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QMS
  • Welcome to your QMS
  • Quality Manual
  • Procedures
  • Records
  • Legit.Health Plus Version 1.1.0.0
  • Legit.Health Plus Version 1.1.0.1
  • Legit.Health version 2.1 (Legacy MDD)
  • Legit.Health Utilities
  • Licenses and accreditations
  • Applicable Standards and Regulations
  • BSI Non-Conformities
    • Technical Review
    • Clinical Review
      • Round 1
        • Item 0: Background & Action Plan
        • Item 1: CER Update Frequency
        • Item 2: Device Description & Claims
          • Request A: Device Description & Intended Purpose
          • Request B: Clinical Benefits, Performance & Safety vs SotA
            • Question
            • Research and planning
            • Response: Item 2B
            • Prompt_resolution_activities
        • Item 3: Clinical Data
        • Item 4: Usability
        • Item 5: PMS Plan
        • Item 6: PMCF Plan
        • Item 7: Risk
        • task-3b2-3b3-legacy-rwe-study
        • task-3b4-mrmc-dark-phototypes
  • Pricing
  • Public tenders
  • BSI Non-Conformities
  • Clinical Review
  • Round 1
  • Item 2: Device Description & Claims
  • Request B: Clinical Benefits, Performance & Safety vs SotA
  • Prompt_resolution_activities

Prompt_resolution_activities

El objetivo de este documento es darte respuesta a las preguntas que me has formulado así como las deficiencias detectadas por la auditora de BSI en el Item 2b. Así, este documento te debe servir como fuente para tener contexto sobre las preguntas que me has formulado y para que puedas responder a la auditora de BSI sobre el Item 2b, así como el resto de aclaraciones necesarias.

You've asked me the following questions:

  1. Melanoma specificity: CEP says ≥90%, CER derivation table says ≥80%

Response: You’re right. The change done was wrong and in the CEP must figure "A specificity of 80% ruling out melanoma", as it was previously stated and correctly.

  1. Acceptance criteria values: Are the low-seeming thresholds called out by BSI (e.g., 3KX remote care sub-criterion sensitivity 30% for remote referrals, 7GH rare disease sub-criterion accuracy 54%, and 5RB kappa 0.6) correct and clinically defensible? If so, we need to provide the clinical rationale for why they are acceptable. If not, do we need to revise these thresholds or withdraw specific claims?

Response: Sí, los valores de los criterios de aceptación que has mencionado son correctos y clínicamente defendibles. La justificación es la siguiente: The provided clinical metrics are correct based on the following justifications. Regarding Female Androgenetic Alopecia, there is currently a lack of literature specifically addressing inter-observer agreement or Cohen’s Kappa (κ\kappaκ) for assessing pathological severity. Consequently, the established acceptance criteria are derived from the standard clinical interpretation of the metric: in Cohen’s Kappa, a κ\kappaκ value of 0.41–0.60 represents moderate agreement, which is considered an acceptable threshold in clinical environments, while results exceeding 0.60 are deemed optimal. Concerning Diagnostic Accuracy in Rare Diseases, these conditions present a very low incidence rate in dermatological consultations. Current literature primarily highlights the high rate of misdiagnosis and the frequency with which these pathologies are confused with one another, rather than providing definitive sensitivity or specificity figures. This underscores the diagnostic challenges faced by both primary care physicians and specialists, for whom biopsy and immunopathology remain essential. Therefore, our results demonstrate the significant improvement in diagnostic precision metrics achieved through the clinical use of the device. Finally, regarding the 30% improvement in Teledermatology outcomes, there is a notable gap in existing literature concerning the sensitivity and specificity of medical devices in enhancing the detection of cases requiring referral. Thus, the reported figures represent the documented enhancement of these metrics for primary care physicians when utilizing the device during consultations.

  1. PPV/NPV for malignant conditions (1QF): in CEP, missing from CER derivation table

Response: You’re right. Clarified as standalone device predictive values with a note that CEP human-in-the-loop PPV/NPV criteria are separately addressed by the performance claims.

  1. Benefits/acceptance criteria hard to follow in CEP §17.4 (the clinical benefits table at lines 281-289 of R-TF-015-001). Three benefits (7GH, 5RB, 3KX) with sub-criteria, each with multiple means of measure and magnitude thresholds, are presented in a dense table without narrative explanation.

Response: You can use the following explanation (it is just for you to have context, improve it as deemed). This table presents the clinical benefits derived from the use of the device, defined as the positive, measurable, and significant impact on a patient’s health or the overall management of their condition. These clinical benefits are substantiated by the performance claims achieved by the device during clinical validation.

  1. 5RB ICC: three different numbers across three documents

Response: The acceptance criteria was ≥0.70, and the results was 0.727.

  1. 5RB alopecia correlation: in CEP, missing from CER

Response: Yes, it was another way to assess the correlation between the device and the clinical reference standard; it must be included along the Cohen’s Kappa in the CER, as it was included in the CEP.

  1. 8PL referral sensitivity and specificity: in CEP, missing from CER summary

Response: Add also these results to the CER summary table, as they are important for the clinical performance of the device and should be clearly presented in the CER.

  1. 0ZC expert opinion criteria: in CEP, absent from CER

Response: It is a complementary method to assess the value perceived by experts in the field and it has been addressed like this.

  1. 3KX expert time reduction criterion: in CEP, absent from CER derivation table

Response: It is a complementary method to assess the value perceived by experts in the field and it has been addressed like this.

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Response: Item 2B
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Item 3: Clinical Data
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