
12 P970003/S207 Cyberonics, VNS Therapy System OUS Postmarket Premarket: For this indication expansion, the Outside-the-US;
Inc. surveillance registry primary source of clinical evidence was RWE from Registry data;
(LivaNova) a postmarket study in Japan conducted through RWE as a primary
the Japan VNS Registry, a national registry source of clinical
launched by three Japanese professional societies evidence;
for this study. The sponsor also submitted adverse
event data from their postmarket surveillance
database.
13 P070015/S128 Abbott XIENCE Family of ACC CathPCI Registry Premarket: A primary source of clinical evidence Registry data;
P110019/S075 Vascular Everolimus Eluting submitted for these PMA supplements for an RWE as a primary
Coronary Stents indication expansion of drug-eluting coronary source of clinical
stents was data from the American College of evidence;
Cardiology (ACC) CathPCI Registry that was
included in the sponsor’s Bayesian Hierarchical
analysis.
14 P140010/S015 Medtronic IN.PACT Admiral SVS Vascular Quality Premarket: For this indication expansion, data Registry data;
Vascular Paclitaxel-Coated Initiative (VQI) Registry from the Society for Vascular Surgery (SVS) Total-Product Lifecycle
Percutaneous Vascular Quality Initiative (VQI) Registry were Example;
Transluminal
utilized as a control for standard-of-care
Angioplasty (PTA)
Balloon Catheter percutaneous, transluminal angioplasty for a
superiority analysis of the sponsor’s clinical trial
data.
Postmarket: For postmarket surveillance, the

sponsor is required to follow sequential patients
from the Society for Vascular Surgery (SVS)
Vascular Quality Initiative (VQI) Registry for 36
months post-procedure.
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15 P070014/S037 Bard LifeStent Vascular Society for Vascular Postmarket: As a condition-of-approval, Registry data;
Peripheral Stent System Surgery Vascular Quality postmarket surveillance of sequential patients for
Vascular, Inc. Initiative (VQI) Registry two years will be conducted through the Society
for Vascular Surgery (SVS) Vascular Quality
Initiative (VQI).
16 P040043/S051 W.L. Gore & GORE TAG Thoracic Society for Vascular Postmarket: For this PMA supplement, Registry data;
Associates, Endoprosthesis Surgery Vascular Quality postmarket surveillance through the Society for
Inc. (Gore) Initiative (VQI) Registry Vascular Surgery (SVS) Vascular Quality Initiative
(VQI) Registry for up to five years was required as
a condition of approval.
17 P100040/S012 Medtronic Valiant Thoracic Stent Society for Vascular Postmarket: As a condition-of-approval, the Registry data;
Vascular Graft with Captivia Surgery Vascular Quality sponsor for this PMA supplement will conduct
Delivery System Initiative (VQI) Registry short-term and long-term performance data
through the Society for Vascular Surgery (SVS)
Vascular Quality Initiative (VQI).
18 P010031/S232 Medtronic, CONCERTO/CONCERTO ACC National Postmarket: For this implantable cardioverter Registry data;
Inc. Cardiac II; CONSULTA; Cardiovascular Data defibrillator, two post-approval studies were
Rhythm MAXIMO II; AND Registry ICD Registry required. One follows patients implanted with the
Disease PROTECTA/PROTECTA
subject device enrolled in the American College of
Management XT National Death Index
Sponsor Registry Cardiology NCDR ICD Registry, with long-term
mortality data collected through the National
Death Index. The second will utilize a sponsor
registry to collect additional data on survival
probability of freedom from adjudicated heart
failure events or all-cause death.
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Example 1. 510(k) - Modification to Indications for Use Statement for a Large Vessel Occlusion
Catheter Using the American Association for the Surgery of Trauma AORTA Registry [1, 2]
File Sponsor Device Approved/Cleared/Granted Indication RWE Source Use of RWE
K170411 Prytime ER-REBOA The ER-REBOA Catheter is intended for temporary occlusion of large vessels American Association for the Premarket: Primary
Medical Catheter and blood pressure monitoring including patients requiring emergency Surgery of Trauma (AAST) source of clinical
Devices, Inc. control of hemorrhage. Aortic Occlusion for evidence
Resuscitation in Trauma and
Acute Care Surgery
(AORTA) registry
Case series
Premarket Use – American Association for the Surgery of Trauma AORTA Registry and Case Series
Population Key Elements or Endpoints from RWE Source
AORTA Registry (RWE): Patients treated with the ER-REBOA catheter for Safety and Effectiveness:
management of emergency hemorrhage. Aorta occlusion success
Use of medical imaging in device placement
Case Series (RWE): Additional patients managed with the ER-REBOA catheter in a
military setting (published literature).
Narrative:
The sponsor submitted this 510(k) to make modifications to the labeling and to modify the indications for use statement to add a specific indication to the general indications for
use. To support the labeling changes and the addition of "including patients requiring emergency control of hemorrhage," the sponsor provided clinical evidence from the
American Association for the Surgery of Trauma (AAST) Aortic Occlusion for Resuscitation in Trauma and Acute Care Surgery (AORTA) registry and a case series. The AORTA
registry was established by the AAST to collect observational data on patients treated with aortic occlusion in accordance to local standard of care. In this example, critically-
injured patients needing emergency-hemorrhage control---who were treated with the device---were identified in the registry. Data on successful aortic occlusion with and
without imaging placement were analyzed from the registry. These data along with additional case reports served as the primary source of clinical evidence for this 510(k).
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Example 2. 510(k) - Modification to Indications for Use Statement for a Scalp Cooling System
using Real-world Evidence from an OUS Registry [3, 4, 5, 6]
File Sponsor Device Approved/Cleared Indication RWE Source Use of RWE
K173032 Paxman Paxman The Paxman Scalp Cooler is indicated to reduce the likelihood of chemotherapy- Premarket: Registry Premarket: Primary
Coolers Scalp Cooler induced alopecia (CIA) in cancer patients with solid tumors. source of clinical
Limited evidence
Premarket Use – OUS Registry Study

Dutch Scalp Cooling Registry (RWE): 1411 cancer patients with multiple cancer Efficacy:
types and various chemotherapy regimens Hair preservation after the fourth cycle of chemotherapy (measured as <50% not requiring use of wig or
head covering)
Paxman Coolers Limited SCALP Study (Non-RWE): 182 women with breast European Organisation for Research and Treatment of Cancer Quality of Life Questionnaire-Core 30 score
cancer requiring chemotherapy Hospital Anxiety and Depression Scale score
Body Image Scale summary scale
Peer-reviewed Literature with Studies Conducted Using RWD Sources: 15 Alopecia occurrence
published studies including 6 retrospective studies (data from some studies is
included in the Dutch Scalp Cooling Registry study above) Safety:
See 510(k) Letter and Summary for additional details. Scalp metastases
Device-related adverse events
Narrative:
For this 510(k), RWE from a registry study in the Netherlands, the Dutch Scalp Cooling Registry, was used as the primary source of clinical evidence. For this study, patients were
enrolled from multiple sites in the Netherlands, with nurses recording patient data including chemotherapy history, hair characteristics, and whether they wore a head cover.
These data along with a literature review and a small randomized clinical trial conducted in the US were used to support a substantial equivalence determination.
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Example 3. 510(k) - Modification to Indications for Use Statement for Da Vinci Surgical Systems
Using the Americas Hernia Society Quality Collaborative (AHSQC) Registry [7]
K173585 Intuitive da Vinci Xi da Vinci Xi Surgical System Americas Hernia Society Quality Premarket: Primary
Surgical, Inc. Surgical The Intuitive Surgical Endoscopic Instrument Control System (da Vinci Xi Surgical Collaborative (AHSQC) Registry source of clinical
System System, Model: lS4000) is intended to assist in the accurate control of Intuitive evidence
(Model Surgical Endoscopic Instruments including rigid endoscopes, blunt and sharp
IS4000), da endoscopic dissectors, scissors, scalpels, forceps/pick-ups, needle holders,
Vinci X endoscopic retractors, electrocautery and accessories for endoscopic
Surgical manipulation of tissue, including grasping, cutting, blunt and sharp dissection,
System approximation, ligation, electrocautery, suturing, and delivery and placement of
(Model microwave and cryogenic ablation probes and accessories, during urologic
IS4200) surgical procedures, general laparoscopic surgical procedures, gynecologic
laparoscopic surgical procedures, general thoracoscopic surgical procedures and
thoracoscopically-assisted cardiotomy procedures. The system can also be
employed with adjunctive mediastinotomy to perform coronary anastomosis
during cardiac revascularization. The system is indicated for adult and pediatric
use. It is intended to be used by trained physicians in an operating room
environment in accordance with the representative, specific procedures set forth
in the Professional Instructions for Use.
da Vinci X Surgical System

See 510(k) Summary for Full Indications for Use.
Premarket Use –AHSQC Registry

Population Key Elements or Endpoints from RWE Source Methods of Note
AHSQC Registry (Non-Complex Ventral Hernia Repair Information from the AHSQC for non-complex and complex Propensity score matching
Procedures): Propensity-matched comparison between robotic-assisted, laparoscopic, and open VHR procedures was
robotic-assisted, open-surgery, and laparoscopic surgery used to generate comparisons for the following key measures:
cohorts • Length of Stay,
• Intraoperative Complications,
AHSQC Registry (Complex Ventral Hernia Repair Procedures): • Transfusions,
Propensity-matched comparison between robotic-assisted and • Postoperative Complications through 30 days,
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open-surgery cohorts. Unmatched comparison between • Readmission Rates through 30 days,

robotic-assisted and laparoscopic surgery cohorts. • Re-encounter Rates (in clinic and in Emergency
Room) through 30 days,
• Reoperation Rates through 30 days,
• Recurrence Rates through 30 days, Mortality through
30 days,
• Operative Time
See 510(k) Summary for additional details and complete list
Narrative:
This submission sought clearance for a labeling modification to include “Ventral Hernia Repair” (VHR) procedures under the cleared “general laparoscopic surgical procedures”
Indication for Use of the da Vinci Xi Surgical System, Model IS4000 and the da Vinci X Surgical System, Model IS4200. In support of this change, the sponsor provided information
collected from the AHSQC registry containing propensity matched comparisons of key measures for robotic-assisted, laparoscopic and open procedures
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Example 4. 510(k) - Modification to Indications for Use Statement for Ultrasonic Pulsed Echo
Imaging System Supported by Data from an OUS Randomized Trial Embedded in a National
Outside the U.S. Registry [8]
K173860 Volcano s5/s5i/CORE/ The Volcanos5TM/s5i/CORE/CORETM Mobile Precision Guided Therapy System is used for the Registry Embedded Premarket: Registry
Corporation CORE Mobile qualitative and quantitative evaluation of vascular morphology in the coronary arteries and vessels Clinical Trial Embedded Clinical Trial
Precision of the peripheral vasculature. It is also indicated as an adjunct to conventional angiographic submitted in support of
Guided procedures to provide an image of vessel lumen and wall structures. the 510(k) submission
Therapy
System Please see Decision Letter and Summary for Full Indications for Use Statement
Premarket Use – Outside-the-US Randomized Trial Embedded in National Registries (e.g. Swedish
Coronary Angiography and Angioplasty Registry, SWEDEHEART, Danish National Patient Registry
and the Western Denmark Heart Registry)
iFR-SWEDEHEART (Instantaneous Wave-free Ratio versus Primary: Composite rate of all-cause mortality, non-fatal OUS randomized clinical trial was embedded in national
Fractional Flow Reserve in Patients with Stable Angina myocardial infarction, or unplanned revascularization within 12 registry, with enrollment, randomization, and data
Pectoris or Acute Coronary Syndrome): 2017 patients with months after the index procedure collection conducted through the registry platform.
coronary artery disease included in the Swedish Coronary
Angiography and Angioplasty Registry from all 30 coronary Please see Summary of Safety and Effectiveness Data for
intervention centers in Sweden and a single site in Iceland additional details and complete list.
Narrative:
This submission sought clearance to modify the indications for use statement to reflect use of the dichotomous 0.89 intravascular pressure index as a cut-point in guiding
revascularization procedures. For the 510(k) submission, the sponsor provided clinical evidence from three clinical studies, including a multicenter observation study, (ADVISE II),
a randomized control trial (DEFINE-FLAIR), and a second randomized control trial (iFR-SWEDEHEART) in which outside-the-US national registries were used for patient
enrollment, data collection, and follow-up.
The iFR SWEDEHEART trial used registry-based enrollment and randomization, in which patients eligible for the trial (and who had consented) were randomized into one of two
arms (Instantaneous Wave-free Ratio versus Fractional Flow Reserve). For this trial, data were entered into Swedish Coronary Angiography and Angioplasty Registry (SCAAR),
using an additional module to collect data specific for the trial. The Swedish Coronary Angiography and Angioplasty Registry (SCAAR) is a national registry that collects standard-
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of-care patient data from 31 coronary intervention centers (all centers (30) in Sweden, 1 in Iceland) for the purposes of quality improvement and benchmarking. For this trial,
follow-up data were obtained from national registries (e.g. SWEDEHEART) and healthcare records.
Clinical evidence from these studies were used to support the clearance of this 510(k) submission. This submission is an example illustrating the use of real-world data sources
(national registries) as a data collection and clinical trial platform supporting a randomized clinical trial.
For additional details, please see the Decision Letter and Summary and Götberg et al.
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Example 5. HDE - Approval for Spinal Posterior Ratcheting Rod System Using OUS Commercial
Data and Sponsor Registry to Satisfy Post-Approval Requirements [10, 11, 12]
H170001 ApiFix, Ltd. Minimally Invasive The MID-C System is indicated for use in patients OUS commercial use data in the European Union, Premarket: Primary
Deformity Correction with adolescent idiopathic scoliosis (AIS) for Singapore, and Israel. source of clinical
(MID-C) System treatment of single curves classified as Lenke 1 evidence
(thoracic major curve) or Lenke 5
(thoracolumbar/lumbar major curve), having a Postmarket: Post-
Cobb angle of 45 to 60 degrees which reduces to approval study
less than or equal to 30 degrees on lateral side-
bending radiographs, and thoracic kyphosis less
than 55 degrees as measured from T5 to T12.
Premarket Use – OUS Commercial Use Data

OUS Prospective, Multi-Center, Non-Randomized, Open Label Clinical Study (Non-RWE): 20 Safety:
patients with AIS in Hungary, Romania, and Israel Reoperations
Adverse events
OUS Postmarket Clinical s=Studies (Non-RWE): 26 patients from OUS post-market clinical
studies, 9 patients from special access cases in Canada Probable Benefit:
Primary Cobb angle less than or equal to 35 degrees and no curve progression at 24-
Target Population (RWE): 25 patients implanted with the HDE Device Version of the MID-C months compared to baseline following treatment with the device.
System, as of September 15, 2018, that meet the US Indications for Use.
Expanded Target Population (RWE): 49 patients implanted with the HDE Device Version of the
MID-C System, as of September 15, 2018, that meet either the US Indications for Use (N=25) or an
Expanded US Indications for Use (N=24) for patients with 40 to 44-degree curves.
See Summary of Safety and Probably Benefit for additional details regarding inclusion criteria.
www.fda.gov
28
Narrative:
This Humanitarian Device Exemption (HDE) was approved for a non-fusion spinal device intended to prevent spinal curve progression in adolescent patients with idiopathic
scoliosis. The decision was based on information gathered from use of the device outside-the-US (OUS) from sources that included an open label clinical study as well data from
commercial use of the device.
Postmarket Use – Post-Approval Study Using Sponsor Registry

Population Key Elements or Endpoints from RWE Source Follow-up/Duration
Minimum of 200 patients from 10 US Primary Safety: Significant adverse events, device or procedure-related adverse events. 5 years
centers with AIS, as assessed by Risser
grade, Sanders score, or a combination of Primary Probable Benefit: Maintenance of major Cobb angle less than or equal to 40
the two degrees at 60 months post-surgery
Narrative:
As a condition-of-approval, the sponsor has agreed to perform a post-approval study that will use an external registry for data collection.
www.fda.gov
29
Example 6. PMA - Approval and Postmarket Surveillance of a Pediatric Ventricular Assist Device
Utilizing National Registry Data [13, 14]
P160035 Berlin Heart EXCOR Pediatric EXCOR Pediatric Ventricular Assist Device (referred to as EXCOR Pediatric) Extracorporeal Life Support Premarket: Primary (Control)
Conversion of HDE Inc. Ventricular is intended to provide mechanical circulatory support as a bridge to Organization (ELSO) Registry and Supplemental (FDA-
to PMA Assist Device cardiac transplantation for pediatric patients. Pediatric candidates with (Historical ECMO control for requested data from all non-
severe isolated left ventricular or biventricular dysfunction who are HDE IDE Trial) study patients post-HDE
candidates for cardiac transplant and require circulatory support may be approval)
treated using the EXCOR Pediatric. Real-world data from all non-
study patients post-HDE Postmarket: CoA to conduct
approval (FDA requested) postmarket surveillance in a
registry
Premarket Use – Real-World Data from All Non-Study, Post-HDE Approval Patients and ELSO Registry
Data
Non-Study Patients Post-HDE (RWE): Data from all Pooled Data Set: Freedom-from-death, competing outcomes, significant adverse Propensity-score analysis in IDE trial for original
non-study patients, post-HDE approval (245 patients events, neurological events, stroke incidence, and mortality. HDE approval.
through December 31, 2015). Pooled with data from
IDE, compassionate-use and PAS patients. Safety: The control RWE ELSO cohort was not used for analysis of safety. Serious Propensity-score analysis done based on age,
adverse event rates from the IDE trial were compared to performance goals derived weight, diagnosis, ventilator status, inotrope
IDE Trial Population (Non-RWE): 48 patients treated from literature and clinical experience. use, and prior cardiac arrest.
with the device and divided into two cohorts by body-
surface area (BSA), 24 patients each (H100004). Effectiveness: Hazard rates between EXCOR and ELSO ECMO cohorts; survival to
successful outcome; survival time; duration of support; competing outcomes
ELSO Registry (RWE): Historical extracorporeal
membrane oxygenation (ECMO) control with 48
patients propensity-score matched to each IDE BSA
cohort (H100004).
Narrative:
www.fda.gov
30
The EXCOR device was previously approved under an HDE (H100004) and provides cardiac support for pediatric patients awaiting cardiac transplantation. This submission was
to convert the HDE to a PMA. For the HDE approval, the sponsor conducted an IDE clinical trial to demonstrate device safety and probable benefit. Specifically, the sponsor
compared safety endpoints from a population treated with the device and a performance goal. In the IDE trial, the sponsor also compared endpoints between the EXCOR trial
population and an historical ECMO control from the ELSO registry, which collects real-world data on extracorporeal life support procedures. For the HDE approval, FDA reviewed
data that compared hazard ratios between pediatric patients treated with EXCOR and those treated with ECMO. FDA reviewed analyses of survival to successful outcome or
failure as well as competing outcomes vs days-post-implant between the device and ELSO cohorts. These data were incorporated into the PMA submission by reference. For the
HDE-to-PMA conversion, FDA also reviewed data from the sponsor’s HDE post-approval study. Finally for the HDE-to-PMA conversion, FDA reviewed pooled freedom-from-
death, competing outcomes, significant adverse events, neurological events, stroke incidence, and mortality data from the IDE cohort (n=94), HDE post-approval study patients
(n=39), compassionate use patients from IDE sites (n=54), compassionate-use patients from non-IDE sites (n=133), as well as real-world data from non-PAS-study implanted
patients (n=245).
Postmarket Use – Surveillance Registry

Minimum of 62 pediatric Primary Endpoints: Five years of surveillance.
patients, (all-comers Observed stroke rate overall; data on anticoagulation protocol
population, pediatric age
range only, <22 years of Secondary Endpoints:
age) Thrombotic event rates, adverse event rates, patient outcomes (e.g. survival to transplant, survival to
recovery)
Narrative:
Surveillance of pediatric patients will be conducted in an all-comers registry. The purpose of surveillance is to continue to monitor the safety and effectiveness of this device and
to quantify the stroke rate overall and as newer concomitant medication therapies (anticoagulant/antithrombotic regimens) are adopted by the medical community. Adverse
events will also be recorded and reported.
www.fda.gov
31
Example 7. PMA - Approval and Postmarket Surveillance for a Left Ventricular Assist Device Using
National Registry Data [15, 16, 17, 18]
P100047 HeartWare, HeartWare The HeartWare Ventricular Assist System (Heart Ware VAS) is indicated for INTERMACS Registry Premarket: Primary (Control)
Inc. Ventricular use as a bridge to cardiac transplantation in patients who are at risk of
(now Assist System death from refractory end stage left ventricular heart failure. The Heart Postmarket: CoA study to
Medtronic) Ware VAS is designed for in-hospital and out-of-hospital settings, leverage INTERMACS Registry
including transportation via fixed wing aircraft or helicopter.
Premarket Use – Control cohort from INTERMACS Registry

ADVANCE TRIAL (Treatment cohort) (Non-RWE): 140 Primary: Proportion of study patients alive on the originally implanted device, Treatment cohort: Every day for first week,
patients in the intent-to-treat population transplanted, or explanted for recovery at 180 days to the same proportion once-a-week for weeks 2-4, at week 6 and 8,
obtained from the INTERMACS cohort (non-inferiority analysis) monthly for first year, every other month for
ADVANCE TRIAL: INTERMACS control (RWE): 499 year 2 (until transplant or device removal).
patients enrolled into the registry between August
18, 2008 and February 18, 2010 (who met the study 30 day and 6-month follow-up after device
criteria) explant or transplant, then check-ups bi-
annually through 5 years.
Annual follow-up for years 2 -5 for patients

using the device.
INTERMACS: Standard-of-care follow-up (1

week, 1 month, 3 months post-implant, at 6
months, and then every 6 months (if device is in
place). For explant patients that are not
transplanted, patients followed for 1 year.
Narrative:
The primary source for clinical evidence and basis for approval came from the ADVANCE Trial comparing HeartWare VAS patients against a contemporaneous control from the
INTERMACS Registry.
www.fda.gov
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Postmarket Use – INTERMACS Registry
Population Key Elements or Endpoints from RWE Source Follow-up / Duration
600 HeartWare VAS Primary endpoints: Two-years (post-implant)
recipients Success at 180 days (e.g. alive, recovery, transplant)
600 non-HeartWare left
ventricular assist device Secondary:
(LVAD) recipients Overall survival on device, re-hospitalization, adverse events, quality-of-life, functional status, post-stroke
quality of life, functional and neurocognitive assessments.
Narrative:
This post approval study utilizes the INTERMACS registry to compare outcomes and adverse events in HeartWare recipients to a control cohort of patients receiving a LVAD
other than HeartWare. Enrollees are followed per standard of care through two-years post-implant.
www.fda.gov
33
Example 8. PMA - Approval of a Heart Valve Replacement Using National Registry Data [12, 19]
P150036 Edwards INTUITY Elite The EDWARDS INTUITY Elite valve is indicated for the replacement The Society of Thoracic Surgeons Premarket: Primary
Lifesciences, LLC Valve System of diseased, damaged, or malfunctioning native or prosthetic aortic (STS) Adult Cardiac Surgery Database (Comparison metric in
valves. evaluation of surgical times
(aortic cross clamp time and
cardiopulmonary bypass time))
Premarket Use – Society of Thoracic Surgeons Adult Cardiac Surgery Database (STS ACSD)
Population Key Elements or Endpoints from RWE Source Follow-up/Duration Methods of Note
TRANSFORM Study (Non-RWE): 889 patients (839 patients Effectiveness: Average aortic cross-clamp and TRANSFORM: Discharge, 3-months, STS surgical time data stratified
received the device for aortic valve replacement (AVR)) cardiopulmonary bypass surgical times 1 year, annually to minimum of 5 by procedure type (isolated AVR,
years isolated AVR using minimally-
STS Adult Cardiac Surgery Database (RWE): AVR patients invasive surgery, AVR and
(7/2011 – 12/2012) STS Adult Cardiac Surgery Database: coronary artery bypass grafting
(Procedural data) (CABG) with 1,2,3 or 4+ grafts)
Narrative:
Clinical evidence from the TRANSFORM clinical trial was the primary basis for PMA approval. The safety endpoints were complication and survival rates compared against
objective performance criteria (ISO 5840:2009) and literature-derived valves. The effectiveness endpoints were echo-derived hemodynamic performance data; NYHA
classification; and average aortic cross-clamp and cardiopulmonary bypass surgical times.
In this example, the sponsor also evaluated the latter two effectiveness endpoints (aortic cross-clamp and cardiopulmonary bypass surgical times) by comparing average aortic
cross-clamp and cardiopulmonary bypass surgical times from TRANSFORM patients against mean aortic cross-clamp and cardiopulmonary bypass surgical times recorded in the
STS Adult Cardiac Surgery Database (data entered between 7/11 – 12/12).
www.fda.gov
34
Example 9. PMA - Approval of a New PMA for an Endovascular System with a Post-approval Study
using the Society for Vascular Surgery Vascular Quality Initiative (VQI) Registry [20, 21]
P180001 William Cook Europe Zenith Dissection The Zenith Dissection Endovascular System (Zenith TX2 Dissection Endovascular Graft Society for Vascular Postmarket: Post-
ApS Endovascular with Pro-Form and Zenith Dissection Endovascular Stent) is indicated for the Surgery Vascular approval study using
System endovascular treatment of patients with Type B aortic dissection. The Zenith TX2 Quality Initiative VQI
Dissection Endovascular Graft with Pro-Form is intended to seal entry tears and to (VQI) Registry
exclude aneurysms associated with chronic dissections. The Zenith Dissection
Endovascular Stent is intended to be used as a distal component to provide support to
delaminated segments of non-aneurysmal aorta with dissection distal to a Zenith TX2
Dissection Endovascular Graft with Pro-Form. The system is indicated for use in patients
having vascular anatomy suitable for endovascular repair, including:
• Adequate iliac/femoral access compatible with the required introduction systems,
• For the Zenith TX2 Dissection Endovascular Graft with Pro-Form:
o Non-dissected/aneurysmal aortic segments (fixation sites) distal to the
left common carotid artery and proximal to the entry tear with a length
of at least 20 mm,
o Non-dissected/aneurysmal aortic segments (fixation sites) distal to the
left common carotid artery and proximal to the entry tear with a
diameter (measured outer-wall to outer-wall) of no greater than 38 mm
and no less than 20 mm, and
• For the Zenith Dissection Endovascular Stent:
o Diameter at non-aneurysmal intended implant site (measured outer-wall
to outer-wall) of no greater than 38 mm (true lumen) and no less than 20
mm (total aortic diameter).
Postmarket Use – VQI Registry
Population Key Elements or Endpoints from RWE Source Follow-up

VQI Registry: Primary endpoints: Five years
Patients with acute Type B dissection treated with the Freedom from dissection-related mortality (all devices combined endpoint).
Zenith TX2 Dissection Endovascular Graft with Pro- Device technical success and device procedural success at 30 days (device-specific endpoints).
Form and the Zenith Dissection Endovascular Stent.
Secondary endpoints:
Device technical (during the procedure) and procedural success for each project device.
www.fda.gov
35
Patients with chronic Type B dissections, treated using Additional endovascular and surgical dissection-related interventions.
the Zenith Dissection Endovascular System. Dissection treatment success and the individual elements of the composite endpoint dissection treatment
success.
Narrative:
As a condition-of-approval for this PMA original application, the sponsor will conduct a post-approval study that will use the Society for Vascular Surgery (SVS) Vascular Quality
Initiative (VQI) Registry. Data will be collected through five-years.
www.fda.gov
36
Example 10. PMA - Modification to Indications for Use Statement and Postmarket Surveillance for
a Portable Normothermic Organ Perfusion, Ventilation and Monitoring Medical Device Using
National Registry Data [22, 23, 24, 25]
P160013/S002 TransMedics, Organ Care The TransMedics Organ Care System (OCS) Lung is a portable, United Network for Organ Premarket: Match-run data
Inc System (OCS) normothermic organ perfusion, ventilation and monitoring medical device Sharing (UNOS)
Lung System indicated for preservation of standard criteria donor lung pairs and for Postmarket: CoA for two post-
preservation of donor lung pairs initially deemed unacceptable for Sponsor Registry approval studies that will
procurement and transplantation based on limitations of cold static leverage RWE
preservation. The device allows for ex vivo assessment of donor lungs
prior to transplantation.
Premarket Use – Additional Match-Run Data from UNOS Registry

EXPAND Clinical Trial (Non-RWE): Single-arm, multi- Number of times EXPAND enrolled lungs were refused by transplant centers prior to EXPAND exclusion
center, international, prospective clinical trial
(n=79,55 in US, 24 OUS).
UNOS Organ Procurement and Transplantation

