23Regulatory Reporting

About Regulatory Reporting

This chapter describes how to use the Siebel Business Application to create and manage regulatory reports for product complaints and adverse events. The reports are generated with unique and sequential numbers and formatted ready for submission to the FDA or other regulatory agencies.

    About Regulatory Reports

    From the time an adverse event or complaint is confirmed as reportable, companies generally have less than 30 days to report to a regulatory agency. An adverse event or complaint can be verified as reportable at various stages of the AECM process, from the initial customer call through to the review of the findings by the analysis team. Companies usually follow certain assessments that determine if an adverse event or complaint is reportable or not.

    Separate reports have to be filed for each product that malfunctioned or caused the adverse event. Reports filed are based on the product issue, which typically contains much of the needed information. After the initial report, companies generally file additional supplemental, summary, and annual reports to update information on the investigation and resolution process.

    The preconfigured Siebel AECM module supports MedWatch and MDV reports:

    • MedWatch Reports.

      Using Siebel AECM, you can automatically generate MedWatch 3500A reports. Sections A to H of the report are populated from the relevant fields in the regulatory report record. The completed report can be saved and submitted electronically to the FDA using the electronic Medical Device Reporting (eMDR) process.

      For more information about eMDR refer to About Electronic Medical Device Reporting.

    • MDV Reports.

      Medical device companies operating in multiple countries report adverse events or complaints to the various NCAs using the MDV form. Unlike MedWatch reports, there is no standard template for the MDV form. However, the Global Harmonization Task Force (GHTF) has guidelines.

      The report created by Siebel AECM follows these guidelines. For more information, see http://www.ghtf.org.

      About Report Types

      The following table details the four regulatory reports that can be created in Siebel AECM.

      Table Report Types in Siebel AECM

      Report Type Use Data for the Report Is Taken from These Views in the Regulatory Reports Screen

      3500A

      For initial mandatory reports to MedWatch (FDA).

      • More Info

      • Patient

      • Importer (if the Facility Type field in the Importer view is not blank)

      • Manufacturer and Investigation (if the Facility Type field in the Importer view is blank)

      3500A Supplemental

      For additional information to MedWatch after initial reports have been submitted.

      • More Info

      • Patient

      • Importer (if the Facility Type field in the Importer view is not blank)

      • Manufacturer and Investigation (if the Facility Type field in the Importer view is blank)

      MDV Initial

      For initial reports to NCAs who accept MDV forms.

      • More Info

      • Patient

      • MDV

      MDV Follow-up

      For additional information to NCAs after initial reports have been submitted.

      • More Info

      • Patient

      • MDV

        About Electronic Medical Device Reporting

        For customers using the AECM process within the United States, you can submit an eMDR using the Siebel Business Application. Doing so transmits an XML message in HL7 ICSR format to the FDA. Moreover, you can also manage batch submission, and view their confirmation status by referring to the FDA Status field once they have been submitted.

        The FDA has created a single system to accept individual, batch, and summary medical device adverse event reports by way of the FDA electronic gateway server. For additional information about the FDA electronic gateway server and FDA standards for eMDR from the FDA, refer to http://www.fda.gov/ForIndustry/FDAeSubmitter/ucm107914.htm.

        For information about eMDR transmission using the Siebel Business Application, refer to Transmitting Electronic Medical Device Reporting Immediately, and Managing Batch Electronic Medical Device Reporting.

          About FDA Confirmations for Electronic Medical Device Reporting

          Once an eMDR or a batch eMDR has been transmitted to the FDA, the FDA Electronic Submissions Gateway (ESG) will respond to the submission. Depending on the processing state, the FDA Status field may be in any of the following three states:

          • 1 of 3 - ESG. Indicates that FDA ESG has sent a Message Delivery Notification (MDN) to confirm that the submission was received. The message includes an official date received.

          • 2 of 3 - ESG. Indicates that FDA ESG has sent an MDN to confirm that the submission has reached the Center for Devices and Radiological Health (CDRH).

          • 3 of 3 - ESG. Indicates that CDRH has sent a message to confirm that the submission has been successfully loaded into the Adverse Event database, or that it has been rejected.

          For information about eMDR transmission using Siebel Business Application, refer to Transmitting Electronic Medical Device Reporting Immediately, and Managing Batch Electronic Medical Device Reporting.

            Scenario for Regulatory Reporting

            This scenario is an example process performed by the Siebel administrator and the quality manager. Your company might follow a different process according to its business requirements.

            This scenario is designed to illustrate the functionality of Siebel AECM.

              Introduction

              A complaint about a cartridge for a blood analyzer machine has been made to the manufacturer. The complaint has been assessed; it needs to be reported to the FDA. A product issue record has already been set up and contains a lot of information about the complaint.

                The Siebel Administrator

                The administrator is responsible for setting up the report number schema for the organization. The company started using Siebel AECM in the middle of the year. Because the company had already submitted eight MedWatch 3500A reports to the FDA, the administrator sets the report number sequence to start at 9.

