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Clinical trials – Data submission requirements for clinical trials of medical devices

2022-11-14

In order to strengthen the supervision and guidance of the registration of medical device products, the Center for Medical Device Evaluation .NMPA released the official version of the Guidelines for the Registration Review of Medical Device Clinical Trial Data Submission. This paper sorts out the final document list and submission requirements for clinical trials of medical devices for the reference of enterprises in need.

1.Data submission and requirements for clinical trial data of medical devices

Basic principles of clinical trial data submission: authenticity, traceability and readable
Material Submission
Material Content
Submission Requirements
Interpretation
Form of Submission
Raw Data Base
Case Report Form
Data sets and variables should be named in accordance with the principle of “readability”. It is recommended to refer to the English or pinyin of data sets or variables when naming them, so that the actual meaning of the name can be easily associated with the name
Interpretation:
① There are no restrictions on the number and capitalization of the data set and a computerized optometer is added. For example, a computerized Optometer could be named COOP or DNYG.② There is no mandatory requirement on identity variables and viewable variables, and there is no requirement on variable capitalization. You can freely name variables as long as they start with a letter.If the subject’s initials can be named SubIN or SSZXMSX, this also conforms to the “easy to read” principle.③ Suggestions for variable naming can refer to the unified standardized rules of drug clinical submission requirements.
XPT
(V5)
Raw data collected directly in external files
Analyzed Database
Variable data in the original database
The variable naming of the analysis dataset is the same as that of the original database.
XPT
(V5)
Data derived from the original database variable data in accordance with the methods previously determined in the clinical trial protocol and statistical analysis plan.
Information  Submission
Material Content
Submission Requirements
Interpretation
Form of Submission
Procedure Code
Code for generating analysis database from original database
The submitted code shall conform to the usual programming format and specification, with clear structure and easy reading. The program code shall include sufficient comments to describe the purpose of different program codes and other contents to be explained, so as to help reviewers better understand the code logic
If the submitted program code references the macro program, the corresponding macro program code shall be provided, and the software version and system environment for running the program shall be described.
①The submission of complex nested macro programs shall be avoided. If a complex nested macro program is submitted, it shall be fully verified to ensure that the program can be run in different computer system environments.
②Analysis and processing involving code are committed, support complex macros, and are executable.

 

 

TXT
Code that analyzes the database to generate statistical analysis results
Supporting paper
Data description file
It is recommended to use Excel files to list data sets, variables, variable types (such as character type and numerical type), labels, assignments and their corresponding relationships in the original database and the analysis database respectively in the form of tables
PDF
WordExcel,and so on
Instructions for the use of program code

Listing the program code files and data set file names used to generate each statistical result chart one by one in the form of a table.

The applicant for registration should state the encoding used for both the original data set and the analytical data set (e.g. UTF-8, EUC-CN, etc.) to avoid garbled data sets submitted.

 

Notes Case Report Form
Some redundant data unrelated to the analysis of clinical trial results may be collected in CRF. These data may not be included in the submitted database, but should be clearly marked as “not submitted” on the comment CRF, and the reasons should be clarified.

 

Other illustrative documents
In addition to the above illustrative documents, applicants for registration are encouraged to submit other illustrative documents (e.g., overview documents, other descriptions of special circumstances, etc.) that will help reviewers quickly understand the content and structure of the clinical trial database.

 

2. Structure of medical device data submission folder