Network Database (RWE): Match-run data was
obtained from UNOS on US lungs enrolled in the
EXPAND (66 out of 67 US lungs).
Narrative:
The sponsor submitted this PMA supplement to modify the indications for use statement to include “preservation of donor lung pairs initially deemed unacceptable for
procurement and transplantation based on limitations of cold static preservation.” The primary basis and source of clinical evidence for this PMA supplement was the EXPAND
trial. The sponsor also provided additional, match-run data from the UNOS database, which contained data on the number of times US lungs were rejected prior to enrollment in
EXPAND.
Postmarket Use – Post-Approval Study Using RWE
www.fda.gov
37
PAS001: Continued follow-up of patients enrolled in PAS001 Endpoints: Five years
the Lung EXPAND clinical trial. Annual follow-up data Bronchiolitis Obliterans Syndrome (BOS)-free survival (freedom from BOS and
on US patients will be collected using the United mortality) through 5 years
Network for Organ Sharing (UNOS) database. Data Please see PAS Database: EXPAND Continuation PAS for full details.
from OUS patients will be collected from
participating sites.
PAS002 Primary Endpoints:
PAS002: Patients transplanted with initially-deemed 12-month patient and graft survival post double-lung transplant
unacceptable OCS-preserved lungs per the Please see PAS Database: OCS-Lun-PAS for full details.
indications for use. Data will be collected in an all-
comers, sponsor registry that leverages the UNOS
database for data collection.
Narrative:
As a condition-of-approval for the PMA supplement, the sponsor is required to conduct two post-approval studies. The first post-approval study will follow all patients currently
enrolled in the Lung EXPAND clinical trial for five years. For currently-enrolled US patients, follow-up data will be collected annually using the United Network for Organ Sharing
(UNOS) database. UNOS administers the Organ Procurement and Transplantation Network in the United States and maintains a national database with data on organ matching
and transplantation. The second post-approval study will collect additional postmarket data using an all-comers registry, the TOP registry. The TOP registry collects data on all US
patients transplanted with OCS-preserved lungs. Data for this PAS study will also come from the UNOS registry in addition to data specifically collected to meet post-approval
requirements
www.fda.gov
38
Example 11. PMA - Postmarket Surveillance of a Total Hip Replacement Using Two OUS National
Registries [26, 27]
P070026/S004 DePuy DePuy The Ceramax® Ceramic Total Hip System is indicated for noncemented use in skeletally UK and Australian Postmarket: CoA to
Orthopaedics Ceramax mature individuals undergoing primary total hip replacement surgery for rehabilitation National Joint Registry leverage UK and Australian
Ceramic Total of Data National Joint Registry
Hip System hips damaged as a result of noninflammatory degenerative joint disease (NIDJD) or any Data for postmarket
of its composite diagnoses of osteoarthritis, avascular necrosis, and post-traumatic evaluation
arthritis.
Postmarket Use – UK National Joint Registry (UK NJR) and Australia Orthopaedic Association
National Joint Replacement Registry
36mm Ceramic-on-ceramic (CoC) patients in UK and Primary: Device survivorship, revision and death rates
Australia joint registries;
Minimum of 500 patients.
Narrative:
This PAS collects, retrospectively and prospectively, short, medium, and long-term information regarding the performance and safety of the 36mm Ceramax Ceramic-on-Ceramic
Total Hip System from series of subjects (minimum of 500 subjects) in the UK National Joint Registry (UK NJR) and Australia Orthopaedic Association National Joint Replacement
Registry (NJRR). The primary endpoints are device survivorship, revision and death rates.
www.fda.gov
39
Example 12. PMA - Approval of an Indication Expansion for an Implanted Autonomic Nerve
Stimulator for Epilepsy Based on OUS National Registry Data in a Bayesian Hierarchical Analysis [28,
29, 30]

P970003/S207 Cyberonics, Inc. VNS Therapy The VNS Therapy System is indicated for use as an adjunctive therapy in reducing the OUS postmarket Premarket: Primary
Supplement to System frequency of seizures in patients 4 years of age and older with partial onset seizures registry data (all
expand that are refractory to antiepileptic medications. consecutive patients Bayesian analysis of real-
indication treated with VNS per world data from a
Japan MHLW approved mandated Japan
indication) postmarket study enrolling
all subjects treated with
VNS (per MHLW approved
indication) serving as
current data and data from
previous clinical trials
serving as the prior
Premarket Use – OUS PMDA Mandated postmarket surveillance capturing data from all consecutive
patients treated with VNS (per MHLW approved indication) using a registry
Population Key Elements or Endpoints from RWE Sources Methods of Note
Japan PAS (RWE): MHLW/PMDA mandated study captures data from all consecutive Japanese patients Primary Safety: Incidence rate of device‐related Bayesian Hierarchical
treated with VNS (per Japan MHLW approved indication). treatment emergent adverse events through 12 Analysis
months of treatment.
E03 (Non-RWE): Randomized controlled trial comparing two treatment arms (high and low stimulation)
in patients with refractory partial onset seizures Primary Effectiveness: Proportion of patients (Japan
E04 (Non-RWE): Open -label study of adjunctive VNS Therapy in patients with refractory seizures PAS, 4-11 years of age) with at least a 50%
E05 (Non-RWE): Randomized controlled trial comparing two treatment arms (low and high stimulation) reduction in the frequency of seizures following 12
in patients with refractory partial onset seizures. E05 patients followed in subsequent XE5 study. months of treatment.
E06 (Non-RWE): Randomized study comparing VNS to drug therapy in a pediatric population (17 years
or less)
Postmarket Surveillance Database (RWE): Sponsor postmarket surveillance database containing

passively reported adverse event reports and device tracking data
www.fda.gov
40
Narrative:
The primary study reviewed by FDA was the Japan postmarket study, which collects data on all patients treated with VNS (per the MHLW approved indication) following market
approval), including 30 patients aged 4-11. The postmarket study was mandated by the Japan PMDA to collect data on all VNS cases for three years following market approval
[28]. Three Japanese professional societies helped launch the Japan VNS Registry to respond to the PMDA request [29, 30]. To demonstrate effectiveness, the sponsor
performed a Bayesian Hierarchical analysis using the Japan data as the source of observed/current data (30 patients) and data from five previous trials as the source of prior
information. For its assessment of safety, FDA reviewed analyses of treatment emergent adverse events pooled from the submitted studies as well as the sponsor’s postmarket
surveillance database. FDA also reviewed summary data of postmarket adverse events recorded in the sponsor’s postmarket surveillance database.
www.fda.gov
41
Example 13. PMA - Indication Expansions of Drug-Eluting Coronary Stents Using National Registry
Data [31, 32]
P070015/S128 Abbott XIENCE XIENCE V and XIENCE nano Everolimus Eluting Coronary Stent System American College Premarket: Primary
P110019/S075 Vascular Family of of Cardiology (Observed/Current data
Supplements to Everolimus The XIENCE V and XIENCE nano Everolimus Eluting Coronary Stent System is indicated for improving CathPCI Registry in Bayesian Hierarchical
expand Eluting coronary luminal diameter in patients, including those with diabetes mellitus, with symptomatic Analysis with prior data
indication Coronary heart disease due to de novo native coronary artery lesions (length ≤ 28 mm) with reference vessel from clinical trial
Stents diameters of 2.25 mm to 4.25 mm. Additionally, the XIENCE V stent system is indicated for treating databases)
de novo chronic total coronary occlusions.
Please see the Summary of Safety and Effectiveness Data for P070015/S128 and P110019/S075 for
the complete indication list.
Premarket Use – American College of Cardiology (ACC) CathPCI Registry

XIENCE Databases (Non-RWE): 949 diabetic patients Safety and Effectiveness: 12-month target vessel failure 12-month data analyzed Bayesian Hierarchical analysis
treated with the device(s) from SPIRIT IV, SPIRIT PRIME, (composite endpoint of cardiac death, target-vessel myocardial
XIENCE V USA Phase I, and XIENCE V USA Phase II trials infarction (TVMI), and ischemia-driven target vessel
revascularization (ID-TVR))
CathPCI Registry (RWE): 290 diabetic patients
Narrative:
To support expanding the indication to include treatment of patients with diabetes mellitus, the sponsor performed a Bayesian Hierarchical analysis using data from four clinical
trial databases as the source of prior information, and real-world data from two registry databases (part of American College of Cardiology CathPCI registry) as the source of
current data. The analysis compared the target vessel failure rate (TVF) at 12 months against a performance goal. The results of this analysis demonstrated that the performance
goal and success criteria for the posterior probability were both achieved. This analysis served as the primary basis for approval of the PMA
www.fda.gov
42
Example 14. PMA - Indication Expansion and Postmarket Surveillance of a DCB Percutaneous
Transluminal Angioplasty Catheter Approval Using National Registry Data [33, 34, 35]
P140010/S015 Medtronic IN.PACT Admiral The IN.PACT Admiral Paclitaxel-coated PTA Balloon Catheter is indicated SVS VQI Registry Premarket: Primary (Control)
Supplement to Vascular, Inc. Paclitaxel- for percutaneous transluminal angioplasty, after appropriate vessel
expand indication Coated preparation, of de novo, restenotic, or in-stent restenotic lesions with Postmarket: CoA to conduct
Percutaneous lengths up to 180 mm in superficial femoral (SFA) or popliteal arteries postmarket surveillance in VQI
Transluminal with reference vessel diameters of 4-7 mm. Registry
Angioplasty
(PTA) Balloon
Catheter
Premarket Use – Society for Vascular Surgery (SVS) - Vascular Quality Initiative (VQI)
IN.PACT Global Study (Non-RWE): 164 OUS Safety: Cumulative complications within 30, 180 and 360 days (all-cause death, IN.PACT:(1, 6, and 12 Propensity-score adjusted
Patients treated with the IN.PACT Admiral DCB at target vessel revascularization, major target limb amputation, target lesion months then annually analysis based on 20 pre-
31 sites. revascularization) up to 5 years) specified variables.
VQI Registry (RWE): 153 patients treated with Effectiveness: 12-month target lesion revascularization (TLR). VQI: Standard of care
standard-of-care percutaneous, transluminal
angioplasty.
Narrative:
To support expanding the indication to include treatment of in-stent restenotic lesions, the sponsor performed a superiority analysis between a device cohort from the sponsor’s
IN.PACT Global Study and a standard-of-care percutaneous, transluminal angioplasty cohort from the SVS Vascular Quality Initiative Registry. This analysis was a prospectively-
designed superiority analysis evaluating target lesion revascularization at 12 months. To account for potential differences between the populations, the sponsor performed a
propensity-score adjusted analysis using 20 pre-specified variables. The propensity score results were reviewed by FDA before the sponsor performed the outcome analysis. The
results of these analyses demonstrated that the success criteria were achieved--- and along with analyses of serious adverse events from the IN.PACT Global Study---was the
primary basis for approval of the supplement
Postmarket Use – Society for Vascular Surgery (SVS) - Vascular Quality Initiative (VQI)
www.fda.gov
43
300 sequential patients from the SVS VQI Primary: Follow-up out to 36 months post-procedure
Peripheral Vascular Intervention (PVI) Registry Target lesion revascularization (TLR) within 12 months
treated with the IN.PACT Admiral DCB per the
standard of care Secondary:
All-cause mortality (12 and 24 months)
TLR (24 months)
Target vessel revascularization (TVR) (12 and 24 months)
Major limb amputation (12 and 24 months)
Narrative
FDA required surveillance of the IN.PACT Admiral DCB to assess its long-term safety and performance in a U.S. population. The premarket study used OUS patients treated with
the device and US control patients from the SVS VQI Registry. Sequential patients (n=300), treated with the IN.PACT Admiral DCB per the standard of care, from this registry will
be followed 36 months post-procedure in this surveillance. The primary endpoint is target lesion revascularization within 12 months.
www.fda.gov
44
Example 15. PMA - Postmarket Surveillance of a Superficial Femoral Artery Stent Utilizing a
National Registry for Condition-of-Approval [36, 37]
P070014/S037 Bard Peripheral Bard LifeStent The Bard LifeStent Vascular Stent System is intended to improve luminal diameter in the Vascular Quality Postmarket: CoA to
Supplement to Vascular, Inc. Vascular Stent treatment of symptomatic de novo or restenotic lesions up to 240 mm in length in the native Initiative PVI use PVI Registry for
expand System superficial femoral artery (SFA) and popliteal artery with reference vessel diameters ranging from Registry postmarket
indication 4.0 – 6.5 mm. surveillance.
Postmarket Use – Society for Vascular Surgery (SVS) Vascular Quality Initiative Registry
All patients in VQI Registry with symptomatic de Primary Safety: Freedom from Major Adverse Events (device and/or procedure-related death Follow-up for 2 years
novo or restenotic lesions in the popliteal artery or target limb major amputation) through 12-month.
(P2/P3) that receive treatment with the Bard Life Primary Effectiveness: Freedom from target lesion revascularization and/or target vessel
Stent; minimum of 74 patients. revascularization through 12- months.
Narrative:
BARD was required per the approval order to conduct surveillance and evaluate the clinical use of the LifeStent Vascular Stent System in the popliteal artery (mid and distal
segments) using the Society for Vascular Surgery (SVS) Vascular Quality Initiative (VQI) Peripheral Vascular Intervention (PVI) Registry. For surveillance, sequential patients
(minimum of n=74) treated with the LifeStent in the mid and distal popliteal will be followed prospectively for 2 years. The primary endpoints are freedom from major adverse
events and TLR/TVR through 12 months.
www.fda.gov
45
Example 16. PMA - Postmarket Surveillance of an Endovascular Graft for Aortic Aneurysms
Utilizing a National Registry for Condition-of-Approval [38, 39]
P040043/S051 W.L. Gore & GORE TAG The GORE TAG Thoracic Endoprosthesis is intended for endovascular repair SVS VQI Postmarket: CoA to conduct
Supplement Associates, Inc. Thoracic of all lesions of the descending thoracic aorta, including: Registry postmarket surveillance in VQI
to expand (Gore) Endoprosthesis • Isolated lesions in patients who have appropriate anatomy, including: Registry
indication - Adequate iliac / femoral access
- Aortic inner diameter in the range of 16-42 mm
- ≥ 20 mm non-aneurysmal aorta proximal and distal to the lesion
• Type B dissections in patients who have appropriate anatomy, including:
- Adequate iliac / femoral access
- ≥ 20 mm landing zone proximal to the primary entry tear; proximal extent of the
landing zone must not be dissected
- Diameter at proximal extent of proximal landing zone in the range of 16-42 mm
Postmarket Use – Society for Vascular Surgery (SVS) Vascular Quality Initiative (VQI) Registry
One (1)-year: All-comers (until 200 patients surveilled) treated with the device to Primary Safety 5-year population: 30
repair Type B dissections in the descending thoracic aorta into the VQI registry 1year arm: Freedom from dissection related mortality through 1 year days, 1 year and then
during the specified enrollment period. 5year arm: Freedom from dissection related mortality at 5 years annually (5 years of
surveillance)
Five (5)-year: Chronic (minimum of 194) and acute (minimum of 200) patients Primary Effectiveness
with Device Technical Success, and treated to repair Type B dissections in the 1 year arm: Device technical success at the time of the procedure (successful 1 year population: 30
descending thoracic aorta at centers agreeing to participate in the Surveillance delivery, successful and accurate deployment, and successful withdrawal of days and 1 year
Project through the VQI registry. the delivery system)
At least 60 patients treated with the final device design of a participating 5-year arm: Device technical success at the time of the procedure (successful
manufacturer will be enrolled in each surveillance arm (i.e., acute and chronic). delivery, successful and accurate deployment, and successful withdrawal of
the delivery system)
If the total sample size of 200 or 194 patients has been reached for one arm (acute
or chronic, respectively) of the 5-year surveillance arm, but an individual device Device procedural success at 30 days (device technical success with absence of
has not met the 60 patients minimum required for that arm, enrollment will only the following at 30 days: major adverse events [MAE] subset, primary intimal
continue for that specific device. tear false lumen perfusion, retrograde extension of the dissection, and
unintentional dissection septum rupture).
www.fda.gov
46
Narrative:
This surveillance project will use the Society for Vascular Surgery (SVS) Vascular Quality Initiative (VQI) Registry to collect surveillance data on the short-term and long-term
performance of the GORE TAG Thoracic Endoprosthesis for the treatment of Type B thoracic aortic dissection. Data will also be used to identify signals and establish
performance goals.
www.fda.gov
47
Example 17. PMA - Postmarket Surveillance of an Endovascular Graft for Aortic Aneurysms
Utilizing a National Registry for Condition-of-Approval [40, 41]
P100040/S012 Medtronic Valiant Thoracic The Valiant Thoracic Stent Graft with the Captivia Delivery System is intended for the SVS VQI Registry Postmarket: CoA to
Supplement to Vascular Stent Graft with endovascular repair of all lesions of the descending thoracic aorta (DTA) in patients having conduct postmarket
expand Captivia Delivery appropriate anatomy including: surveillance in VQI
indication System • iliac/femoral access vessel morphology that is compatible with vascular access Registry
techniques, devices, and/or accessories;
• non-aneurysmal aortic diameter in the range of 18–42 mm (fusiform and saccular
aneurysms/penetrating ulcers), 18 mm to 44 mm (blunt traumatic aortic injuries) or 20
mm to 44 mm (dissections) and
• non-aneurysmal aortic proximal and distal neck lengths ≥ 20 mm (fusiform and saccular
aneurysms/penetrating ulcers), landing zone ≥20 mm proximal to the primary entry
tear (BTAI, dissection). The proximal extent of the landing zone must not be dissected.
Postmarket Use – Society for Vascular Surgery (SVS) Vascular Quality Initiative (VQI) Registry
Population Key Elements or Endpoints from RWE source Follow-
up/Duration
One (1)-year: All-comers (until 200 patients surveilled) treated with the device to repair Primary Safety 5-year
Type B dissections in the descending thoracic aorta into the VQI registry during the 1-year arm: Freedom from dissection related mortality through 1 year population: 30
specified enrollment period. 5-year arm: Freedom from dissection related mortality at 5 years days, 1 year and
then annually (5
Five (5)-year: Chronic (minimum of 194) and acute (minimum of 200) patients with Device Primary Effectiveness years of
Technical Success, and treated to repair Type B dissections in the descending thoracic aorta 1-year arm: Device technical success at the time of the procedure (successful surveillance)
at centers agreeing to participate in the Surveillance Project through the VQI registry. delivery, successful and accurate deployment, and successful withdrawal of the
delivery system). 1-year
At least 60 patients treated with the final device design of a participating manufacturer will population: 30
be enrolled in each surveillance arm (i.e., acute and chronic). 5-year arm: Device technical success at the time of the procedure (successful days and 1 year
delivery, successful and accurate deployment, and successful withdrawal of the
If the total sample size of 200 or 194 patients has been reached for one arm (acute or delivery system).
chronic, respectively) of the 5-year surveillance arm, but an individual device has not met
the 60 patient minimum required for that arm, enrollment will only continue for that Device procedural success at 30 days (device technical success with absence of
specific device. the following at 30 days: major adverse events [MAE] subset, primary intimal
tear false lumen perfusion, retrograde extension of the dissection, and
unintentional dissection septum rupture).
www.fda.gov
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Narrative:
This surveillance project will use the Society for Vascular Surgery Vascular (SVS) Quality Initiative (VQI) Registry to collect surveillance data on the short-term and long-term
performance of the Valiant Thoracic Stent Graft with Captiva Delivery System for the treatment of Type B thoracic aortic dissection. Data will also be used to identify signals and
establish performance goals.
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Example 18. PMA - Post-Approval Studies for an Implantable Cardioverter Defibrillator Utilizing a
National Registry, the National Death Index, and a Sponsor Registry [42, 43, 44]
P010031/S232 Medtronic, Inc. CONCERTO/CONCERTO II; Please refer to approval order for full indications ACC National Cardiovascular Data Registry Postmarket: Post-
Cardiac Rhythm CONSULTA; MAXIMO II; for use. ICD Registry approval study using
Disease AND PROTECTA/PROTECTA multiple RWE data
Management XT National Death Index sources
Sponsor Registry
Postmarket Use – American College of Cardiology NCDR ICD Registry, National Death Index, Sponsor
Registry Used to Satisfy Post-Approval Requirements
PAS001, REVERSE NCDR ICD Registry Study: Patients Primary Endpoints (PAS001): Use of multiple real-world
identified in the registry that meet the indication. Mortality for patients identified in the ACC NCDR Registry, using the National Death Index evidence data sources
Enrollment target is 1500 patients overall and 500 including the ACC NCDR ICD
patients with QRS < 150ms. Primary Endpoints (PAS002): Registry, a sponsor registry,
Survival probability of freedom from centrally adjudicated heart failure hospitalization or all- and the National Death Index.
PAS002, Sponsor Registry (Product Surveillance cause death.
Registry): Patients treated with the subject device per the Survival probability of freedom from centrally adjudicated heart failure event or all cause death.
indication and who have a QRS duration < 150ms.
Enrollment target is 500 patients.
Narrative:
As a condition-of-approval for this PMA supplement, the sponsor agreed to perform two post-approval studies in order to collect long-term data for patients with a prolonged
QRS and who were treated with the subject device. For the first post-approval study, patients implanted with device meeting the indication were identified in the American
College of Cardiology NCDR ICD Registry. Long-term mortality will be collected using the National Death Index. For the second post-approval study, additional clinical data on
survival probability of freedom from adjudicated heart failure events or all-cause death will be collected from patients participating in a sponsor registry.
Subsection B. Examples of Registries as a Source of Real-World Evidence

Guide to Examples Leveraging Sponsor Registries for Real-World Data Collection
www.fda.gov
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File Sponsor Device Real-World Data (RWD) RWE Use Key Tags
Source(s)
K163244 CSA Medical, truFreeze System Sponsor Registry Premarket: For this 510(k) submission to expand Registry data;
19 Inc. the indication of a cryosurgical device, the sole RWE as a primary source
source of clinical evidence was the sponsor’s all- of clinical evidence;
comers postmarket registry.
K171626 CSA Medical, truFreeze System Sponsor Registry Premarket: Data from the sponsor’s all-comers Registry data;
20 Inc. postmarket registry served as the primary source RWE as a primary source
of clinical evidence supporting an indication of clinical evidence;
expansion of a cryosurgical tool.
K171257 MRI ClearPoint System Registry Premarket: Clinical information from a registry Registry data;
21 Interventions, data was combined with published literature to RWE as a primary source
Inc. support this submission modifying of the of clinical evidence;
indications for use statement to include positioning
of deep brain stimulator (DBS) leads.
K190779 Stryker Trevo XP ProVue Trevo Retriever Registry Premarket: Data from the sponsor’s registry served Outside-the-US;
22 Neurovascular Retriever as the primary source of clinical evidence for Registry data;
modifying the labeling and instructions for use in RWE as a primary source
this 510(k). of clinical evidence;
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H190005 Zimmer The Tether - Retrospective review of Premarket: Pediatric patients treated with the Medical records (EHR,
23 Biomet Vertebral Body medical records used to device under real-world conditions were EMR or chart review);
Spine, Inc. Tethering System enroll patients into a retrospectively identified for enrollment into a Pediatric RWE;
follow-up clinical study prospective long-term follow-up clinical study
Total-Product Lifecycle
from one (1) US site under an IDE.
Example;
under an IDE;
Postmarket: The sponsor has agreed to perform a
Postmarket registry post-approval study (PAS) that will use registry-
based data collection (PAS protocol pending as of
1/02/20).
DEN160062 IlluminOss IlluminOss EU Registry for the Premarket: Data from a postmarket EU registry Medical records (EHR,
24 Medical, Inc. Photodynamic Bone IlluminOss Bone study was used as a secondary source of clinical EMR or chart review);
Stabilization System Stabilization System evidence to support the granting of this de novo, Outside-the-US;
with medical record data collected from patients Registry data;
and uploaded to the sponsor’s own database.
P120017 Medtronic, Model 5071 Lead Sponsor Registry, Premarket: This PMA original was approved Device-generated data;
25 Inc. Remote-monitoring following a classification order, and the primary Registry data;
source of clinical evidence were data from the RWE as a primary source
sponsor’s postmarket surveillance registry and of clinical evidence;
remote monitoring data from the sponsor’s
CareLink system.
P140003 ABIOMED, Impella 2.5 System Sponsor Registry Premarket: In this PMA original, clinical evidence Registry data;
26 Inc. from the sponsor’s USPELLA registry that captures
routine care data for all device models,
specifically in-hospital mortality rates, were used
to supplement the submission and provide a
comparison for the clinical trial data.
P150033 Medtronic, Micra Transcatheter Sponsor Registry Postmarket: For this PMA original, nine years of Registry data;
27 Inc. Pacing System postmarket surveillance data will be collected in
the sponsor’s registry as a condition-of-approval.
www.fda.gov
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P160036 DT MedTech, Hintermann Series Outside-the-US registry Premarket: RWE was a primary source of clinical Outside-the-US;
28 LLC H3 Total Ankle evidence for this original PMA, which relied on Performance goal or
Replacement System Formal meta-analysis of comparison of data abstracted from an OUS comparator derived from
literature and registry registry to a performance goal derived from a RWE;
data meta-analysis of published literature and registry
Registry data;
data for a control device legally marketed in the
United States. RWE as a primary source
Postmarket: The sponsor has agreed to conduct a Total-Product Lifecycle
post-approval study (PAS) that will follow patients Example;
included in the premarket cohort (i.e. patients
from the OUS registry) to a performance goal.
Similar to the PMA study, the sponsor was
requested to derive the performance goal using a
meta-analysis of published literature and registry
data for a control device legally marketed in the
United States
P160043 Medtronic, Resolute Onyx Sponsor Registry Premarket: Supplemental clinical evidence in Outside-the-US;
29 Inc. Zotarolimus-Eluting support of this PMA original was drawn from the Registry data;
Coronary Stent sponsor’s international, all-comers, observational
System registry.
P170011 ABIOMED, Impella RP Sponsor Registry Postmarket: As a condition-of-approval for this Registry data;
30 Inc. PMA converting from an HDE, the sponsor will
conduct postmarket surveillance through their
registry.
P140003/S004 ABIOMED, Impella 2.5, 5.0, CP, Sponsor Registries Premarket: In this indication expansion, sponsor Registry data;
31 Inc. LD registry data was leveraged as a supplemental Total-Product Lifecycle
source of clinical evidence and was utilized for Example;
analysis of survival-to-discharge and freedom-
from-death rates, as well as other endpoints,
providing supportive evidence of the effectiveness
and benefit-to-risk ratio of the device.
Postmarket: As a condition-of-approval,
postmarket surveillance will be conducted
through the sponsor’s registry.
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P140003/S005 ABIOMED, Impella 2.5, 5.0, CP, Sponsor Registries Premarket: For this PMA supplement, sponsor Registry data;
32 Inc. LD registry data served as a supplemental source of Total-Product Lifecycle
clinical evidence on freedom-from-death and Example;
adverse event rates, as well as benchmark
analyses between the subject device and a
comparator.
Postmarket: Postmarket surveillance will be

conducted through the sponsor’s registry as a
condition-of-approval.
P130024/S009 Lutonix, Inc Lutonix 035 Drug Sponsor Registry Premarket: In this PMA supplement for an Outside-the-US;
33 Coated Balloon PTA indication expansion, RWE from the sponsor’s Registry data;
Catheter international registry served as the primary RWE as a primary source
source of clinical evidence supporting approval. of clinical evidence;
Postmarket: As a condition-of-approval, the Total-Product Lifecycle
sponsor will conduct postmarket surveillance Example;
through 24 months post-procedure using their
OUS registry.
P100021/S063 Medtronic Endurant II/Endurant ANCHOR Registry Premarket: Data from the sponsor’s registry Registry data;
34 Vascular IIs Stent Graft served as the primary source of clinical evidence RWE as a primary source
System supporting approval of this indication expansion. of clinical evidence;
Postmarket: Postmarket surveillance will be
Example;
conducted through the sponsor’s registry for 5
years as a condition-of-approval.
P100047/S090 Medtronic, HeartWare HVAD Sponsor Registry Postmarket: As a condition-of-approval, the Registry data;
35 Inc. system sponsor will conduct postmarket surveillance of
300 subjects for five years post-implant through
the sponsor’s registry.
www.fda.gov
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P960043/S097 Abbott Perclose ProGlide EVEREST II/REALISM Premarket: Data from the sponsor’s continued Medical records (EHR,
36 Vascular Inc. Suture-Mediated Continued Access Registry access registry were extracted to serve as the sole EMR or chart review);
Closure System (US and OUS) source of clinical evidence supporting an Outside-the-US;
indication expansion of their suture delivery Registry data;
system to include closing femoral artery access
sites with sheaths up to 24F. A patient cohort
from the continued access registry was selected,
and their medical records were retrospectively
analyzed.
P160043/S012, Medtronic Resolute Onyx Global RESOLUTE Clinical Premarket: Data extracted from the sponsor’s Medical records;
37 P110013/S088 Vascular Zotarolimus-Eluting Trial Program: RESOLUTE registry data were pooled to form a cohort of Outside-the-US;
Coronary Stent International Registry and patients treated with the subject device that was
Registry data;
System, Resolute RESOLUTE China Registry analyzed to support expansion of the indication of
Integrity (US and OUS) this family of coronary stents to include treatment Total-Product Lifecycle
Zotarolimus-Eluting of coronary chronic total occlusions. Example;
Coronary Stent
System Postmarket: As a condition-of-approval, the
sponsor will follow patients treated with the
subject device for chronic total occlusions
enrolled in a PAS and OUS clinical trial for two
years, with the primary endpoint being freedom
from MACE.
www.fda.gov
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Example 19. 510(k) - Clearance of a Cryosurgical Tool Using Sponsor Registry Data [45]
K163244 CSA Medical, truFreeze The truFreeze System is indicated for use as a cryosurgical tool in the Sponsor Registry Premarket: Sole-source
Inc. System fields of dermatology, gynecology, and general surgery, to ablate benign
(e.g. Barrett’s Esophagus with high grade dysplasia) and malignant lesions.
Premarket Use – Sponsor Registry

Population Key Elements or Endpoints from RWE Sources
Postmarket Registry: All-comers population of patients with Safety:
Barrett’s Esophagus (BE) treated using the truFreeze device. Stricture; Abdominal Pain; Pancreatitis; Chest Pain; GI Hemorrhage; Mucosal Lacerations event rates
(111 patients included in the safety population analysis; 46
patients included in the efficacy population analysis). Effectiveness:
Number of responders and percentage with complete eradication of dysplasia
Response rate by BE segment length
Procedural information to achieve best response (e.g. number of sessions to best response)
Narrative:
To support adding “Barrett’s Esophagus with high grade dysplasia” to the indications for use, the sponsor provided clinical evidence from an all-comers, postmarket registry,
which collected data on patients --- including those with high-grade dysplasia --- treated using the FDA-cleared device. This study was the primary source of clinical evidence for
the premarket clearance decision.
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Example 20. 510(k) - Clearance of a Cryosurgical Tool Using Sponsor Registry Data [47]
K171626 CSA Medical, truFreeze The truFreeze System is indicated for use as a cryosurgical tool in the Sponsor Registry Premarket: Primary
Inc. System fields of dermatology, gynecology, and general surgery, to ablate benign
(e.g. Barrett’s Esophagus with high grade dysplasia and/or low grade
dysplasia) and malignant lesions.