                  Quality Manager

                  It is the quality manager’s responsibility to prepare the initial MedWatch 3500A form and send it to the FDA. First, she creates a new regulatory report record and populates the record with data from the product issue. Then she reviews the data.

                  Because her company manufactures the cartridge, she enters data into the Manufacturer and Investigation views. This data will appear in sections G and H of the MedWatch 3500A form.

                  Satisfied that the necessary data has been entered, she generates the MedWatch 3500A report. This report is a facsimile of the MedWatch 3500A form. But, it is also a standard Siebel report, so the quality manager prints it as she would any other Siebel report.

                  After reviewing the printed version of the report, she submits it. When she submits the report record, two things happen:

                  • A report number is generated.

                  • Most fields in the report record become read-only.

                  It is the submitted version of the MedWatch 3500A form that the quality manager sends to the FDA.

                  The quality manager complied with regulations by sending her initial report within 30 days of the company becoming aware of the issue. However, the product analysis had not been completed at that time. Later, the product analysis team discovers the root cause of the cartridge failure, and the quality manager submits a supplemental report to the FDA.

                    Process of Regulatory Reporting

                    This example process represents the tasks that are carried out in the Scenario for Regulatory Reporting.

                      Administrator Procedures

                        Additional End-User Procedure

                        This end-user procedure is not part of the scenario described:

                          Setting Up Report Numbers

                          The administrator determines the numbering scheme for regulatory reports. The number is generated automatically when the regulatory report record is submitted. The report number is made up of concatenated fields. The report number field is incremented by 1 each time a report is generated for a new product issue.

                          Reports numbers of this type... Are the concatenation of these fields... Example

                          MedWatch 3500A

                          • Manufacturer Id

                          • Report Year
                          • Report Number

                          XERCO-2003-0004

                          MDV Initial

                          • MDV Id

                          • MDV Report Number

                          MEDDEV-000008

                          This task is a step in Process of Regulatory Reporting.

                          To set up report numbering scheme

                          1. Navigate to Administration - Group screen, then the Organizations view.

                          2. In the Organizations list, select your organization.

                          3. To set up numbering for MedWatch 3500A reports, complete the following fields.

                            Field Comments

                            Manufacturer Id

                            None.

                            Report Year

                            None.

                            Report Number

                            Set to zero to have the first report numbered 0001.

                          4. To set up numbering for MDV Initial reports, complete the following fields.

                            Field Comments

                            MDV Id

                            MDV Report Number

                            Set to zero to have the first report numbered 000001.

                            Creating and Populating New Regulatory Reports

                            The best way to create a regulatory report record is from the product issue record. When a report is created from the regulatory report, fields (for example, products) can be populated from the product issue record to the regulatory report record.

                            There are two kinds of initial regulatory report that you can create:

                            • MedWatch 3500A

                            • MDV Initial

                            Note: If you want to create supplemental or follow-up reports, see Creating Supplemental or Follow-Up Regulatory Reports.
                            Caution: Regulatory report records cannot be deleted.

                            This task is a step in Process of Regulatory Reporting.

                            To create a regulatory report record

                            1. Navigate to Product Issues screen, then the Product Issue List view.

                            2. In the Product Issue List, drill down on a product issue.

                            3. Click the Regulatory Reports tab.

                            4. In the Regulatory Reports list, create a new record and complete the necessary fields.

                              When a regulatory report is created:

                              • The following fields are copied from the product issue: PI# and SR #

                              • The following fields are set with a default value: Status is set to In Progress, Owner is set to Creator of the record

                            5. For the new record, set the Report Type field to MedWatch 3500A or MDV Initial.

                            6. Click Populate Report.

                              This starts the LS Medical Product Issue Populate Report workflow, which copies data from the product issue according to the report type. For more information about the workflow, see LS Medical Product Issue Populate Report Workflow.

                              Entering and Reviewing Data for 3500A Reports

                              When you populate a regulatory report, many fields are copied from the product issue record. When you edit these fields in the regulatory report record, the edits are not copied back to the product issue record.

                              Note: The process described here is to enter data in the Manufacturer, Investigation, and Importer views of the Regulatory Reports screen. However, an alternate way is to enter the data in these views in the Product Issues screen before the regulatory report is populated. If you use the Product Issues screen, you have copies of the data in both the product issue record and in the regulatory report record.

                              This task is a step in Process of Regulatory Reporting.

                              To review and enter data for the 3500A report

                              1. Navigate to Regulatory Reports screen, then the Regulatory Report List view.

                              2. In the Regulatory Report List, drill down on a 3500A regulatory report record.

                              3. Review and if necessary modify the information in the More Info and Patient views.

                              4. If you are a manufacturer:

                                1. Make sure that the Facility Type field in the Importer view is blank. By default, this field is set to blank.

                                2. Complete the fields in the Manufacturer view.

                                  These fields populate section G of the 3500A form. Some fields are described in the following table. Note that the letter and number combination in the last column indicates how this field maps to the 3500A form.

