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25/02/13
What about regulation ?
Anaïs Althapé Arhondo - Pauline Colin - Chloé Dubroca - Olivier Heloir - Marie-Caroline Richard
This is an independent study performed by
students from the « Faculté des Sciences
Pharmaceutiques de Lille »
2
3
JAMA Dermatology
January 2013
1st major comparative
clinical trial about
Smartphone health
Apps for the public
4
Regulatory problems
Technology development goes faster than
regulation
Danger for public
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To know :
o Who the consumers of health Apps are?
o Which smartphone?
o What kind of Apps?
o Why do they use them?
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276 answers
Sex
o Men 37 %
o Women 63%
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Ages
o <25 ans : 45%
o 25-34 ans : 39%
o 35-44 ans : 1%
o 45-54 ans : 7%
o 55-65 ans : 7%
o >65 ans : 0%
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Activities
o
o
o
o
o
o
o
Etudiant en santé : 35%
Etudiant dans les nouvelles technologies : 0%
Etudiant (autre domaine) : 9%
Professionnel de santé :15%
Professionnel dans les nouvelles technologies : 5%
Professionnel (autre domaine) : 28%
Autres (sans emploi, retraité …) : 7%
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Have you got a smartphone ?
o Yes : 80%
o No : 20%
Androïd VS Iphone
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Advice for Health application ?
o Yes : 14%
o No : 86%
If yes, who ?
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Have you already use health app?
o Yes : 28%
o No : 72%
Advice for health app : professional mission?
o Yes : 64%
o No : 36%
Did you pay for health app?
o Yes : 5%
o No : 95%
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Which kind of app?
o
o
o
o
o
o
Renseignements sur des médicaments : 32%
Suivi quotidien d’une pathologie chronique : 17%
Conseils hygiéno-diététique : 11%
Informations sur des pathologies : 9%
Aide à un auto-diagnostic :15%
Aucune : 13%
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Health’s professional validation ?
o Yes : 65%
o No : 35%
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11)
Environment
21)
Regulatory situation
31)
Cases study
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Smartphones
Applications
Health applications
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18
Phone
+
Mobility
=
Bluetooth
Photo
Medical
Device
Geo
localisation
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1st quarter of 2012
~144,4 million of Smartphones sold
Up 44% / 1st quarter 2011
In the same time : 2% decline of worldwide sales of mobile phones
*Source Gartner – May 2012
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Global Internet Device Sales
3,000
Units in millions
2,500
Tablets
2,000
1,500
Smartphones
1,000
500
Computers
0
2000
2001
2002
2003
*Source Gartner – May 2012
2004
2005
2006
2007
2008
2009
2010
2011
2012E
2013E
2014E
2015E
2016E
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SAMSUNG
APPLE
VS
TOP 2
Q4 2012
SAMSUNG
APPLE
Smartphone sales (million)
63,7
47,8
Market share
29%
21,8%
*Source Ecoconscient
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Which countries did use more Smartphones in 2012 ?
38%
38%
45%
27% (2011)
*Source : Sondage Ipsos – Google, Février 2012
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Where are smartphones used ?
Home
96%
Work
69%
On-the-go
49%
Doctor's office
55%
Airport
32%
3%
*Source : Sondage Ipsos – Google, Février 2012
64%
59%
61%
44%
43%
50%
36%
School
56%
43%
59%
Public transport
76%
27%
48%
At a social gathering/function
75%
63%
70%
Café or coffee shop
78%
85%
76%
Restaurant
98%
71%
83%
In a store
Somewhere else
97%
42%
61%
64%
16%
5%
27%
3%
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What is a mobile application ?
