Clinical Evidence
Why Clinical Studies Matter Under MDR
- Clinical safety
- Clinical performance
- Clinical benefit
This is achieved through a Clinical Evaluation (Article 61, Annex XIV), often supported by clinical investigations (Annex XV). For many Class IIa, IIb, and III devices, clinical studies are no longer optional they are a regulatory and commercial necessity. Strong clinical evidence doesn’t just satisfy regulators, it builds trust with clinicians, payers, and patients.
Strong clinical evidence doesn’t just satisfy regulators—it builds trust with clinicians, payers, and patients.
Prospective Clinical Studies
A prospective clinical study is a planned investigation where patients are followed forward in time after receiving the device. Outcomes are predefined and collected according to a Clinical Investigation Plan (CIP). These studies may be:
- Single-arm (device only)
- Comparative (against standard of care or literature benchmarks)
When Prospective Studies Work Best
Prospective studies are widely accepted under MDR when:
- The device is Class IIa or IIb
- The technology is incremental or well-established
- Clinical benefit is already known
- Randomization is impractical or unethical
Key Benefits
- Faster study start-up
- Lower cost and complexity
- Strong real-world relevance
- Often sufficient for CE marking when well justified
Limitations
- Higher potential for bias
- Weaker evidence for novel or high-risk devices
- May not support superiority claims
Randomized Controlled Trials (RCTs)
When MDR Typically Expects an RCT
Notified Bodies often expect RCTs for:
- Class III devices
- Implantable devices
- Novel or breakthrough technologies
- Claims of superior clinical performance
Key Benefits
- Highest level of scientific credibility
- Minimizes bias
- Strong support for benefit–risk assessment
- Highly persuasive for regulators and investors
Limitations
- Higher cost and longer timelines
- Operational and ethical challenges
- Not always feasible for every device
Prospective Study vs RCT — At a Glance
| Feature | Prospective Study | Randomised Controlled Trial |
|---|---|---|
| Study design | Observational or comparative | Comparative |
| Randomisation | No | Yes |
| Evidence strength | Moderate | High |
| Typical MDR use | Class IIa / IIb | Class IIb / III |
| Cost & complexity | Lower | Higher |
| Suitable for novel devices | Sometimes | Preferred |
Choosing the Right Clinical Strategy
A Prospective Study May Be Sufficient If:
- Your device is an iteration of existing technology
- You can justify a state-of-the-art comparison
- The risk profile is moderate
- You aim for efficient market entry
An RCT Is Advisable If:
- Your device is innovative or implantable
- Clinical benefit is not yet established
- You claim superiority over existing solutions
- Long-term market acceptance is critical
Choosing the wrong study design is one of the most common causes of MDR delays.
Beyond CE Marking: The Market Value of Strong Clinical Evidence
Well-designed clinical studies can help you:
- Accelerate Notified Body approval
- Strengthen clinical adoption
- Support pricing and reimbursement
- Increase investor confidence
- Reduce post-market compliance risk
Clinical evidence is not just regulatory documentation—it is a commercial asset.
How We Help
We support medical device manufacturers with:
- Clinical strategy aligned to MDR expectations
- Study design (Prospective studies & RCTs)
- Clinical Investigation Plans (CIP)
- Clinical Evaluation Reports (CER)
- PMCF planning and execution
From clinical evidence to CE marking—and beyond.
Ready to Define Your Clinical Path?
The right clinical strategy can mean the difference between regulatory delay and market success. Let’s build evidence that regulators accept and markets trust.
Talk to us about your device class, novelty, and target claims to define a study approach that supports both CE marking and commercial adoption.
service related FAQ’s
The 510(k) file includes documents used to establish the safety and efficiency of the proposed medical device through substantial equivalence. The documents included in the 510(k) file are:
- Form FDA 3601: Medical Device User Fee Cover Sheet (MDUFC sheet)
- FDA Form 3514- CDRH Premarket Review Submission Cover Sheet: This document includes basic administrative and device information.
- 510(k) Cover Letter: This document provides a brief idea about the purpose of the submission, device, manufacturer and the U.S agent (if any).
- FDA Form 3881: Indications for Use Statement
- 510(k) Summary or 510(k) Statement: This includes a summary of the device undergoing the 510(k) clearance.
- Truthful & Accuracy Statement: This is to certify that the 510(k) submission contents are truthful and accurate and no information omitted.
- Class III Summary and Certification: If the proposed device is a Class III exempt from PMA, otherwise, this can be marked as not applicable.
- Financial Certification or Disclosure Statement: This is applicable only if clinical studies were conducted
- Declarations of Conformity and Summary Reports: Lists the voluntary consensus standards used and includes DOC to such standards.
- Device Description: This document includes the description of the device design requirements and performance specifications.
- Executive Summary: a brief description of the device & comparison table with the predicate device identified.
- Substantial Equivalence Discussion: Detailed comparison between the proposed device and the predicate device chosen.
- Proposed Labeling: Is discussed in detail to comply with 21 CFR 807.87(e) for general medical devices and 21 CFR 809.10 for IVD’s
- Sterilization and Shelf Life: This document provides details regarding the sterilization and shelf life claim being made.
- Biocompatibility: This document is applicable if the proposed device comes into direct or indirect contact with the human body tissue.
- Software: This includes the documentation for any software used in the proposed device
- Electromagnetic Compatibility and Electrical Safety- If the proposed device is powered electrically, in which case the EMC must be evaluated.
- Performance Testing – Bench: This document included details of the bench tests performed to evaluate the efficiency of the proposed device.
- Performance Testing – Animal: This document included details of the animal testing performed to evaluate the efficiency of the proposed device.
- Performance Testing – Clinical: This document included details of the clinical studies performed to evaluate the efficiency of the proposed device.
The completed FDA 510(k) file is submitted in electronic format as an e-copy to the FDA. The submission package is sent to the CDRH through registered mail or commercial delivery service.
Any medical device or new in vitro diagnostic medical device that is imported or manufactured for the purpose of clinical investigation, clinical performance evaluation, testing, evaluation, demonstration, or training must be kept in containers with labels clearly indicating:
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Name of the product or code number
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Batch or lot number
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Serial number (wherever applicable)
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Date of manufacture
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Use-before date
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Storage conditions
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Name and address of the manufacturer
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The specific purpose for which it has been manufactured
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“For Clinical Investigation / Evaluation Only – Not for Sale”
Based on the number of models and varients the timeline may change. usually the timeline for class B is approx 8-10 montsh and Class D is 14 months.
Form MD-22: This is the application form submitted to the Central Licensing Authority (CLA) (i.e., DCGI under CDSCO) to seek permission for conducting a clinical investigation of a new medical device or an investigational medical device without a predicate device in India.
Form MD-23: If the CLA is satisfied with the application, it grants permission to conduct the clinical investigation through Form MD-23. This permission allows the sponsor to begin the study in accordance with an approved clinical investigation plan reviewed by a registered Ethics Committee.
Additional requirements:
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The clinical investigation must be registered with the Clinical Trials Registry – India (CTRI) before the enrolment of the first participant.
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The first participant must be enrolled within one year of the grant of permission; otherwise, fresh permission from the CLA is required.
Yes. Under EU MDR 2017/745, PMCF is a mandatory and ongoing activity for all CE-marked medical devices, regardless of risk class. The extent of PMCF activities may vary depending on the device’s risk profile, clinical history, and available data.