                                  Field Comments Mapping to 3500A Form

                                  (A)NDA #

                                  The abbreviated new drug application or the new drug application number.

                                  This field is automatically populated if there is an (A)NDA number associated with the protocol site.

                                  G5

                                  10-day

                                  Select the check box to indicate the report is a 10-day report.

                                  G7

                                  15-day

                                  For reports of serious and unexpected adverse events.

                                  G7

                                  5-day

                                  For events requiring remedial action to prevent unreasonable risk to public health, or where written notice is required.

                                  G7

                                  Address

                                  Manufacturer contact office address - Street.

                                  G1

                                  AE Terms

                                  List of adverse event terms that most accurately characterize the adverse event described in Event Detail section.

                                  G8

                                  City

                                  Manufacturer contact office address - City.

                                  G1

                                  Consumer

                                  Report Source is the consumer or treating health care provider.

                                  G3

                                  Contact Name

                                  Manufacturer contact’s last name.

                                  G1

                                  Contact Office

                                  Manufacturer’s contact office.

                                  G1

                                  Country

                                  Manufacturer contact office address - Country.

                                  G1

                                  Distributor

                                  Check this if report was received from the distributor (importer) of the suspect product.

                                  G3

                                  First Name

                                  Manufacturer contact’s first name.

                                  G1

                                  Follow-up

                                  Check if the report is a follow-up to a previously submitted report.

                                  G7

                                  Follow-Up #

                                  Follow-up sequence number.

                                  G7

                                  Foreign

                                  Report Source is a foreign source (for example, foreign medical facility, affiliate, or government).

                                  G3

                                  IND #

                                  The investigational new drug (IND) application number.

                                  This field is automatically populated if there is an IND number associated with the protocol site.

                                  G5

                                  Initial

                                  Check if the report is the first submission of a manufacturer report (30 day report for device).

                                  G7

                                  Literature

                                  Report Source is the scientific literature or an unpublished manuscript.

                                  G3

                                  Mfg Report #

                                  Regulatory report number.

                                  G9

                                  OTC Product

                                  Check if the suspect medication can be purchased over-the-counter (without a prescription).

                                  G5

                                  Other

                                  Report Source is any source not covered by the previous categories.

                                  G3

                                  Periodic

                                  For reports of serious labeled and non-serious (labeled and unlabeled) adverse events.

                                  G7

                                  Phone #

                                  Manufacturer contact’s work phone number.

                                  G2

                                  PI Received

                                  The date when a company representative became aware of the event.

                                  G4

                                  Postal Code

                                  Manufacturer contact office address - Postal Code.

                                  G1

                                  Pre-1938

                                  Check the box if the suspect medication was marketed prior to 1938 and does not have an NDA #.

                                  G5

                                  Products

                                  Product(s) involved in the event.

                                  Professional

                                  Report Source is a physician, pharmacist, nurse, and so on.

                                  G3

                                  Protocol #

                                  Protocol number identifies the clinical trial at a site. If regulatory report is an IND safety report, enter the protocol number.

                                  G6

                                  Received Report #

                                  Report number for the MedWatch form received from a Importer or a User Facility.

                                  MedWatch Header

                                  Representative

                                  Check this if a company representative reported the event based on information from a health professional.

                                  G3

                                  State

                                  Manufacturer contact office address - State.

                                  G1

                                  Study

                                  Report Source is a postmarketing, clinical trial, surveillance, or other study.

                                  G3

                                  User Facility

                                  Check this if the manufacturer received the report from the MDR contact in a user facility as identified in section F.

                                  G3

                              5. If you are a device manufacturer, complete the fields in the Investigation view.

                                These fields populate section H of the 3500A form. Some fields are described in the following table. Note that the letter and number combination in the last column indicates how this field maps to the 3500A form.

                                Field Comments Mapping to 3500A Form

                                Evaluation

                                If an evaluation was conducted, note summary here and choose Evaluation Summary Attached in Evaluated by Mfg Field.

                                H3

                                Death

                                Check only if the death was an outcome of the adverse event.

                                H1

                                Correction

                                Do not check when creating an initial report.

                                Follow-up with changes to previously submitted information.

                                H2

                                Serious Injury

                                Event is life-threatening, results in permanent impairment, requires intervention to prevent permanent impairment.

                                H1

                                Additional Information

                                Do not check when creating an initial report.

                                Information concerning the event that was not provided in the initial report.

                                H2

                                Malfunction

                                Device malfunctions.

                                H1

                                Response to FDA Request

                                Do not check when creating an initial report.

                                Additional information requested by FDA concerning the device/event.

                                H2

                                Other

                                Event not covered by death, serious injury, or malfunction. This type of category should be rarely used.

                                H1

                                Device Evaluation

                                Do not check when creating an initial report.

                                Evaluation/analysis of device.

                                H2

                                Mfg Narrative

                                Any additional information, evaluation, or clarification of data presented in previous sections.

                                H10

                                Recall

                                Remedial Action - Recall.

