The FDA and Software: A Historical Overview with Dr. Donna-Bea Tillman

This video is part of a series of guest expert interviews that we recorded for our new Yale Certificate Program on Medical Software and Medical AI – https://online.yale.edu/medical-software-ai-program. Our guest is Donna-Bea Tillman, a principal consultant at Biologics Consulting Group. She has 30 years of medical device regulatory experience. Prior to joining Biologics Consulting she held numerous positions within FDA’s Center for Devices and Radiological Health, culminating in her 2004 appointment to the position of Director of the Office of Device Evaluation, where she oversaw the medical device premarket review program for non-IVD devices.

During her 17-years tenure at FDA, she played a pivotal role in the development of guidance documents, standards, and policy frameworks for medical device software and health IT. In 2010 she joined Microsoft’s Health Solutions Group as the Director of Regulations and Policy, where she was responsible for obtaining the appropriate global premarket registrations and managing Microsoft’s postmarket safety programs.

She joined Biologics Consulting in 2012 and over the past 12 years has submitted more than one hundred 510(k) submissions as well as several noteworthy de novos in the digital health space. Donna-Bea received her B.S.E. in Engineering from Tulane University, her Ph.D. in Biomedical Engineering from the Johns Hopkins University, and her Master’s in Public Administration from the American University.

00:10 Introduction
01:37 The origins of FDA’s software regulation
08:44 The PC Era and off-the-shelf (OTS) components
14:34 The Quality Systems Regulation and its antecedents. Bad design not bad manufacturing.
16:56 Software-as-a-Medical Device and the role of imaging
23:02 Medical device data systems. The FDA and EHR systems.
27:43 The role of mobile devices, phones and watches.
30:47 Digital health, wellness and medical devices
37:03 Concluding thoughts.

Additional Reading Material

U.S. Federal Drug Administration (FDA). FDA POLICY FOR THE REGULATION OF COMPUTER PRODUCTS. 1989. Available from https://drive.google.com/file/d/1_7d2xB3E3ngu9UWPVlqYKRxtJ93gj3cP/view?usp=drive_link

U.S. Food and Drug Administration (FDA). Medical Devices; Current Good Manufacturing Practice Final Rule; Quality System Regulation. Fed Regist . 1996;61(195). Available from: https://www.fda.gov/medical-devices/postmarket-requirements-devices/quality-system-qs-regulationmedical-device-good-manufacturing-practices

U.S. Food and Drug Administration (FDA). General Principles of Software Validation; Final Guidance for Industry and FDA Staff. 2002. Available from: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/general-principles-software-validation

U.S. Food and Drug Administration (FDA): Center for Devices and Radiological Health. Software as Medical Device (SAMD): Clinical Evaluation. Guidance for Industry and Food and Drug Administration Staff . 2017. Available from: https://www.fda.gov/medical-devices/digital-health-center-excellence/software-medical-device-samd

Center for Devices and Radiological Health. General Wellness: Policy for Low Risk Devices. Guidance for Industry and Food and Drug Administration Staff . U.S. Food and Drug Administration (FDA); 2019. Available from: https://www.fda.gov/media/90652/download

Center for Devices, Radiological Health. Medical Device Data Systems, Medical Image Storage Devices, and Medical Image Communications Devices . U.S. Food and Drug Administration. FDA; 2019. Available from: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/medical-device-data-systems-medical-image-storage-devices-and-medical-image-communications-devices

Center for Devices, Radiological Health. Multiple function device products: Policy and considerations . U.S. Food and Drug Administration. FDA; 2020. Available from: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/multiple-function-device-products-policy-and-considerations

Center for Devices, Radiological Health. Off-the-shelf software use in medical devices . U.S. Food and Drug Administration. FDA; 2023 . Available from: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/shelf-software-use-medical-devices

Apple DeNovo Clearance Photoplethysmograph analysis software for over-the-counter use https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/denovo.cfm?id=DEN180042 09/11/2018 (Ms. Tillman is listed as the contact person for this)