The rigorous regulatory pathway for connected devices makes market access a challenge. The US Food and Drug Administration, for instance, now has twenty-four guidance documents related to digital health regulation. These help manufacturers to ensure they’ve covered the full range of concerns related to these products, including cybersecurity and interoperability.
To add to this complexity, requirements also differ between countries, particularly when it comes to the process of storing and managing data. There may be a requirement for data to be stored locally on servers within the country where it is collected, such as in China, where overseas data transfers come with specific conditions and processes, and which also does not yet have any international data protection framework or agreements.
Developing a connected add-on to an existing device may have an easier regulatory pathway; since the drug device combination product has already been validated and approved, a regulatory filing may be submitted solely for the accessory, which may not be defined as a medical device. But fully integrated connectivity requires specific additional human factors testing and user studies to evaluate the connectivity and functionality – and its impact on the performance of the combination product.