                                H7

                                Method Codes

                                Method codes capture two items — the source of the device that was evaluated and the type of evaluation performed.

                                Do not enter more than four codes.

                                H6

                                Repair

                                Remedial Action - Repair.

                                H7

                                Result Codes

                                Describes the results of evaluation and analyses of the reported device problem(s).

                                Do not enter more than four codes.

                                H6

                                Replace

                                Remedial Action - Replace.

                                H7

                                Conclusion Codes

                                Describes the evaluation conclusions.

                                Do not enter more than four codes.

                                H6

                                Relabeling

                                Remedial Action - Relabeling.

                                H7

                                Evaluated by Mfg

                                If you do not check this box, then you should complete the Non-Evaluation Codes field.

                                Identify if the device was evaluated.

                                H3

                                Notification

                                Remedial Action - Notification.

                                H7

                                Non-Evaluation Codes

                                If an evaluation of a returned medical device was NOT conducted, provide the appropriate code.

                                H3

                                Corrected Data

                                Additional, corrected, or missing information, identifying each data item by the applicable section and block number.

                                H11

                                Inspection

                                Remedial Action - Inspection.

                                H7

                                Usage of Device

                                Indicates whether the use of the suspect medical device was the initial use, reuse, or unknown.

                                H8

                                Patient Monitoring

                                Remedial Action - Patient monitoring.

                                H7

                                Mfg Date

                                Month and year of manufacture of the suspect medical device.

                                This field can be based on asset number (asset manufacture date) or lot number (effective start date).

                                H4

                                Modification

                                Remedial Action - Modification.

                                H7

                                Labeled Single Use

                                Indicates whether the device was labeled for single use.

                                H5

                                Other

                                Remedial Action - Other - Specify the type of action in this field.

                                H7

                                Correction #

                                If action reported to FDA under 21 USC 360i(f), list correction or removal reporting number.

                                H9

                              6. If you are a user facility or importer, complete the fields in the Importer view.

                                These fields populate section F of the form. Some fields are described in the following table. Note that the letter and number combination in the last column indicates how this field maps to the 3500A form.

                                Field Comments Mapping to 3500A Form

                                Facility Type

                                Indicate whether the report is from a user facility, importer, or others.

                                F1

                                Importer

                                Name of the distributor or importer.

                                F3

                                Contact Name

                                Last name of the distributor’s or importer’s representative to contact regarding the event.

                                F4

                                Device Age

                                The approximate age of the device.

                                F9

                                Report #

                                Regulatory report # for this report, which is being submitted by an importer.

                                This number is auto-populated when the report is generated.

                                F2

                                Address

                                Distributor’s or Importer’s address - Street Address line #1.

                                This field is auto-populated based on the distributor’s or importer’s name.

                                F3

                                First Name

                                First name of the distributor’s or importer’s representative to contact regarding the event.

                                F4

                                Age UoM

                                Unit of measurement for device age.

                                F9

                                Report Type

                                Indicates if the report to the regulatory agency will be an initial or follow-up report.

                                F7

                                City

                                Distributor’s or importer’s address - City.

                                F3

                                Phone #

                                Contact’s work phone number.

                                F5

                                Patient Codes

                                Patient codes describe what happened to the patient as a result of the event.

                                Do not enter more than three codes.

                                F10

                                Follow-up #

                                Sequence number of the follow-up report.

                                F7

                                Postal Code

                                Distributor’s or importer’s address - Postal Code.

                                F3

                                Reported FDA

                                Indicates if the distributor or importer has already sent a report to the regulatory agency.

                                F11

                                Device Codes

                                Device codes describe device failures or problems encountered during the event.

                                Do not enter more than four codes.

                                F10

                                Reported Mfg

                                Indicates if the distributor or importer has sent a report to the manufacturer.

                                F13

                                State

                                Distributor’s or importer’s address - State.

                                F3

                                FDA Report Date

                                Date the report was sent to the regulator agency.

                                F11

                                Event Location

                                Location of the actual occurrence of the event.

                                F12

                                Mfg Report Date

                                Date the report was sent to the manufacturer.

                                F13

                                Country

                                Distributor’s or importer’s address - Country.

                                F3

                                PI Received

                                The date when a company representative became aware of the event.

                                F6

                                Entering and Reviewing Data for MDV Reports

                                When you populate the regulatory report, many fields are copied from the product issue record. When you edit these fields in the regulatory report record, the edits are not copied back to the product issue record.

                                Note: The process described here is to enter data in the MDV view in the Regulatory Reports screen. However, an alternate way is to enter the data in the MDV view in the Product Issues screen before the regulatory report is populated. If you use this alternative, you have copies of the data in both the product issue record and in the regulatory report record.

                                This task is a step in Process of Regulatory Reporting.

                                To review and enter data for an MDV Initial report

                                1. Navigate to Regulatory Reports screen, then the Regulatory Report List view.

                                2. In the Regulatory Report List, drill down on an MDV regulatory report record.

                                3. Review and if necessary modify the information in the More Info and Patient views.

                                4. Click the MDV tab.

                                5. On the MDV form, complete the necessary fields.

                                  Some fields are described in the following table.

