Credibility Assessment of Patient-Specific Computational Models��Pras Pathmanathan, PhD�Division of Biomedical Physics�Office of Science and Engineering Laboratories (OSEL)�Center for Devices and Radiological Health (CDRH)�FDA
OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Disclaimer
The mention of commercial products, their sources, or their use in connection with material reported herein is not to be construed as either an actual or implied endorsement of such products by the Department of Health and Human Services.
The following slides represent personal views and opinions, and not those of FDA
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Avenues for M&S in device regulatory submissions
In Silico Device Testing
Simulate a physical device to generate evidence for safety and/or effectiveness
Software in/as medical device
Algorithm within the device takes in patient data and simulates the patient
In Silico Clinical Trials
Proposed method where device performance is evaluated using a ‘virtual cohort’ of simulated patients.
Medical Device Development Tools (MDDTs)
MDDTs are tools, qualified by FDA, that device manufacturers can use to evaluate their device
OSEL VICTRE project
IT’IS
Heartflow
CardioInsight
Patient-specific models – Digital Twins
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Cardiac electrophysiological models
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Clinical tools vs virtual cohorts
g
Virtual cohort of ‘synthetic patients’
Model is/in the device
In scope
Out of scope as not patient-specific models
PSM workflow used in a clinical tool
Virtual cohort of patient-specific models
Used to evaluate a device (incl. in silico clinical trials)
Virtual cohort of ‘synthetic patients’
New model generated for every new patient
Fixed set of pre-generated PSMs, each corresponds to a real patient
Large number of models generated by sampling space – models do not correspond to any real patient
OSEL VICTRE project
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Little formal credibility assessment
Growing awareness in devices community (incl. CDRH) of need for better credibility assessment
ASME V&V40 subcommittee formed
CDRH M&S Reporting Guidance
ASME V&V40 Standard
OSEL Credibility of Models Regulatory Science Program
2000s
~2010
2013
2016
2018
2020
Draft Guidance on Credibility Assessment
2021
Model Credibility Assessment
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Verification, validation and uncertainty quantification
Computational Model
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p2
p3
p4
p5
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‘quantity of interest’ (QOI)
Parameters
Verification
Validation
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
ASME V&V40 Standard
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Project goals and approach
Goals
Approach
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Project goals and approach
Goals
Approach
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Verification of patient-specific models
| PSM as clinical tools | Virtual cohorts of PSMs |
Code verification | Code verification theory and methods equally applicable to PSMs as generic models | |
Calculation verification |
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Use error | For PSMs with semi-manual stages, possible user variability in subjectively-chosen inputs | |
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Verification of patient-specific models
| PSM as clinical tools | Virtual cohorts of PSMs |
Code verification | Code verification theory and methods equally applicable to PSMs as generic models | |
Calculation verification |
|
|
Use error | For PSMs with semi-manual stages, possible user variability in subjectively-chosen inputs | |
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Verification of patient-specific models
| PSM as clinical tools | Virtual cohorts of PSMs |
Code verification | Code verification theory and methods equally applicable to PSMs as generic models | |
Calculation verification |
|
|
Use error | For PSMs with semi-manual stages, possible user variability in subjectively-chosen inputs | |
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Multi-patient mesh resolution study
| Average edge length (microns) | Number of elements (millions of elements) |
Very low | 1029 ± 1.6 | 1.15 ± 0.28 |
Low | 630 ± 0.1 | 5.57 ±1.35 |
Medium | 426 ± 0.5 | 16.7 ± 4.1 |
High | 275 ± 0.02 | 69.1 ± 16.9 |
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Multi-patient mesh resolution study
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Validation of patient-specific models
Review identified myriad approaches to validation of PSMs
Three example approaches validating a virtual cohort of PSMs:
For example, three approaches for validating a PSM clinical tool:
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Validation of patient-specific models
Review identified myriad approaches to validation of PSMs
Three example approaches validating a virtual cohort of PSMs:
For example, three approaches for validating a PSM clinical tool:
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Uncertainty quantification for patient-specific models
Similarly, there are many possibilities when considering UQ of PSMs
Critical to distinguish between personalized and non-personalized inputs:
population variability
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
UQ for a virtual cohort study
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
UQ for a virtual cohort study
VT risk was computed at both pacing sites using all new meshes
Considered three cases:
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
PSM considerations using ASME V&V40 2018
Category | V&V40 Credibility factor | PSM-CT | PSM-VC |
Verification | Software quality assurance | No unique PSM considerations identified.
