FDA Articles / Blogs / Perficient https://blogs.perficient.com/tag/fda/ Expert Digital Insights Wed, 29 Jun 2022 15:42:50 +0000 en-US hourly 1 https://blogs.perficient.com/files/favicon-194x194-1-150x150.png FDA Articles / Blogs / Perficient https://blogs.perficient.com/tag/fda/ 32 32 30508587 Big Foot Forward With AI To Treat Insulin Dependent Diabetics https://blogs.perficient.com/2021/05/21/bigfoot-forward-with-ai-to-treat-insulin-dependent-diabetics/ https://blogs.perficient.com/2021/05/21/bigfoot-forward-with-ai-to-treat-insulin-dependent-diabetics/#respond Fri, 21 May 2021 12:44:51 +0000 https://blogs.perficient.com/?p=292661

Background of Diabetic Market in the US

According to a 2020 Center for Disease Control (“CDC”), the United States has approximately 34 million people with diabetes. Of these, the Juvenile Diabetes Research Foundation (JDRF) estimates that 7% are Type 1, meaning their body produces no insulin, and cannot survive without does of insulin. Of the 93% who are either Type II, meaning their body does not produce enough insulin, or have Gestational Diabetes, one of every four must inject insulin to keep their diabetes under control.

How do diabetics know how much insulin to take? Since the early to mid-1980’s, diabetics measured their blood sugar and then used either a syringe or pump to inject themselves with insulin. The exact amount of insulin would be calculated by hand, or via a pre-determined algorithm in an insulin pump.

As a Type 1 diabetic since 1974, measuring blood sugar and doing the calculations in my head seemed normal and easily done. More recently, rather than finger sticks to measure blood glucose directly, continuous glucose meters (CGMs) have been developed which attach to the shoulder of a diabetic and automatically take blood sugars every five minutes. The CGMs currently on the market last for two weeks before needing to be replaced.

My normal routine is to check my blood sugar on my CGM; manually enter that into my PDA (the front end of my insulin pump); manually enter my anticipated carbohydrates; have the pump propose an insulin dose; manually adjust the insulin dosage for anticipated exercise, and then have the pump administer the insulin dose.

Bigfoot Unity Diabetes Management System Approved by Regulators

However, a new product being brought to the Diabetic market, which was approved in May by the U.S. Food and Drug Administration (FDA) is Bigfoot Biomedical’s “Bigfoot Unity Diabetes Management System.” The newest and main component of the system is a “smart” insulin pen cap that recommends insulin doses for diabetics who require insulin injections.

Bigfoot Unity Smart Pen Cap

The Bigfoot Unity smart pen caps provide on-demand, insulin dose decision support to reduce manual estimates. The required insulin dose is displayed directly on a proprietary, connected smart cap for the person’s disposable insulin pens without the need to manually input glucose data on a separate device such as an insulin pump. Approved for patients 12 and up, the system is designed to clearly, and in real-time, help answer the question, “How much insulin should I take right now?”

Particularly valuable for my fellow diabetics who are not on an insulin pump, which can cost in excess of $5,000, the new Bigfoot product would have the patient measure their blood sugar on their CGM, and then have the proposed dosage on the pen cap which can be administered by the patient. Much simpler, and far fewer steps.

The Bigfoot product also offers a related App to view data on your smartphone, as well as a protected cloud to store readings and insulin dosages for review by a patient’s endocrinologist.

Not an artificial pancreas yet, but it’s another step forward in the treatment of diabetes.

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FDA Approves Marketing of AI/ML Device To Find Colon Cancer https://blogs.perficient.com/2021/05/03/fda-approves-marketing-of-ai-ml-device-to-find-colon-cancer/ https://blogs.perficient.com/2021/05/03/fda-approves-marketing-of-ai-ml-device-to-find-colon-cancer/#respond Mon, 03 May 2021 15:34:10 +0000 https://blogs.perficient.com/?p=291924

The Impact of Colon Cancer

According to the National Institutes of Health (NIH), colon cancer is the third-leading type of cancer death in the United States. Cancer in the colon usually starts from polyps or other precancerous growths in the rectum or the colon (large intestine). As part of a colorectal cancer screening and surveillance plan, colonoscopies are performed to detect changes or abnormalities in the lining of the colon and rectum. A colonoscopy involves threading an endoscope (thin, flexible tube with a camera at the end) through the rectum and throughout the entire length of the colon, allowing a doctor to see signs of cancer or precancerous lesions.