                                  Field Comments

                                  MDV Report #

                                  MDV Report number.

                                  This number is auto-populated when the report is generated.

                                  Authorities

                                  The name of the regulatory agencies to send the report to.

                                  Affiliate Acct

                                  The affiliate account representing the company.

                                  PI Received

                                  The date when the company became aware of the event.

                                  Determination

                                  The type of the reportable event for MDV reporting.

                                  Patient Codes

                                  Patient codes describe what happened to the patient as a result of the event.

                                  Device Codes

                                  Device codes describe device failures or problems encountered during the event.

                                  Usage of Device

                                  Indicates whether the use of the suspect medical device was the initial use, reuse, or unknown.

                                  Follow-up Date

                                  Date field to indicate the approximate follow-up or final report date.

                                  Approval Org

                                  The approval body for the device.

                                  Approval #

                                  The approval number for the device.

                                  Evaluation

                                  If the evaluation was conducted, note summary here and choose Evaluation Summary Attached in Evaluated by Mfg field.

                                  Mfg Narrative

                                  Any additional information, evaluation, or clarification of data presented in previous sections.

                                  Running 3500A and MDV Reports

                                  Siebel AECM uses the Siebel Reports Server to create formatted reports suitable for submitting to the FDA or other regulatory agency.

                                  Typically, the user views the report:

                                  • Before generating it, to make sure that the data is correct

                                  • After generating it, to print a final report for sending to the FDA or other regulatory agencies

                                  Note: The fields used to fill in the report are those in the regulatory report record (not the product issue record).

                                  This task is a step in Process of Regulatory Reporting.

                                  To run a report

                                  1. Navigate to the Regulatory Reports screen, then the Regulatory Report List view.

                                  2. In the Regulatory Report List, drill down on a report.

                                    For this type of report... Navigate to one of these views... Select this report from the Reports button menu

                                    MedWatch 3500A

                                    • More Info

                                    • Patient
                                    • Importer
                                    • Manufacturer
                                    • Investigation

                                    3500A

                                    MVD

                                    • More Info

                                    • Patient
                                    • MDV

                                    MDV

                                  3. Run, print, and save the report as necessary. For information about reports, see Siebel Fundamentals.

                                    Which Sections of the Med Watch 3500A Form Are Filled In?

                                    Not all sections of the MedWatch 3500A are filled in for every report. Which sections are filled in depends upon the Event Type and Facility Type fields. The Event Type field is in the More Info view of the Regulatory Reports screen. The Facility Type field is in the Importer view of the Regulatory Reports screen.

                                    These sections always are filled in:

                                    • A. Patient Information

                                    • B. Adverse Event or Product Problem

                                    • E. Initial Reporter

                                      The following information lists the conditions for which the other sections get filled in.

                                      Table Sections of the Report Filled In According to Event Type and Facility Type Field Values

                                      If... And... These sections are filled in... And these sections can remain blank...

                                      Event Type = Adverse Event Drug, Product Problem Drug, or AE and PP Drug

                                      C

                                      G

                                      D

                                      F

                                      H

                                      Event Type = Adverse Event Device, Product Problem Device, or AE and PP Device

                                      Facility Type = NULL (blank)

                                      D

                                      G

                                      H

                                      C

                                      F

                                      Event Type = Adverse Event Device, Product Problem Device, or AE and PP Device

                                      Facility Type = User Facility, Distributor, or Importer (That is, not blank)

                                      D

                                      F

                                      G

                                      C

                                      H

                                      Generating Regulatory Report Numbers and Submitting Reports

                                      When you generate a 3500A or MDV initial report:

                                      • The report number is generated and filled in

                                      • The Status field changes to Submitted

                                      • The fields in the regulatory report record become read-only (except for the Sub Status field)

                                      Only the primary owner of the regulatory report can generate the report number and submit the report.

                                      This task is a step in Process of Regulatory Reporting.

                                      To generate and submit a regulatory report

                                      1. Make sure the application is running on a server database.

                                        You cannot generate a report number on the Siebel Mobile Web Client.

                                      2. Navigate to Regulatory Reports screen, then the My Regulatory Reports view.

                                      3. In the Regulatory Report List, drill down on a regulatory report with status of In Progress.

                                      4. Click Generate.

                                        This starts the LS Medical Product Issue RR Submit workflow, which authenticates the user, adds a number for the regulatory report, changes the status to Submitted, and makes all fields except Sub Status read-only.

                                        For more information about the workflow, see LS Medical Product Issue RR Submit Workflow.

                                      5. To submit the regulatory report to the FDA, click eMDR Queue.

                                        This changes the Sub Status of the report to eMDR and places the report in the queue to be sent to the FDA at the end of the month. If you want to submit the report immediately, follow the instructions outlined in Transmitting Electronic Medical Device Reporting Immediately.