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Numerical code verification | |||
Discretization error | Gradations could account for number of patients these activities are performed on (see Table 5 & Supplement). | ||
Numerical solver Error | |||
Use error | For PSMs, with manual stages, there is a possibility of user variability related to subjectively chosen inputs. See supplement for example gradation accounting for this. | No unique PSM considerations identified. | |
Validation – model | Model form | No unique PSM considerations identified. | |
Model inputs – quantification of sensitivities | For PSMs, sensitivity analysis and uncertainty quantification are intimately linked, so an alternative approach is have a single sensitivity analysis and uncertainty quantification factor with possible subfactors:
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Model inputs – quantification of uncertainties | |||
Validation -comparator | Quantity of Test Samples | There may be unique PSM considerations, but these will be dependent on the specific validation activities performed. For some cases where a PSM is validated against clinical data, these factors could be interpreted as:
See supplement for example gradations. | |
Range of Characteristics of Test Samples | |||
Characteristics of Test Samples | |||
Measurements of Test Samples | |||
Quantity of Test Conditions |
There may be unique PSM considerations, but these will be dependent on the specific validation activities performed. | ||
Range of Test Conditions | |||
Measurements of Test Conditions | |||
Uncertainty of Test Condition Measurements | |||
Validation - comparison | Equivalency of Input Parameters |
No unique PSM considerations identified. | |
Output Comparison – quantity | |||
Equivalency of Output Parameters | |||
Agreement of Output Comparison | |||
Rigor of Output Comparison | |||
Applicability | Relevance of the QOIs | ||
Relevance of the Validation Activities to the COU | For PSMs, assessing the relevance of the validation subjects to the full patient population / full virtual cohort is a component of applicability assessment | ||
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Example – “Discretization error” factor
Example gradation in ASME V&V40 | Possible gradation for PSMs as clinical tools | Possible gradation for virtual cohorts of PSMs |
(a) No grid or time-step convergence analysis was performed to estimate the discretization error.
(b) Applicable grid or time-step convergence analyses were performed and their respective convergence behaviors were observed to be stable, but the discretization error was not estimated.
(c) Applicable grid or time-step convergence analyses were performed and discretization error was estimated.
| (a) No grid or time-step convergence analysis was performed to estimate the discretization error.
(b) Applicable grid or time-step convergence analyses were performed, using one or a small number of patients, and their respective convergence behaviors were observed to be stable, but the discretization error was not estimated.
(c) Applicable grid or time-step convergence analyses were performed and discretization error was estimated, using one or a small number of patients.
(d) Applicable grid or time-step convergence analyses were performed and discretization error was estimated using a range of representative patients
(e) Applicable grid or time-step convergence analyses are automatically performed on each new patient, and discretization error is estimated, and used in processing the results.
| (a) No grid or time-step convergence analysis was performed to estimate the discretization error.
(b) Applicable grid or time-step convergence analyses were performed and their respective convergence behaviors were observed to be stable, but the discretization error was not estimated, using one or a small number of subjects.
(c) Applicable grid or time-step convergence analyses were performed and discretization error was estimated, using one or a small number of subjects.
(d) Applicable grid or time-step convergence analyses were performed and discretization error was estimated, using a range of patients covering the virtual cohort.
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Summary and take-home messages
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023
Thank you for your attention
Acknowledgements (paper co-authors)
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OSEL Accelerating patient access to innovative, safe, and effective medical devices through best-in-the-world regulatory science IMAG Feb 2023