ML Hardware and AI Software To Aid Doctors

The U.S. Food and Drug Administration (FDA) granted marketing authorization of the GI Genius to Cosmo Artificial Intelligence, Ltd. GI Genius is the first device that uses artificial intelligence (AI) based on machine learning (ML) to assist in the detection of lesions, such as polyps or suspected tumors, in the colon in real time during a colonoscopy.

As explained by Dr. Courtney Lias, Director of the FDA’s Center for Devices and Radiological Health, “Artificial intelligence has the potential to transform health care to better assist health care providers and improve patient care. When AI is combined with traditional screenings or surveillance methods, it could help find problems early on, when they may be easier to treat. Studies show that during colorectal cancer screenings, missed lesions can be a problem even for well-trained clinicians. With the FDA’s authorization of this device, clinicians now have a tool that could help improve their ability to detect gastrointestinal lesions they may have missed otherwise.”

What Is GI Genius?

The GI Genius is comprised of integrated hardware and software that is designed to highlight portions of the colon where the device detects a potential lesion. The software uses artificial intelligence algorithm techniques to identify “regions of interest.” During a colonoscopy, the GI Genius system generates markers, which look like green squares and are accompanied by a short, low-volume sound, and superimposes them on the video from the endoscope camera when it identifies a potential lesion. These signs signal to the doctor that further assessment may be needed. Options include:

  • a closer visual inspection
  • tissue sampling
  • testing or removal
  • or burning the lesion with a laser

The GI Genius does not (at least yet anyway) characterize or classify a lesion. The system does not provide any diagnostic assessments of colorectal polyp pathology, nor does it suggest to the doctor how to manage suspicious polyps. GI Genius only identifies regions of the colon within the endoscope’s field of view where a colorectal polyp might be located, allowing for a more extended examination in real time during colonoscopy. It is up to the doctor to decide whether the identified region actually contains a suspected lesion, and how the lesion should be managed and processed per standard clinical practice and guidelines.

Safety and Detection Impact of GI Genius

The FDA assessed the safety and effectiveness of the GI Genius through a multi-center, prospective, randomized, controlled study in Italy with 700 subjects. Subjects were 40-80 years old who were undergoing a colonoscopy for colorectal cancer screening. The primary analyses from the study were based on a sub-population of 263 patients who were being screened or surveilled every three years or more. Study subjects underwent either white light standard colonoscopy with the GI Genius (136 patients) or standard white light colonoscopy without the GI Genius (127 patients).

The primary endpoint of the study compared how often colonoscopy plus GI Genius identified a patient with at least one lab-confirmed tumor, either cancerous or precancerous, to the frequency the standard colonoscopy made the same identifications. In the study, colonoscopy plus GI Genius was able to identify lab-confirmed tumors in 55.1% of patients compared to identifying them in 42.0% of patients with standard colonoscopy.

The FDA reviewed the GI Genius through the De Novo premarket review pathway, a regulatory pathway for some low- to moderate-risk devices that are novel and for which there is no legally marketed predicate device to which the device can claim substantial equivalence.

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Overview of FDA’s AI/ML-Based Software as a Medical Device Action Plan https://blogs.perficient.com/2021/03/26/overview-of-fdas-ai-ml-based-software-as-a-medical-device-action-plan/ https://blogs.perficient.com/2021/03/26/overview-of-fdas-ai-ml-based-software-as-a-medical-device-action-plan/#respond Fri, 26 Mar 2021 12:25:52 +0000 https://blogs.perficient.com/?p=290260

In a landmark effort to both guide and spur artificial intelligence (AI) and machine learning (ML) development in the medical field, the US Food and Drug Administration (FDA) has released an Artificial Intelligence/Machine Learning (AI/ML)-Based Software as a Medical Device (SaMD) Action Plan.

Background

The plan was created by the FDA’s Digital Health Center of Excellence (DHCE) in the Center for Devices and Radiological Health (CDRH). Organized in September 2020, DHCE is committed to strategically advancing digital health technologies within the framework of the FDA’s regulatory and oversight role. The goal of the Center is to empower stakeholders to advance healthcare by fostering high-quality yet responsible digital health innovation.