Postmarket Registry: All-comers population of patients with Safety Events:
Barrett’s Esophagus (BE) treated using the truFreeze device. (111 Stricture; Abdominal Pain; Pancreatitis; Chest Pain; GI Hemorrhage; Mucosal Lacerations event rates
patients included in the safety population analysis; 22 patients
included in the efficacy population analysis). Effectiveness:
Number of responders and percentage with complete eradication of dysplasia
Response rate by BE segment length
Procedural information to achieve best response (e.g. number of sessions to best response)
Narrative:
The truFreeze device was previously cleared using clinical data to support adding “Barrett’s Esophagus with high grade dysplasia” to the indications for use. To support adding
“low-grade dysplasia” to the indications for use, the sponsor provided clinical evidence from all-comers, postmarket registry, which collected data on patients---including those
with low-grade dysplasia---treated using the FDA-cleared device. This study, along with peer-reviewed literature, was the primary source of clinical evidence for the premarket
clearance decision.
www.fda.gov
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Example 21. 510(k) - Modification to Indications for Use Statement for a Neurological Stereotaxic
Instrument Supported by RWE from a Registry [48]
K171257 MRI ClearPoint System The ClearPoint System is intended to provide stereotactic guidance for the placement Registry Premarket: Registry
Interventio and operation of instruments or devices during planning and operation of neurological data (RWE), submitted
ns, Inc. procedures within the MRI environment and in conjunction with MR imaging. The with literature, were
ClearPoint System is intended as an integral part of procedures that have traditionally the primary sources of
used stereotactic methodology. These procedures include biopsies, catheter and clinical information.
electrode insertion, including deep brain stimulation (DBS) lead placement. The System
is intended for use only with 1.5 and 3.0 Tesla MRI scanners and MR Conditional
implants and devices. The user should consult the "Navigational Accuracy" section of
the User’s Guide to assess if the accuracy of the system is suitable for their needs.
Premarket Use – Registry Data

Registry (RWE): Patients treated with the device in Safety and Effectiveness:
standard practice (35 institutions) Placement accuracy
Procedure type
Narrative:
The 510(k) was submitted to modify the indications for use statement of the system to include positioning of deep brain stimulator (DBS) leads. Clinical evidence for this 510(k)
included both literature and data from a registry (35 participating institutions, 828 DBS lead placement procedures), which collected data on the device as used in standard
practice. The collected data included placement accuracy data for DBS procedures. The 510(k) submission was found to be substantially-equivalent.
www.fda.gov
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Example 22. 510(k) - Modification to the Instructions for Use for a Neurovascular Mechanical
Thrombectomy Device for Acute Ischemic Stroke Treatment Using Registry Data [49, 50]
File Sponsor Device Approved / Cleared / Granted Indication RWE Source Use of RWE
K190779 Stryker Trevo XP 1. The Trevo Retriever is indicated for use to restore blood flow in the neurovasculature by Sponsor registry Premarket: Primary
Neurovascula ProVue removing thrombus for the treatment of acute ischemic stroke to reduce disability in source of clinical
r Retriever patients with a persistent, proximal anterior circulation, large vessel occlusion, and smaller evidence
core infarcts who have first received intravenous tissue plasminogen activator (IV t-PA).
Endovascular therapy with the device should start within 6 hours of symptom onset.
2. The Trevo Retriever is intended to restore blood flow in the neurovasculature by

removing thrombus in patients experiencing ischemic stroke within 8 hours of symptom
onset. Patients who are ineligible for intravenous tissue plasminogen activator (IV t-PA) or
who fail IV t-PA therapy are candidates for treatment.
3. The Trevo Retriever is indicated for use to restore blood flow in the neurovasculature by
removing thrombus for the treatment of acute ischemic stroke to reduce disability in
patients with a persistent, proximal anterior circulation, large vessel occlusion of the
internal carotid artery (ICA) or middle cerebral artery (MCA)-M1 segments with smaller
core infarcts (0-50 cc for age < 80 years, 0-20 cc for age ≥ 80 years). Endovascular therapy
with the device should start within 6-24 hours of time last seen well in patients who are
ineligible for intravenous tissue plasminogen activator (IV t-PA) or who fail IV t-PA therapy.
Premarket Use – Real-world Evidence from Trevo Retriever Registry

Trevo Retriever Registry: 2010 ischemic stroke Primary:
patients worldwide treated with subject device Revascularization status assessment at the end of the Trevo Retriever procedure using the modified Thrombolysis in Cerebral Infarctions
as initial device in mechanical neuro- (TICI) score
thrombectomy
Secondary:
Modified Rankin Score at 90 days
Other:
Device and procedure related serious adverse events at 90 days
All-cause mortality at 90 days
Neurological deterioration at 24 hours post procedure, defined as a four or more point increase in the NIH Stroke Scale from the baseline
score
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For additional details and complete list, please see ClinicalTrials.gov Page.
Narrative:
This submission sought clearance for modifications to the labeling and instructions for use for using the subject device with an aspiration catheter (AXS Catalyst Distal Access
Catheter) and aspiration pump (AXS Universal Aspiration System) as an alternative use. Clinical evidence supporting this 510(k) included real-world evidence of the subject
device used in combination with catheter aspiration from the Trevo Retriever Registry along with a literature review.
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Example 23. HDE - Approval for Vertebral Body Tethering System Using RWE from a Retrospective
Review of Medical Records and to Satisfy Post-Approval Requirements [51, 52, 53, 54, 55]
H190005 Zimmer The Tether – Vertebral The Tether - Vertebral Body Tethering System is indicated for skeletally Premarket: Patient medical Premarket: Patient
Biomet Body Tethering System immature patients that require surgical treatment to obtain and records. identification for enrollment
Spine, Inc. maintain correction of progressive idiopathic scoliosis, with a major Cobb in support of a trial using a
angle of 30 to 65 degrees whose osseous structure is dimensionally Postmarket: Harms Study retrospective chart review
adequate to accommodate screw fixation, as determined by radiographic Group registry of medical records
imaging. Patients should have failed bracing and/or be intolerant to
brace wear. Postmarket: Post-approval
study
Premarket Use – Retrospective Review of Medical Records

Population Key Elements or Endpoint Methods of Note
Prospective study of patients identified from retrospective Safety: Patients treated with the device under real-world
review of medical records: 57 pediatric patients with adolescent Analysis of adverse events with adjudication by an independent conditions were retrospectively identified for
idiopathic scoliosis that have been implanted with the subject Adverse Event Adjudication Committee. enrollment into a prospective long-term follow-up
device, identified through a retrospective review of patient clinical study.
medical records and enrolled in a long-term follow-up study Probable Benefit:
under an investigational device exemption and followed Measurement of coronal curve correction on post-operative
prospectively to collect additional data radiographs.
Narrative:
Approval of this HDE for a first-of-a-kind spinal tethering device for pediatric idiopathic scoliosis was supported by clinical data collected from patients after having been
implanted with a device cleared for use in adults. Patients were retrospectively identified and consented to participate in a long-term study under an investigational device
exemption to collect data on clinical outcomes. This is an example of using real-world evidence to identify and enroll patients treated with the device in routine practice in a
follow-up clinical trial with prospective data collection.
Postmarket Use – Post-Approval Study Using a Registry
www.fda.gov
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Skeletally immature patients Primary Safety: 5 years (60 months).

with idiopathic scoliosis. Serious adverse events (SAEs), and device- or procedure-related AEs.
Primary probable benefit endpoint:

Maintenance of major Cobb angle less than or equal to 40 degrees at 60-months post-surgery.
See H190005 Approval Order for additional secondary endpoints.
Narrative:
The sponsor has agreed to conduct a post-approval study to collect additional long-term data on the performance of The Tether System in treatment of skeletally immature
patients with idiopathic scoliosis. For this post-approval study, the sponsor has stated that it will partner with the Harms Study Group to create a patient registry to support the
post-approval study. The full post-approval study protocol is pending as of 1/2/20.
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Example 24. De Novo - Classification of an In Vivo Cured Intramedullary Fixation Rod Using the
Medical Records from Sponsor’s OUS Registry [57]
DEN160062 IlluminOss IlluminOss The IlluminOss Photodynamic Bone Stabilization System (PBSS) is indicated for EU Registry for the Premarket: Secondary
Medical, Inc. Photodynamic skeletally mature patients in the treatment of impending and actual pathological fractures IlluminOss Bone source of clinical
Bone of the humerus, radius, and ulna, from metastatic bone disease. Stabilization evidence
Stabilization System
System
Premarket Use – EU Registry for the IlluminOss Bone Stabilization System

EU Registry for the IlluminOss Bone Stabilization System: 132 patients at three Safety and Effectiveness:
centers in Germany and four centers in the Netherlands treated with subject device Local or systemic device-related complications, radiographs
for acute fractures or revision surgeries
Narrative:
For this de novo request, part of the clinical evidence submitted was an EU registry study, conducted after the device had received CE Mark approval in Europe. The EU Registry
for the IlluminOss Bone Stabilization System was initiated in September 2010, with the aim of collecting technical and clinical outcomes on treated patients. Subjects were
followed either until they were discharged from clinical care, or were followed for up to two years post-index surgery and medical record data was collected from patients and
uploaded to the sponsor's own web-based database. The database was prospectively queried for the incidence of adverse device effects. These real-world evidence were used
as a secondary source of clinical evidence to support the granting of this de novo classification request.
www.fda.gov
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Example 25. PMA - Approval of a Permanent Pacemaker Electrode Following a Classification
Order Leveraging RWE from a Sponsor Registry and Device-Generated Data from Remote
Monitoring [58]
P120017 Medtronic, Inc. Model 5071 Lead The Medtronic Model 5071 Lead is indicated for unipolar ventricular pacing and sensing. The lead Sponsor registry Premarket: Primary
has application where permanent ventricular or dual-chamber pacing systems are indicated. Two
leads may be used for bipolar pacing Device-generated
data (remote
monitoring)
Premarket Use– Sponsor Registry, Remote-Monitoring of Device-Generated Data

Population Key Elements or Endpoints from RWE Sources Follow-up/Duration (RWE)
SLS Registry (RWE): Patients implanted with the Model Primary Endpoint: Follow-up per standard care practices of
5071 lead and enrolled into the registry. 290 Model 5071 Model 5071 lead related complications (Complication-free survival rate). their care provider.
leads in 212 subjects enrolled. (First implant 2/17/94 –
1/31/2013 cut-off). Effectiveness:
Summary statistics for weekly minimum and maximum pacing capture thresholds
CareLink Remote Monitoring System (RWE): De-identified (PCT) vs time for de-identified patients followed using the sponsor’s remote
subjects implanted with Model 5071 lead and registered in monitoring system (CareLink)
CareLink system
Supplemental Data: Chronic complication rates, chronic lead survival probability,
and acute lead observations between Model 5071 vs Model 4965 and Model 4968
data from sponsor’s Product Surveillance Registry (incorporates SLS)
Narrative:
Approval of a PMA original following a classification order. The Model 5071 lead was originally cleared on September 26, 1990 (K902002) to be legally marketed in the United
States. This application was submitted to comply with FDA-2011-N-00505 (Final rule issued July 6, 2012), which requires premarket approval for all pre-amendment Class III
leads with a DTB product code.
Analysis of clinical data collected in a postmarket sponsor surveillance registry (SLS), remote monitoring data from the Medtronic CareLink System, comparative data from two
previous models (4965 and 4968) collected in a sponsor postmarket surveillance registry, and data from the sponsor’s complaint handling system were submitted in support of
the application. The analyses were described under the Summary of Primary Clinical Study and Supplementary Clinical Data sections in the SSED and were used in the evaluation
of safety and effectiveness.
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Example 26. PMA - Approval of a Ventricular Support Device Using Supplemental Sponsor
Registry Data [59]
P140003 ABIOMED, Impella 2.5 The Impella 2.5 System is a temporary (≤ 6 hours) ventricular support device indicated for use USpella Registry Premarket:
Inc. System during high risk percutaneous coronary interventions (PCI) performed in elective or urgent, (Sponsor) Supplemental source
hemodynamically stable patients with severe coronary artery disease and depressed left ventricular of clinical evidence
ejection fraction, when a heart team, including a cardiac surgeon, has determined high risk PCI is
the appropriate therapeutic option. Use of the Impella 2.5 System in these patients may prevent
hemodynamic instability which can result from repeat episodes of reversible myocardial ischemia
that occur during planned temporary coronary occlusions and may reduce peri- and post-
procedural adverse events

Population Key Elements or Endpoints from RWE Follow-up/Duration Methods of Note
Source
PROTECT I trial (Non-RWE): 20 Impella 2.5 patients; 7 sites Supplemental: In-hospital mortality rate PROTECT II: Discharge or 30-days, Analyses included analysis of all USPELLA
90 days patients undergoing high-risk PCI and
PROTECT II Trial (Non-RWE): 216 Impella 2.5 arm patients USPELLA patients who meet the criteria
(per-protocol) and 211 IABP arm patients (per-protocol); USPELLA: Discharge for PROTECT II.
112 sites
USPELLA (RWE): 637 Impella 2.5 patients; 49 sites
Narrative:
For this PMA submission, the primary study (PROTECT II) was a randomized clinical trial with two arms (intra-aortic balloon pump arm vs Impella arm). FDA also looked at
supplemental information from the sponsor’s USPELLA registry (captures routine care data for all Impella device models, post 510k clearance). FDA specifically looked at the
Impella 2.5 in-hospital mortality rate for all high-risk PCI patients captured in USPELLA (n=637) as well as the Impella 2.5 in-hospital mortality rate after applying the PROTECT II
criteria to that USPELLA dataset (n=339).
USPELLA in-hospital mortality rates were then compared to data from the pivotal trial (n=211 IABP arm, n=216 Impella arm) to serve as a potential real-world estimate of in-
hospital mortality.
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Example 27. PMA - Postmarket Surveillance of a Leadless Pacemaker Using a Sponsor Registry [60,
61, 62, 63]
P150033 Medtronic, Micra The Micra Transcatheter Pacing System is indicated for use in patients who have experienced one Sponsor registry Postmarket: CoA to use sponsor
Inc. Transcatheter or more of the following conditions: registry to collect postmarket
Pacing System • symptomatic paroxysmal or permanent high-grade AV block in the presence of Atrial Fibrillation data.
(AF)
• symptomatic paroxysmal or permanent high-grade AV block in the absence of AF, as an
alternative to dual chamber pacing, when atrial lead placement is considered difficult, high risk,
or not deemed necessary for effective therapy
• symptomatic bradycardia-tachycardia syndrome or sinus node dysfunction (sinus bradycardia or
sinus pauses), as an alternative to atrial or dual chamber pacing, when atrial lead placement is
considered difficult, high risk, or not deemed necessary for effective therapy.
Rate-responsive pacing is indicated to provide increased heart rate appropriate to increasing

levels of activity.
Postmarket Use – Sponsor Registry

Population Key Elements or Endpoints from RWE Sources Follow-up/Duration
(RWE)
Micra PAS: Patients implanted with a Primary: Nine-years of follow-up.
Micra Transcatheter Pacing System. 1) Acute-complication rate (≤ 30 days) related to MICRA system or implant procedure
2) Long-term complication-free survival rate
Narrative:
As a condition-of-approval, the sponsor has agreed to conduct a post-approval study using a sponsor registry.
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Example 28. PMA - Approval for a Total Ankle Replacement System using Outside-the-US RWE as
a Primary Source of Clinical Evidence and RWE for a Post-Approval Study [64, 65]
P160036 DT MedTech, Hintermann Series H3 The Hintermann Series H3 Total Ankle Outside-the-US Registry Premarket: Primary
LLC Total Ankle Replacement Replacement System is indicated for use as a non- source of clinical
System cemented implant to replace a painful arthritic Performance goal derived from a meta-analysis that evidence
ankle joint due to primary osteoarthritis, post- included published literature and registry data
traumatic osteoarthritis or arthritis secondary to Postmarket: Post-
inflammatory disease. approval study
The device system is for prescription use.
Premarket Use –Outside-the-US Registry

H3 Registry: Retrospective analysis of Primary Endpoints (Co-primary)
patients treated with the subject device • American Orthopaedic Foot and Ankle Society (AOFAS) Hindfoot Score at 2 years or later.
who met the inclusion criteria for • Survivorship (absence of revision/removal) within 5 years
enrollment in the retrospective analysis. • Occurrence of a Serious Device-Related Adverse Event (SADE), as determined by the independent Clinical Events Committee) other than a
The H3 Registry is a single-site registry removal/revision within 2 years
in Switzerland. The H3 system has been
commercially available in Europe since Safety:
2003. • Serious device related adverse event rates compared against a performance goal derived from literature and registry data
Narrative:
For this PMA application, the sponsor performed a retrospective analysis that compared data abstracted from an outside-the-US registry (H3 Registry) against a performance
goal. The performance goal was derived from literature and registry data for a control device legally-marketed in the United States. The subject device has been commercially
available in Europe since 2003. The sponsor also performed a safety analysis comparing adverse event data from the registry against adverse event data extracted from
published literature and national joint registries. These analyses served as the primary basis supporting approval of the PMA.
Postmarket Use – Post-approval study

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Key Elements or Endpoints from RWE source Follow-up/Duration
Primary Safety: Significant adverse events, device or procedure-related adverse events. 10 years
Primary Probable Benefit: Maintenance of major Cobb angle less than or equal to 40 degrees at 60 months post-surgery
Narrative:
As a condition-of-approval, the sponsor has agreed to conduct a post-approval study (PAS) that will follow patients included in the premarket cohort (i.e. patients from the OUS
registry). The results will be compared against a performance goal. Similar to the PMA study, the sponsor was requested to derive the performance goal using a meta-analysis of
published literature and registry data for a control device legally marketed in the United States.
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Example 29. PMA - Approval of a Coronary Drug-Eluting Stent Leveraging Supplemental OUS
Sponsor Registry Data [67, 68, 69, 70]
P160043 Medtronic, Resolute Onyx The Resolute Onyx Zotarolimus-Eluting Coronary Stent System is indicated for improving RESOLUTE Premarket:
Inc. Zotarolimus-Eluting coronary luminal diameters in patients, including those with diabetes mellitus, with International Supplemental
Coronary Stent System symptomatic ischemic heart disease due to de novo lesions of length ≤ 35 mm in native Registry
coronary arteries with reference vessel diameters of 2.25 mm to 5.0 mm.
Premarket Use– Sponsor Registry

Population Key Elements or Endpoints from RWE Follow-up/Duration (RWE)
Sources
RESOLUTE ONYX Core (2.25 mm – 4.0 mm) Clinical Study (Non-RWE): Single-arm, open-label trial, 75 Primary endpoint: Composite endpoint of Baseline, 30 days, 6 months, 1,
enrolled patients cardiac death or target vessel myocardial 2 and 3 years
infarction at 12 months
Supplemental Clinical Studies (Non-RWE excluding RESOLUTE INTERNATIONAL Study):
RESOLUTE INTEGRITY US PAS: Resolute Integrity post-approval study
RESOLUTE US: Prospective, non-randomized, historically controlled trial
RESOLUTE AC: Prospective, all-comers randomized trial (randomized 1:1 to XIENCE V or Resolute); 2292
patients.
RESOLUTE FIM: Single-arm trial (139 patients)
RESOLUTE Japan: Prospective, single arm trial (100 patients)
RESOLUTE Asia 38 mm Cohort: Prospective, non-randomized study (38mm Resolute stent); 109
patients
RESOLUTE INTERNATIONAL (RWE): Prospective, all-comers, real-world observational study; 2349
patients.
Narrative:
The RESOLUTE ONYX Core (2.25mm-4.0mm) Clinical Study was the primary source of clinical evidence for the approval. FDA also reviewed clinical data from prior clinical
investigations of stents in the Resolute device family, including clinical data collected in the RESOLUTE INTERNATIONAL, an all-comers, observational registry with subjects
treated per local, routine practice. These prior clinical studies provided additional information on the safety and effectiveness performance of the Resolute stent family
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Example 30. PMA - Postmarket Surveillance of a Ventricular Support Device Using Sponsor
Registry Data [71]
P170011 ABIOMED, Impella RP System The Impella RP® System is indicated for providing temporary right ventricular support for cVAD Registry Postmarket: PAS to be
Conversion from Inc. up to 14 days in patients with a body surface area ≥1.5 m2, who develop acute right heart (Sponsor) conducted using cVAD
HDE failure or decompensation following left ventricular assist device implantation, myocardial registry (former USPELLA)
infarction, heart transplant, or open-heart surgery.
Postmarket Use– Sponsor Registry

Population Key Elements or Endpoints from RWE Follow-up/Duration (RWE)
Sources
IMPELLA RP – Real-world Evidence Evaluation: 60 consecutively treated patients (age Primary (Both populations): Age ≥ 18: Post-discharge data at 30 days, 90 days
≥ 18 Survival rate at 30 days post-explant or and 1 year.
years old) treated with IMPELLA RP. Data collected through the cVAD registry. discharge (whichever is longer)
Bleeding, hemolysis, and pulmonary embolism Under 18 years of age: Post-discharge data at 30
IMPELLA RP – Pediatric Real-world Evidence Evaluation: 15 consecutively treated at 30 days or discharge (whichever is longer) days and 180 days.
pediatric patients (under 18 years of age) or all pediatric patients under 18 years of age Device malfunction, central venous pressure,
treated over a 5-year period (whichever comes first). Data collected using the cVAD cardiac index, and LVAD flow
registry.
Pediatric Population: Survival rate at 180 days
Narrative:
As a condition-of-approval, the sponsor has agreed to collect RWE on patients treated with the IMPELLA RP using the cVAD registry. Patients are treated and followed in the
cVAD registry per standard of care and institution guidelines. Post-discharge data will be collected by telephone contact and review of medical records.
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Ventricular Support Device Leveraging Sponsor Registry Data [72, 73]
P140003/S004 ABIOMED, Impella The Impella 2.5, Impella CP, Impella 5.0, and Impella LD catheters, in conjunction with the Sponsor registries Premarket:
Supplement to Inc. Ventricular Automated Impella Controller, are temporary ventricular support devices intended for short (e.g. USPELLA, Supplemental
expand indication Support term use (< 4 days for the Impella 2.5 and Impella CP, and ≤ 6 days for Impella 5.0 and LD) cVAD)
and to include Systems and indicated for the treatment of ongoing cardiogenic shock that occurs immediately (< 48 Postmarket: PAS to be
additional device (Impella 2.5, hours) following acute myocardial infarction or open heart surgery as a result of isolated left conducted using cVAD
catheters 5.0, CP, LD) ventricular failure that is not responsive to optimal medical management and conventional registry
treatment measures.* The intent of the Impella system therapy is to reduce ventricular
work and to provide the circulatory support necessary to allow heart recovery and early
assessment of residual myocardial function.
*optimal medical management and conventional measures include volume loading, use of
pressors and inotropes support with or without IABP
Premarket Use – Sponsor Registries (e.g. USPELLA Registry)

Sources
ISAR-SHOCK trial (Non-RWE): 13 intra-aortic balloon pump arm Supplemental: Freedom-from-death; duration-of- ISAR-SHOCK: Up to six Analyses included analysis of all UPSELLA
and 13 Impella 2.5 patients with acute myocardial infarction support; 30-day survival rate; survival-to- months. patients as well as a sub-analysis of
with cardiogenic shock (AMICS) discharge; Adverse events (e.g. death, stroke/CVA, patients stratified by those who may
TIA, acute renal dysfunction, acute hepatic failure, USPELLA: Discharge, 30- qualify for ISAR-SHOCK and a population
USPELLA (RWE): 324 Impella patients with AMICS (Impella 2.5, bleeding, infection, hemolysis, MSOF, respiratory day who would likely be excluded from ISAR-
Impella 5.0/LD, and Impella CP) failure/dysfunction, supraventricular arrhythmia) SHOCK.
AB5000 (RWE): 115 AB5000 patients with AMICS

Narrative:
The primary clinical study (ISAR-SHOCK) was a randomized clinical trial with two arms (intra-aortic balloon pump arm vs Impella 2.5 arm).
FDA also reviewed supplemental analyses of freedom-from-death and 30-day survival rate, survival-to-discharge rate, duration-of-support and adverse events from AMICS
patients from the sponsor’s USPELLA registry, including data from device models (e.g. Impella 5.0/LD and Impella CP) not in the pivotal ISAR-SHOCK trial. FDA also reviewed
survival-to-discharge rates (the primary effectiveness outcome of interest) between two UPSELLA cohorts: patients who may have qualified for ISAR-SHOCK and a higher-risk
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cohort that would likely not qualify. Finally, FDA also reviewed supplemental analyses of freedom-from-death and survival-to-discharge rate between matched patients
supported with the Impella device family and a temporary ventricular assist device comparator (AB5000).
These analyses provided supportive evidence on the effectiveness and benefit-to-risk of the device as well as additional clinical evidence on device catheters (e.g., Impella
5.0/LD, Impella CP) not evaluated in the pivotal trial
Postmarket Use– Sponsor Registry (cVAD Registry)

Population Key Elements or Endpoints from RWE source Follow-up/Duration
cVAD Registry (RWE): Minimum of 276 patients supported Primary: Survival rates (longer between discharge or 30 days) 30 days, 90 days, 1 year post
with Impella devices for the indication of AMICS with implant follow ups
revascularization and enrolled in the cVAD registry Secondary: Adverse event rates (longer between discharge or 30 days). Technical and
implant success rate (exit from catheterization laboratory or operation room).
Narrative:
As a condition-of-approval, the sponsor has agreed to conduct a post-approval study evaluating the safety and effectiveness of Impella devices in a real-world population using
data through the cVAD registry.
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Ventricular Support Device Leveraging Sponsor Registry Data [74, 75]
P140003/S005 ABIOMED, Inc. Impella The Impella 2.5, Impella CP, Impella 5.0, and Impella LD catheters, in conjunction with the Sponsor registries Premarket:
Supplement to Ventricular Automated Impella Controller, are temporary ventricular support devices intended for short (e.g. USPELLA, Supplemental
expand Support term use (≤ 4 days for the Impella 2.5 and Impella CP, and ≤ 6 days for Impella 5.0 and LD) cVAD))
indication and Systems and indicated for the treatment of ongoing cardiogenic shock that occurs immediately (< 48 Postmarket: PAS to be
include (Impella 2.5, hours) following acute myocardial infarction or open heart surgery as a result of isolated left conducted using cVAD
additional 5.0, CP, LD) ventricular failure that is not responsive to optimal medical management and conventional registry
device
treatment measures.* The intent of the Impella system therapy is to reduce ventricular work
catheters
and to provide the circulatory support necessary to allow heart recovery and early
assessment of residual myocardial function.
*optimal medical management and conventional treatment measures include volume loading
and use of pressors and inotropes, with or without IABP.
Premarket Use– Sponsor Registry (e.g. UPSELLA Registry)

sources
RECOVER I trial (Non-RWE): Single-arm study of 15 Supplemental: Freedom-from-death (survival RECOVER I: 30 days,60 Analyses included analysis of all UPSELLA patients as
Impella 5.0/LD patients met inclusion/exclusion criteria. to 30 days); Adverse events (e.g. death, days,180 days, 1-year well as two sub-analyses of patients. The first sub-
stroke/CVA, TIA, acute renal dysfunction, acute analysis analyzed USPELLA data based on ascending
USPELLA (RWE): 77 post-cardiotomy cardiogenic shock hepatic failure, bleeding, infection, hemolysis, USPELLA/AB5000: risk of mortality. The second sub-analysis---requested
(PCCS) Impella patients (Impella 2.5, Impella 5.0/LD, and multi-system organ failure, acute hepatic Discharge/30 days by FDA---analyzed data from UPSELLA patients
Impella CP) failure, supraventricular arrhythmia, sepsis, supported by Impella before, during and after
respiratory failure/dysfunction) surgery.
AB5000 (RWE): 79 AB5000 patients with PCCS
(benchmark for comparison)
Narrative:
The primary clinical study (RECOVER I) was a single-arm clinical trial which evaluated outcomes of cardiogenic shock or low-cardiac output syndrome patients supported using
Impella 5.0/LD.
FDA reviewed supplemental analyses of freedom-from-death and adverse events from PCCS patients from the sponsor’s USPELLA registry, including data from device models
(Impella 2.5 and Impella CP) not in the pivotal trial. FDA also reviewed analyses of freedom-from-death for patients categorized by risk-of-mortality and those supported with
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the device before, during and after surgery. Finally, FDA also reviewed supplemental benchmark analyses between the Impella device family and a temporary ventricular assist
device comparator (AB5000).
These analyses provided supportive evidence on the effectiveness and benefit-to-risk of the device as well as additional clinical evidence on device catheters not evaluated in the
pivotal study.
Postmarket Use– Sponsor Registry (cVAD Registry)

cVAD Registry: Minimum of 44 patients supported with Impella devices Primary: Survival rates (longer between discharge or 30 days) 30 days, 90 days, 1 year post
for post-cardiotomy cardiogenic shock (PCCS) and enrolled in the cVAD implant follow ups
registry. Secondary: Adverse event rates (longer between discharge or 30 days).
Technical and implant success rate (exit from catheterization laboratory or
operation room).
Narrative:
The sponsor has agreed to conduct a post-approval study evaluating the safety and effectiveness of Impella devices in a real-world population using the cVAD registry.
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Example 33. PMA - Indication Expansion and Postmarket Surveillance of a Drug-Eluting Peripheral
Transluminal Angioplasty Catheter Leveraging OUS Sponsor Registry Data [76, 77]
P130024/S009 Lutonix, Inc. Lutonix 035 Drug The Lutonix 035 Drug Coated Balloon PTA Catheter is indicated for percutaneous Global SFA Registry Premarket: Primary
Supplement to Coated Balloon transluminal angioplasty, after appropriate vessel preparation, of de novo, restenotic or (Sponsor Registry)
expand indication PTA Catheter in-stent restenotic lesions up to 300mm in length in native superficial femoral or popliteal
arteries with reference vessel diameters of 4-7mm.
Premarket Use– Sponsor Registry (GLOBAL SFA Registry)