                                        Transmitting Electronic Medical Device Reporting Immediately

                                        Occasionally, you may be made aware of a unique medical device report that cannot wait until month-end processing, and must be reported to the FDA immediately.

                                        For more information about rules and guidelines for regulatory reporting delays, refer http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm149672.htm.

                                        To force immediate FDA reporting

                                        1. Navigate to Regulatory Reports screen, then the eMDR view.

                                          A list of all regulatory reports whose RR Sub Status is eMDR will be listed.

                                        2. In the eMDR list, select the regulatory report you want to transmit.

                                          Regulatory reports that have not yet been transmitted will have Transmission Status set to Not Transmitted.

                                        3. Click Transmit.

                                          Note: The Transmit button will be grayed out if the regulatory report has already been transmitted or has been overridden.

                                        Once transmitted, monitor the FDA Status field of the eMDR for FDA confirmation. For more information on confirmation statuses, refer to About FDA Confirmations for Electronic Medical Device Reporting.

                                          Managing Batch Electronic Medical Device Reporting

                                          Occasionally, you may want to submit multiple medical device reports as a batch. For example, if you are submitting 100 month-end reports, creating a batch enables you to submit reports in one transmission rather than 100 individual transmissions.

                                          To create a batch e MDR and populate it with regulatory reports

                                          1. Navigate to Regulatory Reports screen, then the eMDR Batch view.

                                            A list of existing eMDR batches will appear.

                                          2. In the eMDR batch list, create a new record and complete the necessary fields.

                                          3. For the new record, enter any unique alpha numeric string in the Batch # field.

                                          4. Navigate to Regulatory Reports screen, then the eMDR view and do the following:

                                            1. Identify a regulatory report that you want to include in batch, and modify the Batch # field to the one specified in Step 3.

                                            2. Repeat Step a for every regulatory report that you want to include in the batch.

                                              This regulatory reports will remain in the eMDR queue and will be sent as part of a batch to the FDA at month end.

                                          5. To transmit the batch immediately, do the following:

                                            1. Navigate to Regulatory Reports screen, then the eMDR Batch view,

                                            2. Select the batch created in Step 3, and then click Transmit.

                                          Note: Once transmitted, you should monitor the FDA Status field of the batch for FDA confirmation. For more information on confirmation statuses, refer to About FDA Confirmations for Electronic Medical Device Reporting.

                                            Reopening a Regulatory Report

                                            If you want to make a change in a generated (submitted) regulatory report record, you need to reopen it. Only the primary owner of the regulatory report can reopen it.

                                            When you reopen a report:

                                            • The Status field changes to Reopen

                                            • The fields in the regulatory report record can be edited

                                            This task is a step in Process of Regulatory Reporting.

                                            To reopen a regulatory report

                                            1. Navigate to Regulatory Reports screen, then the Regulatory Report List view.

                                            2. In the Regulatory Report List, drill down on a regulatory report with status of Submitted.

                                            3. Click Reopen.

                                              This starts the LS Medical Product Issue RR Reopen workflow, which authenticates the user and changes the status of the report to Reopen.

                                              For more information about the workflow, see LS Medical Product Issue RR Reopen Workflow.

                                              Creating Supplemental or Follow-Up Regulatory Reports

                                              Often, it is necessary to follow-up an initial report with a follow-up report that provides supplementary information to the regulatory agency.

                                              When you run a supplemental or follow-up report, the report should contain the initial report number and any corrected or new data.

                                              Caution: Regulatory report records cannot be deleted.

                                              This task is a step in Process of Regulatory Reporting.

                                              To create a follow-up or supplemental regulatory report

                                              1. Navigate to Product Issues screen, then the Product Issue List view.

                                              2. In the Product Issue List, drill down on a product issue.

                                              3. Click the Regulatory Reports tab.

                                              4. In the Regulatory Reports list, create a new record and complete the necessary fields.

                                                When the regulatory report is created:

                                                • The following fields are copied from the product issue: PI # and SR #

                                                • The following fields are set with a default value: Status is set to In Progress, Owner is set to Creator of the record.

                                              5. Set the Report Type field to 3500A Supplemental or MDV Follow-up.

                                              6. Click Populate Report.

                                                The Populate Report button only copies the initial report number to the supplemental report. (No other fields are copied.) You can configure the application to copy additional fields such as Mfg Narrative and Corrected Data to the supplemental report. Review the LS Medical Product Issue Populate Report Workflow for an example of a similar configuration.

                                              7. If you are a device manufacturer preparing a 3500A Supplemental report, make sure to check a Follow-Up Type in the Investigation view.