The AI/ML Action Plan is a response to stakeholder feedback received from an April 2019 discussion paper, Proposed Regulatory Framework for Modifications to Artificial Intelligence/Machine Learning-Based Software as a Medical Device. Readers may access that 2019 proposal here: US FDA Artificial Intelligence and Machine Learning Discussion Paper

5 Action Items From the SaMD Plan

The SaMD Action Plan propagates a multi-pronged approach with five actions that the FDA intends to take, including:

  1. Tailoring the FDA’s regulatory framework for AI/ML-based SaMD, including the issuance of draft guidance on a predetermined change control plan (for software’s learning over time).
  2. Encourage harmonization of Good Machine Learning Practice (GMLP) development to evaluate and improve machine learning algorithms.
  3. Fostering a patient-centered approach, including device transparency to users and holding a public workshop on how device labeling supports transparency to users and enhances trust in AI/ML-based devices.
  4. Developing methods to evaluate and improve machine learning algorithms.
    • This includes algorithm bias and promotion of algorithm robustness.
  5. Advancing real-world performance monitoring pilots.

If you are interested in reading the entire plan, please visit: https://www.fda.gov/medical-devices/software-medical-device-samd/artificial-intelligence-and-machine-learning-software-medical-device

Conclusion

Federal government bureaucracy needs to adjust to the quickly changing world of technology. A two-year lapse between a discussion paper and an actionable plan may seem like decades to developers from Silicon Valley to Silicon Alley, but the plan to adjust their regulatory framework with published draft guidance is a positive start in the right direction.

As a Type 1 diabetic who has been looking forward to a real-world artificial pancreas for more than a decade, I look forward to software and medical device companies advancing the care and treatment of diabetes (as I’m sure readers battling other chronic condition diseases) faster because of this plan.

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Top 5 Pharma & Medical Device Blog Posts From January 2018 https://blogs.perficient.com/2018/02/01/top-5-pharma-medical-device-blog-posts-february-2018/ https://blogs.perficient.com/2018/02/01/top-5-pharma-medical-device-blog-posts-february-2018/#respond Thu, 01 Feb 2018 12:59:13 +0000 https://blogs.perficient.com/lifesciences/?p=6758

Now that February is here, I thought it would be neat to look back at what our readers found most interesting last month. Below are the top five blog posts Perficient’s life sciences practice wrote in January – they’re ranked in order of popularity, with number one being the most viewed piece.

  1. [Guide] 2018 Pharmaceutical And Medical Device Industry Trends
  2. How Many Novel Drugs Were Approved In 2017?
  3. Patient Support Programs Are Making A Big Difference In Pharma
  4. How Pharma Is Tackling Drug Abuse
  5. How To Fix A Report Timeout Issue In Siebel 8.1.1.9 And Earlier

As always, thank you for your continued support – our team finds it very rewarding to have you as a reader.

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How Pharma Is Tackling Drug Abuse https://blogs.perficient.com/2018/01/17/how-pharma-is-tackling-drug-abuse/ https://blogs.perficient.com/2018/01/17/how-pharma-is-tackling-drug-abuse/#respond Wed, 17 Jan 2018 12:30:59 +0000 https://blogs.perficient.com/lifesciences/?p=6529

Our country is in the midst of an opioid epidemic. We are seeing staggering statistics of drug abuse, not to mention graphic images and videos of the effects drugs are having on families and their loved ones. While the FDA has taken a serious stance in the fight against drug abuse and has even come up with the FDA Opioids Action Plan, companies that work in the life sciences and healthcare industries also realize the seriousness of the problem.

From awareness campaigns to medication take-back days to ongoing safe medication disposal programs, we’re seeing a tremendous amount of activity and success with these initiatives. At the same time, the FDA is encouraging pharmaceutical companies to develop new, non-addictive drugs for patients in pain. That could be the ultimate lifesaver.

To learn about other trends that we can also expect to see in 2018, click here.

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How Many Novel Drugs Were Approved In 2017? https://blogs.perficient.com/2018/01/05/how-many-novel-drugs-were-approved-in-2017/ https://blogs.perficient.com/2018/01/05/how-many-novel-drugs-were-approved-in-2017/#respond Fri, 05 Jan 2018 12:30:20 +0000 https://blogs.perficient.com/lifesciences/?p=6678

When it comes to drug approvals, 2017 was a great year for the pharmaceutical industry. According to Reuters, the number of drugs approved in the United States was the highest number in 21 years.