o A downloadable program (free or paying) used
thanks to the operating system of the phone
o A software that can run on a mobile device
such as a cell phone that will allow the device
to perform specific tasks that are typically
restricted to PCs
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Apple Store
Androïd Market
TOP 2
VS
25 billion of apps downloaded
o in march 2012 for iOS
o in september 2012 for Androïd
Apps classification not clear
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Top of Apps categories according to audience (in US)
35000
30000
25000
+134%
20000
15000
10000
5000
0
Déc. 2010
Déc. 2011
*Source : comScore MobieLens, 3 mon. avg. ending Dec-2011 vs. Dec-2010
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In January 2012
17 000
Health & Fitness
apps
74%
paid
apps
*Source : Proximamobile – January 2012
6 000
Health & Fitness
apps
73%
for the
public
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Consumer Health Apps for Apple’s iPhone
Cardio
16%
Other
27%
Sleep, Emergency, Smoking
cessation, Medication
Adherence, PHR…
Diet
14%
Chronic
conditions
6%
Stress &
Relaxation
11%
Mental Health
6%
Calculator
6%
*Source : MobiHealthNews’2011 report
Strength
Training
7%
Women's
Health
7%
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Various kinds of health apps
Health professionnals
Promotional tools
(pharmaceutical industries)
Secured instructions about
medecines or anything else
Social network for discussions
eLearning
Serious game
Live meeting
Public
Instructions about medecines
Medical calculation (not secured)
Follow-up of quantified data
o Written by the patient himself
or thanks to a connected
device
o Sent to a health professional
eLearning or Serious Game
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Guidelines
Evaluation by clinical trials
Private agencies
French practices
A manufacturer point of view
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FDA Guidance
MEDDEV
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2011
2005
1989
Draft Software
Policy released
Policy was withdrawn because
- Use of computer products
and software products as
medical devices has grown
exponentially
- FDA determined that
computer systems and their
software were too complex
and diverse for one policy to
encompass
The FDA stepped up
regulatory efforts
Mobile Apps Draft
Guidance
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Draft Guidance for Industry and Food and Drug Administration Staff
Mobile Medical Applications
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FDA has the authority to regulate software if it
falls within the definition of a “device”
o Class I - most Class I devices are exempt from
Premarket Notification 510(k)
o Class II - most Class II devices require Premarket
Notification 510(k)
o Class III - all Class III devices require Premarket
Approval
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THE FDA SCOPE
MOBILE MEDICAL APPS
Used as an accessory to a regulated medical
device
OR
Transform a mobile platform into a regulated
medical device
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1
Displaying, storing or transmitting patientspecific medical device data in its original format
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Controlling the intended use, function, modes, or
energy source of the connected medical device
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3
4
Transforming or making the mobile
platform into a regulated medical device
Creating alarms, recommendations or creating new
information (data) by analyzing or interpreting medical
device data
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OUT OF FDA SCOPE
1
Mobile apps that only automate
general office operations with
functionalities that include billing,
inventory, appointments, or
insurance transactions
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2
Electronic “copies” of medical
textbooks, teaching aids or
reference materials, or are
solely used to provide
clinicians with training or
reinforce training previously
received
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3
Solely used to log, record,
track, evaluate, or make
decisions or suggestions
related to developing or
maintaining general health
and wellness
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4
Mobile apps that are generic
aids that assist users but are
not commercially marketed
for a specific medical
indication
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Guide elaborated by the task force of the European
Commission : European Medical Device Expert Group
Contain advice for the implementation of European
guidelines
Common approach by manufacturers and Notified
Bodies involved in the conformity of assessment
procedures
Not legally binding
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MEDDEV 2.1/6
Guidelines on the qualification and classification of
standalone software used in healthcare within the
regulatory framework of medical devices (MD)
Published on January 2012
Purpose : clarify the rules of standalone software in a
healthcare environment
2 main questions
o In which cases should a software be considered as a medical
device?
o If it is considered like a medical device, which guidelines apply?