Sources
GLOBAL SFA Registry (RWE): OUS registry. 691 patients (38 sites) treated with Primary Safety: Composite endpoint of freedom GLOBAL SFA Registry: 1, 6, 12 and Sub-analyses by
the device for stenotic or obstructive femoropopliteal arteries including those at 30 days from target vessel revascularization 24 months. gender, long-lesions
with in-stent restenotic lesions (ISR). (TVR), major index limb amputation, and device- >140mm), ISR
and procedure-related death lesions
SFA ISR Study (Non-RWE): Randomized clinical trial. 82 patients randomized
2:1 to Lutonix DCB or standard balloon angioplasty for treatment of Primary Effectiveness: Freedom from target
femoropopliteal in-stent restenosis. lesion revascularization (TLR) at 12 months
Long-Lesion SFA Study (Non-RWE): Single-arm study; 118 patients (14 sites)
treated with device and presenting with long-lesions ( ≥ 14cm)
Narrative:
The primary clinical studies submitted in support of the PMA included a real-world registry, a randomized clinical trial, and a single arm study. RWE from the GLOBAL SFA
Registry was used in the primary assessment of effectiveness and safety for both the ISR and long-lesion (up-to 300mm in length) indication expansions.
FDA’s review of clinical effectiveness for treatment of ISR included assessments of twelve-month freedom-from-TLR and twelve-month primary patency data from the GLOBAL
SFA Registry (RWE) and twelve-month patency data and freedom from clinically-driven-TLF data from the SFA ISR Study. FDA’s review of clinical safety included assessments of
composite endpoints from the GLOBAL SFA Registry (RWE) and SFA ISR Study.
FDA’s review of clinical effectiveness for treatment of lesions up-to-300mm in length with the device included assessments of twelve-month freedom-from-TLR and twelve-
month primary patency data from the long-lesion subset in the GLOBAL SFA Registry (RWE) and twelve-month primary patency and twelve-month freedom from clinically-driven
TLR from the Long-lesion SFA Study. FDA’s review of clinical safety included assessments of composite endpoints from the GLOBAL SFA Registry (RWE) and Long-Lesion SFA
Study.
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Postmarket Use– Sponsor Registry (GLOBAL SFA Registry)
Global SFA Registry: Continued follow-up of the ISR and Primary: Composite of freedom from all-cause peri-procedural death (≤30 days). 12-month Through 24-months post-
long-lesion cohorts in the GLOBAL SFA Registry and 24-month freedom from index limb amputation, index limb re-intervention, index limb- procedure.
death, and TLR.
Narrative:
As a condition-of-approval, the sponsor has agreed to conduct a post-approval study following SFA and long-lesion cohorts (through 24-months post-procedure) in the GLOBAL
SFA Registry.
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Example 34. PMA - Indication Expansion and Postmarket Surveillance of an Endovascular Graft for
Aortic Aneurysms Leveraging Sponsor Registry Data [78]
P100021/S063 Medtronic Endurant The Endurant II/IIs bifurcated stent grafts are indicated for the endovascular treatment of ANCHOR Registry Premarket: Sole-source
Supplement to Vascular II/Endurant IIs infrarenal abdominal aortic or aortoiliac aneurysms. They may be utilized in conjunction of primary clinical
expand indication Stent Graft with the Heli-FX EndoAnchor System when augmented radial fixation and/or sealing is information
System required; in particular, in the treatment of abdominal aortic aneurysms with short (> 4 mm
and < 10 mm) infrarenal necks. The Endurant II aorto-uni-iliac (AUI) stent graft is indicated Postmarket: CoA to
for the endovascular treatment of infrarenal abdominal aortic or aortoiliac aneurysms in conduct postmarket
patients whose anatomy does not allow the use of a bifurcated stent graft. The Endurant data collection utilizing
II/IIs Stent Graft System is indicated for use in patients with the following characteristics: same registry.
[See approval order for full list]
Premarket Use– ANCHOR Registry

Population Key Elements or Endpoints from RWE Follow-up / Duration Methods of Note
sources
ANCHOR Registry: 70 patients enrolled into the Primary Safety: No primary safety endpoint, Follow-up per local standard of care. Imaging data is collected per standard
registry who were treated with Endurant or Endurant but supportive data collected on morbidity and of care and is evaluated by an imaging
II/IIs Stent Graft Systems and met enrollment criteria. mortality. Data collected at baseline and up to 5 core lab (per-protocol).
(22 sites, 19 in US, 3 OUS) years post-procedure.
Primary Effectiveness: Technical success rate; Broadly-defined analysis time windows
Type Ia endoleak rate at 1 month and 12 (due to collection of data per standard
months; re-intervention rate through 12 of care and to include as many subjects
months. as possible)
Narrative:
The ANCHOR Registry collects clinical data from patients treated with the Heli-FX EndoAnchor system and endovascular grafts from several manufacturers, including the graft in
the submission. RWE from this real-world registry were the sole-source of primary clinical evidence used in the assessment of safety and effectiveness for the proposed
indication (FDA also reviewed supplemental clinical information from literature).
Specifically, for effectiveness, FDA reviewed analyses of technical success rate (successful delivery and successful and accurate deployment of the graft), Type Ia endoleak rates
at 1 and 12 months, and re-intervention rates through 12 months. For safety, FDA reviewed aneurysm-related mortality, aneurysm rupture through 30 days and 12 months,
major adverse events through 30 days, and renal insufficiency and failure through 30 days. FDA also reviewed all-cause mortality, major adverse events and serious adverse
events through 12 months.
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Postmarket Use– ANCHOR Registry
ANCHOR Registry (RWE): Continued follow-up of the Primary: Aneurysm-related mortality, aneurysm rupture, aneurysm expansion, Type Ia Five-year follow-up with data
short-neck cohort in the ANCHOR Registry. endoleak, migration, Type III endoleak, re-intervention, device-related adverse events, and analyzed annually.
device integrity.
Narrative:
As a condition-of-approval, the sponsor has agreed to conduct a post-approval study following the PMA cohort (through 5 years post-procedure) in the ANCHOR Registry.
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Example 35. PMA - Postmarket Surveillance of a Ventricular Assist Device Leveraging a Sponsor
Registry [79]
P100047/S090 Medtronic, HeartWare The HeartWare™ HVAD™ System is indicated for hemodynamic support in patients with Sponsor registry Postmarket: CoA to use
Supplement to Inc. HVAD System advanced, refractory left ventricular heart failure; either as a bridge to cardiac sponsor registry to
expand indication transplantation (BTT), myocardial recovery, or as destination therapy (DT) in patients for collect postmarket data.
whom subsequent transplantation is not planned.
Postmarket Use– Sponsor Registry

Population Key Elements or Endpoints from RWE sources Follow-up/Duration (RWE)
ENDURANCE Supplemental PAS: 300 subjects enrolled Primary Endpoint: Survival free of disabling stroke or device malfunction Through five-years post implant.
and followed using the sponsor’s Product Surveillance requiring exchange, explant, or urgent transplant.
Registry (PSR).
Secondary: Observed early stroke rate (≤2 years post-implant) and stroke risk
factors; late stroke rate (>2 years post-implant) and late stroke risk factors,
and stroke severity.
Narrative:
As a condition-of-approval, the sponsor has agreed to conduct a post-approval study using a sponsor registry
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Example 36. PMA - Modification to Indications for Use Statement for a Vascular Hemostasis
Device Using the Sponsor’s Registry Study [80]
P960043/S097 Abbott Perclose The Perclose ProGlide SMC System is indicated for the percutaneous EVEREST II/REALISM Premarket: Sole source of
Vascular Inc. ProGlide Suture- delivery of suture for closing the common femoral artery and vein access Continued Access Registry clinical evidence
Mediated site of patients who have undergone diagnostic or interventional Study for Abbott MitraClip
Closure System catheterization procedures. The Perclose ProGlide SMC System is used device
without or, if required, with adjunctive manual compression:
- For access sites in the common femoral artery using 5F to 21F
sheaths
- For access sites in the common femoral vein using 5F to 24F
sheaths.
- For arterial and venous sheath sizes greater than 8F, at least two
devices and the pre-close technique are required.
Premarket Use – Analysis of Retrospectively Collected Data from EVEREST II/REALISM Continued
Access Registry Study
Population Key Elements or Endpoints from RWE source
ProGlide Cohort from EVEREST II/REALISM Continued Access Registry Study: Primary:
159 patients in whom the subject device was used as the primary method for Rate of freedom from major femoral vein access-site related complications at 30-days post MitraClip index
large bore venous access-site closure with or without secondary closure procedure
methods during the MitraClip index procedure with the MitraClip 24Fr vascular
sheath, and who were enrolled in the five (5) REALISM sites identified as high See Summary of Safety and Effectiveness Data for additional details and complete list.
frequency users of vessel closure devices and utilized the subject device for
vessel closure
Narrative:
For this PMA panel track supplement, data from the sponsor's continued access registry for a different device were utilized to expand the indication of their suture delivery
system to include closing femoral artery access sites using sheaths up to 24F, increased from 21F in the previous indication. A patient cohort from the continued access study
that received the suture delivery system was selected based on usage of the subject device across the sites in the continued access study, and their medical records were
retrospectively analyzed for safety and efficacy. This supplement was exempted from going to the Circulatory Systems Devices Panel, and the submitted real-world evidence
served as the sole support for supplement approval.
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Example 37. PMA - Modification for Indications for Use Statement for Two Coronary Drug-Eluting
Stents Using Sponsor Registry Data and a Post-Approval Study [81, 82, 83, 84]
File Sponsor Devices Approved / Cleared Indication RWE Source Use of RWE
P160043/S012, Medtronic Vascular Resolute Onyx Please see Approval Orders for P160043/S012 and PERSPECTIVE Study Premarket: Primary source
P110013/S088 Zotarolimus-Eluting P110013/S088. of clinical evidence
Coronary Stent Global RESOLUTE Clinical Trial
System, Resolute Integrity Program: RESOLUTE Postmarket: CoA to collect
Zotarolimus-Eluting International Registry & postmarket data in sponsor
Coronary Stent System RESOLUTE China Registry PAS and RCT.
Premarket Use – Sponsor Registry Data (US and OUS)

PERSPECTIVE Study – Resolute CTO Cohort (RWE): 183 patients who Safety and Effectiveness:
underwent attempted percutaneous chronic total occlusion Occurrence of major adverse cardiac events (MACE) defined as: death, myocardial infarction (MI) (ARC defined),
revascularization treated with the Resolute Integrity stent at a single
and clinically-driven target lesion revascularization at one-year post-procedure
center in US Lesion success defined as: attainment of <50% residual stenosis of the target lesion using any percutaneous
method
Global RESOLUTE Clinical Trial Program – RESOLUTE International Device success defined as: attainment of <50% residual stenosis of the target lesion using only the assigned device
Registry & RESOLUTE China Registry (RWE): 358 patients treated with Procedure success defined as: attainment <50% residual stenosis of the target lesion and no in-hospital MACE
Resolute DES for chronic total occlusions
Please see Summary of Safety and Effectiveness Data for P160043/S012 and P11013/S088 for additional details and
complete list.
Narrative:
These bundled panel track PMA supplements are in support of an indication expansion for the Resolute family of stents to include treatment of patients with coronary chronic
total occlusions. The sponsor submitted real-world evidence in the form of a US single-center prospective/retrospective observational study collecting data from medical records
and US and OUS sponsor registry data pooled for analysis of a cohort of patients treated with the subject devices. These data were used to support approval of these
supplements.
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Post-market Use – Post-approval study
Population Key Elements or Endpoints from RWE source Follow-up
RESOLUTE ONYX CTO Post-Approval Study (PAS001): Lesion- and patient- PAS001 Endpoints: Two years
level meta-analyses of approximately 100 subjects with chronic total Primary:
occlusions treated with subject devices enrolled in the RESOLUTE ONYX CTO Freedom from MACE (death, myocardial infarction, and clinically-driven target
Post-Approval Study and ONYX ONE OUS randomized clinical trial. lesion revascularization) at 30 days
Secondary:
Please see the Resolute Onyx PAS pages (P160043/S012, Acute success (device, lesion, and procedure), cardiac death, target vessel MI,
P110013/S088, P160043/S001)) for additional details. TLR, TLF, TVF, stent thrombosis
Narrative:
As a condition-of-approval for these bundled PMA supplements, the sponsor is required to conduct a post-approval study following patients with chronic total occlusions treated
with the subject devices enrolled in the RESOLUTE ONYX CTO Post-Approval Study and ONYX ONE OUS randomized clinical trial in order to demonstrate the generalizability of
the performance the Resolute family of drug-eluting stents for the treatment of chronic total occlusions (CTOs) in a real-world setting. Approximately 100 patients will be
followed for two years, with the primary safety and effectiveness endpoint being freedom from MACE.
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Appendix Section II. Examples Leveraging Administrative Claims Data for Real-World Data
Collection
Guide to Examples Leveraging Administrative Claims Data for Real-World Data Collection
Source(s)
38 P180035 CooperVision, MiSight 1 Day Retrospective review of Premarket: RWE in addition to clinical trial data was a Administrative claims
Inc. (omafilcon A) Soft medical records from primary source of clinical evidence for this original data;
(Hydrophilic) seven (7) US clinics PMA. Medical records (EHR,
Contact Lenses EMR or chart review);
for Daily Wear Electronic health-records Postmarket: The sponsor has agreed to conduct a
post-approval study (PAS) that proposes to use RWE Pediatric RWE;
and claims data
from electronic health records and claims data from RWE as a primary source
integrated health care and coverage providers or of clinical evidence;
integrated optometry/ophthalmology practices (PAS Total-Product Lifecycle
protocol pending as of 1/2/20). Example;
39 P040020/S049 Alcon AcrySof IQ CMS Medicare Beneficiary Postmarket: For this indication expansion of a Administrative claims
Research, Ltd ReSTOR +3.0 D Encrypted Files multifocal intraocular lens, the post-approval study data;
Multifocal Toric will utilize Medicare Beneficiary Encrypted Files as
Intraocular Lens part of a retrospective study of all cataract surgeries
in the Medicare population from 2011-2013,
comprising approximately 180,000 surgeries, in order
to estimate the background rate of post-surgical
intraocular inflammation to compare to the subject
device.
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Example 38. PMA - Approval for a Daily Wear Soft Contact Lens to Reduce the Progression of
Myopia Using Retrospective Review of Medical Records and RWE for a Post-Approval Study [85, 86,
87]

P180035 CooperVision MiSight 1 Day (omafilcon MiSight 1 Day (Omafilcon A) Soft (Hydrophilic) Contact Lenses for Daily Premarket: Retrospective review Premarket: Primary
, Inc. A) Soft (Hydrophilic) Wear are indicated for the correction of myopic ametropia and for of medical records from source of clinical
Contact Lenses for Daily slowing the progression of myopia in children with non-diseased eyes, community optometry clinics evidence
Wear who at the initiation of treatment are 8-12 years of age and have a
refraction of -0.75 D to -4.00 D (spherical equivalent) with ≤ 0.75 Postmarket: RWE from electronic Postmarket: Post-
diopters of astigmatism. The lens is to be discarded after each removal. health-records and claims data approval study
from integrated health care and
coverage providers or integrated
optometry/ophthalmology
practices
Premarket Use – Retrospective Review of Medical Records from Community Clinics

MiSight Randomized Controlled Study (MIST-401) (Non-RWE): Two-arm, Safety:
randomized, controlled trial (n=187) Rate of Microbial Keratitis (no higher than 0.4% per patient-year)
Retrospective Review of Medical Records (RWE): 2134 patient-years from 782 US Effectiveness:
pediatric patients with soft contact lens, age 8-12. Assessed in a separate clinical trial
Narrative:
MiSight 1 Day (omafilcon A) Soft (Hydrophilic) Contact Lenses for Daily Wear are indicated for the correction of myopic ametropia and for slowing the progression of myopia in
children. For this original PMA, the sponsor provided clinical evidence from a randomized, controlled trial. In addition---to satisfy the premarket requirement---the sponsor was
required to demonstrate that the rate of Microbial Keratitis (MK), a potential vision-threatening adverse event, is no higher than 0.4% per patient-year. This risk has not been
extensively evaluated in pediatric populations and requires a sample size greater than the pivotal trial to estimate because of the low prevalence.
To meet the FDA premarket requirement, the sponsor conducted a retrospective study investigating real-world soft contact lens use among children. In this study, the sponsor
conducted a retrospective analysis of medical records of 782 pediatric patients, age 8 – 12, wearing commercially available soft contact lens from seven (7) US community clinics.
SAEs and MK were identified through chart review conducted by an adjudication committee consisted of three independent ophthalmologists and optometrists. In total, two MK
were identified (both were resolved), and a rate of 9.4/10,000 patient-years were established (95% CI: [2.3 to 37.7 per 10,000]), with the upper bound of 95% CI lower than the
0.4%/patient-year requirement.
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Postmarket Use – Post-approval study with RWE from electronic health-records and claims data
from integrated health care and coverage providers or integrated optometry/ophthalmology
practices
Consecutive subjects Microbial keratitis, Three-years (post-fitting)
receiving the device who Incidence of loss of best-corrected visual acuity
consent to the use and Incidence of non-infectious infiltrative keratitis
release of their health Peripheral noninfectious ulcers
encounter data for this
PAS.
Narrative:
As a condition-of-approval, the sponsor agreed to conduct a post-approval to provide additional long-term data on the safety and effectiveness of the device. The sponsor
agreed to evaluate the rate of MK among those who use the MiSight against a performance goal of 0.2%/patient-year. This endpoint would be difficult to assess in a traditional
clinical trial due to its low-prevalence. Instead, the sponsor has agreed to conduct this post-approval study within integrated health care and coverage organization systems or
integrated (optometry/ophthalmology) eyecare practices. Outcome data will come from electronic health records and administrative claims. The full post-approval study
protocol is pending as of 1/2/2020.
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Example 39. PMA - Postmarket Surveillance of a Multifocal Intraocular Lens Utilizing Data from
Medicare Beneficiary Encrypted Files (CMS) [88]
P040020/S049 Alcon Research, AcrySof IQ The AcrySof IQ ReSTOR +3.0 D Multifocal Toric Posterior Chamber Intraocular Lens CMS Medicare Postmarket: Multi-center
Supplement to Ltd. ReSTOR +3.0 D (IOL) is indicated for primary implantation in the capsular bag of the eye for the Beneficiary surveillance study that will also
expand Multifocal Toric visual Encrypted Files use data from Medicare
indication Intraocular Lens correction of aphakia and pre-existing corneal astigmatism secondary to removal of Beneficiary Encrypted Files (BEF)
a to estimate background rate of
cataractous lens in adult patients with and without presbyopia, who desire near, post-surgical intraocular
intermediate and distance vision, reduction of residual refractive cylinder and inflammation
increased spectacle independence. The lens is intended to be placed in the capsular
bag.
Postmarket Use – Post-approval study leveraging CMS Medicare Beneficiary Encrypted Files
Population Key Elements or Endpoints from RWE source Follow-up Methods of Note
Data from all cataract surgeries in the Medicare population Primary: Primary rates to be Using Medicare beneficiary files for a
(from 2011-2013) will be used to estimate the background rate Rate of post‐surgical intraocular inflammation (using estimated from a retrospective study to estimate the
of the outcome of interest. (Estimated to contain 180,000 associated coding for endophthalmitis, uveitis, 180-day period background rate of post-surgery ocular
surgeries) postsurgical intraocular inflammation or other related following intraocular inflammation, which will be used to
codes). lens implantation compare with the observed rate in the
Sponsor is also collecting data on the device patients in a device group (for which new data
separate study phase. (3000 eyes) collection will take place).
Narrative:
The post-approval study will evaluate the rate of post-surgical intraocular inflammation between a device cohort against the rate of post-surgical intraocular inflammation
extracted from ICD-9 codes in 2011-2013 Medicare Beneficiary Encrypted Files (BEF). The study consists of two phases. Phase A involves new data collection from 3000 eyes
implanted with the AcrySof IQ ReSTOR +3.0 D Toric IOL for up to 180 days. The second phase is the analysis of 2011-2013 Medicare Beneficiary Encrypted Files (BEF) to
determine the background post-surgical intraocular inflammation rate.
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Appendix Section III. Examples Leveraging Both National Registries and Administrative Claims
Data for Real-World Data Collection
Guide to Examples Leveraging Both National Registries and Administrative Claims Data for Real-
World Data Collection
Source(s)
40 P130013 Boston WATCHMAN LAA ACC LAAO Registry As a condition-approval, postmarket surveillance Administrative claims
Scientific Closure will be performed through the ACC Left Atrial data;
Corporation Technology Centers for Medicare and
Appendage Occlusion (LAAO) Registry in an all- Registry data;
Medicaid Services (CMS)
comers population. Longer-term outcomes in
claims database.
interest will be collected by linkage to CMS.
41 P140031 Edwards SAPIEN 3 STS/ACC TVT Registry For this original PMA, postmarket surveillance will Administrative claims
Lifesciences, Transcatheter be conducted through the STS/ACC TVT Registry data;
LLC Heart Valve Centers for Medicare and with linkage to CMS as a condition-of-approval. Registry data;
claims database.
42 P110042/S077 Boston EMBLEM S-ICD ACC NCDR: ICD Registry; As a condition-of-approval, the sponsor agreed to Administrative claims
Scientific Subcutaneous LATITUDE NXT Patient conduct postmarket surveillance using RWE from data;
Corporation Electrode, Model Management System; CMS multiple real-world data sources including a Registry data;
3501 Claims Database; Truven national registry, public and private claims, remote
MarketScan; National monitoring of device generated data, and the
Death Index National Death Index.
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43 P140031/S028 Edwards SAPIEN 3 STS/ACC TVT Registry For this PMA supplement seeking an indication Administrative claims
Lifesciences, Transcatheter expansion, clinical evidence from the STS/ACC data;
LLC Heart Valve Centers for Medicare and registry served as the sole support for approval, and Registry data;
Medicaid Services (CMS) was utilized, with additional linkage to CMS for long- RWE as a primary source
claims database. term outcomes, for postmarket surveillance as a of clinical evidence;
condition-of-approval.
Example;
44 P130009/S034 Edwards SAPIEN XT Sponsor Registry, STS/ACC RWE from a sponsor registry served as supplemental Administrative claims
Lifesciences, Transcatheter TVT Registry evidence for this PMA supplement for an indication data;
LLC Heart Valve expansion, and postmarket surveillance will be Registry data;
Centers for Medicare and performed through the STS/ACC TVT Registry with Total-Product Lifecycle
Medicaid Services (CMS) linkage to CMS as a condition-of-approval. Example;
claims database
45 P130021/S010 Medtronic CoreValve System STS/ACC TVT Registry For this indication expansion, postmarket Administrative claims
CoreValve surveillance will be conducted through the STS/ACC data;
LLC Centers for Medicare and TVT registry with linkage to CMS for long term Registry data;
Medicaid Services (CMS) outcomes of up to five years post-implantation.
claims database
46 P130009/S057 Edwards SAPIEN XT STS/ACC TVT Registry Postmarket surveillance will be conducted through Administrative claims
Lifesciences, Transcatheter the STS/ACC TVT Registry with linkage to CMS for data;
LLC Heart Valve Centers for Medicare and
longer-term outcomes for this PMA supplement for Registry data;
an indication expansion.
claims database.
47 P130021/S033 Medtronic CoreValve System STS/ACC TVT Registry For this PMA supplement to expand indication, Administrative claims
CoreValve postmarket surveillance will be conducted through data;
Centers for Medicare and the STS/ACC TVT Registry with linkage to CMS as a Registry data;
Medicaid Services (CMS) condition-of-approval.
claims database.
48 P140031/S010 Edwards SAPIEN 3 STS/ACC TVT Registry Postmarket surveillance will be conducted through Administrative claims
Lifesciences, Transcatheter the STS/ACC TVT Registry with linkage to CMS for data;
LLC Heart Valve Centers for Medicare and this PMA supplement for indication expansion. Registry data;
claims database.
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49 P100009/S028 ABBOTT MitraClip NT Clip STS/ACC TVT Registry For this PMA supplement for an indication Administrative claims
VASCULAR Delivery System expansion, postmarket surveillance will be data;
INC and MitraClip Centers for Medicare and conducted through the STS/ACC TVT Registry with Registry data;
NTR/XTR Clip Medicaid Services (CMS) linkage to CMS as a condition-of-approval.
Delivery System claims database.
50 P130021/S058 Medtronic Medtronic STS/ACC TVT Registry Postmarket surveillance will be conducted through Administrative claims
CoreValve CoreValve Evolut the STS/ACC TVT Registry with linkage to CMS for data;
LLC R System, Centers for Medicare and
this PMA supplement for an indication expansion. Registry data;
Medtronic Medicaid Services (CMS)
CoreValve Evolut claims database.
PRO System
51 P140031/S085 Edwards Edwards SAPIEN 3 STS/ACC TVT Registry For this PMA supplement for an indication Administrative claims
Lifesciences Transcatheter expansion, postmarket surveillance will be data;
LLC Heart Valve Centers for Medicare and performed using the STS/ACC TVT Registry with Registry data;
System, Edwards Medicaid Services (CMS) linkage to CMS.
SAPIEN 3 Ultra claims database.
Transcatheter
Heart Valve
System
52 NCT02687035 Edwards SAPIEN 3 STS/ACC TVT Registry For this continued-access program, data will be Administrative claims
Lifesciences, Transcatheter collected using the STS/ACC TVT Registry with data;
LLC Heart Valve Centers for Medicare and linkage to CMS. Registry data;
claims database.
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Example 40. PMA - Postmarket Surveillance of a Left Atrial Appendage Closure Device Utilizing a
National Registry and Claims Data for Condition-of-Approval [89, 90]
P130013 Boston WATCHMAN The WATCHMAN Device is indicated to reduce the risk of thromboembolism from the ACC LAAO Registry Postmarket: CoA to use
Scientific LAA Closure left atrial appendage (LAA) in patients with non-valvular atrial fibrillation who: LAAO Registry with linkage
Corporation Technology *Are at increased risk for stroke and systemic embolism based on CHADS2 or CMS to CMS for postmarket
CHA2DS2-VASc1 scores and are recommended for anticoagulation therapy; surveillance.
*Are deemed by their physicians to be suitable for warfarin; and
*Have an appropriate rationale to seek a non-pharmacologic alternative to warfarin,
taking into account the safety and effectiveness of the device compared to warfarin
Postmarket Use – American College of Cardiology (ACC) Left Atrial Appendage Occlusion (LAAO)
Registry
Population Key Elements or Endpoints from RWE source Follow-up/Duration Methods of Note
Minimum of 2000 patients, (all-comers Primary: Five years of surveillance Linkage to CMS for longer-
population) Implant success rate; Procedural safety; Effective Closure of left- term outcomes of interest
atrial appendage; Composite Stroke and all-cause mortality;
Ischemic stroke or systemic embolism; Peri-procedural events
Narrative:
This hypothesis-driven, post-approval surveillance project was designed to evaluate several performance goals in an all-comers population. Some of the performance goals are
related to longer-term outcomes (stroke, systemic embolism, etc.). The enrollees are being followed per standard of care for two years in the registry, and then specific
outcomes of interest are being collected via linkage to CMS claims data for follow-up years three through five.
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Registry for Condition-of-Approval [91, 92, 93, 94]
P140031 Edwards SAPIEN 3 The Edwards SAPIEN 3 Transcatheter Heart Valve (THV), model 9600TFX, and accessories STS/ACC TVT Postmarket: CoA to use TVT
Lifesciences, LLC Transcatheter are indicated for relief of aortic stenosis in patients with symptomatic heart disease due Registry Registry with linkage to CMS
Heart Valve to severe native calcific aortic stenosis who are judged by a heart team, including a for postmarket surveillance.
cardiac surgeon, to be at high or greater risk for open surgical therapy (i.e., Society of CMS
Thoracic Surgeons operative risk score ≥8% or at a ≥15% risk of mortality at 30 days).
Postmarket Use – STS/ACC TVT Registry

Population Key Elements or Endpoints from RWE source Follow- Methods of Note
up/Duration
All implanted patients Primary: Five years of Linkage to CMS for longer-
(as described in the (1) Device success (intra-procedure); surveillance term outcomes of interest
approved indication) in (2) all-cause mortality, all stroke, life-threatening (or disabling) bleeding, acute kidney injury-stage 3 (including
the STS/ACC TVT renal replacement therapy, acute events associated with index TAVR procedure), peri- procedural myocardial
Registry within 5 years infarction, and repeat procedure for valve-related dysfunction (surgical or interventional therapy) at 30 days and
of device approval 12 months;
(3) neurological (non- stroke), vascular complications, and quality of life (KCCQ) outcomes at 30 days and 12
months;
(4) all-cause mortality, all stroke, and repeat procedure for valve-related dysfunction (surgical or interventional
therapy) annually through 5-year post implantation
Narrative:
Surveillance will be conducted in the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the SAPIEN 3 THV in implanted patients (at high or greater
risk for open surgical therapy) within 5 years of device approval. Follow up of these patients will be conducted through linkage to the CMS database for long-term surveillance
through 5 years post implantation.
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Example 42. PMA - Postmarket Surveillance of an Implantable Cardioverter-Defibrillator Utilizing
National Registries and Claims Data for Condition-of-Approval [95, 96, 97, 98]
P110042/S077 Boston EMBLEM S-ICD The S-ICD System is intended to provide defibrillation • ACC NCDR: ICD Registry; Postmarket – CoA post-
Scientific Subcutaneous therapy for the treatment of life-threatening ventricular • LATITUDE NXT Patient Management approval study utilizing
Corporation Electrode, Model tachyarrhythmia in patients who do not have symptomatic System multiple RWE data
3501 bradycardia, incessant ventricular tachycardia, or sources
• CMS Claims Database
spontaneous, frequently recurring ventricular tachycardia
that is reliably terminated with anti-tachycardia pacing. • Truven MarketScan
• National Death Index (linkage to NCDR
patients).
Postmarket Use – Post-Approval Study with Data Collected Using American College of Cardiology -
National Cardiovascular Data Registry (NCDR) ICD Registry, CMS Claims, Truven MarketScan,
National Death Index, and Remote-Monitoring
US consecutive patients implanted with Primary: 5 years of surveillance Use of multiple real-world
EMBLEM S-ICD Electrode Model 3501 • NCDR: The first primary endpoint evaluates the rate of Model 3501 implant and evidence data sources
whose data are captured in one of the periprocedural complications. including registries and
databases utilized for this study. • Remote Monitoring (LATITUDE NXT): The second primary endpoint evaluates the device remote monitoring,
five-year rate of Model 3501 EMBLEM S-ICD Electrode integrity alerts. as well as linkages with
• NCDR ICD Registry (N=2,100) • Administrative Claims (CMS): The third primary endpoint evaluates the five-year claims data and the National
• National Death Index linkage to rate of Model 3501 EMBLEM S-ICD Electrode complications requiring reoperation or Death Index.
NCDR patients (N=2,100). hospitalization.
• LATITUDE NXT Patient • National Death Index: The fourth primary endpoint evaluates the five-year rate of
Management System (N=2,000); Model 3501 EMBLEM S-ICD Electrode patient deaths from any cause.
• CMS Claims Database (N=2,100)
Secondary:
• Administrative Claims (Truven): The secondary endpoint evaluates the five-year
rate of Model 3501 EMBLEM S-ICD Electrode complications requiring reoperation or
hospitalization.
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Narrative:
This surveillance study marks a significant advancement on the methodologies used to monitor long-term performance of ICDs where multiple real-world data sources will be
leveraged to monitor multiple aspects of real-world device safety and effectiveness. Usually, a new enrollment study requiring direct follow-up of patients of up to 5 years would
have been required. For this approval, the postmarket study will leverage an existing national registry, remote monitoring of device-generated data, claims data from public and
private payers, and the national death index, using only data collecting during routine-care.
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Valve Using a National Registry [99, 100, 101, 102]
Fil Sponsor Device Approved / Cleared / Granted Indication RWE Source Use of RWE
P140031/S028 Edwards SAPIEN 3 The Edwards SAPIEN 3 Transcatheter Heart Valve (THV), Model 9600TFX, and STS/ACC Premarket: Sole-Source of
Supplement to Lifesciences Transcatheter accessories are indicated for patients with symptomatic heart disease due to failure Transcatheter Valve clinical evidence (STS/ACC
expand indication LLC Heart Valve (stenosed, insufficient, or combined) of a surgical bioprosthetic aortic or mitral valve Therapy (TVT) TVT Registry)
who are judged by a heart team, including a cardiac surgeon, to be at high or greater Registry
risk for open surgical therapy (i.e., predicted risk of surgical mortality ≥ 8% at 30 Postmarket: CoA to use TVT
days, based on the STS risk score and other clinical co-morbidities unmeasured by Centers for Medicare Registry with linkage to CMS
the STS risk calculator). and Medicaid for postmarket surveillance.
Services (CMS)
database
Premarket Use – STS/ACC TVT Registry

TVT Registry (Aortic Population) (RWE): Safety: All-cause mortality, cardiac mortality, stroke, transient TVT Registry captures data at discharge, 30- Adverse event adjudication
Patients treated with SAPIEN 3 (314) for failed ischemic attack (TIA), aortic valve intervention, mitral valve days and 1 year. (readmission for heart
surgical aortic prosthesis (aortic valve-in-valve) intervention failure, stroke/TIA and
Data in this submission analyzed at baseline, aortic and mitral valve
TVT Registry (Mitral Population) (RWE): Effectiveness: Echocardiographic performance, NYHA discharge, and 30-days. reinterventions) performed
Patients treated with SAPIEN XT (241) or classification, 5-meter walk test (aortic valve dataset), 6-minute per TVT Registry Coder’s
SAPIEN 3 (70) for failed surgical mitral walk test (mitral valve dataset), length of stay and quality of life Data Dictionary
prosthesis (mitral valve-in-valve) score (KCCQ)
Narrative:
The device is used in transcatheter aortic valve replacement. FDA reviewed analyses of real-world use of the device captured in the Society of Thoracic Surgeons / American
College of Cardiology Transcatheter Valve Therapy (TVT) registry for this supplement seeking to expand the indication (to include treatment of patients with failed surgical
bioprosthetic aortic or mitral valves and in high-risk patients). Analyses included both safety endpoints at discharge and 30-days (all-cause mortality, cardiac mortality, stroke,
TIA, re-intervention) and effectiveness endpoints at baseline, discharge and 30-days (echo-derived gradient data, regurgitation, NYHA classification, 5-meter or 6-minute walk
test, quality of life score, and length of index hospitalization stay) from aortic or mitral valve-in-valve patients. These analyses were the primary basis for approval of the PMA.

