open mhealth - legal hackers - may 22, 2014

Legal HackersMay 22, 2014

Growth in tools

Chronic disease is on the rise

An infinite number of questions about our health

Unlocking data to tell better patient stories

Open data formatClinical face-value

Products

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

A mobile health tool as a medical device

Is something that is: 1. Used as an accessory to a regulated medical device2. 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)

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.

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?

Thanks

david@openmhealth.org / @haddaddawww.openmhealth.org