In fact, the 46 novel drugs that were approved was more than double what was approved in 2016. This figure doesn’t include cell and gene therapies, such as Kymriah from Novartis and Yescarta developed by Kite Pharma.

With the 21st Century Cures Act and the FDA’s expedited programs, such as the “breakthrough therapy” designation, quicker reviews for gene and cell therapies will help push these special drugs to the market faster.

The number of drugs approved in the European Union last year spiked to 92. The previous year brought 81 new medicines to the market. Other governments, such as China, have also indicated plans to lessen the regulatory burden in order to bring drugs to patients faster. Interestingly enough, China has become the second largest pharmaceutical market, behind the United States.

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6 Investigators Received FDA Warning Letters In 2017 https://blogs.perficient.com/2017/12/21/6-investigators-received-fda-warning-letters-in-2017/ https://blogs.perficient.com/2017/12/21/6-investigators-received-fda-warning-letters-in-2017/#respond Thu, 21 Dec 2017 13:58:52 +0000 https://blogs.perficient.com/lifesciences/?p=6656

It’s been awhile since I’ve written about FDA warning letters, so I thought I would take a look at the letters issued throughout the year and see if anything egregious (or at least interesting) came up.

I was surprised to learn that the FDA issued letters to six separate clinical investigators, and I thought the reasons why might interest you. Here are the areas in which they fell short, along with some noteworthy highlights.

5/6 violated 21 CFR 312.60, General Responsibilities of Investigators, for failing to follow the protocol. The biggest issue was ignoring inclusion/exclusion criteria; all five letters cited enrolling patients who should have been excluded. The second biggest issue was skipping procedures that were required for patient safety, the worst of which was not performing chest x-rays on subjects enrolled in a lung-related trial when they reported worsening symptoms. There was also a citation for skipping an early termination visit and not indicating whether any adverse events were involved.

2/6 violated 21 CFR 312.62(a), Disposition of Drug, for not maintaining adequate records of study drug. One investigator couldn’t account for 25 units of unused study drug; he claimed the units were destroyed, but had no evidence or documentation of the destruction. The other investigator had a number of discrepancies in her records about how much drug was dispensed, taken, and returned to the site.

2/6 violated 21 CFR 312.62(c), Record Retention, for not keeping records for the required two years following either drug approval or overall study termination. One investigator shredded or otherwise destroyed (he thinks) all records related to a study two years after the sponsor terminated his site, clearly not understanding when the two year retention period actually begins. The other investigator “misplaced” 15 ECG tracings for 7 subjects and the completed C-SSRS for 1 subject.

1/6 violated 21 CFR 312.62(b), Case Histories, for not maintaining adequate and accurate records of observations and data. This particular investigator had files for several subjects that contained a critical form that had not been completed, along with a recorded diagnosis that cited the content of the (blank) form as the basis for the diagnosis.

So, what can we learn from all of this? The most obvious takeaway is to not work with these specific investigators! But, beyond that, here’s what I see:

  • The process of determining eligibility needs an overhaul. It seems like it would be safest for patients if the human element were removed altogether, and the automated process were calibrated to err on the side of caution/exclusion. After a patient is excluded, the investigator could review the exclusion reasons and decide whether to lobby to have the patient included.
  • Subject recruitment needs to be easier/faster. Perhaps if more tools were in place to support subject recruitment, investigators would feel less pressure to enroll patients who don’t meet eligibility criteria. These tools could involve the use of mobile apps, social media, and even artificial intelligence combing giant databases of patient data to find exactly the right fit.

We discuss these and other common issues in our guide, 7 Ways to Fix Your Relationship with Clinical Sites. If any of the content in this post is hitting home for you, it might just be worth a look.

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A Compliant Do-Over For Regulated IT Systems https://blogs.perficient.com/2017/12/19/a-compliant-do-over-for-regulated-it-systems/ https://blogs.perficient.com/2017/12/19/a-compliant-do-over-for-regulated-it-systems/#respond Tue, 19 Dec 2017 13:15:53 +0000 https://blogs.perficient.com/lifesciences/?p=6643

You know how you implemented that regulated IT system a few years ago, and it was all shiny and new, and then it went through a bunch of change controls and the validation documentation got kind of unwieldy, and now you’re kinda wishing you could start over with a clean slate, but without losing the functionality you’ve come to depend on?