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up/Duration
All mitral or aortic SAPIEN Aortic Indication Endpoints: (1) Device success (intra-procedure); Surveillance Linkage to CMS for
3 Valve in Surgical Valve (2) all-cause mortality, all stroke, life-threatening/major bleeding, new requirement for dialysis, peri-procedural through five-years long-term
patients over 2 years post myocardial infarction, and repeat procedure for valve-related dysfunction (surgical or interventional therapy) at 30 post implantation outcomes
approval (June 5, 2017 to days and 12 months;
June 4, 2019). (3) neurological (nonstroke), vascular complications, and quality of life (KCCQ) outcomes at 30 days and 12 months;
(4) all-cause mortality, all stroke, and repeat procedure for valve-related dysfunction at 2-5 year post-implantation
Mitral Indication Endpoints:

(1) all-cause mortality, heart failure rehospitalization, and mitral valve reintervention at 30 days and 12 months;
(2) 6-minute walk distance, KCCQ, and change in NYHA functional class at 30 days and 12 months;
(3) device- or procedure-related adverse events, major bleeding complications, stroke and other cerebrovascular
events, myocardial infarction, new requirement for dialysis, new onset atrial fibrillation, and other events or
complications
[See Approval Order for full list] at 30 days and 12 months
(4) mitral valve hemodynamics at 30 days and 12 months;
(5) all-cause mortality, all stroke, and repeat procedure for valve-related dysfunction at 2-5 years post implantation
Narrative:
This surveillance plan will use the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the SAPIEN 3 Transcatheter Heart Valve in patients with a
failed surgical bioprosthetic aortic or mitral valve for two years following device approval. Follow up of these patients will be performed through linkage to the CMS database for
long-term surveillance through 5 years post implantation.
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Valve with National Registry Data [104, 105, 106]
P130009/S034 Edwards SAPIEN XT The Edwards SAPIEN XT Transcatheter Heart Valve is indicated for patients with SOURCE XT (Sponsor Premarket: Supplemental
Supplement to Lifesciences, Transcathete symptomatic heart disease due to either severe native calcific aortic stenosis or failure Registry, Premarket)
expand LLC r Heart Valve (stenosed, insufficient, or combined) of a surgical bioprosthetic aortic valve who are judged Postmarket: CoA to use TVT
indication by a heart team, including a cardiac surgeon, to be at high or greater risk for open surgical STS/ACC TVT Registry Registry with linkage to CMS
therapy (i.e., Society of Thoracic Surgeons operative risk score ≥8% or at a ≥15% risk of (Postmarket), w/ CMS for postmarket surveillance.
mortality at 30 days).
Premarket Use – Supplemental RWE from SOURCE XT Registry

PARTNER II Nested Studies (Non-RWE): Single-arm study and continued Safety: SOURCE XT: Discharge, 30 days, and
access study nested in PARTNER II Trial (197 attempted implant; 195 All-cause death (30 days, 1 year, 2 years) 12 months post-implant, and annually
patients implanted, pooled across the original population and continued- Cardiac death (30 days, 1 year, 2 years) thereafter for up to 5 years.
access population). Included patients met the device sizing requirements Stroke (All, Major stoke; 30 days, 1 year, 2 years)
(23mm or 26mm SAPIEN XT THV). Repeat hospitalization (30 days, 1 year, 2 years)
Other events (i.e. MI, See Summary of Safety and Effectiveness data for full
SOURCE XT (RWE): OUS post-approval registry collecting data on list.)
consecutive patients treated with the SAPIEN XT THV. 2688 patients
enrolled in SOURCE XT; 57 of those underwent a “TAV-in-SAV” procedure Effectiveness:
(the proposed indication), using 23, 26 or 29mm valve sizes. Valve hemodynamics: Doppler velocity index, mean gradient, total aortic
regurgitation at baseline, discharge, 30 days, 1 year, 2 years
Quality-of-life (ED-5Q) at baseline, 30 days, 1 year, 2 years
NYHA Classification change (baseline to 30 days, 1 year, 2 years)
Narrative:
The primary source for clinical evidence and basis for approval for this supplement was from the PARTNER II nested clinical studies for “TAV-in-SAV” indications and included
clinical evidence on two device sizes (23, 26mm). FDA also reviewed supplemental clinical information from the SOURCE XT Registry, which provided additional clinical evidence
for all three valve sizes (23, 26 and 29mm), including an additional valve size (29mm) not evaluated in the PARTNER II nested studies. FDA approved the indication expansion for
all three valve sizes (23, 26 and 29mm).

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up/Duration
All implanted SAPIEN XT Primary endpoints: Five years of Linkage to CMS for long-
patients (1) Device success (intra-procedure); surveillance term outcomes
with symptomatic heart (2) all-cause mortality, all stroke, life-threatening (or disabling) bleeding, acute kidney injury-stage 3 (through 5 years)
disease, due to either severe (including renal replacement therapy, acute events associated with index TAVR procedure), peri-
native calcific aortic stenosis or procedural myocardial infarction, and repeat procedure for valve-related dysfunction (surgical or
failure of a surgical bioprothesis interventional therapy) at 30 days and 12 months;
valve who are at high or greater (3) neurological (non-stroke), vascular complications, and quality of life (KCCQ) outcomes at 30 days and
risk for open surgical therapy 12 months;
(4) all-cause mortality, all stroke, and repeat procedure for valve-related dysfunction (surgical or
interventional therapy) annually through 5 year post implantation
Narrative:
This Surveillance Plan will use the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the SAPIEN XT Transcatheter Heart Valve in patients with
either severe native calcific aortic stenosis or failure of a surgical bioprosthetic aortic valve that are at high or greater risk for open surgical therapy. Follow up of these patients
will be linked to the CMS database for long-term surveillance through 5 years post implantation.
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Registry and Claims Data for Condition-of-Approval [94, 107, 108]
P130021/S010 Medtronic CoreValve The Medtronic CoreValve system is indicated for use in patients with symptomatic heart disease STS/ACC TVT Postmarket: CoA to use TVT
Supplement to CoreValve System due to either severe native calcific aortic stenosis or failure (stenosed, insufficient, or combined) Registry Registry with linkage to CMS
expand indication LLC of a surgical bioprosthetic aortic valve who are judged by a heart team, including a cardiac for postmarket surveillance.
surgeon, to be at high or greater risk for open surgical therapy (i.e., Society of Thoracic Surgeons CMS
operative risk score ≥8% or at a ≥15% risk of mortality at 30 days).

All implanted patients (as described Primary: Five years of surveillance Linkage to CMS for longer-
in the approved indication) in the (1) Device success (intra-procedure) term outcomes of interest
STS/ACC TVT Registry within 5 (2) all-cause mortality, all stroke, life-threatening (or disabling) bleeding, acute kidney injury-stage 3
years of device approval (including renal replacement therapy), peri-procedural myocardial infarction, repeat procedure for
valve-related dysfunction (surgical or interventional therapy) at 30 days and 12 months;
(3) neurological, vascular and quality of life outcomes at 30 days and 12 months;
(4) all-cause mortality, neurological and vascular outcomes annually through 5-year post
implantation.
Narrative:
Surveillance will be conducted in the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the CoreValve system in implanted patients within 5 years
of device approval. Follow up of these patients will be conducted through linkage to the CMS database for long-term surveillance through 5 years’ post implantation.
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P130009/S057 Edwards SAPIEN XT The Edwards SAPIEN XT transcatheter heart valve (THV), model 9300TFX, and accessories are STS/ACC TVT Registry Postmarket: CoA to
Supplement to Lifesciences, Transcatheter indicated for relief of aortic stenosis in patients with symptomatic heart disease due to use TVT Registry with
expand LLC Heart Valve severe native calcific aortic stenosis who are judged by a heart team, including a cardiac CMS linkage to CMS for
indication surgeon, to be at intermediate or greater risk for open surgical therapy (i.e., predicted risk of postmarket
surgical mortality ≥ 3% at 30 days, based on the Society of Thoracic Surgeons (STS) risk score surveillance.
and other clinical co-morbidities unmeasured by the STS risk calculator).

Population Key Elements or Endpoints from RWE Source Follow-up / Methods of note
Duration
All implanted patients, with intermediate or Primary: Five years of Linkage to CMS for longer-term
greater risk for open surgical therapy, in the (1) Device success (intra-procedure); surveillance outcomes of interest
TVT-registry within five years of the device (2) all-cause mortality, all stroke, life-threatening/major bleeding, new requirement for
approval dialysis, peri-procedural myocardial infarction, and repeat procedure for valve-related
dysfunction (surgical or interventional therapy) at 30 days and 12 months;
(3) neurological complications (non-stroke), vascular complications, and quality of life
(KCCQ) outcomes at 30 days and 12 months;
(4) all-cause mortality, all stroke, and repeat procedure for valve-related dysfunction
(surgical or interventional therapy) at 2-5 years post implantation
Narrative:
Surveillance will be conducted in the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the SAPIEN XT THV in implanted patients (at intermediate
or greater risk for open surgical therapy) within 5 years of device approval. Follow up of these patients will be conducted through linkage to the CMS database for long-term
surveillance through 5 years post implantation
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Registry and Claims Data for Condition-of-Approval [111]
P130021/S033 Medtronic CoreValve The Medtronic CoreValve, CoreValve Evolut R, CoreValve Evolut PRO systems are indicated for STS/ACC TVT Registry Postmarket: CoA to
Supplement to CoreValve LLC System relief of aortic stenosis in patients with symptomatic heart disease due to severe native calcific use TVT Registry
expand aortic stenosis who are judged by a heart team, including a cardiac surgeon, to be at intermediate CMS with linkage to CMS
indication or greater risk for open surgical therapy (i.e., predicted risk of surgical mortality ≥ 3% at 30 days, for postmarket
based on the Society of Thoracic Surgeons (STS) risk score and other clinical comorbidities surveillance.
unmeasured by the STS risk calculator).

Population Key Elements or Endpoints from RWE Source Follow-up / Methods of Note
Duration
All implanted patients, with intermediate or Primary: Five years of Linkage to CMS for longer-term
greater risk for open surgical therapy, in the (1) Device success (intra-procedure); surveillance outcomes of interest
TVT-registry (2) all-cause mortality, all stroke, life-threatening/major bleeding, new requirement for
dialysis, peri-procedural myocardial infarction, and repeat procedure for valve-related
(3) neurological complications (non-stroke), vascular complications, and quality of life
(KCCQ) outcomes at 30 days and 12 months;
(surgical or interventional therapy) at 2-5 years post implantation.
Narrative:
Surveillance will be conducted in the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the CoreValve system in implanted patients (at
intermediate or greater risk for open surgical therapy). Follow up of these patients will be conducted through linkage to the CMS database for long-term surveillance through 5
years post implantation
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P140031/S010 Edwards SAPIEN 3 The Edwards SAPIEN 3 Transcatheter Heart Valve (THV), model 9600TFX, and accessories are STS/ACC TVT Registry Postmarket: CoA to
Lifesciences, LLC Transcathete indicated for relief of aortic stenosis in patients with symptomatic heart disease due to severe CMS use TVT Registry with
r Heart Valve native calcific aortic stenosis who are judged by a heart team, including a cardiac surgeon, to be linkage to CMS for
at intermediate or greater risk for open surgical therapy (i.e., predicted risk of surgical mortality postmarket
≥ 3% at 30 days, based on the Society of Thoracic Surgeons (STS) risk score and other clinical co- surveillance.
morbidities unmeasured by the STS risk calculator)

Population Key Elements or Endpoints from RWE source Follow-up Methods of note Population
All implanted patients, with Primary endpoints: Five years of Linkage to CMS for All implanted
intermediate or greater risk for open (1) Device success (intra-procedure) surveillance longer-term patients, with
surgical therapy, in the TVT registry (2) all-cause mortality, all stroke, life-threatening/major bleeding, new requirement outcomes intermediate or
within five-years of the device approval for dialysis, myocardial infarction, and repeat procedure for valve-related dysfunction greater risk for
(surgical or interventional therapy) at 30 days and 12 months; open surgical
(3) neurological complications (non-stroke), vascular complications, and quality of life therapy, in the
(KCCQ) outcomes at 30 days and 12 months; TVT registry
(4) all-cause mortality, all stroke and repeat procedure for valve-related dysfunction within five-years
(surgical or interventional therapy) at 2-5 years post implantation. of the device
approval
Narrative:
This surveillance plan will use the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the SAPIEN 3 Transcatheter Heart Valve in patients at
intermediate or greater risk for open surgical therapy. Follow up of these patients will be performed through linkage to the CMS database for long-term surveillance through 5
years post implantation.
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Example 49. PMA - Postmarket Surveillance of a Mitral Valve Repair Device Utilizing a National
Registry and Claims Data for Condition-of-Approval [114, 115]
P100009/S028 Abbott MitraClip NT Clip The MitraClip NT Clip Delivery System and MitraClip NTR/XTR Clip Delivery System, when STS/ACC TVT Registry Postmarket: Post-
Vascular Inc. Delivery System used with maximally tolerated guideline-directed medical therapy (GDMT), are indicated Centers for Medicare approval study using
and MitraClip for the treatment of symptomatic, moderate-to-severe or severe secondary (or functional) and Medicaid Services STS/ACC TVT Registry
NTR/XTR Clip mitral regurgitation (MR; MR ≥ Grade III per American Society of Echocardiography (CMS) claims database. with linkage to CMS
Delivery System criteria) in patients with a left ventricular ejection fraction (LVEF) ≥ 20% and ≤ 50%, and a
left ventricular end systolic dimension (LVESD) ≤ 70 mm whose symptoms and MR severity
persist despite maximally tolerated GDMT as determined by a multidisciplinary heart team
experienced in the evaluation and treatment of heart failure and mitral valve disease.

Duration
STS/ACC TVT Registry: Continued follow-up Primary Endpoints: Five years Linkage to CMS claims data for
of patients enrolled in the continued access Clinical data up-to-one year collected using the TVT Registry. Follow-up data will include follow-up data
protocol and consecutive patients treated All-cause mortality, Stroke, Repeat-procedure for mitral valve-related dysfunction, and
with the subject device for the indication Hospitalization.
Narrative:
The sponsor submitted this PMA supplement to modify the indications for use statement to include secondary mitral regurgitation. As a condition-of-approval, the sponsor will
perform a post-approval study that will use the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the MitraClip System and to collect annual,
follow-up data of subjects enrolled in the continued access protocol study. Follow-up of these patients will be performed through linkage to the CMS database for long-term
surveillance through 5 years post-implantation
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P130021/S058 Medtroni Medtronic The Medtronic CoreValve Evolut R System and Medtronic CoreValve Evolut PRO System STS/ACC TVT Registry Postmarket: Post-
c CoreValve Evolut are indicated for relief of aortic stenosis in patients with symptomatic heart disease due CMS approval study using
CoreValve R System, to severe native calcific aortic stenosis who are judged by a heart team, including a STS/ACC TVT Registry
LLC Medtronic cardiac surgeon, to be appropriate for the transcatheter heart valve replacement with linkage to CMS
CoreValve Evolut therapy.
PRO System
Postmarket use – STS/ACC TVT Registry

Duration
STS/ACC TVT Registry: Continued follow-up Primary Endpoints: Ten years Linkage to CMS claims data for
of patients enrolled in the continued access (1) Device success (intra-procedure); follow-up data
protocol and consecutive patients treated (2) All-cause mortality, all stroke, life-threatening/major bleeding, new requirement for
with the subject device for the low-risk dialysis, peri-procedural myocardial infarction, and repeat procedure for valve-related
indication dysfunction (surgical or interventional therapy) at 30 days and 12 months;
(3) neurological (non-stroke), vascular complications, and quality of life (KCCQ) outcomes
at 30 days and 12 months; and
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Narrative:
The sponsor submitted this PMA supplement to modify the indications for use statement to include patients at low-risk for surgical aortic valve replacement (SAVR). As a
condition-of-approval, the sponsor will perform a post-approval study that will use the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the
CoreValve Evolute R and PRO system. Follow up of these patients will be performed through linkage to the CMS database for long-term surveillance through ten years post
implantation. Additionally, the post-approval study will continue to follow subjects enrolled in the continued-access protocol study using the STS/ACC TVT Registry for data
collection.
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P140031/S085 Edwards Lifesciences Edwards SAPIEN 3 The Edwards SAPIEN 3 Transcatheter Heart Valve System and Edwards STS/ACC TVT Registry Postmarket: Post-
LLC Transcatheter Heart Valve SAPIEN 3 Ultra Transcatheter Heart Valve System are indicated for relief of CMS approval study using
System, Edwards SAPIEN 3 aortic stenosis in patients with symptomatic heart disease due to severe STS/ACC TVT Registry
Ultra Transcatheter Heart native calcific aortic stenosis who are judged by a heart team, including a with linkage to CMS
Valve System cardiac surgeon, to be appropriate for the transcatheter heart valve
replacement therapy.

Population Key Elements or Endpoints from RWE source Follow-up Methods of Note
STS/ACC TVT Registry: Continued follow-up of Primary endpoints: Ten years Linkage to CMS for longer-term
patients enrolled in the continued access protocol (1) Device success (intra-procedure) outcomes
and consecutive patients treated with the subject (2) all-cause mortality, all stroke, life-threatening/major bleeding, new requirement
device for the low-risk indication for dialysis, myocardial infarction, and repeat procedure for valve-related
(3) neurological complications (non-stroke), vascular complications, and quality of
life (KCCQ) outcomes at 30 days and 12 months;
(4) all-cause mortality, all stroke and repeat procedure for valve-related dysfunction
Narrative:
The sponsor submitted this PMA supplement to modify the indications for use statement to include patients at low-risk for surgical aortic valve replacement (SAVR). As a
condition-of-approval, the sponsor will perform a post-approval study that will use the STS/ACC TVT Registry to monitor long term durability, safety and effectiveness of the
SAPIEN 3 and SAPIEN 3 Ultra systems. Follow up of these patients will be performed through linkage to the CMS database for long-term surveillance through ten years post
implantation. Additionally, the post-approval study will continue to follow subjects enrolled in the continued-access protocol study using the STS/ACC TVT Registry for data
collection.
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Example 52. Continued-Access Program Leveraging National Registry and Claims Data for Data
Collection [45, 118]

NCT02687035 Edwards SAPIEN 3 The Edwards SAPIEN 3 Transcatheter Heart Valve (THV), model 9600TFX, and STS/ACC TVT Registry Continued-access program leveraging
Lifesciences, accessories are indicated for relief of aortic stenosis in patients with CMS TVT Registry and CMS databases for data
LLC symptomatic heart disease due to severe native calcific aortic stenosis who are collection
judged by a heart team, including a cardiac surgeon, to be at intermediate or
greater risk for open surgical therapy (i.e., predicted risk of surgical mortality ≥
3% at 30 days, based on the Society of Thoracic Surgeons (STS) risk score and
other clinical co-morbidities unmeasured by the STS risk calculator)
Continued Access Protocol – STS/SCC TVT Registry

Source
PARTNER II S3iCAP Using the TVT Registry: Severe aortic Primary: STS/ACC TVT Registry (screening to Data entered into STS/ACC TVT Registry
stenosis patients at intermediate risk for standard aortic Stroke (30 days) one year) with linkage to CMS for longer-term
valve replacement. (1822 patients, continued-access Aortic valve reintervention (30 days) outcomes
program). Data to be entered into STS/ACC TVT Registry. Death (30 days) Five-year follow-up (through CMS
linkage)
Narrative:
The PARTNER II S3iCAP is a continued-access program to provide continued access of the device to patients. Data will be collected in the STS/ACC TVT Registry with linkage to
CMS.
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Appendix Section IV. Examples Utilizing Medical Records as Real-World Evidence
Guide to Examples Utilizing Medical Records as Real-World Evidence
Source(s)
53 K171120 TransEnterix, Senhance Surgical Retrospective review of Premarket: Data extracted from a retrospective Medical records (EHR,
Inc. System medical records medical chart review was compared to performance EMR or chart review);
drawn from published literature to support the RWE as a primary source
clearance of this new robotically assisted surgical of clinical evidence;
device.
54 K172959 PeraHealth, PeraServer and Medical record data used Premarket: Three publications were submitted for Digital Health Example;
Inc. PeraTrend System for validation of software this 510(k), in which the subject software as a medical Medical records (EHR,
as a medical device (SaMD) device (SaMD) product was tested on data from EMR or chart review);
product retrospective medical records of adult and pediatric
patients.
55 K180111 Pursuit ClearGuard HD Data abstraction from Premarket: RWE was a primary source of clinical Medical records (EHR,
Vascular, Inc. Antimicrobial electronic health records evidence supporting modifying the indications for use EMR or chart review);
Barrier Cap and National Healthcare statement to include information related to reduction RWE as a primary source
Safety Network (NHSN) of bloodstream infection. The sponsor performed a of clinical evidence;
Dialysis Event forms of cluster-randomized, multi-arm, unblinded study that
patients from forty (40) analyzed routinely-collected blood infection
dialysis centers in the US
surveillance data from 40 dialysis centers in the US.
56 K180163 TransEnterix, Senhance Surgical Retrospective review of Premarket: Data extracted from retrospective Medical records (EHR,
Inc. System medical records from four medical chart reviews on the performance of the EMR or chart review);
(4) OUS sites subject device was compared to data from published Outside-the-US;
literature on laparoscopic procedures, and used as RWE as a primary source
the primary support to expand the indication of this of clinical evidence;
robotically assisted surgical device to include inguinal
hernia repair and cholecystectomy procedures.
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57 K180894 Levita Levita Magnetic Retrospective review of Premarket: Data extracted from a retrospective Medical records (EHR,
Magnetics Surgical System medical records from one review of medical records were used to support EMR or chart review);
International (1) US site modifications to the indications for use statement RWE as a primary source
Corp. to include use to retract the liver in bariatric of clinical evidence;
procedures and an expansion of the Body Mass
Index (BMI) range for patients.
58 K180986 XableCath, XableCath Support Retrospective review of Premarket: RWE was the sole source of clinical Medical records (EHR,
Inc. Catheter Product OUS medical records evidence, with data from a retrospective medical EMR or chart review);
Family records review of patients treated OUS supporting Outside-the-US;
the determination of substantial equivalence. RWE as a primary source
59 K181323 C. R. Bard, Atlas Gold PTA Retrospective review of Premarket: Data extracted from a retrospective Medical records (EHR,
Inc. Dilatation Catheter medical records from one review of medical records were used to support EMR or chart review);
(1) US site expansion of the indications for use for the device RWE as a primary source
to include use in the venous system. of clinical evidence;
60 K191173 Abbott Emboshield NAV6 Retrospective review of Premarket: Data extracted from a retrospective Medical records (EHR,
Vascular Embolic Protection medical records from one review of medical records were used to support EMR or chart review);
System (1) US site modifications to the indications for use statement RWE as a primary source
to include use while performing atherectomy in of clinical evidence;
lower extremity arteries.
61 DEN170001 Vapotherm, Precision Flow Vermont Oxford Network Premarket: RWE was the sole source of evidence Medical records (EHR,
Inc. HVNI Database for the pediatric and neonate population for this EMR or chart review);
submission. The sponsor submitted a retrospective Pediatric RWE;
study of medical chart data of patients treated with
the subject device for high velocity nasal infusion
that was compared to neonate outcome data with
CPAP treatment from the Vermont Oxford Network.
62 DEN170015 Wilson-Cook Hemospray Three (3) outside-the-US Premarket: RWE was a primary source of clinical Medical records (EHR,
Medical, Inc. Endoscopic postmarket studies evidence for this de novo, which included a registry EMR or chart review);
Hemostat study with data submitted by physicians to a Outside-the-US;
database and two postmarket studies, all conducted RWE as a primary source
OUS. of clinical evidence;
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63 DEN170064 Rapid- Comaneci Retrospective review of Premarket: The primary source of clinical evidence Medical records (EHR,
Medical Ltd Embolization Assist medical records from two for this de novo was a retrospective case series of EMR or chart review);
Device (2) OUS sites patients treated OUS, with data collected from the Outside-the-US;
patients’ medical records using a prespecified data RWE as a primary source
collection form. of clinical evidence;
64 DEN170073 Viz.Al, Inc ContaCT Radiology reports and Premarket: This is a radiological computer aided Digital Health Example;
Real-world Literature triage and notification software. A secondary RWE Medical records (EHR,
analysis compared the standard-of-care notification EMR or chart review);
time extracted from radiologist reports against a Performance goal or
comparable metric from standalone testing. comparator derived from
RWE;
65 P160022 Zoll Medical X Series, R Series, Device-generated and Premarket: Prior clinical trial data and real-world Device-generated data;
Corporation AED Pro, AED 3 BLS clinical data from out-of- evidence, including device-generated data and Medical records;
Professional hospital use, medical clinical data recorded by the AEDs during routine
Defibrillators, Pro- records RWE as a primary source
field use, were used to support approval after call of clinical evidence;
Padz for premarket approval applications for AEDs.
Radiotransparent Total-Product Lifecycle
Electrode, etc. Postmarket: Post-approval study will collect ECG Example;
(See Approval waveform and device data from devices used to
Order for full list) treat patients in cardiac arrest during routine use.
These data will then be analyzed to compare the
performance of the device's algorithm against
expert annotation
66 P140010/S037 Medtronic IN.PACT Admiral IN.PACT Admiral DCB Long Premarket: RWE was the primary source of clinical Medical records (EHR,
Vascular, Inc. Paclitaxel-Coated Lesion Sub-Cohort Clinical data supporting expanding the indication to include EMR or chart review);
Percutaneous Evaluation (US and OUS) treatment of long lesions of up to 410 mm. The Outside-the-US;
Transluminal RWE consisted of a retrospective analysis of the RWE as a primary source
Angioplasty (PTA) Long Lesion Sub-Cohort from the sponsor’s global of clinical evidence;
Balloon Catheter study of the subject device.
67 P140017/S005 Medtronic, Melody TPV Real-world study (medical Premarket: For this indication expansion, the Medical records;
Inc. records, 10 sites) primary source of clinical evidence was from RWE as a primary source
medical records collected across 10 sites and of clinical evidence;
pooled with data from two post-approval studies
for analysis.
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Example 53. 510(k) - Clearance of New Robotically Assisted Surgical Device Using a Retrospective
Review of Medical Records [119]
K171120 TransEnterix, Senhance The Senhance Surgical System is intended to assist in the accurate control of Retrospective Premarket: Primary source
Inc. Surgical System laparoscopic instruments for visualization and endoscopic manipulation of tissue review of medical of clinical evidence
including grasping, cutting, blunt and sharp dissection, approximation, ligation, records
electrocautery, suturing, mobilization and retraction in laparoscopic colorectal surgery
and laparoscopic gynecological surgery. The system is indicated for adult use. It is Real-world
intended for use by trained physicians in an operating room environment in Literature
accordance with the Instructions for Use.