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EXAMPLES
Telesurgery
Radiology Information System
are not qualified as MD
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The telecommunication system (mobile, wireless,
wire , etc…) is not as such a medical device
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Mersey Burns
Free clinical tool
o Calculating burn area
percentages
o Prescribing fluids using Parkland,
background fluids
1st app to be registered by the
MHRA as a Class I medical
device
1st publically available UK app to
carry the CE mark
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USA versus EU
The FDA became aware of health
apps problems a long time ago
In Europe, we are still at the
stage of software problem
hard to follow innovation
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Melanoma detection
Blood glucose control compliance
Measure of lung function
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OBJECTIVE
To measure the performance of 4 smartphone
applications that evaluate photographs of skin
lesions and provide the user with feedback
about the likelihood of malignancy
Primary endpoint : sensibility to categorize melanoma
*Source : www.jamaderm.com - published online January 16, 2013
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RESULTS
Sensitivity
o + : analysed by a board-certified
dermatologist
o - : analysed by automated algorithms
CONCLUSION
Reliance on these applications in lieu
of medical consultation
o Can delay the diagnosis of melanoma
o Can harm users
*Source : www.jamaderm.com - published online January 16, 2013
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OBJECTIVE
Comparison of mobile app and standard
diabetes management effect for glycated
hemoglobin levels in patients with type 2
diabetes
Primary endpoint
o Glycated hemoglobin levels
Secondary endpoints
o Diabetes distress, depression, and other clinical (blood pressure)
and laboratory (lipid)values
*Source : www.welldoc.com - Cluster-Randomized Trial of a Mobile Phone Personalized Behavioral
Intervention for Blood Glucose Control
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RESULTS
Glycated hemoglobin
o Dicrease of 1.2% over 12 months
o Appreciable differences were not observed
for secondary outcomes
CONCLUSION
Mobile coaching improves compliance
and therefore reduces glycated
hemoglobin levels over 1 year
*Source : www.welldoc.com - Cluster-Randomized Trial of a Mobile Phone Personalized Behavioral
Intervention for Blood Glucose Control
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OBJECTIVE
To compare the accuracy of SpiroSmart™
to a clinical spirometer endorsed by the
American Thoracic Society (ATS)
Primary endpoint
o Standard spirometer measures flow rate
Secondary endpoints
o Comparison diagnoses from pulmonologists using
SpiroSmart™ and a clinical spirometer
*Source: http://abstract.cs.washington.edu/~shwetak//papers/SpiroSmart.CR.Final.pdf
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RESULTS
Accuracy of measures : 80-90%
CONCLUSION
SpiroSmart™ can be used to
diagnose normal vs obstructed
spirometry
SpiroSmart™ can be effective for
diagnosing the degree of the
obstruction
*Source: http://abstract.cs.washington.edu/~shwetak//papers/SpiroSmart.CR.Final.pdf
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Define Benefit/Risk ratio
Seems to be necessary to approve health apps
o For diagnosis apps mainly
o +++ If reimbursement in the future ?
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DMD
Happtique
D4
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What is DMD ?
o A French private company which evaluates health
mobile apps
How it works?
o A medical team tests and compares apps on a totally
free platform
Source: http://www.dmd-sante.com/
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Founded in 2010
First mobile application store developed by
healthcare professionals for healthcare professionals
App management solution that helps healthcare
providers, physicians, and patients easily integrate
mHealth into treatment
Draft app certification standards
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A non profit organisation based in the UK
Practical guide : Regulation of health apps
o Published in January 2012
o Purpose : regulatory standpoint for health apps
• How are health apps regulated?
• What other issues should I consider if I’m developing a
health app ?
• How can I support the use of health apps across my
organisation ?
Objective : start debate on this topic across the world
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Responsabilities
CNIL
HON
Monitoring
Internet convention
Advertising control
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Responsabilities
Publisher
Who is it ?
o He creates the content
OR
o He has the power to make
the editorial choice about the
content
Total responsibility
o Respect of principles related
to content published
o Respect of rules for medical
publishing
Host
Role
o Only technical
o No obligation to watch over
contents
Responsibility
o None
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An independent French administrative authority
Aims : to ensure that data privacy law
is applied to the collection, storage,
and use of personal data
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Advice for App user
Managing passwords
Data confidentiality
o Coding of personal
information
o Cryption
Obligation for publishers
of App
Collection/storage/use of
personal data
Law on computers, files
and liberties
Collect only personal data
necessary
Data integrity
Limited duration = time
required
Internet connection
Ensure confidentiality and
security of information
o Firewall or software
protection barriers
Declare applications to
CNIL before
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A non-profit, non-governmental organization
Funded by the State of Geneva, several European
projects, the French National Health Authority
(HAS) and the Provisu foundation
Aims : Promotes and guides deployment of useful
and reliable online health information, and its
appropriate and efficient use