One of our clients was recently in that boat with their Oracle Siebel Clinical system. Back in 2013, they implemented Oracle Siebel 8.1.1.4. At that time, they assessed the clinical trial management system (CTMS) as non-GxP, so the initial implementation followed a non-GxP process, as did the subsequent change controls.

But, in 2015, they decided to integrate their CTMS with a GxP system. The nature of the integration changed the intended use of their CTMS, so they converted it to a GxP system and got all of their documentation up to snuff. Then, the subsequent change controls followed a GxP process.

Earlier this year, they realized that Siebel 8.1.1.4 had become quite outdated and they wanted to upgrade to IP2017 to gain all of the new features and benefits it provides. They also wanted to move the system to a more secure IT network container on brand new, powerful, sparkly servers. But, what they didn’t want was to bring along all of the old baggage (i.e., messy, complex testing and validation documentation).

So, we helped them design a compliant approach to a fresh start.

Essentially, they are going to treat the implementation as a new system, since the hardware is new and the installation of Siebel IP2017 will be from scratch. Once the base system is installed in the new development environment, they will bring the old configuration over to the new system using the incremental repository merge (IRM) process that comes out of the box with Siebel these days. Any configuration conflicts identified by the IRM process will be thoughtfully resolved and tested by a developer.

In terms of validation documents, they will leverage some of the existing documents, but drop those extra few pounds. The old requirements specification will be converted to a new one, removing all of the revision history and starting with version 1.0, as will the old traceability matrix. And the old test scripts from the myriad prior change controls will be combined into a new, comprehensive test suite.

With that, the validation process itself will be like any other new IT system implementation: a validation plan, qualification protocols, installation logs, test execution records, summary reports, etc. At the end, the old system will be taken offline and the new system will be open for business. All of their requirements will still be met, but they will be free from their documentation baggage (i.e., it will be archived and retrievable, per the regulations).

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Top 5 Pharma & Medical Device Blog Posts From October 2017 https://blogs.perficient.com/2017/11/01/top-5-pharma-medical-device-blog-posts-from-october-2017/ https://blogs.perficient.com/2017/11/01/top-5-pharma-medical-device-blog-posts-from-october-2017/#respond Wed, 01 Nov 2017 11:30:04 +0000 https://blogs.perficient.com/lifesciences/?p=6455

Now that November is here, I thought it would be neat to look back at what our readers found most interesting last month. Below are the top five blog posts Perficient’s life sciences practice wrote in October – they’re ranked in order of popularity, with number one being the most viewed piece.

  1. Aggregate Report Preparation In Safety And Pharmacovigilance
  2. Oracle Clinical 5.2 Released: 7 Changes To Know
  3. FDA Ciphers Update: What To Consider If You Have Argus Safety
  4. 6 Applications And 1 Real-Life Example Of IoT In Life Sciences
  5. Incoming Novartis CEO Looks To Disney For Inspiration

As always, thank you for your continued support – our team finds it very rewarding to have you as a reader.

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MedDRA Upgrades: 4 Clarifications https://blogs.perficient.com/2017/10/19/meddra-upgrades-4-clarifications/ https://blogs.perficient.com/2017/10/19/meddra-upgrades-4-clarifications/#respond Thu, 19 Oct 2017 11:21:42 +0000 http://blogs.perficient.com/lifesciences/?p=6430

We are quickly coming up to the go-live of the MedDRA 20.1 dictionary. The new version; maintained by the MSSO was released in September 2017; per regulatory guidance will go live on the first Monday, two months after its release. This version, 20.1 will be live 06Nov2017.

Our clients often have questions about upgrading their MedDRA dictionary, as they relate to their Oracle Argus Safety systems.

A couple of things that are urban legends…and those that are not:

  1. Your users don’t have to be out of Argus to run the “View Only” upgrade – it can be done quickly and efficiently in the background – but Oracle does have some recommendations
  2. You do need to take a look at the “view mode” to ensure all cases were re-coded and not inadvertently left out because a case processor left a case open
  3. The current EMA and FDA guidelines regarding how often you should upgrade your MedDRA dictionary is twice per year; WHO Drug is annual.
  4. There are non-English translations of MedDRA available; check the MSSO site for more information.