Gynecological Laparoscopic Surgery (Non-RWE): Key Elements: Surgical complication, post-surgical adverse events, reoperation, Results from surgeries with subject device were
Prospective non-randomized open-label clinical trial readmission, mortality, transfusion, conversion to standard laparoscopy, operative compared to results from published literature of
of gynecological laparoscopic surgical patients time, hospital length of stay. the predicate device (some of which were
(n=150) treated with the subject device. drawn from real-world use).
See 510(k) Summary for additional details and complete list
Colorectal Laparoscopic Surgery (RWE):
Retrospective review of medical records of colorectal
surgical patients (n=45) treated with the subject
device.
Narrative:
Clinical data were provided to support use of this device in laparoscopic colorectal surgery and laparoscopic gynecological surgery. For use in gynecological procedures, data
were drawn from a prospective non-randomized clinical trial for 150 patients undergoing surgery with the Senhance system. These data were compared to results from
published literature of the predicate device (8 publications, more than 8,000 gynecological operations). For use in colorectal laparoscopic surgery, data were from a
retrospective case series review of 45 patients undergoing colorectal procedures using the Senhance system. These data were compared to results from published literature of
the predicate device (11 publications, more than 5,000 colorectal operations).
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Example 54. 510(k) - Clearance of a New Adjunct to Multiparameter Patient Monitor Using Data
from Electronic Medical Records for Validation [120, 121, 122, 123]
K172959 PeraHealth, PeraServer The Rothman Index uses commonly recorded vital sign, nursing assessment, and lab data Electronic medical Premarket: Validation
Inc. and PeraTrend to compute a patient status index. The Rothman Index is a single measure of a patient’s records using data from
System physiologic condition based on the aggregate statistical mortality risk associated with the electronic medical
values of the patient’s vital signs, nursing assessments, and selected lab values. records
PeraServer is indicated for use wherever there is interest in generating Rothman Index (RI)
scores and/or associated configurable warnings.
PeraTrend is indicated for use by healthcare providers whenever there is need for
displaying and/or trending RI scores and displaying associated configurable warning states
as an adjunct to clinical decision support.
PeraServer/PeraTrend is intended for the care of patients throughout the hospital setting
(e.g., in the emergency department, on the wards, in intensive care units).
The Rothman Index score is validated for use with neonatal, pediatric, and adult patients.
It is an adjunct-to and is not intended to replace vital signs monitoring and is not intended
for use in the Neonatal Intensive Care Unit.
Premarket Use –Data from Patient Medical Records Used for Validation
Population Methods of Note
Adult (RWE): Model development and validation using data calculated from the electronic medical records of adult patients The Rothman Index (RI) score was validated in adult and
(n~170,000 patients) pediatric patients using data and outcomes derived from
electronic medical records. Additionally, real-world
Pediatric (RWE): Model development and validation using data calculated from the electronic medical records of pediatric literature was provided describing a comparison between
patients (105,470 patient visits) the RI score and the modified early warning score using
data derived from the electronic medical record (32,472
Modified Early Warning Score Comparison (RWE): Comparison between the Rothman Index and the modified early warning patient visits)
score using data calculated from the electronic medical record (32,472 patient visits)
Narrative:
The subject device is a software platform that extracts data from the electronic medical record to compute a Rothman Index score (and associated warnings), which are then
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displayed to the user. For this 510(k), the sponsor demonstrated the validity of the RI score by providing data from three publications. Two publications described the validation
of the RI score calculated using data and outcomes retrospectively derived from the electronic medical records of adult and pediatric patients. The third publication provided a
comparison between the RI score and the modified early warning score calculated using data derived from the electronic medical records. This submission is an example of using
real-world data from the electronic medical or health record as source data for validating a software-only device.
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Example 55. 510(k) - Modification to Indications for Use Statement for a Hemodialysis Catheter
End Cap Using a Cluster-Randomized Trial with Data Abstracted from Electronic Health Records
and National Healthcare Safety Network (NHSN) Dialysis Event Forms of Patients [124, 125, 126, 127]
K180111 Pursuit ClearGuard ClearGuard HD Antimicrobial Barrier Cap is indicated for use with hemodialysis catheter hubs. Cluster- Premarket:
Vascular, Inc. HD randomized, Primary source of
Antimicrobial Using in vitro methods, the antimicrobial treatment on the ClearGuard HD Antimicrobial Barrier Cap has multi-arm, clinical evidence
Barrier Cap been shown to be effective at reducing microbial colonization in hemodialysis catheter hubs against the unblinded study
following microorganisms: Enterococcus faecium (VRE), Enterococcus faecalis (VRE), Acinetobacter using routinely
baumannii, Escherichia coli, Staphylococcus aureus (MRSA), Staphylococcus aureus, Staphylococcus collected data at
epidermidis (MRSE), Pseudomonas aeruginosa, Candida albicans and Candida parapsilosis and has not been 40 dialysis
shown to be effective against Candida paratropicalis and Klebsiella pneumoniae. centers
throughout the
Using Postmarket clinical surveillance data, use of the ClearGuard HD Antimicrobial Barrier Cap has been US.
shown to reduce the incidence of central-line associated bloodstream infections (CLABSI) in hemodialysis
patients with catheters. Note: CLABSI was defined as a positive blood culture (PBC) not related to an
alternative source of infection per the National Healthcare Safety Network (NHSN) surveillance definition.
Alternative sources were excluded if dialysis sites attributed the PBC to vascular access on the dialysis event
form. The actual reduction in CLABSI rates may be less substantial as the evaluation for alternative PBC
sources was not pre-specified, nor standardized between patients and clinical sites, and supplemental data
evaluating for alternative sources were not available for review.
The subject device is not intended to be used for the treatment of existing infections. The antimicrobial is
only present within the hub of the catheter and does not migrate to distal portions of the catheter.
Premarket Use – Prospective Study of Hemodialysis Centers Participating in the CDC National
Healthcare Safety Network
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DaVita Dialysis Centers Participating in the CDC National Healthcare Primary: This submission included the results of a
Safety Network (RWE): The US Centers for Disease Control and The pre-specified primary study endpoint was the rate of positive blood cluster-randomized prospective open-
Prevention (CDC) maintains the National Healthcare Safety Network culture. An additional exploratory ad-hoc analysis was conducted to label study that took advantage of
(NHSN) to track healthcare-associated infection (HAI) in Ambulatory explore the possible reduction of Central Line-Associated Bloodstream existing public-health data collection for
Surgery Centers, Acute and long-term Care Hospitals and Facilities, Infection (CLABSI). the NHSN.
Outpatient Dialysis Facilities and other healthcare facilities. As participants
in the NHSN, DaVita routinely collects information on patients receiving Data were abstracted from the
hemodialysis. During the study, 1,671 subjects participated. electronic health record and from the
NHSN Dialysis Event form.
Narrative:
In K180111, the sponsor sought to modify the indications for use statement to include information related to reduction of bloodstream infection. The clinical data used to
support clearance of the modification were generated from a cluster-randomized prospective open-label study conducted in 40 dialysis centers across the US, randomized to use
either the subject device or a comparator in a 1:1 ratio. The variables collected for this study were those routinely collected by dialysis centers as part of participation in the
CDC’s NHSN for routine blood infection surveillance. In this study, patients were treated according to the local standard of care, which included blood culture specimen
collection for routine blood infection surveillance. Blood cultures were analyzed by a clinical laboratory and the results were entered into the patient’s electronic health record
(EHR) and to the NHSN Dialysis Event form for reporting to the NHSN. Data were then abstracted for the purposes of the study. The information was considered sufficient to
support adding to the indications for use a statement that addressed reduction in CLABSI for dialysis patients treated with the subject device.
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Example 56. 510(k) - Modification to Indications for Use Statement for a Robotic Surgical System
Using Retrospective Reviews of Medical Records [128]
K180163 TransEnterix, Transenterix The Senhance Surgical System is intended to assist in the accurate control of Retrospective Premarket: Primary source
Inc. Senhance laparoscopic instruments for visualization and endoscopic manipulation of tissue review of medical of clinical evidence
Surgical System including grasping, cutting, blunt and sharp dissection, approximation, ligation, records (OUS)
electrocautery, suturing, mobilization and retraction. The Senhance Surgical System is
intended for use in laparoscopic gynecological surgery, colorectal surgery,
cholecystectomy, and inguinal hernia repair. The system is indicated for adult use. It is
intended for use by trained physicians in an operating room environment in
accordance with the Instructions for Use.

Cholecystectomy Case Series (RWE): Two Key Elements: Conversion to laparoscopy, conversion to open technique, Results from surgeries with subject device were
retrospective chart reviews of 40 patients who had intraoperative and postoperative complications, reoperations, readmissions related compared to results from published literature of
robotic cholecystectomy procedures performed with to procedure, transfusion, operative time, mortality the predicate device.
the subject device
See 510(k) Summary for additional details and complete list.
Inguinal Hernia Repair Surgery Data (RWE):
Retrospective chart review of 64 patients who had
robotic transabdominal preperitoneal inguinal hernia
repair performed with subject device
Narrative:
For this 510(k) submission, the sponsor sought to expand the subject device indication to include laparoscopic inguinal hernia repair and cholecystectomy (gallbladder removal)
procedures. The sponsor submitted clinical evidence consisting of two retrospective chart reviews of robotic cholecystectomies performed with the subject device that were
compared to clinical data on use of the predicate robotic device and conventional laparoscopic procedures derived from published literature. For the inguinal hernia procedure,
they submitted a retrospective chart review study of patients who underwent surgery with the subject device, that was also compared to clinical literature on procedures
performed with the predicate robotic device and with conventional laparoscopy. This real-world evidence, along with the cited literature, was used to support a decision of
substantial equivalence.
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Example 57. 510(k) - Modification to Indications for Use and Labeling for Magnetic Surgical
Instrument System Using a Retrospective Review of Medical Records [129]
K180894 Levita Levita Magnetic Surgical System The Magnetic Surgical System is designed to grasp and retract Retrospective Premarket: Primary source
Magnetics the body and the fundus of the gallbladder in laparoscopic review of medical of clinical evidence
International cholecystectomy procedures and the liver in bariatric records
Corp. procedures to facilitate access and visualization of the surgical
site. The device is indicated for use in patients with a BMI range
of 20-60 kg/m2.

Retrospective Review of Medical Records (RWE): A retrospective clinical Primary:
study of 73 subjects with ten participating surgeons Successful completion of laparoscopic bariatric surgery using the device
Mean operative times
Outside-the-US Prospective Study (Non-RWE): An OUS prospective clinical Adverse Events, including intraoperative complications, morbidity and mortality at follow-up.
study of 30 subjects with three participating surgeons.
Narrative:
In this submission, real-world evidence was provided to support modification to the indications for use statement and labeling of a magnetic surgical device intended aid in
retraction and visualization of specific organs during surgical procedures. The modification includes use to retract the liver in bariatric procedures and an expansion of the BMI
range for patients. Two different studies provided clinical data supporting this submission: real-world evidence from a retrospective evaluation of patients treated with the
subject device and a prospective open-label study conducted OUS. The information from these studies was used to support a substantial equivalence determination.
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Example 58. 510(k) - Clearance of an Updated Percutaneous Catheter with Active Tip Using a
Retrospective Review of OUS Medical Records [130]
K180986 XableCath, XableCath The XableCath catheter is intended to be used to facilitate access to discrete regions OUS retrospective Premarket: Sole source of
Inc. Support of the peripheral vasculature in conjunction with steerable guidewires. This device chart review clinical evidence
Catheter may be used to facilitate placement and exchange of guidewires and other
Product Family interventional devices.

Real-World Validation Study: 26 patients who Safety and Effectiveness:
underwent angiography of the lower extremity Procedural complications
through various arterial access sites including Thrombosis
femoral, brachial, and radial locations, with Arterial rupture
therapeutic vascular deployment performed with Distal embolization
subject device Complication at mean follow-up of 53 days post-procedure
Narrative:
For this special 510(k) submission, the clinical evidence submitted was OUS data obtained from an extension of their product validation assessment, including a review of
patients' medical records, which were analyzed for successful device use and adverse event occurrence in the real-world validation study cohort. The submitted real-world
evidence served as the sole support for the determination of substantial equivalence.
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Example 59. 510(k) - Modification to Indications for Use Statement and Labeling for 510(k)
Dilation Catheter Using a Retrospective Review of Medical Records [131, 132, 133]
K181323 C. R. Bard, Atlas Gold PTA The Atlas Gold PTA Dilatation Catheter is indicated for use in Percutaneous Retrospective review of Premarket: Primary source
Inc. Dilatation Transluminal Angioplasty of the peripheral vasculature, including the iliac medical records of clinical evidence
Catheter arteries and iliac and femoral veins, and for the treatment of obstructive
lesions of native or synthetic arteriovenous dialysis fistulae. This device is
also indicated for post-dilatation of stents and stent grafts in the peripheral
vasculature. This catheter is not for use in coronary arteries.
Premarket Use –Retrospective Review of Medical Records

Retrospective Review of Medical Records: Patients Primary Endpoint: Intra-procedural freedom from major adverse events (acute thrombosis, perforation, or device-related
treated with illiofemoral vein compression (61 with complications).
the device post-stent dilation and 20 pre-dilation).
Narrative:
The sponsor submitted this 510(k) submission to modify the indications of use to include use in the venous system and include a summary of the retrospective study results in
the labeling. To support the submission, the sponsor provided clinical evidence from a retrospective analysis of medical records, and a literature review to support an expansion
of the indication for the device. For the retrospective study, patients treated with illiofemoral vein compression from September 1, 2013 to May 30, 2017 were identified during
the medical chart review and data were abstracted from the patient's medical chart. The primary safety endpoint used in the analysis was intra-procedural freedom from major
adverse events, which was compared to a benchmark. These data, along with the literature review, supported FDA's decision of substantial equivalence.
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Example 60. 510(k) - Modification to Indications for Use Statement for Embolic Protection System
Using a Retrospective Review of Medical Records [134]
K191173 Abbott Emboshield NAV The Emboshield NAV Embolic Protection System is indicated for use as a Retrospective review of Premarket: Primary source
Vascular Embolic guide wire and embolic protection system to contain and remove embolic medical records of clinical evidence
Protection material (thrombus/debris) while performing angioplasty and stenting
System procedures in carotid arteries and while performing atherectomy, during
standalone procedures or together with PTA and/or stenting, in lower
extremity arteries. The diameter of the artery at the site of the Filtration
Element placement should be between 2.5 and 7.0 mm.

Retrospective Review of Medical Records: Primary: 30-day freedom from major adverse events, a composite of death, myocardial infarction (MI), thrombosis, dissection (grade C
Patients (n=162) undergoing atherectomy or greater), distal embolization (DE), perforation at the level of the filter, unplanned amputation and target vessel revascularization
procedures using embolic protection devices for (TVR). This endpoint was compared against a performance goal (83%).
treatment of lower extremity lesions.
Narrative:
The submission sought to modify the indications for use statement for the previously cleared device, to include use while performing atherectomy in lower extremity arteries
(LEA). Associated updates were made to contraindications, warnings, precautions and adverse events. The clinical data supporting this modification came from retrospective
review of medical records from the Mt Sinai Health Center of patients treated for lower extremity lesions using the subject device under the practice of medicine. These patients
presented lesions representative of complex PAD, and the rate of freedom from major adverse events after use of the subject device was considered to be sufficient to
demonstrate substantial equivalence.
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Example 61. De Novo - Classification of High Velocity Nasal Insufflation Device for Neonates Using
a Retrospective Review of Medical Records [22, 135, 136]
DEN170001 Vapotherm, Precision Flow Precision Flow HVNI is intended for use to add warm moisture to breathing gases Retrospective Premarket: One of the
Inc. HVNI from an external source for administration to a neonate/infant, pediatric and adult review of medical sources of clinical evidence
patients in the hospital and subacute institutions settings. It adds heat and moisture records supporting neonate
to a blended medical air/ oxygen mixture and assures the integrity of the precise population indication
air/oxygen mixture via an integral oxygen analyzer. The flow rates may be from 1 to
40 liters per minute via nasal cannula.
Precision Flow HVNI provides high velocity nasal insufflation (HVNI) with
simultaneous oxygen delivery to augment breathing of spontaneously breathing
patients suffering from respiratory distress and/or hypoxemia in the hospital setting.
Precision Flow HVNI is not intended to provide total ventilatory requirements of the
patient and not for use during field transport.

Vermont Oxford Network Database Retrospective Safety and Effectiveness:
EMR Review (RWE): 1,363 very low birth weight Pneumothorax
infants (<1500 g) with respiratory failure treated at Nosocomial infection
critical care centers Oxygen use (28 days, 36 weeks, and at home)
Retinopathy of prematurity
Randomized Clinical Trial in Adult Patient Population Intraventricular hemorrhage
(Non-RWE): 204 adult patients presenting with Length of hospital stay
respiratory failure not requiring intubation
Narrative:
For this De Novo classification request, the sponsor was seeking an indication for their device in adult, pediatric, and neonate populations. They performed a randomized clinical
trial for the adult population and submitted a literature review for the neonate population. The sponsor submitted four studies in neonates, including three small prospective
studies, and one retrospective study. The retrospective study analyzed medical chart data from patients treated at five centers and compared it to neonate outcome data from
the Vermont Oxford Network to show safety and efficacy for high velocity nasal infusion compared to CPAP. These data supported the granting of the classification request for a
neonatal indication.
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Example 62. De Novo - Classification of a Hemostatic Device for Intraluminal Gastrointestinal
Bleeding Using Medical Records from OUS Postmarket Studies [15, 137]
DEN170015 Wilson-Cook Medical, Hemospray Endoscopic Hemostat The COOK Hemospray Endoscopic Hemostat is used for OUS postmarket Premarket: Primary source
Inc. hemostasis of non-variceal gastrointestinal bleeding. studies of clinical evidence
Peer-reviewed real-
world literature
Premarket Use – OUS Postmarket Studies

Premarket Pilot Study (Non-RWE): OUS early feasibility study of 20 patients Safety and Effectiveness:
with peptic ulcers. Successful hemostasis achieved by device
Rebleeding within 72 hours
SEAL Registry Study (RWE): 89 patients with upper GI bleeds including peptic Recurrent bleeding
ulcers, bleeding after endoscopic mucosal resection or dissection, diffuse Device-related adverse events
bleeding from gastric malignancy, Mallory-Weiss tears, and upper-GI post-
polypectomy bleeding Secondary:
Initial hemostasis, clinical success, early recurrent bleed, late recurrent bleed, serious adverse GI events
APPROACH Study (RWE): OUS postmarket trial of 50 adult patients with with 30 days of procedure, serious adverse events within 30 days of procedure, 30 day all-cause mortality
nonvariceal lower gastrointestinal bleeding
Peer-Reviewed Literature with Select Studies Conducted Using RWD Sources:

30 studies identified in literature search comprising the treatment of 522
patients with the subject device, with 12 studies utilizing data from registries.
See Summary of Safety and Effectiveness Data for additional details.
Narrative:
For this de novo submission, the clinical evidence submitted included a pilot clinical trial in Hong Kong and three postmarket investigations outside the US: the SEAL registry
survey in Europe and Canada, the HALT Study in Europe and Canada, and the APPROACH study in Canada. The SEAL survey collected clinical data on cases of device use by
having physicians enter case information in a database. The HALT and APPROACH studies, both sponsored by the submitter, were prospective, single-arm studies to assess safety
and effectiveness. These data as well as a literature review were used to support the granted De Novo classification request.
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Example 63. De Novo - Classification of a Temporary Coil Embolization Assist Device Using Real-
World Evidence from Retrospective OUS Case Series [138]
DEN170064 Rapid- Comaneci The Comaneci Embolization Assist Device is indicated for use in the neurovasculature as a Patient medical Premarket: Primary
Medical Ltd Embolization temporary endovascular device used to assist in the coil embolization of wide-necked records source of clinical
Assist Device intracranial aneurysms with a neck width ≤ 10 mm. A wide-necked intracranial aneurysm evidence
defines the neck width as ≥ 4 mm or a dome-to-neck ratio < 2.
Premarket Use – Data from Patient Medical Records Used for Validation
Medical Records: 63 consecutively-treated patients Adverse events Data was abstracted from patient medical
with intracranial aneurysms treated with the Technical success records using a pre-specified data collection
subject device at two outside-the-US sites Please see Decision Summary for complete list and for additional details. form
Narrative:
For this de novo classification request, the sponsor provided clinical evidence from a retrospective case series of patients consecutively treated between March and December
2017 from two outside-the-US sites. Data were abstracted using a prespecified data collection form and the analysis included assessment by an independent imaging lab and as
well as independent event adjudication. These data were the primary source of clinical evidence supporting the submission. To meet the premarket requirement, the sponsor
will also conduct a postmarket study to collect additional data on the device as used in the US population.
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Example 64. De Novo - Classification of a Radiological Computer-Assisted Triage and Notification
Software Using A Secondary Analysis of Medical Records and Real-world Literature [139, 140]
DEN170073 Viz.Al, Inc ContaCT ContaCT is a notification-only, parallel workflow tool for use by hospital networks and Patient medical Premarket: Support a
trained clinicians to identify and communicate images of specific patients to a specialist, records (radiology secondary analysis in
independent of standard of care workflow. reports) standalone testing
ContaCT uses an artificial intelligence algorithm to analyze images for findings suggestive Real-world Literature
of a prespecified clinical condition and to notify an appropriate medical specialist of these
findings in parallel to standard of care image interpretation. Identification of suspected
findings is not for diagnostic use beyond notification. Specifically, the device analyzes CT
angiogram images of the brain acquired in the acute setting, and sends notifications to a
neurovascular specialist that a suspected large vessel occlusion has been identified and
recommends review of those images. Images can be previewed through a mobile
application.
Images that are previewed through the mobile application are compressed and are for
informational purposes only and not intended for diagnostic use beyond notification.
Notified clinicians are responsible for viewing non-compressed images on a diagnostic
viewer and engaging in appropriate patient evaluation and relevant discussion with a
treating physician before making care-related decisions or requests. ContaCT is limited to
analysis of imaging data and should not be used in-lieu of full patient evaluation or relied
upon to make or confirm diagnosis.
Premarket Use – Secondary Analysis of Medical Records and Real-World Literature

CT Imaging Datasets and Radiologist Reports: Safety and Effectiveness: Real-world data (notification-time) extracted
(300) CT angiogram (CTA) images (studies) were Standard-of-care notification time from radiologist reports
obtained from two clinical sites in the U.S along
with the corresponding radiologist reports.
Narrative:
This device is an adjunctive workflow and notification tool (software as a medical device) that analyzes CT angiogram images of the brain and notifies a neurovascular specialist
when a large vessel occlusion has been identified for further image review. The sponsor conducted standalone performance testing evaluating the performance of their
algorithm on CT images from two sites against expert-established ground truth. The primary analysis evaluated the sensitivity and specificity of the device's algorithm. A
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secondary analysis (RWE) compared the standard-of-care notification time (extracted from the standard-of-care final radiologist report documenting when results were
communicated to a specialist) against a comparable metric from the standalone testing of the device. FDA also considered non real-world and real-world literature (e.g. from the
STRATIS Registry) describing the potential patient benefit from earlier endovascular treatment, time from presentation to reperfusion and time to stroke center notification. This
is an example of leveraging real-world data on clinical workflow and notification time to assess the benefit of a SaMD that is used as a parallel workflow and notification tool.
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Example 65. PMA - Approval for Automated External Defibrillator Using Device-Generated Data
and for a Post-Approval Study After Call for PMA [141, 142, 143, 144]
P160022 ZOLL MEDICAL X Series, R Series, Propaq MD, AED Pro, AED 3 For full indication, please see Summary of Safety Device and clinical data from Premarket: Primary source
CORPORATIO BLS Professional Defibrillators, ProPadz and Effectiveness Data. out-of-hospital use, medical of clinical evidence
N Radiotransparent Electrode, SurePower records
Battery Pack, SurePower II Battery Pack, AED Postmarket: CoA with
Pro Non-Rechargeable Lithium Battery Pack, Postmarket RWE collection
AED 3 Battery Pack, SurePower Charger, and
SurePower Single Bay Charger
Premarket Use – Device Generated Data and Real-World Evidence Supporting a PMA Submitted in
Response to a Classification Order
Randomized Multi-Center In-Hospital Clinical Trial for VF/VT Defibrillation (Non-RWE): 192 Safety and Effectiveness: Device-generated data extracted from
patients enrolled in this clinical trial comparing shock efficiency of the device's rectilinear Initial Shock Success AED devices used commercially in the
biphasic waveform against a monophasic damped sine waveform. Subsequent Shock Success field.
Return of spontaneous circulation
In-Hospital Study (Non-RWE): Patients undergoing coronary artery bypass graft (CABG) surgery
(n=20).
Published Literature (RWE): Out-of-hospital cardiac patients with VF treated with the
rectilinear biphasic waveform (n=94).
Narrative:
This PMA was submitted to fulfil requirements imposed by a Final Order (Docket FDA-2013- N-0234) issued on January 29, 2015, which required premarket approval of Class III
Automated External Defibrillators (AED). The devices in this PMA were first cleared under K112432, K060559, and K041892. For this PMA, FDA reviewed clinical data from three
prior studies, including a published observational study of out-of-hospital use by responding EMTs. This study included analyses of device data from the AED following use by
EMTs and survival data of patients transported to treating hospitals.
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Postmarket Use – Post-Approval Study Supported by Real-World Data Collection (Device-Generated
Data)
Device-Generated Data: Device and clinical Primary Endpoints: N/A
data recorded by the AED from patients in Accuracy of the device's algorithm compared to expert, annotation of ECG data files
cardiac arrest and who receive attempted captured by the device during routine use of the device.
resuscitation using the device.
Narrative:
For this post-approval study, the sponsor will collect ECG waveform and device data from devices used to treat patients in cardiac arrest during routine use. These data will then be
analyzed to compare the performance of the device's algorithm against expert annotation. This example illustrates the use of real-world and device-generated data collection to help
support a post-approval study.
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Example 66. PMA - Modification to Indications for Use Statement for a Drug-Eluting Peripheral
Transluminal Angioplasty Catheter Supported by a Retrospective Review of Medical Records from
the Sponsor’s Database [145]
P140010/S037 Medtronic IN.PACT Admiral The IN.PACT Admiral Paclitaxel-coated PTA Balloon Catheter is indicated for IN.PACT Admiral Premarket: Primary
Vascular, Inc. Paclitaxel-Coated percutaneous transluminal angioplasty, after appropriate vessel preparation, of de novo, DCB Long Lesion source of clinical
Percutaneous restenotic, or in-stent restenotic lesions with lengths up to 360 mm in superficial femoral Sub-Cohort Clinical evidence
Transluminal or popliteal arteries with reference vessel diameters of 4-7 mm Evaluation (US and
Angioplasty (PTA) OUS)
Balloon Catheter
Premarket Use – Sponsor Registry (US and OUS)

IN.PACT Admiral DCB Long Lesion Sub-Cohort Clinical Primary Safety Endpoint: Freedom from device- and procedure-related death through 30 days post-procedure and
Evaluation (RWE): 227 subjects with lesion length > 180 mm freedom from target limb major amputation and clinically-driven target vessel revascularization (CD-TVR) within 12
based on angiographic core lab assessment, Rutherford Clinical months post-index procedure
Category 2-4, single unilateral treated lesion confirmed by
angiographic core lab and site reported procedure information Primary Effectiveness Endpoint: Primary patency within 12 months post-index procedure, defined as: freedom from
clinically-driven target lesion revascularization (CD-TLR), and freedom from restenosis as determined by Doppler
Ultrasound Peak Systolic Velocity Ratio (PSVR)
See Summary of Safety and Effectiveness Data for additional details and complete list of secondary endpoints.
Narrative:
In this PMA panel track supplement, the sponsor was seeking to expand its indication beyond the 180 mm lesion length previously indicated. The primary clinical evidence
submitted came from analysis of data from patients meeting the retrospectively applied inclusion criteria, comprising the Long Lesion Sub-Cohort from the IN.PACT DCB Global
Study database. These RWD supported the effectiveness for lesion lengths up to 360 mm and served as the primary source of clinical evidence supporting the approval of this
PMA panel track supplement.
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Example 67. PMA - Approval of an Indication Expansion for a Transcatheter Pulmonary Valve
Using Medical Record Data [146]
P140017/S005 Medtronic, Melody The Melody TPV is indicated for use in the management of pediatric and adult patients who Real-world study Premarket: RWD was
Supplement to Inc. Transcatheter have a clinical indication for intervention on a dysfunctional RVOT conduit or bioprosthetic (medical records, 10 pooled with non-
expand indication Pulmonary pulmonary valve that has ≥ moderate regurgitation and/or a mean RVOT gradient ≥ 35 mm Hg sites) RWD and analyzed
Valve descriptively to
support expanded
indication
Premarket Use – Real-World Study