                                              8. After creating a follow-up or supplemental regulatory report, you can view it, submit it, reopen it in the same way as a initial report:

                                                Field Mapping for the MedWatch Report

                                                The following table shows how the fields in the Regulatory Reports screen map to the fields in the MedWatch 3500A report. If the content for text fields extends to continuation pages, it starts from the third page. Note the following about the different areas on the Location MedWatch Form 3500A:

                                                • A: Patient Information

                                                • B: Adverse Event or Product Problem

                                                • C: Suspect Medication(s)

                                                • D: Suspect Medical Device

                                                • E: Initial Reporter

                                                • F: For Use by User Facility/Importer (Devices Only)

                                                • G: All Manufacturers

                                                • H: Device Manufacturers Only

                                                  Table Mapping of Fields from the Siebel AECM UI to the Med Watch 3500A Form

                                                  Location on MedWatch Form 3500A Field Name View (Applet) on the Regulatory Reports and the Product Issues screen

                                                  A1

                                                  Patient Identifier

                                                  Patient

                                                  A2

                                                  Age

                                                  Patient

                                                  A2

                                                  Date of Birth

                                                  Patient

                                                  A3

                                                  Gender

                                                  Patient

                                                  A4

                                                  U/M

                                                  Patient

                                                  A4

                                                  Weight

                                                  Patient

                                                  B1

                                                  Event Type

                                                  More Info (Event Detail)

                                                  B2

                                                  Congenital Anomaly

                                                  More Info (Event Detail)

                                                  B2

                                                  Date of Death

                                                  More Info (Event Detail)

                                                  B2

                                                  Death

                                                  More Info (Event Detail)

                                                  B2

                                                  Disability

                                                  More Info (Event Detail)

                                                  B2

                                                  Hospitalization

                                                  More Info (Event Detail)

                                                  B2

                                                  Life Threatening

                                                  More Info (Event Detail)

                                                  B2

                                                  Other

                                                  More Info (Event Detail)

                                                  B2

                                                  Required Intervention

                                                  More Info (Event Detail)

                                                  B3

                                                  Event Date

                                                  More Info (Event Detail)

                                                  B4

                                                  Report Date

                                                  More Info, Regulatory Reports screen only

                                                  B5

                                                  Description

                                                  More Info (Event Detail)

                                                  B6

                                                  Tests/Data

                                                  More Info (Event Detail)

                                                  B7

                                                  Relevant History

                                                  More Info (Event Detail)

                                                  C1

                                                  Product

                                                  More Info (Products)

                                                  C2

                                                  Dose Per Unit

                                                  More Info (Products)

                                                  C2

                                                  Frequency

                                                  More Info (Products)

                                                  C2

                                                  Route Used

                                                  More Info (Products)

                                                  C3

                                                  Therapy From Date

                                                  More Info (Products)

                                                  C3

                                                  Therapy To Date

                                                  More Info (Products)

                                                  C4

                                                  Indication

                                                  More Info (Products)

                                                  C5

                                                  Event Abated

                                                  More Info (Products)

                                                  C6

                                                  Lot #

                                                  More Info (Products)

                                                  C7

                                                  Expiration Date

                                                  More Info (Products)

                                                  C8

                                                  Reintroduce Reoccur

                                                  More Info (Products)

                                                  C9

                                                  NDC#

                                                  More Info (Products)

                                                  C10

                                                  External Products

                                                  More Info (Event Detail)

                                                  D1

                                                  Product

                                                  More Info (Products)

                                                  D2

                                                  Common Device Name

                                                  More Info (Products)

                                                  D3

                                                  City

                                                  More Info (Products)

                                                  D3

                                                  Mfg Name

                                                  More Info (Products)

                                                  D3

                                                  Postal Code

                                                  More Info (Products)

                                                  D3

                                                  State

                                                  More Info (Products)

                                                  D3

                                                  Street Address

                                                  More Info (Products)

                                                  D4

                                                  Asset #

                                                  More Info (Products)

                                                  D4

                                                  Catalog #

                                                  More Info (Products)

                                                  D4

                                                  Expiration Date

                                                  More Info (Products)

                                                  D4

                                                  Lot #

                                                  More Info (Products)

                                                  D4

                                                  Model #

                                                  More Info (Products)

                                                  D4

                                                  Part #

                                                  More Info (Products)

                                                  D4

                                                  Serial #

                                                  More Info (Products)

                                                  D5

                                                  Device Operator

                                                  More Info (Products)

                                                  D6

                                                  Implant Date

                                                  More Info (Products)

                                                  D7

                                                  Explant Date

                                                  More Info (Products)

                                                  D8

                                                  Reprocessed

                                                  More Info (Products)

                                                  D9

                                                  Reprocessor

                                                  More Info (Products)

                                                  D10

                                                  Device Available

                                                  More Info (Products)

                                                  D10

                                                  Return Date

                                                  More Info (Products)

                                                  D11

                                                  External Products

                                                  More Info (Event Detail)

                                                  E1

                                                  Account

                                                  More Info

                                                  E1

                                                  Address

                                                  More Info

                                                  E1

                                                  City

                                                  More Info

                                                  E1

                                                  Contacts (Contact Last Name in list)

                                                  More Info

                                                  E1

                                                  CSN #

                                                  More Info

                                                  E1

                                                  First Name (Contact First Name in list)

