Film-style poster for the Programs for Health Startups presentation

Programs for Health Startups Programs for Health Startups

How to design a program and its mentoring for digital health and medtech startups.

What this presentation covers

What this presentation covers

What this presentation covers

When software is a device

Health software can be a medical device

Under EU law, software meant to diagnose, monitor, predict or treat disease is a device.

  • Diagnosis
  • Prevention
  • Monitoring
  • Prediction and prognosis
  • Treatment

Risk class under Rule 11

Rule 11 sorts software by harm

Software that informs diagnosis or therapy starts at class IIa and rises with possible harm.

  • Class I all other software
  • Class IIa informs diagnosis or therapy
  • Class IIb serious deterioration or surgery
  • Class III death or irreversible harm

Clinical evidence

Plan the clinical evaluation early

The MDR requires a planned, documented clinical evaluation with evidence suited to the device.

  • Set and justify the level of evidence
  • Plan the evaluation
  • Run it
  • Document every step

The FDA’s approach

The FDA focuses on risky software

The FDA oversees software functions that could harm patients if they fail.

  • Not a device not regulated as one
  • Low-risk device enforcement discretion
  • Risky device FDA oversight

Evidence that fits the risk

Match the evidence to the risk

NICE asks for more evidence as risk rises; most medical devices fall in tier C.

  • Tier A system services
  • Tier B communicating about health and care
  • Tier C informs, diagnoses or treats

The evidence gap

Funding is not evidence

Top-funded US digital health firms had not yet shown impact on disease burden or cost.

  • Healthy volunteers studied most
  • Few studies in high-burden patients
  • Few measured outcomes, cost or access

Getting reimbursed

Germany reimburses apps while evidence grows

Low-risk health apps can be listed for up to 12 months while proving benefit.

  • Apply to BfArM safety, data protection, evaluation plan
  • Decision within 3 months
  • Trial listing up to 12 months
  • Final listing once benefit is shown

Hospital pilots

Give every pilot a clinical owner

Agree an endpoint, a data plan and a decision date before any pilot starts.

The mentor pool

Clinicians and regulators in the pool

Pair clinicians with experts in regulation, reimbursement, hospital buying and data protection.

  • Clinicians workflow and endpoints
  • Regulatory affairs risk class, MDR, FDA
  • Health economics reimbursement and price
  • Hospital buyers how purchases are decided

Measure progress

Track evidence, not only users

Follow each startup from risk class to clinical proof and a paying buyer.

  • Risk class decided and documented
  • Evaluation plan endpoints agreed
  • Pilot sites signed hospitals
  • Payer route reimbursement filed

Sources

The research behind this presentation

  1. European Parliament & Council of the European Union (2017) Regulation (EU) 2017/745 on medical devices (MDR), Article 2, Article 61 and Annex VIII Rule 11 Official Journal of the European Union, L 117, 5 May 2017
  2. U.S. Food and Drug Administration (2022) Policy for Device Software Functions and Mobile Medical Applications: Guidance for Industry and Food and Drug Administration Staff FDA, Center for Devices and Radiological Health, 28 September 2022
  3. National Institute for Health and Care Excellence (2022) Evidence standards framework for digital health technologies (ECD7) NICE, published 2018, updated 9 August 2022
  4. Federal Republic of Germany (2019) Sozialgesetzbuch (SGB) Fünftes Buch, § 139e Verzeichnis für digitale Gesundheitsanwendungen Federal Ministry of Justice, gesetze-im-internet.de
  5. Safavi, K., Mathews, S. C., Bates, D. W., Dorsey, E. R. & Cohen, A. B. (2019) Top-funded digital health companies and their impact on high-burden, high-cost conditions Health Affairs, 38(1), 115-123

Design for clinical proof

Settle the risk class early, plan the evidence and line up the payers.

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