Population Key Elements or Endpoints from RWE Follow-up/Duration (RWE) Methods of Note
Source
Melody TPV Long-Term Follow-up PAS (Non-RWE): Long-term follow- Safety: Baseline, implant procedure, Data were pooled for
up of HDE IDE population (8 patients) Procedure-related serious adverse events discharge, 6 months, and then analysis
Device-related serious adverse events annually.
Melody TPV New Enrollment PAS (Non-RWE): Post-approval study All-cause mortality
following HDE approval (17 patients)
Effectiveness:
Retrospective Analysis (RWE): of 100 consecutive patients (10 sites) Procedural success; TPV dysfunction;
implanted with a Melody TPV within a dysfunctional bioprosthetic Reoperation on the TPV; Catheter re-
pulmonary valve. Patients were treated between 1/25/2010 and intervention on the TPV; Hemodynamic
6/1/2015. performance
Narrative:
Real-world data collected from 10 sites was pooled with data from two post-approval studies. Safety and effectiveness outcomes from this pooled analysis were the primary
source of clinical evidence for the supplement. For assessment of safety, FDA reviewed analyses of freedom from all-cause mortality, stent-related major fracture and
endocarditis as well as procedure and device related serious adverse events. For assessment of effectiveness, FDA reviewed procedural success, freedom from TPV dysfunction,
freedom from TPV reoperation, freedom from catheter TPV re-intervention, and hemodynamic performance. This analysis was used to expand the indications to include
pulmonary valve-in-valve.
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Appendix Section V. Examples Utilizing Other Sources of Real-World Evidence
Guide to Examples Utilizing Other Sources of Real-World Evidence
Source(s)
68 DEN160014 Ovesco RemOVE System OUS compassionate use Premarket: OUS compassionate use data served Outside-the-US;
Endoscopy AG data as the sole source of clinical evidence supporting RWE as a primary
this de novo classification request. source of clinical
evidence;
69 DEN140018 Advanced ESOPHAGEAL OUS Clinical case Premarket: OUS clinical case summaries and Medical records (EHR,
Cooling COOLING DEVICE summaries and chart data patient body temperature charts served as the EMR or chart review);
Therapy, LLC primary source of clinical evidence for this de Outside-the-US;
novo classification request.
RWE as a primary
source of clinical
evidence;
70 DEN150010 DIGNITANA AB DIGNICAP SCALP OUS Postmarket Premarket: For this de novo classification Outside-the-US;
COOLING SYSTEM surveillance data request, OUS postmarket surveillance data served
as a supplemental source of clinical evidence.
71 DEN160006 TVA Medical, everlinQ endoAVF Global everlinQ endoAVF Premarket: Real-world evidence in the form of Outside-the-US;
Inc. System System Clinical Program OUS commercial use data was submitted in
support of this de novo classification request,
serving as a secondary source of clinical evidence
for long term endpoints.
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72 DEN170052 Natural Cycles Natural Cycles Outside-the-US data from Premarket: This is a web and mobile-based Digital Health Example;
Nordic AB a web and mobile-based standalone software application for conception. Outside-the-US;
standalone software For this submission, the sponsor performed a Patient-generated or
application for conception retrospective analysis of data from approximately patient-entered data;
15,000 users of the mobile application. This was a RWE as a primary source
primary source of clinical evidence supporting the of clinical evidence;
De Novo classification request.
73 P120024 Aesculap activL Artificial Explant analysis, medical Postmarket: As a condition-of-approval for this Medical records (EHR,
Implant Disc records PMA original, the sponsor will conduct an explant EMR or chart review);
Systems, Inc. analysis retrieval study over 10 years, including
medical records from each explant case.
74 P160012 Physio-Control, LIFEPAK CR Plus Device-generated data Premarket: Real-world evidence from two Device-generated data;
Inc. Defibrillator, collected during field-use postmarket studies analyzing device-generated Outside-the-US;
LIFEPAK EXPRESS of the AEDs, medical data and clinical details of out-of-hospital use of Pediatric RWE;
Defibrillator, and record review (US and the subject device in adult and pediatric patients
CHARGEPAK OUS) RWE as a primary source
were used to support this premarket approval of clinical evidence;
Battery Charger submitted in response to a classification order for
AEDs.
75 P160032 Defibtech, LLC Lifeline/ReviveR Device-generated and Premarket: Real-world evidence from studies of Device-generated data;
DDU-100, clinical data collected out-of-hospital use of the AEDs, including device- Outside-the-US;
Lifeline/ReviveR during field-use of the generated data and clinical data recorded by the Pediatric RWE;
AUTO DDU-120, AEDs (US and OUS) subject devices in adult and pediatric populations
Lifeline/ReviveR RWE as a primary source
(US and OUS) were used to support approval after of clinical evidence;
VIEW DDU-2300, a call for premarket approval applications for AEDs
Lifeline/ReviveR
following a classification order.
VIEW AUTO DDU-
2200,
Lifeline/ReviveR
ECG DDU-2450,
and
Lifeline/ReviveR
ECG+ DDU-2475
Automated
External
Defibrillators
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76 P160033 Cardiac Science Powerheart AED Device-generated and Premarket: Prior clinical trial data and real-world Device-generated data;
Corporation G3, Powerheart clinical data collected evidence, including device-generated data and Outside-the-US;
AED G3 Plus, and during field-use of the clinical data recorded by the AEDs during routine RWE as a primary source
Powerheart AED AEDs (includes US and field use (includes US and OUS use), were used to of clinical evidence;
G5 OUS use) support approval after call for premarket approval
applications for AEDs.
77 P100022/S020 Cook Medical, Zilver PTX Drug- OUS Postmarket Premarket: For this indication expansion, Outside-the-US;
Inc. Eluting Peripheral surveillance data postmarket surveillance data from Japan served as
Stent a supplemental source of clinical evidence.
78 P010030/S056 ZOLL LifeVest Wearable Sponsor Database, Device- Premarket: This PMA supplement for an indication Device-generated data;
Manufacturing Cardioverter generated data, Real- expansion was solely supported by RWE, including RWE as a primary source
Corporation Defibrillator world Literature device-generated and clinical data in the sponsor’s of clinical evidence;
database, as well as real-world literature analyzing Total-Product Lifecycle
device-generated and clinical data form pediatric Example;
populations.
Postmarket: As part of the condition-of-approval,

the sponsor will collect additional device-
generated and clinical data on patients meeting the
approved indication in the sponsor’s database.
79 P050023/S087 Biotronix, Inc. PROMRI FULL Device-generated data; Postmarket: Postmarket surveillance as a Device-generated data;
BODY SCAN (FBS) home/remote monitoring condition-of-approval will be conducted through a Registry data;
ICD SYSTEM system remote monitoring system to analyze device-
generated data from patients with a post-MRI VF
episode.
80 P120005/S041 Dexcom, Inc. Dexcom G5 Mobile Device-generated data Postmarket: As a condition-of-approval, the Device-generated data;
Continuous during home-use sponsor will perform a home use study of device- Patient-generated or
Glucose generated data and patient-reported data. patient-entered data;
Monitoring System
81 P930016/S044 AMO STAR S4 IR Excimer Retrospective studies Premarket: For this indication expansion, real- Outside-the-US;
Manufacturing Laser System (Published Literature) world literature from two OUS retrospective
USA iDesign Advanced studies of de-identified patient data extracted from
WaveScan Studio a LASIK provider’s medical record database.
System
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82 P020050/S023 Alcon WaveLight EX500 Retrospective studies Premarket: Real-world literature in the form of
Laboratories, Excimer Laser (RWE Literature) two single-site retrospective studies served as a
Inc. System, supplemental source of clinical evidence for this
ALLEGRETTO indication expansion.
WAVE EYE-Q
Excimer Laser
System
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Example 68. De Novo - Classification of an Endoscopic Electroscopic Clip Cutting System Using
OUS Compassionate Use Data [147]
DEN160014 Ovesco remOVE The remOVE System consists of the DC Impulse and the DC Cutter Set. OUS Premarket: Sole source
Endoscopy AG System compassionate use of clinical evidence
The remOVE DC Impulse is a medical electrical device for fragmentation of OTSC data
(endoscopic device for effective treatment of hemorrhage and acute or chronic wall defects
in the GI tract) and FTRD (endoscopic device for full-thickness resection of colorectal
wall lesions) clips made by Ovesco Endoscopy AG for the digestive tract.
The remOVE DC Cutter Set is a set of instruments for use in flexible endoscopy. It
consists of a bipolar DC instrument for the fragmentation of OTSC (endoscopic device for
effective treatment of hemorrhage and acute or chronic wall defects in the GI tract) and
FTRD (endoscopic device for full-thickness resection of colorectal wall lesion) clips from
Ovesco Endoscopy AG, a pair of forceps and a cap for removal of these fragmented clips.
Premarket Use – OUS Compassionate Use Data

European Compassionate Use Data (RWE): 11 patients in Europe who underwent Safety and Effectiveness:
OTSC removal with the subject device Retrieval of clip fragment
Adverse events
OUS Compassionate Use Data (RWE): 74 patients (including 11 patients in above
study) who underwent OTSC removal with subject device
Narrative:
For this de novo request, the clinical evidence submitted consisted of retrospective studies of compassionate use cases in Europe prior to commercial market launch, including a
retrospective case series. RWE from the compassionate use cases served as the sole source of clinical evidence supporting the granting of this de novo classification request. The
de novo submission was ultimately approved.
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Example 69. De Novo - Classification of an Esophageal Cooling Device Using OUS Clinical Case
Summaries and Temperature Charts [148]
DEN140018 Advanced Esophageal Cooling The Esophageal Cooling Device is a thermal regulating device, intended to: OUS clinical case Premarket: Primary,
Cooling Device • connect to a Gaymar Medi-Therm III Conductive Hyper/Hypothermia System summaries and patient supportive
Therapy, LLC to control patient temperature, and body temperature charts
• provide gastric decompression and suctioning
Premarket Use – OUS Clinical Case Summaries and Patient Body Temperature Charts
Population Key Elements from RWE Sources Follow-up/Duration (RWE)
OUS Clinical Summaries: Clinical data summaries and patient body temperature charts (n=16 Elements: N/A
patients, 10 reports w/ body temperature charts) of the device used commercially outside of Target temperature
US. Body temperature vs time data
Narrative:
A formal clinical study was not requested by FDA. Assessment of device risk was based on the provided non-clinical and animal studies, while assessment of probable benefit
was based on the provided non-clinical and clinical data.

OUS clinical summaries: Clinical data summaries and patient body temperature charts (n=16 Elements: N/A
patients, 10 reports w/ body temperature charts) of the device used commercially outside of Target temperature
US. Body temperature vs time data
Narrative:
A formal clinical study was not requested by FDA. Assessment of device risk was based on the provided non-clinical and animal studies, while assessment of probable benefit
was based on the provided non-clinical and clinical data.
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Example 70. De Novo - Classification of a Scalp Cooling System Using Supplemental RWE from
OUS Postmarket Surveillance Study [149]
DEN150010 DIGNITANA AB DigniCap Scalp The DigniCap Scalp Cooling System is indicated to reduce the likelihood of chemotherapy- Postmarket Premarket:
Cooling System induced alopecia in women with breast cancer. surveillance study Supplemental
Premarket Use – OUS Postmarket Surveillance

Population Key Elements from RWE Sources
Feasibility Study (Non-RWE): Patients with stage I breast cancer receiving adjuvant chemotherapy treatment Elements:
Adverse events
Pivotal Study (Non-RWE): Non-randomized, multi-center trial
Dignitana Postmarket Surveillance (RWE): Postmarket surveillance of approximately 6000 patients
Narrative:
The primary source of clinical evidence for the submission was based on two studies of the Dignicap, which collected patient efficacy and safety data of the device from patients
with early-stage breast cancer. FDA also reviewed postmarket surveillance data provided by the sponsor on device-use outside-the-US, which provided additional data on the
risk of scalp metastasis.
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Example 71. De Novo - Classification of a Percutaneous Catheter for Creation of an Arteriovenous
Fistula for Hemodialysis Access Using OUS Commercial Use Data [150]
DEN160006 TVA Medical, everlinQ endoAVF The everlinQ endoAVF System is indicated for the Outside-the-US commercial use in Europe Premarket:
Inc. System creation of an arteriovenous fistula (AVF) using the Supplemental source of
ulnar artery and ulnar vein in patients with clinical evidence for long
minimum artery and vein diameters of 2.0 mm and term endpoint
less than 2.0 mm separation between the artery
and vein at the fistula creation site who have
chronic kidney disease and need hemodialysis.
Premarket Use – OUS Commercial Use Data

COMM Commercial Use Dataset: 79 patients with Safety and Effectiveness: Open-label commercial use of the subject device was
chronic kidney disease requiring hemodialysis, treated Serious adverse events reported by physicians to the sponsor through the
under open-label commercial use of the 6Fr version of Procedure success defined as proportion of subjects who achieved sponsor’s form that excluded personal data on
the subject device successful endoAVF creation as confirmed by intraprocedural patients
angiography/fistulogram or duplex ultrasound verification performed post-
procedure
Please see Decision Summary for additional details and complete list.
Narrative:
For this de novo classification request, part of the clinical evidence submitted was a pooled dataset with postmarket commercial data on open-label use of the device in Europe.
The sponsor generated a form for physicians to report data on patients being treated with the device. This real-world evidence supported granting of the classification request
by serving as a secondary source of clinical evidence for long term endpoint data.
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Example 72. De Novo - Classification of a Web and Mobile-Based Software Application for
Contraception Using Real-World Evidence from a Software Application with Patient-
Entered/Patient-Generated Data [151, 152]
DEN170052 Natural Natural Cycles Natural Cycles is a stand-alone software application, intended for Real-world evidence from a web Premarket:
Cycles Nordic women 18 years and older, to monitor their fertility. Natural Cycles and mobile-based software Primary source of
AB can be used for preventing a pregnancy (contraception) or planning a application with patient- clinical evidence
pregnancy (conception). entered/patient-generated data
Premarket Use – Analysis of Real-World Evidence from a Web and Mobile-Based Software
Application, Including Patient-Entered/Patient-Generated Data
Web and Mobile-Based Software Application with Patient-Entered/Patient- Effectiveness of Pregnancy Prevention:
Generated Data: 15,570 women age 18-45 (average 29) that registered in the Method failure rate
software application from September 2017 to October 2017. Pearl Index (perfect-use)
Pearl Index (typical-use)
Please see the De Novo Summary for additional details.
Narrative:
Natural Cycles is a web and mobile-based software application for contraception. To support the De Novo classification, outside-the-US data was collected from 15,570 women
(age 18-45, average 29 years old) who had registered in the software application between September to October 2017. These women were prospectively followed until April 30,
2018. Along with pregnancy tests or follow-up by email, pregnancy status was determined by the application’s algorithm. Patient data were retrospectively analyzed to validate
the accuracy of the algorithm in identifying ovulation by temperature and luteinizing hormone (LH). Additionally, a subgroup analysis was performed on women who had
recently used (or had not used) hormonal contraception. Please see the De Novo Summary for additional details.
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Example 73. PMA - Postmarket Surveillance of an Intervertebral Disc Prosthesis Using an Explant
Retrieval Study [153]
P120024 Aesculap activL Artificial Disc The activL Artificial Disc (activL) is indicated for reconstruction of the disc at one level (L4- Clinical data from Postmarket: Explant
Implant L5 or L5-S1) following single-level discectomy in skeletally mature patients with patient medical retrieval study,
Systems, Inc. symptomatic degenerative disc disease (DDD) with no more than Grade I spondylolisthesis records enhanced surveillance
at the involved level. DDD is defined as discogenic back pain with degeneration of the disc
confirmed by patient history, physical examination, and radiographic studies. The activL
Artificial Disc is implanted using an anterior retroperitoneal approach. Patients receiving
the activL Artificial Disc should have failed at least six months of nonoperative treatment
prior to implantation of the device.
Postmarket Use – Explant Retrieval Study

Explant Analysis: All patients with explanted Primary Elements:
device Detailed clinical narrative, copies of the original implant operative report, copies of all subsequent surgical operative reports, copies of
the operative report from the explant/removal surgery, copies of all pathology reports, results of the explant analysis.
Narrative:
As part of the condition-of-approval, the sponsor agreed to conduct an explant analysis retrieval study over a ten-year period. For all explanted devices, the sponsor agreed to
provide a clinical narrative, copies of operative reports from the original surgery, copies of operative reports from subsequent surgeries as well as the explant surgery, copies of
pathology reports, and conduct an explant analysis.
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as a Primary Source of Clinical Evidence After Call for PMA [154, 155, 156, 157]
P160012 Physio- LIFEPAK CR Plus Defibrillator, LIFEPAK EXPRESS Please see Approval Order. Device-generated data Premarket: Primary source
Control, Inc. Defibrillator, and CHARGEPAK Battery Charger collected during field-use of of clinical evidence
the AEDs
Medical chart review
Premarket Use – Device-Generated Data and Real-World Evidence Supporting a PMA Submitted in
In-hospital Prospective Randomized Trial of Monophasic vs. Biphasic Primary: Device-generated data extracted from AED
Waveforms (Non-RWE): 154 patients in which VVF was induced (See Higgins Success of first shock: termination of ventricular fibrillation devices used commercially in the field. Study
et al for additional information) into an organized rhythm within 1 minute after shock delivery data collectors traveled to the scene when EMS
were called for cardiac arrest and recorded data
Postmarket Out-of-Hospital Study of Adult Waveform in the Netherlands Secondary: on the circumstances of the cardiac arrest,
(RWE): 120 patients with witnessed and un-witnessed cardiac arrest and Termination of ventricular fibrillation at 5 seconds after first interviewed witnesses, and collected data from
ventricular fibrillation as initial recorded rhythm, in whom the first shock shock the AED and the manual defibrillators.
was delivered using the subject device by non-medical first responders
Please see Summary of Safety and Effectiveness Data for
Postmarket Surveillance Study of Infant/Child Electrodes (RWE): 19 additional details and complete list.
patients, most uses appropriate to age/weight labeling of up to 8 years or up
to 25 kg (55 lbs.), 2 patients in upper end of age range exceeding weight
range
Narrative:
This PMA was submitted in response to the Final Order (Docket FDA-2013- N-0234) issued on January 29, 2015, which required premarket approval of marketed pre-amendment
Class III Automated External Defibrillators. In this PMA submission, the sponsor submitted two postmarket studies that analyzed device-generated data and clinical details of
out-of-hospital use of the subject devices. The first was a prospective, randomized, out-of-hospital study in the Netherlands of the subject devices’ use in adults, with ECG and
shock data obtained from the AEDs and data obtained from medical records and study data collectors’ interviews of witnesses at the scene. The sponsor also submitted results
from a postmarket surveillance study of the use of the device with Infant/Child electrodes in a pediatric population. These data supported exemption of this submission from
review by the Circulatory System Devices Panel, since it was previously reviewed by this panel on January 25, 2011 as part of the 515(i) process, and also supported approval of
the PMA.
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as a Primary Source of Clinical Evidence After Call for PMA [158, 159, 160, 161]
P160032 Defibtech, LLC Lifeline/ReviveR DDU-100, Lifeline/ReviveR Please see Approval Order. Device-generated data Premarket: Sole source of
AUTO DDU-120, Lifeline/ReviveR VIEW DDU- collected during field-use of clinical evidence
2300, Lifeline/ReviveR VIEW AUTO DDU-2200, the AEDs
Lifeline/ReviveR ECG DDU-2450, and
Lifeline/ReviveR ECG+ DDU-2475 Automated
External Defibrillators
Postmarket Out-of-Hospital Study of Adult Waveform in Europe (RWE): Safety and Effectiveness: Device-generated data extracted from AED
115 patients who weighed ≥36 kg with known or suspected sudden cardiac Percentage of patients with ventricular fibrillation as the devices used commercially in the field.
arrest out-of-hospital, attended by emergency medical services and treated initial monitored rhythm who were defibrillated in the first
with AED series of ≤3 shocks
Survival to hospital admission and discharge
Observational Postmarket Study of Pediatric Pads (RWE): 27 pediatric Return of spontaneous circulation (ROSC)
patients 0 – 8 years old or up to 25 kg (55 lbs.) treated with subject device
with pediatric pads that reduces AED waveform from 150J to 50J See Summary of Safety and Effectiveness Data for additional
details and complete list.
Narrative:
This PMA was submitted in response to the Final Order (Docket FDA-2013- N-0234) issued on January 29, 2015, which required premarket approval of marketed pre-amendment
Class III Automated External Defibrillators (AED). For this PMA submission, the sponsor submitted real-world evidence in the form of two postmarket studies that analyzed
device-generated data as well as clinical details of out-of-hospital use of the subject devices. The first was a prospective, randomized, out-of-hospital study in Europe of the
sponsor's AED in adults, with ECG and shock data obtained from the AED recording system and patient data collected from incidence and follow-up reports. The second was a US
and OUS postmarket observational study of the pediatric pads for the device that asked users to submit ECG and shock data from the AEDs in addition to details about the
patient and event. These data were used to support FDA's evaluation of safety, effectiveness, and benefit-risk for this PMA. They also supported exemption of the subject
devices from review by the Circulatory System Devices Panel, since it was previously reviewed by this panel on January 25, 2011 as part of the 515(i) process.
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as a Primary Source of Clinical Evidence After Call for PMA [162, 163]
P160033 Cardiac Powerheart AED G3, Powerheart AED G3 Plus, Please see approval order. Device-generated and clinical Premarket: Primary source
Science and Powerheart AED G5 data collected during field-use of clinical evidence
Corporation of the AEDs
RhythmX ECG Analysis IDE G920078 (Non-RWE): Randomized, controlled Safety and Effectiveness: Device-generated data extracted from AED
trial (156 patients) with two arms. Shock success devices used commercially in the field.
Restoration of spontaneous circulation (ROSC)
Postmarket Performance of the RhythmX Analysis Algorithm (RWE): Restoration of an organized rhythm (ROR)
Retrospective analysis of rescue data from the AED as used in the field from
December 1999 to December 2016.
Adult Defibrillation Waveform (Non-RWE): STAR Biphasic Waveform IDE

G970230: Randomized, controlled trial (118 patients) with two arms.
Postmarket Performance of the STAR Biphasic Waveform (RWE):

Retrospective analysis of rescue data from the AED as used in the field from
December 1999 to December 2016.
Narrative:
This PMA was submitted to fulfill requirements imposed by a Final Order (Docket FDA-2013- N-0234) issued on January 29, 2015, which required premarket approval of Class III
Automated External Defibrillators (AED). The devices in this PMA have been available in the US since 2003. For this PMA, FDA reviewed prior clinical trial data and real-world
evidence including analyses of device-generated data and clinical data recorded by the AEDs during routine, field use in the US and OUS. These data, in addition to the clinical
trial data, were used to support FDA's evaluation of safety, effectiveness, and benefit-risk for the PMA.
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Example 77. PMA - Approval of an Indication Expansion of a Superficial Femoral Artery Drug-
Eluting Stent Using Supplemental OUS Postmarket Surveillance Data [164, 165]
P100022/S020 Cook Medical, Zilver PTX The Zilver PTX Drug-Eluting Stent is indicated for improving luminal diameter for the OUS postmarket Premarket:
Supplement to Inc. Drug-Eluting treatment of de novo or restenotic symptomatic lesions in native vascular disease of the surveillance Supplemental
expand indication Peripheral above-the-knee femoropopliteal arteries having reference vessel diameter from 4 mm to 7
Stent mm and total lesion lengths up to 300 mm per patient.
Premarket Use – OUS Postmarket Surveillance Data

Population Key Elements or Endpoints from RWE
Sources
Zilver PTX Single Arm Study Analysis (Non-RWE): Retrospective analysis of patient data from Zilver PTX single arm clinical trial (30 Outcomes Included in Supplemental Analysis:
outside-the-US sites, 787 patients enrolled, 665 patients with 755 lesions in analysis population). Freedom from target lesion revascularization at 1,
2, and 3 years
The population included three analysis sub-groups: 493 patients (lesion length ≤ 140 mm); 110 patients (lesion-length > 140 mm to 240 Primary patency at one year
mm); 62 patients (lesion length > 240mm to 300mm).
Japan Postmarket Surveillance (Non-RWE): Postmarket surveillance study with no inclusion/exclusion criteria and consecutive
enrollment of patients treated with the Zilver PTX stent (905 patients; 717 patients with 842 lesions included in analysis population).
The population included three analysis sub-groups: 391 patients with 494 lesions (lesion length up to 140mm); 183 patients with 201
lesions (lesion length > 140 mm to 240 mm); and 143 patients with 147 lesions (lesion length > 240 mm to 300 mm in length)
Narrative:
The primary source of clinical evidence for the submission was an analysis of patient data from the Zilver PTX Single Arm Study, an OUS study with clinical sites in Europe, Canada
and Korea.
FDA also reviewed Japanese postmarket surveillance data from patients treated with the Zilver PTX Stent, with no inclusion / exclusion criteria. Patients were treated per
standard of care. Specifically, FDA reviewed analyses of 1, 2 and 3-year freedom from target lesion vascularization and primary patency at one year.
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Example 78. PMA - Approval of an Indication Expansion and Postmarket Surveillance for a
Wearable Automated External Defibrillator Using Device-Generated Data, Sponsor Database, and
Real-World Literature [166, 167, 168, 169, 170, 171]
P010030/S056 ZOLL LifeVest The LifeVest system is indicated for patients 18 years of age and older who are at risk Sponsor database Premarket: Primary source
Manufacturing Wearable for sudden cardiac arrest and are not candidates for or refuse an implantable of clinical evidence
Corporation Cardioverter defibrillator. Device-generated data
Defibrillator The LifeVest system is indicated for patients under 18 years of age who are at risk for Postmarket: CoA with
sudden cardiac arrest and are not candidates for or refuse an implantable defibrillator. Real-world literature postmarket RWE collection
Patients must have a chest circumference of 26 inches (66 centimeters) or greater and
a
weight of 18.75 kilograms (41.3 pounds) or greater.
Premarket Use – Sponsor Database, Device-Generated Data and Real-World Literature

Population Key Elements or Endpoints from RWE Sources Methods of Note
Zoll Database (RWE): Clinical database of patients prescribed and fitted with device. Zoll Database: Patient demographics; Wear duration; Indication for use; Device generated data
Before and after treatment ECG waveform data; Treatment summary
Study 1 (RWE Literature): Retrospective analysis of sponsor’s database (81 patients (appropriate vs inappropriate); Energy Delivered; reason for ending
9-18 years of age, 103 patients aged 19-21 years of age). device use.
Study 2 (RWE Literature): Retrospective analysis of all patients prescribed WCD Study 1: Patient demographics; diagnoses and reason for device use;
(January 1, 2007 to June 30, 2009) at a single site (4 patients, l18 years of age or wear compliance, device discharge data, and reason for ending use.
younger)
Study 2: Patient demographics; Diagnosis and LVEF; Indication for ICD;
Study 3 (Literature) (Non-RWE): Case report Wear duration and compliance; Device discharge data
Study 3: Case report
Narrative:
The device is a prescription device that also collects device-generated data (e.g. electrocardiograms (ECG)) recorded before and after delivery of therapy. Patients can also
record their ECG data manually with the device. These device-generated data can be uploaded to the sponsor’s database and reviewed by the patient’s physician. For this
submission seeking to expand the indication to include patients under 18 years of age (and who meet specified chest-circumference and weight requirements), FDA reviewed
clinical and device-generated data collected in the sponsor’s database. FDA also reviewed published analyses of device-generated data and clinical data from pediatric
populations. FDA relied on this data during its assessment of benefit-risk, device safety and effectiveness.
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Postmarket Use – Sponsor Database, Device-Generated Data
Zoll Database: Data collection from patients under 18 years of age who meet the Effectiveness: Compliance with use, duration of use, appropriate therapy delivery, ECG data, call
approved indication. Data will be collected from the sponsor’s medical order reports
database, device-generated data, and call reports for device use (150 patients).
Safety: Inappropriate therapy, ECG data, call reports and adverse events.
Narrative:
As part of a condition-of-approval for the PMA, the sponsor agreed to collect additional clinical and device data routinely collected in the sponsor’s databases from patients who
meet the approved indication. The final, corrected report for the study was received by FDA on September 7, 2016. On April 25th, 2017, FDA approved an update of the labeling
to include the results of the completed post-approval study.
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Example 79. PMA - Postmarket Surveillance of Implantable Cardioverter Defibrillators Using
Remote Monitoring [172, 173]
P050023/S087 Biotronik, Inc. PROMRI FULL Iforia 7/Iperia/Inventra ICDs Sponsor Registry Postmarket: CoA to
BODY SCAN The Iforia 7/Iperia/Inventra Families of Implantable Cardioverter Defibrillators (ICDs) are (Home monitoring collect de-identified
(FBS) ICD intended to provide ventricular anti tachycardia pacing and ventricular defibrillation, for system) patient and device data
SYSTEM automated treatment of lifethreatening ventricular arrhythmias. The VR-T DX ICDs are part of a using remote/home
system that includes both a BIOTRONIK DX ICD lead and an Iforia 7 DX/Iperia DX/Inventra DX monitoring system.
ICD.
Linox/Protego DF-1 ICD Leads

The Linox/Protego DF-1 8F steroid-eluting, bipolar, IS-1 transvenous lead system is intended for
use in the right ventricle of patients for whom implantable cardioverter defibrillators are
indicated. The Linox S DX/Protego DF-1 S DX lead is indicated for use as a system that includes
both the Linox S DX/Protego DF-1 S DX and a BIOTRONIK DX ICD.
Protego ICD Leads

The Protego 8F steroid-eluting, bipolar, DF4 transvenous lead system is intended for use in the
right ventricle of patients for whom implantable cardioverter defibrillators are indicated.
Setrox S/Safio S Pacing Leads

BIOTRONIK’s Setrox S/Safio S transvenous, steroid-eluting, active fixation endocardial leads are
indicated for permanent pacing and sensing. Active fixation pacing leads with a bipolar (BP) IS-1
connector configuration are designed for use in conjunction with implantable pulse generators
with IS-1 headers. The leads may be used with single or dual chamber pacing systems, dual
chamber ICDs, CRT-Ps and CRT-Ds. The Setrox S/Safio S lead models are intended for placement
in either the right atrium or right ventricle.
Postmarket Use – Sponsor Database

