impact of the regulatory framework on medical device software manufacturers: are the guidance documents supporting the practical implementation?; comment on “clinical decision support and new regulatory frameworks for medical devices: are we ready for it? – a viewpoint paper”

The increasing use in clinical practice of software such as mobile apps and clinical decision support (cds) software has only recently been taken up by regulators around the world. specifically, the european commission and the us food and drug administration (fda) have updated their regulatory framework in the last years. van laere et al have given an extensive overview of the european and us approaches to regulate cds software. this commentary further discusses regulatory differences between the two geographies and their impact on manufacturers of medical device software. we discuss the practical implementation of the regulatory framework for medical device software (especially cds software) with a reference to the available international guidance documents and their limitations. given the direction of stricter regulatory oversight in europe, additional european guidelines/examples are desirable to enable a pragmatic regulatory approach ensuring continued access to innovative medical device software for european patients.