When upgrading MedDRA, internal organizations should allow time to review the changes and its impact on internal medical coding and signal detection.

Specifics on timing for going live should coincide with the first Monday, two months after the dictionary has been released. The following are helpful links:

As a reminder, the English version of MedDRA is realized twice a year – March 1 and September 1.

Have questions about MedDRA or need assistance with upgrading? Feel free to reach out to me.

*Indy Ahluwalia, Tammy Howard, and Waseem Syeed also contributed to this blog post.

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FDA Ciphers Update: What To Consider If You Have Argus Safety https://blogs.perficient.com/2017/10/11/fda-ciphers-update-what-to-consider-if-you-have-argus-safety/ https://blogs.perficient.com/2017/10/11/fda-ciphers-update-what-to-consider-if-you-have-argus-safety/#respond Wed, 11 Oct 2017 13:28:52 +0000 http://blogs.perficient.com/lifesciences/?p=6406

The FDA has decided that it will update the ciphers for their Electronic Submissions Gateway (ESG), but what does this mean for you?

Here is the message that was received:

FDA Electronic Submissions Gateway (ESG) will update ciphers and SSL protocols in Production on Saturday, January 20, 2018 at 9:00 PM EST. Please make sure your AS2 system can connect to ESG with compatible secure ciphers and SSL protocols listed below. To make sure your AS2 system can connect to ESG, you may test in the ESG Pre-Production environment. The ESG Pre-Production environment already has the following updated SSL protocols and Cipher suites:

*  SSL Protocols

*  TLS 1.2

*  Cipher Suites (suites in server-preferred order)

*  TLS 1.2

*  TLS_RSA_WITH_AES_128_CBC_SHA (0x2f)

*  TLS_RSA_WITH_AES_256_CBC_SHA (0x35)

*  TLS_RSA_WITH_AES_128_CBC_SHA256 (0x3c)

*  TLS_RSA_WITH_AES_256_CBC_SHA256 (0x3d)

***Warning: if your AS2 system CANNOT connect to ESG with compatible secure ciphers and SSL protocols, you will not be able to send submissions to the FDA.***

A couple of things come to mind, as far as what steps you should take, based on the information the FDA has provided.

The first thing to do is to check which version of Axway you are using to see if the above cipher changes impact you.

Some companies do not have a version of Axway that will be able to deal with the new security settings, so one option is to upgrade to the newest version of Axway (5.12).

Some considerations need to be taken with this approach, depending on the partnerships you may have in place. For example, you may wish to test with other agencies/partners when an upgrade is being evaluated.

Also, there is the potential for downtime when upgrading. So, do you keep your current Axway running while installing the new version?

Something else to consider. If you have a version of Oracle Argus in 7.x, you will need to install the patch 8.9.9.97. This patch contains an updated JAR file, which will allow you to upgrade from 5.10.1 to 5.12 SP8 in product v7.x line. Upgrading Axway to 5.12 SP8 will be possible, but it requires Argus patch 8.9.9.97. This patch is not applicable if you are in the Argus 8.x range.

If you are interested in learning more about how we can help you upgrade Argus and Axway, feel free to reach out.

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Top 5 Pharma & Medical Device Blog Posts From August 2017 https://blogs.perficient.com/2017/09/01/top-5-pharma-medical-device-blog-posts-from-august-2017/ https://blogs.perficient.com/2017/09/01/top-5-pharma-medical-device-blog-posts-from-august-2017/#respond Fri, 01 Sep 2017 11:30:25 +0000 http://blogs.perficient.com/lifesciences/?p=6234

Now that September is here, I thought it would be neat to look back at what our readers found most interesting last month. Below are the top five blog posts Perficient’s life sciences practice wrote in August – they’re ranked in order of popularity, with number one being the most viewed piece.

  1. What The FDA Requires Of Drugs On The Market
  2. What Is Internet Of Things (IoT) For Clinical Data Collection?
  3. Post-Market Surveillance Of Drug Safety
  4. Oracle Data Management Workbench Overview And Use Cases
  5. How Great CX Drastically Increases Revenue, Even In Life Sciences

As always, thank you for your continued support – our team finds it very rewarding to have you as a reader.

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