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The Incredible Shrinking Exemption: FDA Final CDS Guidance Would Significantly Narrow the Scope of Exempt Clinical Decision Support Software Under the Cures Act

The FDA Law Blog

Javitt — On September 28, 2022, the FDA issued the long anticipated final Clinical Decision Support Software Guidance (CDS Guidance), which replaces the revised draft guidance document from 2019. The final guidance focuses on labeling as a means to effectuate Criterion 4. software or labeling.

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Challenges & Opportunities in Emerging Digital Health Technologies

ISPE

There are important considerations if the DHTT is classified as a medical device, which may change the level of regulatory controls and evidentiary requirements to support its appropriate use, such as off-label versus on-label use of a device with prior marketing authorization. IMDRF SaMD Risk Categorization. Framework 26.

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Challenges & Opportunities in Emerging Digital Health Technologies

ISPE

There are important considerations if the DHTT is classified as a medical device, which may change the level of regulatory controls and evidentiary requirements to support its appropriate use, such as off-label versus on-label use of a device with prior marketing authorization. IMDRF SaMD Risk Categorization. Framework 26.