HONcode : “Improving the quality of online health
information” Ethic
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Top des Medocs, a certified app
Santéclair
Medicines without prescription
o 2400 drugs
o 100 selftreatment situations (cold,
cough, bloating, stomach
heartburn…)
Health app certified by HON
Foundation
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Remote monitoring : from a distance to
interpret data to monitor a medical patient if
necessary to make decisions
Safety projects implemented will ensure
o Authentication
o Patient information and consent to collection
o Confidentiality and integrity of data exchanged
and hosted
*Source: Décret du 19 octobre 2010 relatif à la télémédecine
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Signed between AFSSAPS and LEEM
President in 2006 (revised in 2010)
Aims = to help pharmaceutical industries to
o Create their web pages with respect to the law
o Differentiate advertising from information
General recommendations
o
o
o
o
Name the company
Identify population concerned
Update information regularly (specify the last update)
Indicate promotional pages
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Problems
o Technology changes faster than regulation
• Quick evolution of social networks (Facebook, Twitter…)
o Future
• The Internet charter is now reviewed
• A new charter between SNITEM and Leem will be
published
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Advertising control
« Product » App
Advertising risk
Comment/Tweet/Like
problems
« Environnement » App
Can’t name ONE product
but all products of a same
therapeutic area
Should be objective and
complete
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Interview of Uwe DIEGEL - iHealth
(28/11/2012)
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CEO iHEALTH
Silicon Valley start-up
An official partner of Apple
Uwe DIEGEL
50% hypertension market share in Europe
3 years $ 80million
*Source : Medical Device Daily – Tuesday, November 20, 2012
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Some iHealth Products
Blood pressure monitor
A new glucometer
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Regulation ≠ innovation restriction
Against diagnosis app (illness)
For Health management app
Self-measures are not medical data
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Defibrillator localisation
First aid techniques reminder
Call emergency ambulance
service directly
80
81
Défibrillateurs
Helpful
(localisation, techniques)
All defibrillators are not listed
Nobody check localisation
Handy
Don’t work without network
Dependence
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Monitor blood glucose,
carbohydrate intake and
insulin
Manages results
o Logbook
o Trend chart
o Statistics
Simplifies communication
with health care professional
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Color-coded
o Hypoglycemia
o Glycemia in medical range
o Hyperglycemia
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86
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iBGStar
Simple and useful
Optimisation for
monitoring
Color-coded dependence
to interpret glucose
results
Device independent of
mobile
Share with doctor
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89
What is it?
o Allows patient to
know UV index/skin
type
o Checks skin lesion
and moles :
Melanoma risk ?
How it works ?
Algorithm
•Picture
•Sexe
•Age
o Finds a
dermatologist
90
91
92
Skinvision
Easy and simple check
Ethic
Immediate analysis
Reliability (Clinical trial)
Finds an appropriate
dermatologist in your
vicinity
To know your skin type
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A privately held personal genomics and
biotechnology company based in Mountain View
(California) that provides rapid genetic testing
95
Gives you the possibility to
o Know if your child will be at risk for
48 inherited conditions and learn
about steps you can take
o Personalize your healthcare by
knowing in advance how you will
respond to certain medications like
Warfarin
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97
23andMe
Can help to plan for the
future
Know in advance how
we respond to certain
medications
Data protection
Information may be
made public or
released to insurance
companies
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99
App for diagnosis at home
For common problems like ear
infections =
telemedicine diagnosis from home
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101
Otoscope
↘ medical consultations
Rapidity
Diagnosis of pediatric ear
infections
Comfortable
for doctor
childrenvisits
= cause
30 million
annually in the United States
Sharing data if necessary
Consultation is opportunity
for a global check
Other associated
symptoms?
Interpretation and quality of
diagnosis
Physician compensation?
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Apps are useful to help patient managing their healthcare
Regulatory aspects
under construction
104
New action plan for the development of e-Health &
m-Health
By the European Commission
Aim : "Improve the care of patients by allowing them
to have control over their benefit care“
Assessment of cost benefits, productivity gains and
business models, notably through Health
Technology Assessment (HTA)
http://ec.europa.eu/information_society/activities/health/docs/policy/ehap2012public-consult-report.pdf
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Created in 2009 by the French government
To develop, coordinate and participate in the
regulation of e-health & m-health in France
Link between the universe of the health and the
new technologies: telemedicine, DMP…
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RELIABILITY
-
Evaluation by
clinical trials
MONITORING
-
Check and approval
by health
Medical supportDATA
professionnal
during diagnosis
≠ DIAGNOSIS
CONFIDENTIALITY
-
Cryption REGULATION
reinforcement
-
Protection
- Scope clearlyNETWORK
improvement
defined
-
PHYSICIAN
More resident
COMPENSATION
applications
-
Find a system
CONTROL
-
Agency :
Public/Private?
-
Platform only for
health apps
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