7. Enabling data prescription
1. Clinician prescribe data based on the metrics that matter to
them (e.g. 30 minutes of moderate activity, 5 days a week)
2. Patient syncs their favorite app or devices
3. Data from disparate apps are integrated, normalized,
analyzed and visualized to provide context between clinical
visits
8.
9. A mobile health tool as a medical device
Is something that is:
1. Used as an accessory to a regulated medical device
2. Transforming a platform into a regulated medical device
“…intended for use in performing a medical device function (i.e.
for diagnosis of disease or other conditions, or the cure,
mitigation, treatment, or prevention of disease) it is a medical
device, regardless of the platform on which it is run.” (Page 8)
10. Enforcement discretion (page 16)
● Help patients self-manage their condition without providing
treatment or treatment suggestions (ex. coaching)
● Provide patients with simple tools to organize and track their
health information (ex. our product)
● Provide easy access to information related to patients’ health
conditions or treatments (ex. personal health record?)
● Help patients document, show, or communicate potential
medical conditions to health care providers (
● Automate simple tasks for health care providers
● Enable patients or providers to interact with Personal Health
Record or Electronic Health Record Systems.
11. My questions
1. We are “transforming” data to be actionable to a patient and
clinician. Not doing diagnostics, but providing insight that has
never been in a clinical visit. Where do we fit?
2. How do we handle devices that are regulated by the FDA?
Like an Omron Series 7 blood pressure cuff.
3. How do we develop language as part of our service
agreements with partners to ensure trust? Where should that
language live (online/in-app)? How do we ensure toolmakers’
T&A work?