Population Key Elements or Endpoints from RWE Sources Follow-up/Duration (RWE)
All subjects implanted with a ProMRI Primary: Through five years post-approval (or
ICD/CRT-D system enabled with the Freedom from VF delays 25 patients with a post-MRI VF
home/remote monitoring system. episode)
Secondary:
User compliance to requirement to restore the tachycardia detection and ICD therapy settings after the
MRI scan
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Narrative:
As part of the condition-of-approval, the sponsor will collect de-identified patient data through a home/remote monitoring system and analyze data from subjects who have had
a post-MRI VF episode.
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Example 80. PMA - Postmarket Surveillance of a Glucose Sensor Using Device-Generated and
Patient-Reported Data [174, 175]
P120005/S041 Dexcom, Inc. Dexcom G5 The Dexcom G5 Mobile Continuous Glucose Monitoring System (Dexcom G5) is a glucose Device data Postmarket
Mobile monitoring system indicated for the management of diabetes in persons age 2 years and (Continuous Glucose
Continuous older. The Dexcom G5 is designed to replace fingerstick blood glucose testing for diabetes Monitoring) and
Glucose treatment decisions. Interpretation of the Dexcom G5 results should be based on the glucose patient-collected data
Monitoring trends and several sequential readings over time. The Dexcom G5 also aids in the detection during home-use
System of episodes of hyperglycemia and hypoglycemia, facilitating both acute and long-term
therapy adjustments. The Dexcom G5 is intended for single patient use and requires a
prescription.
Postmarket Use – Patient Home Use Study of Continuous Glucose Monitor (CGM)
Post-approval study: Primary Elements:
1110 participants (2 years of age or older with Type I Diabetes or insulin- Average number of hypoglycemic (hypo) events per patient.
requiring Type 2 diabetes).
Secondary elements:
Each participant will also serve as their own control. Hemoglobin A1c
Other hypoglycemia metrics
Diabetic ketoacidosis (DKA) metrics
Patient reported outcomes (PROs).
CGM average glucose
CGM standard deviation
Time-in-range and time-above/below-range metrics
CGM use frequency at 6 months vs. 1 month and change in SMBG frequency.
Narrative:
As a condition-of-approval, the sponsor agreed to conduct a post-approval study evaluating the safety of non-adjunctive use of the Dexcom G5 CGM against standard glucose
meters. Patients will use a glucose meter for six months followed by six months of using the CGM. In this example, data is collected from patients in a home-use setting. The
data for this study are generated both by the device (CGM data) and by the patients (including patient-reported outcomes). It should be noted that this CGM is an electronic
monitoring system that is used to determine the delivery of insulin by patients (as opposed to medical professionals).
Similar example: P160030
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Supplemental Real-World Literature [176, 177, 178]
P930016/S044 AMO STAR S4 IR The STAR S4 IR Excimer Laser System and iDesign Advanced WaveScan Studio System is indicated for Retrospective Premarket:
Supplement to Manufacturin Excimer Laser wavefront-guided laser assisted in situ keratomileusis (LASIK) in patients: studies (data Supplemental
expand indication g USA, LLC. System ▪ with myopia as measured by the iDesign Advanced WaveScan Studio system up to -11 D spherical extracted from
iDesign equivalent with up to -5 D cylinder provider medical
Advanced ▪ with agreement between manifest refraction (adjusted for optical infinity) and iDesign Advanced record database)
WaveScan WaveScan Studio System refraction as follows:
Studio System • Spherical Equivalent: Magnitude of the difference is less than 0.625 D.
• Cylinder: Magnitude of the difference is less than or equal to 0.5 D.
▪ 18 years of age or older, and
▪ with refractive stability (a change of ≤1.0 D in sphere or cylinder for a minimum of 12 months prior
to surgery).
Premarket Use – Published Literature

Population Key Elements or Endpoints from Follow-up/Duration (RWE)
RWE sources
Primary Clinical Study (Non-RWE): Prospective, multicenter, open-label, non-randomized (170 patients, Elements: Study 1: Follow-up through
334 treated eyes, 12 US sites) Visual outcomes (e.g. UDVA and CDVA) one-month
Refractive outcomes
RWE Study 1: RWE Literature describing a retrospective study of de-identified patient data extracted from Patient satisfaction Study 2: Baseline, one-week,
electronic medical records of a LASIK provider. one-month, 3 months
RWE Study 2: RWE Literature describing a retrospective study of de-identified patient data extracted from
electronic medical records of a LASIK provider.
Narrative:
The primary source of clinical evidence for the submission was a prospective open-label investigation of the device. FDA also reviewed supplemental real-world literature from
two outside-the-US studies, which were retrospective studies of de-identified patient data extracted from the electronic medical record database of a LASIK provider. These
studies provided additional safety and effectiveness data for the device during the early post-operative period.
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Supplemental Real-World Literature [179, 180, 181]
P020050/S023 Alcon WaveLight The WaveLight EX500 Excimer Laser System and ALLEGRETTO WAVE Eye-Q Excimer Laser Peer-reviewed Premarket:
(Supplement Laboratories EX500 Excimer Systems are indicated for use in Photorefractive Keratectomy (PRK) treatments for: real-world Supplemental
expansion to Laser System, • the reduction or elimination of up to -6.0 diopters (D) of spherical equivalent myopia or literature
include PRK ALLEGRETTO myopia with astigmatism, with up to -6.0 D of spherical component and up to -3.0 D of (retrospective
treatment WAVE EYE-Q astigmatic component at the spectacle plane, studies with chart
indication) Excimer Laser • patients who are 18 years of age or older and, review)
System • patients with documentation of a stable manifest refraction defined as ≤ 0.5 D preoperative
spherical equivalent shift over one year prior to surgery.
Premarket Use – Real-World Literature

Primary Clinical Study (Non-RWE): Prospective, multicenter, open-label, non-randomized study with Study 1 Elements: Study 1: 1 month, 3 months, 6
two stages. Refractive and visual outcomes, adverse events, months and 12 months
post-operative complications
RWE Study 1: RWE Literature describing a retrospective review of all consecutive patients treated Study 2: 3 days, 1 month, 3
with PRK between February 2004 and January 2006 (64 patients, 128 eyes) Study 2 Elements: months and 6 months
Refractive and visual outcomes, complications
RWE Study 2: RWE Literature describing a retrospective review of all consecutive patients treated
with PRK between April 2009 and January 2010 (151 patients, 222 eyes)
Narrative:
two single-site retrospective studies and non-real-world literature from a third study (randomized study of tomography guided vs wavefront optimized PRK). These two RWE
studies provided additional data on refractive and visual outcomes as well as complications.
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Population Key Elements from RWE sources Follow-up/Duration (RWE)
Primary Clinical Study (Non-RWE): Prospective, multicenter, open-label, non-randomized study with Study 1 Elements: Study 1: 1 month, 3 months, 6
two stages. Refractive and visual outcomes, adverse events, months and 12 months
post-operative complications
RWE Study 1: RWE Literature describing a retrospective review of all consecutive patients treated Study 2: 3 days, 1 month, 3
with PRK between 2/2004 and 1/2006 (64 patients, 128 eyes) Study 2 Elements: months and 6 months
Refractive and visual outcomes, complications
RWE Study 2: RWE Literature describing a retrospective review of all consecutive patients treated
with PRK between 4/2009 and 1/2010 (151 patients, 222 eyes)
Narrative:
two single-site retrospective studies and non-real-world literature from a third study (randomized study of tomography guided vs wavefront optimized PRK). These two RWE
studies provided additional data on refractive and visual outcomes as well as complications.
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Appendix Section VI. Examples of Real-World Evidence Use for In Vitro Diagnostics
Guide to Examples of Real-World Evidence Use for In Vitro Diagnostics
Source(s)
83 K132750 Illumina, Inc. Illumina MiSeqDx CFTR2 Database Premarket: Information from the CFTR2 Next-generation
Cystic Fibrosis Database, a publicly-maintained Next Generation sequencing;
Clinical Sequencing Sequencing database, was used as the sole source
Assay of evidence supporting this 510(k) for a cystic
fibrosis indication for the subject IVD.
84 K124006 Illumina, Inc. Illumina MiSeqDx CFTR2 Database Premarket: Clinical evidence from the CFTR2 Next-generation
Cystic Fibrosis 139- Database, a publicly-maintained Next Generation sequencing;
Variant Assay Sequencing database, was used as the sole source
of evidence supporting this 510(k) for a cystic
fibrosis variant assay.
85 DEN150035 Baebies, Inc. SEEKER System Missouri State Public Health Premarket: This de novo classification request Pediatric RWE;
Laboratory and Missouri was solely supported by a pivotal trial embedded RWE as a primary source
Department of Health and in a state-run routine screening program testing of clinical evidence;
Senior Services (MDHSS) newborn dried blood samples and actively
Surveillance Program surveilling for false negatives.
86 DEN140010 Wallac Oy EnLite Neonatal Danish Newborn Screening Premarket: This de novo classification request Medical records (EHR,
TREC Kit Biobank was primarily supported by a pivotal trial that EMR or chart review);
Danish medical records analyzed and linked samples from an Pediatric RWE;
international biobank to data from medical
records systems.
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DEN160026 23andMe 23andMe Real-world literature Premarket: To support this de novo classification RWE as a primary source
87 Personal Genome request, peer-reviewed real-world literature was of clinical evidence;
Service (PGS) submitted for each of the 10 conditions included in
the Genetic Health Risk tests.
DEN170058 Memorial MSK-IMPACT Retrospective review of Premarket: This is a next generation sequencing Medical records (EHR,
88 Sloan- (Integrated medical records from one based tumor profiling test. RWE extracted from a EMR or chart review);
Kettering Mutation Profiling (1) US site retrospective review of medical records was used to Next-generation
Cancer of Actionable estimate somatic mutation prevalence, to validate a sequencing;
Center Cancer cut-off, and to support evaluation of a claim for this
Targets) De Novo classification request. RWE as a primary source
P140020 Myriad BRACAnalysis CDx Sponsor database Postmarket: As a condition-of-approval, the sponsor
89 Genetic is required to collect data on all IVD results during
Laboratories commercial use.
P160052 QIAGEN, Inc. PartoSure Test Observational clinical Premarket: To support this PMA, the primary clinical Medical records (EHR,
90 study with follow-up data evidence submitted was an observational study of EMR or chart review);
collected from medical pregnant patients tested with the subject device to RWE as a primary source
records detect preterm delivery, with follow-up data on of clinical evidence;
pregnancy and delivery outcomes collected from the
patients’ medical records. Total-Product Lifecycle
Example;
Postmarket: As a condition-of-approval, the sponsor
agreed to conduct a confirmatory study to collect
additional data from medical records of pregnant
women presenting with signs and symptoms of
preterm labor, with the sponsor following up with
study participants up to 39 weeks of gestation to
collect outcome data.
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Example 83. 510(k) - Clearance of an IVD Using a Publicly Maintained Next Generation
Sequencing Database [182, 183, 184]
K132750 Illumina, Inc. Illumina The Illumina MiSeqDx Cystic Fibrosis Clinical Sequencing Assay is a targeted sequencing in vitro diagnostic system that CFTR2 Premarket:
MiSeqDx re-sequences the protein coding regions and intron/exon boundaries of the Cystic Fibrosis Transmembrane Database (Sole-source)
Cystic Fibrosis Conductance Regulator (CFTR) gene in genomic DNA isolated from human peripheral whole blood specimens collected for indications
Clinical in K2EDTA. The test detects single nucleotide variants, and small InDels within the region sequenced, and additionally
Sequencing reports on two deep intronic mutations and two large deletions. The test is intended to be used on the Illumina
Assay MiSeqDx Instrument. The test is intended to be used as an aid in the diagnosis of individuals with suspected cystic
fibrosis (CF). The test is most appropriate when the patient has an atypical or non-classic presentation of CF or when
other mutation panels have failed to identify both causative mutations. The results of the test are intended to be
interpreted by a board-certified clinical molecular geneticist or equivalent and should be used in conjunction with other
available information including clinical symptoms, other diagnostic tests, and family history. This test is not indicated
for use for stand-alone diagnostic purposes, fetal diagnostic testing, for pre-implantation testing, carrier screening,
newborn screening, or population screening.
Premarket Use – Next Generation Sequencing Database – CFTR2 Database

Narrative:
The clinical sensitivity and specificity was estimated based on the information from the CFTR2 database (as of August 2013) as published in Sosnay PR et al., “Defining the
disease liability of variants in the cystic fibrosis transmembrane conductance regulator gene” Nat. Genet., published online on 25 August 2013. The CFTR2 database provides
additional information on genetic variants in the cystic fibrosis (CF) gene and was used as a source of valid scientific evidence to establish which variants were disease-causing.
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Example 84. 510(k) - Clearance of an IVD Using a Publicly Maintained Next Generation
Sequencing Database [183, 184, 185]
K124006 Illumina, Inc. Illumina The Illumina MiSeqDx Cystic Fibrosis 139-Variant Assay is a qualitative in vitro diagnostic system used to CFTR2 Premarket:
MiSeqDx simultaneously detect 139 clinically relevant cystic fibrosis disease causing mutations and variants of the cystic Database (sole-source)
Cystic fibrosis transmembrane conductance regulator (CFTR) gene in genomic DNA isolated from human peripheral whole for indications
Fibrosis 139- blood ‐specimens. The variants include those recommended in 2004 by the American College of Medical Genetics
Variant Assay (ACMG) and in 2011 by the American College of Obstetricians and Gynecologists (ACOG). The test is intended for
carrier screening in adults of reproductive age, in confirmatory diagnostic testing of newborns and children, and as
an initial test to aid in the diagnosis of individuals with suspected cystic fibrosis. The results of this test are intended
to be interpreted by a board-certified clinical molecular geneticist or equivalent and should be used in conjunction
with other available laboratory and clinical information.
This test is not indicated for use for newborn screening, fetal diagnostic testing, pre-implantation testing, or for
standalone diagnostic purposes. The test is intended to be used on the Illumina MiSeqDx instrument.
Premarket Use – Next Generation Sequencing Database – CFTR2 Database

Narrative:
The clinical sensitivity and specificity was estimated based on the information from the CFTR2 database (as of August 2013) as published in Sosnay PR et al., “Defining the
disease liability of variants in the cystic fibrosis transmembrane conductance regulator gene” Nat. Genet., published online on 25 August 2013. The CFTR2 database provides
additional information on genetic variants in the cystic fibrosis (CF) gene and was used as a source of valid scientific evidence to establish which variants were disease-causing.
www.fda.gov
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Example 85. De Novo - Classification of a Newborn Screening IVD Using Clinical Evidence from a
Pivotal Trial Leveraging Real-World Data Collection in a State Public Health Laboratory [186, 187]
DEN150035 Baebies, Inc. SEEKER System The SEEKER System, including the SEEKER Instrument and the SEEKER LSD Missouri Department Premarket: Sole-Source
Reagent Kit IDUA|GAA|GBA|GLA for use on the SEEKER Instrument, is of Health and Senior
intended for quantitative measurement of the activity of α-L-iduronidase, α- Services (MDHSS)
D-glucosidase, β-glucocerebrosidase and α-D-galactosidase A from newborn Surveillance Program
dried blood spot specimens as an aid in screening newborns for
Mucopolysaccharidosis Type I, Pompe, Gaucher and Fabry diseases. Reduced Missouri State Public
activity of these enzymes may be indicative of these lysosomal storage Health Laboratory
diseases. The enzymes measured using the SEEKER LSD Reagent (MSPHL)
KitIDUA|GAA|GBA|GLA and their associated lysosomal storage diseases are
listed below.
Enzyme (abbreviation) Disease

α-L-iduronidase (IDUA); Mucopolysaccharidosis Type I (MPS I);
α-D-glucosidase (GAA) Pompe
β-glucocerebrosidase (GBA) Gaucher
α-D-galactosidase A (GLA) Fabry
Premarket Use – Missouri State Public Health Laboratory, Missouri Department of Health and Senior
Service Surveillance Program
MSPHL: All newborn dried blood samples Performance: 15 months of active surveillance Pivotal trial protocol utilized MSPHL’s study
submitted to the MSPHL for routine newborn Total Number of samples where 1st test is below monitoring to check for false protocol for new screening tests.
screening between 1/11/13 and 1/14/15. Samples borderline negatives following study
from 105,089 newborns (babies born on or after Total average test result below high risk. completion.
8/27/13) were screened and included in the Total not referred after risk assessment
pivotal phase analysis. The pilot phase included Total Presumed Affected
samples from babies born before 8/27/13. True Positives
Total Refused/Moved
MDHSS: Routine active surveillance program to Total presumptive false positives
check for false negatives during study and for Presumptive False Positive Rate
fifteen months after study completion. Presumptive False Negative Rate
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Narrative:
The clinical performance of the IVD was evaluated in a clinical trial in collaboration with the MSPHL as part of their routine screening program. All dried-blood spot specimens
submitted to the MSPHL for routine newborn screening between January 11, 2013 and January 14, 2015 were included in the study. Babies born after or on 8/27/13 were
included in the pivotal trial phase.
A Missouri Department of Health and Senior Services (MDHSS) active surveillance program used to track false negative reports and confirm diagnosis for routine screening was
also used to check for false negatives in this study. Briefly, the active surveillance program checks for false negatives reported to the state’s contracting metabolic centers.
This is an example of embedding a pivotal IVD clinical trial in routine practice. Note that the pivotal phase of the trial does not use presumed normal banked bio-specimens
enriched with known positive samples but instead evaluates IVD performance on all samples submitted to a state lab for routine screening.
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Example 86. De Novo - Classification of an IVD Using Clinical Evidence from a Pivotal Trial
Leveraging Real-World Data Collection from an International Biobank and Medical Records [135, 188]
DEN140010 Wallac Oy EnLite Neonatal The EnLite Neonatal TREC Kit is an in vitro diagnostic device intended for the Danish Newborn Premarket: Primary
TREC Kit semiquantitative determination of TREC (T-cell receptor excision circle) DNA in blood Screening Biobank
specimens dried on filter paper. The test is for use on the VICTOR EnLite instrument.
The test is indicated for use as an aid in screening newborns for severe combined Danish medical
immunodeficiency disorder (SCID). records
This test is not intended for use as a diagnostic test or for screening of SCID-like
Syndromes, such as DiGeorge Syndrome, or Omenn Syndrome. It is also not
intended to screen for less acute SCID syndromes such as leaky-SCID or variant SCID.
Premarket Use – Danish Newborn Screening Biobank, Danish Medical Records

Source
Cut-Off Study (RWE): 3243 archived dried blood spot samples from the Performance: Clinical assessment of DNSB samples from Dried-blood spot samples
Danish Newborn Screening Biobank (DNSB) to establish clinical cut-off Invalid test rate patient medical records to confirm that linked to medical records.
values. Presumed positive rate the newborn had not died from SCID-
Normal rate related complications (or had been
Pivotal Study (RWE): 6389 consecutive, archived dried blood spot associated with SCID) at one-year.
samples from the DNSB, enriched with 17 confirmed positive SCID
samples, 9 low-level TREC samples, and 56 normal samples (to mask
identification of the positive samples) from other newborn screening
laboratories.
Narrative:
The clinical cut-off values for the IVD were determined in a clinical trial using retrospective dried blood spot specimens (DBSS) from the Danish Newborn Screening Biobank
(DNSB). IVD performance was then evaluated in a pivotal trial using retrospective DBSS from DNSB and confirmed positive samples from other laboratories. Clinical assessment
of the DNSB samples was determined using data from Danish medical records to confirm that the newborn had not died from SCID-related complications (or had been
associated with SCID) at one-year.
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Example 87. De Novo - Classification of an IVD Using Peer-Reviewed Real-World Literature [189]
DEN160026 23andMe 23andMe Meta-analysis, real- Premarket:
Please see De Novo Decision Summary for indications for use.
Personal world literature Sole source of
Genome clinical
Service evidence
(PGS)
Premarket Use – Real-World Literature

Individual real-world literature evaluations were conducted for each of the 10 analytes claimed to calculate Primary Elements:
likelihood ratios. Relevant patient descent represented in these studies were delineated in the intended use. Likelihood ratios to estimate how the test result affects the chances of a
In each case, a lower bound of 95% confidence interval for LR greater than 1 indicates that the test result is condition.
associated with the disease.
Narrative:
Authorization of the 23andMe GHR tests was supported by data from peer-reviewed literature that demonstrated a link between specific genetic variants and each of the 10
health conditions. The published data originated from studies that compared genetic variants present in people with a specific condition to those without that condition. The
FDA also reviewed studies, which demonstrated that 23andMe GHR tests correctly and consistently identified variants associated with the 10 indicated conditions or diseases
from a saliva sample.
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Example 88. De Novo - Classification of a Next Generation Sequencing Based Tumor Profiling Test
Using an Analysis of Medical Records [190, 191, 192]
DEN170058 Memorial Sloan- MSK-IMPACT The MSK-IMPACT assay is a qualitative in vitro diagnostic test that uses targeted Medical records Premarket: Evaluation
Kettering Cancer (Integrated next generation sequencing of formalin-fixed paraffin-embedded tumor tissue of a claim, validation of
Center Mutation matched with normal specimens from patients with solid malignant neoplasms to Genomic sequencing data a cut-off and to provide
Profiling of detect tumor gene alterations in a broad multi gene panel. The test is intended to additional clinical data
Actionable provide information on somatic mutations (point mutations and small insertions and on somatic mutation
Cancer deletions) and microsatellite instability for use by qualified health care professionals prevalence and cancer
Targets) in accordance with professional guidelines, and is not conclusive or prescriptive for type
labeled use of any specific therapeutic product. MSK-IMPACT is a single-site assay
performed at Memorial Sloan Kettering Cancer Center.
Premarket Use – Analysis of Patient Medical Records and Genomic Sequencing Data to Support a De
Novo Classification Request
Narrative:
In DEN170058, the sponsor submitted a De Novo classification request for a next generation sequencing based tumor profiling test. Clinical data for this submission came from
an electronic medical record database of advanced cancer patients with associated pathological and clinical data generated as part of routine workflow at Memorial Sloan
Kettering Cancer Center. This database includes patient-matched normal controls as well, to create a comprehensive catalog of tumor-specific mutations. A retrospective
analysis of the electronic medical records provided evidence to support a pan-cancer claim, to validate a test cut-off, and to provide data on somatic mutation prevalence.
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Example 89. PMA - Additional Postmarket RWE Data Collection Through Sponsor Database for
Condition-of-Approval [193]
P140020 Myriad BRACAnalysis BRACAnalysis CDx is an in vitro diagnostic device intended for the qualitative detection and Sponsor database Postmarket: Postmarket
Genetic CDx classification of variants in the protein coding regions and intron/exon boundaries of the BRCA1 data collection of IVD
Laboratories, and BRCA2 genes using genomic DNA obtained from whole blood specimens collected in EDTA. results during
Inc. Single nucleotide variants and small insertions and deletions (indels) are identified by commercial use
polymerase chain reaction (PCR) and Sanger sequencing. Large deletions and duplications in
BRCA1 and BRCA2 are detected using multiplex PCR. Results of the test are used as an aid in
identifying ovarian cancer patients with deleterious or suspected deleterious germline BRCA
variants eligible for treatment with Lynparza (olaparib). This assay is for professional use only
and is to be performed only at Myriad Genetic Laboratories, a single laboratory site located at
320 Wakara Way, Salt Lake City, UT 84108.
Postmarket Use – Sponsor Database
Narrative:
As part of the condition-of-approval, the sponsor will be required to monitor and assess all variants detected by the assay during commercial use, summarize and report the
results annually. Additionally, the sponsor is to track and report results from samples provided in both K2EDTA and K3EDTA tubes submitted for testing. In this case, data
collected in the postmarket setting during real-world / commercial use will be analyzed to evaluate the robustness of the classification process and the impact of K2EDTA and
K3EDTA tubes on performance.
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Example 90. PMA - Approval for a Placental Alpha Microglobulin-1 Immunoassay using
Observational Study with Follow-up Data Collection from Medical Records [194, 195, 196, 197]
P160052 QIAGEN, Inc. PartoSure Test The PartoSure test is a rapid, qualitative test for detecting the presence of placental alpha Premarket: Patient Premarket: Primary
microglobulin 1 (PAMG-1) in cervicovaginal secretions. The device is indicated as an aid to medical records source of clinical
rapidly assess the risk of spontaneous preterm delivery in ≤ 7 days from the time of evidence
cervicovaginal sample collection in pregnant women with signs and symptoms of early
preterm labor, intact amniotic membranes and minimal cervical dilatation (<3 cm), sampled
between 24 weeks, 0 days and 34 weeks, 6 days gestation in women with a singleton
gestation.
Premarket Use – Observational, Clinical Study with Follow-Up Data Collected from Patient Medical
Records
Multi-Center Clinical Study: Observational study performed in the United States Pregnancy outcomes
(15 sites) with 839 enrolled pregnant patients who were symptomatic for pre-term Delivery within seven days or less of testing
labor Spontaneous or medically indicated preterm labor
Adverse events
Please see Summary of Safety and Effectiveness Data for full list.
Narrative:
For this original premarket approval application, the sponsor provided clinical evidence from an observational, clinical study that enrolled 839 pregnant patients who were
symptomatic for pre-term labor. To evaluate the performance of the subject device, samples were obtained from consented patients and then tested with the subject device.
Follow-up pregnancy and delivery outcomes were also collected from the patient’s (and infant’s) medical records. These data were used to evaluate the effectiveness of the test
(e.g. positive predictive value, negative predictive value, test sensitivity and test specificity) as well as the safety (e.g. adverse events). Clinical evidence from this study was
considered to be the basis for the PMA. The sponsor also submitted additional, supplemental data from an Outside-the-US retrospective study performed at single site. This
submission illustrates an example of a clinical study used to support a PMA that leverages follow-up data collection from patient medical records.
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Postmarket Use – Post-Approval Study
PartoSure PAS (PAS001): Pregnant women presenting with signs and PartoSure Test result (positive or negative) Until subject reaches 39
symptoms of preterm labor with clinically intact membranes, a cervical Patient’s delivery status, defined as whether a spontaneous preterm delivery weeks of gestation,
dilation <3 cm, a singleton gestation between 240/7 and 346/7 weeks of occurred within 7 days of test with subject device sponsor will attempt to
gestation and tested with the Partosure Test in routine clinical care. collect missing delivery
data via follow-up
Please see the Partosure PAS page for additional details and complete list of telephone calls
inclusion and exclusion criteria.
Narrative:
As a conditional-of-approval, the sponsor has agreed to conduct a confirmatory study to collect additional safety and effectiveness data from medical records of pregnant
women presenting with signs and symptoms of preterm labor. 4800 patients will be enrolled in the study to obtain data from 168 spontaneous preterm deliveries within 7 days
of testing with the subject device, based on a prevalence of 3.5%. The key endpoints are the subject device test results and the patients’ delivery status, and the sponsor will
follow-up with study participants up to 39 weeks of gestation in order to collect any missing delivery data.
www.fda.gov
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Examples RWE Report - 0

Uploaded by

Examples RWE Report - 0

Uploaded by

U.S.

FOOD & DRUG

Examples of Real-World Evidence (RWE)

Center for Devices and Radiological Health

Section I. Examples of Registries as a Source of Real-World Evidence .............................................. 11

Section IV. Examples Utilizing Medical Records as Real-World Evidence ......................................... 13

Section V. Examples Utilizing Other Sources of Real-World Evidence .............................................. 13

Additional Consideration: Use of Real-World Evidence from Pediatric Populations ......................... 14

Key Tag Definitions ............................................................................................................................. 15

Appendix Section I. Examples of Registries as a Source of Real-World Evidence .............................. 17

Subsection B. Examples of Registries as a Source of Real-World Evidence ....................................... 50

Example 31. PMA - Approval of an Indication Expansion and Postmarket Surveillance of a

Example 32. PMA - Approval of an Indication Expansion and Postmarket Surveillance of a

Example 42. PMA - Postmarket Surveillance of an Implantable Cardioverter-Defibrillator Utilizing

Example 62. De Novo - Classification of a Hemostatic Device for Intraluminal Gastrointestinal

Example 71. De Novo - Classification of a Percutaneous Catheter for Creation of an Arteriovenous

Example 79. PMA - Postmarket Surveillance of Implantable Cardioverter Defibrillators Using

References ........................................................................................................................................ 164

The examples demonstrate a diversity in the usage of RWE, where:

These examples represent 18 premarket notification (510(k)) submissions, 14 De Novo classification

Section I. Examples of Registries as a Source of Real-World Evidence

Subsection IA. Examples Leveraging National or International Registries for

Subsection IB. Examples Leveraging Sponsor Registries for Real-World Data

Section II. Examples Leveraging Administrative Claims Data for Real-World

Section III. Examples Leveraging Both National Registries and

Section IV. Examples Utilizing Medical Records as Real-World Evidence

Section V. Examples Utilizing Other Sources of Real-World Evidence

Additional Consideration: Use of Real-World Evidence from Pediatric

Section VI. Examples of Real-World Evidence Use for In Vitro Diagnostics

Key Tag Definitions

The tag definitions below are used for all examples:

Subsection A. Examples Leveraging National Registries for Real-World Data Collection

Guide to Examples Leveraging National Registries for Real-World Data Collection

Postmarket: The INTERMACS Registry will be

Postmarket: The sponsor will conduct two post-

Postmarket: For postmarket surveillance, the

Premarket Use – OUS Registry Study

da Vinci X Surgical System

Premarket Use –AHSQC Registry

open-surgery cohorts. Unmatched comparison between • Readmission Rates through 30 days,

Premarket Use – OUS Commercial Use Data

Postmarket Use – Post-Approval Study Using Sponsor Registry

Postmarket Use – Surveillance Registry

Premarket Use – Control cohort from INTERMACS Registry

Annual follow-up for years 2 -5 for patients

INTERMACS: Standard-of-care follow-up (1

Postmarket Use – VQI Registry

Population Key Elements or Endpoints from RWE Source Follow-up

Premarket Use – Additional Match-Run Data from UNOS Registry

UNOS Organ Procurement and Transplantation

Postmarket Use – Post-Approval Study Using RWE

Minimum of 500 patients.

File Sponsor Device Approved/Cleared/Granted Indication RWE Source Use of RWE

Postmarket Surveillance Database (RWE): Sponsor postmarket surveillance database containing

Premarket Use – American College of Cardiology (ACC) CathPCI Registry

Subsection B. Examples of Registries as a Source of Real-World Evidence

Postmarket: Postmarket surveillance will be

Premarket Use – Sponsor Registry

Premarket Use – Sponsor Registry

Premarket Use – Registry Data

2. The Trevo Retriever is intended to restore blood flow in the neurovasculature by

Premarket Use – Real-world Evidence from Trevo Retriever Registry

Premarket Use – Retrospective Review of Medical Records

Postmarket Use – Post-Approval Study Using a Registry

Skeletally immature patients Primary Safety: 5 years (60 months).

Primary probable benefit endpoint:

See H190005 Approval Order for additional secondary endpoints.

Premarket Use – EU Registry for the IlluminOss Bone Stabilization System

Premarket Use– Sponsor Registry, Remote-Monitoring of Device-Generated Data

Premarket Use – Sponsor Registry

USPELLA (RWE): 637 Impella 2.5 patients; 49 sites

File Sponsor Device Approved/Cleared/Granted Indication RWE Source Use of RWE

Rate-responsive pacing is indicated to provide increased heart rate appropriate to increasing

Postmarket Use – Sponsor Registry

The device system is for prescription use.

Premarket Use –Outside-the-US Registry