Global Medical Device Podcast powered by Greenlight Guru

#406: Over the Counter (OTC) vs. Prescription (RX) Medical Devices, Pt. 2

5 snips

May 12, 2025

In this insightful discussion, regulatory affairs expert Mike Drues shares his expertise on transitioning medical devices from prescription (Rx) to over-the-counter (OTC). He reveals what triggers new submissions and emphasizes the vital role of usability testing for lay users. Drues elaborates on the risk management challenges posed by removing healthcare providers from the process and the implications of real-world evidence for FDA approvals. Listeners gain practical insights into navigating FDA interactions and aligning regulatory strategies with business goals.

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ADVICE

Submission Needs for Rx to OTC Switch

Switching a device from prescription to OTC often requires a new FDA submission, depending on the device class and exemption status.
You must ensure the device safety and effectiveness for lay users without healthcare provider oversight, often requiring label and usability updates.

ANECDOTE

Hospital IV Anecdote on User Risk

Mike Drues shared a personal hospital experience highlighting risks when non-clinicians use medical devices unsupervised.
Such scenarios expose the need for increased risk management and design changes when expanding usage to laypeople.

ADVICE

Usability Testing for OTC Devices

Usability testing is critical for OTC devices because lay users operate without healthcare supervision.
Human factors studies must assess label comprehension and device selection choices by laypersons to mitigate serious user errors.

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In part 2 of a critical two-part series, Etienne Nichols and regulatory affairs expert Mike Drues explore the nuanced pathway of switching a medical device from prescription (Rx) to over-the-counter (OTC).

This episode dives deep into what triggers a new submission, how usability testing and human factors play an expanded role for lay users, and the regulatory logic that guides these transitions. The conversation highlights the importance of aligning regulatory strategy with business goals, and offers practical insights on leveraging real-world evidence, understanding the limits of FDA databases, and optimizing pre-submission meetings.

Key Timestamps

02:10 – Starting from a cleared 510(k): Do you need a new submission for OTC?
06:45 – Implications of removing the healthcare provider from the equation
12:00 – Risk management: Expanding risk profiles when lay users are involved
18:15 – When a 510(k) becomes a De Novo or PMA
22:50 – Usability testing and the risk of user error in OTC devices
31:20 – Clinical investigations and good clinical practices (GCPs)
36:00 – Real-world evidence vs. real-world data—what’s usable?
41:30 – Using Pre-Subs effectively and what “quality data” really means
47:10 – Labeling, cleaning, and UDI for OTC products
53:40 – OTC software and digital health—when is it a regulated device?
01:00:00 – Summary: Aligning regulatory logic with common sense and business strategy

Quotes

“With an OTC device, we are taking the healthcare professional totally, completely, and utterly out of the loop.”

– Mike Drues

This quote encapsulates the core regulatory challenge in moving a device to OTC: every element, from labeling to usability, must assume zero clinical supervision.

“If the clinical trial won’t tell you anything you don’t already know from good real-world evidence, why spend the time and money?”

– Mike Drues

A powerful argument for using well-documented real-world evidence over unnecessary trials—provided the data truly meets evidentiary standards.

Top Takeaways

Label Expansion ≠ Shortcut: Moving from prescription to OTC usually requires a new submission—especially when removing the healthcare provider introduces new risks.
Usability Testing Is Critical: OTC usability studies must go beyond IFU comprehension to include risk of misuse, poor device selection, and user decision-making.
Real-World Evidence Can Help—If It’s Clean: Real-world data isn’t always usable. FDA will expect reproducibility, traceability, and strong justifications.
Labeling & Design Must Assume No Clinical Oversight: Cleaning procedures, warnings, and directions must all be validated for home use and layperson comprehension.
Use Pre-Subs Wisely: Especially for label expansions or gray-area digital health tools, pre-subs provide critical alignment with FDA and prevent costly errors.

References & Resources

Etienne Nichols on LinkedIn
FDA Guidance on Real-World Evidence for Regulatory Decision-Making
Greenlight Guru Webinar: What is and Isn't a Regulated Medical Device (feat. Mike Drues)
FDA Guidance: Clinical Decision Support Software

MedTech 101: OTC vs Prescription Devices

Analogy: Think of prescription vs. OTC devices like driving a manual vs. automatic car. Prescription devices assume a trained “driver” (the healthcare provider), while OTC devices must be intuitive and safe enough for anyone to “drive” without instruction.

Graphic Suggestion: A split diagram comparing IFU complexity, user training, and supervision levels between Rx and OTC pathways.

Concept Simplified: Usability testing for OTC devices isn’t just about making it “easy”—it’s about ensuring safety in the absence of clinical guidance.

Audience Engagement

Poll Question:

Have you ever considered transitioning a medical device from prescription to OTC?

Yes, we’ve explored it
No, but we’re curious
We plan to stay prescription-only
Not applicable to our device

What’s your biggest challenge in designing for lay users? Share your thoughts with us on LinkedIn or email us at podcast@greenlight.guru—we’d love to hear your story.

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Sponsor Note

This episode is brought to you by Greenlight Guru, the only MedTech-specific Quality and Clinical platform. Whether you're transitioning to OTC or optimizing your device's QMS, Greenlight Guru is your partner for faster development and safer products. Visit www.greenlight.guru to learn more.