                                                  More Info

                                                  E1

                                                  Phone #

                                                  More Info

                                                  E1

                                                  Postal Code

                                                  More Info

                                                  E1

                                                  Site

                                                  More Info

                                                  E1

                                                  State

                                                  More Info

                                                  E2

                                                  Provider

                                                  More Info

                                                  E3

                                                  Occupation

                                                  More Info

                                                  E4

                                                  Reported FDA

                                                  More Info

                                                  F1

                                                  Facility Type

                                                  Importer

                                                  F2

                                                  Report #

                                                  Importer

                                                  F3

                                                  Address

                                                  Importer

                                                  F3

                                                  City

                                                  Importer

                                                  F3

                                                  Country

                                                  Importer

                                                  F3

                                                  Importer

                                                  Importer

                                                  F3

                                                  Postal Code

                                                  Importer

                                                  F3

                                                  State

                                                  Importer

                                                  F4

                                                  Contact Name

                                                  Importer

                                                  F4

                                                  First Name

                                                  Importer

                                                  F5

                                                  Phone #

                                                  Importer

                                                  F6

                                                  PI Received

                                                  Importer

                                                  F7

                                                  Follow-up #

                                                  Importer

                                                  F7

                                                  Report Type

                                                  Importer

                                                  F8

                                                  Report Date

                                                  More Info

                                                  F9

                                                  Age UoM

                                                  Importer

                                                  F9

                                                  Device Age

                                                  Importer

                                                  F10

                                                  Device Codes

                                                  Importer

                                                  F10

                                                  Patient Codes

                                                  Importer

                                                  F11

                                                  FDA Report Date

                                                  Importer

                                                  F11

                                                  Reported FDA

                                                  Importer

                                                  F12

                                                  Event Location

                                                  Importer

                                                  F13

                                                  Mfg Report Date

                                                  Importer

                                                  F13

                                                  Reported Mfg

                                                  Importer

                                                  G1

                                                  Address

                                                  Manufacturer

                                                  G1

                                                  City

                                                  Manufacturer

                                                  G1

                                                  Contact Name

                                                  Manufacturer

                                                  G1

                                                  Contact Office

                                                  Manufacturer

                                                  G1

                                                  Country

                                                  Manufacturer

                                                  G1

                                                  First Name

                                                  Manufacturer

                                                  G1

                                                  Postal Code

                                                  Manufacturer

                                                  G1

                                                  State

                                                  Manufacturer

                                                  G2

                                                  Phone #

                                                  Manufacturer

                                                  G3

                                                  Consumer

                                                  Manufacturer

                                                  G3

                                                  Foreign

                                                  Manufacturer

                                                  G3

                                                  Distributor

                                                  Manufacturer

                                                  G3

                                                  Literature

                                                  Manufacturer

                                                  G3

                                                  Other

                                                  Manufacturer

                                                  G3

                                                  Professional

                                                  Manufacturer

                                                  G3

                                                  Representative

                                                  Manufacturer

                                                  G3

                                                  Study

                                                  Manufacturer

                                                  G3

                                                  User Facility

                                                  Manufacturer

                                                  G4

                                                  PI Received

                                                  Manufacturer

                                                  G5

                                                  (A)NDA #

                                                  Manufacturer

                                                  G5

                                                  IND #

                                                  Manufacturer

                                                  G5

                                                  OTC Product

                                                  Manufacturer

                                                  G5

                                                  Pre-1938

                                                  Manufacturer

                                                  G6

                                                  Protocol #

                                                  More Info (Product Issues) and Manufacturer

                                                  G7

                                                  10-day

                                                  Manufacturer

                                                  G7

                                                  15-day

                                                  Manufacturer

                                                  G7

                                                  5-day

                                                  Manufacturer

                                                  G7

                                                  Follow-up

                                                  Manufacturer

                                                  G7

                                                  Follow-Up #

                                                  Manufacturer

                                                  G7

                                                  Initial

                                                  Manufacturer

                                                  G7

                                                  Periodic

                                                  Manufacturer

                                                  G8

                                                  AE Terms

                                                  Manufacturer

                                                  G9

                                                  Mfg Report #

                                                  Manufacturer

                                                  H1

                                                  Death

                                                  Investigation

                                                  H1

                                                  Malfunction

                                                  Investigation

                                                  H1

                                                  Other

                                                  Investigation

                                                  H1

                                                  Serious Injury

                                                  Investigation

                                                  H2

                                                  Additional Information

                                                  Investigation

                                                  H2

                                                  Correction

                                                  Investigation

                                                  H2

                                                  Device Evaluation

                                                  Investigation

                                                  H2

                                                  Response to FDA Request

                                                  Investigation

                                                  H3

                                                  Evaluated by Mfg

                                                  Investigation

                                                  H3

                                                  Evaluation

                                                  Investigation

                                                  MDV

                                                  H3

                                                  Non-Evaluation Codes

                                                  Investigation

                                                  H4

                                                  Mfg Date

                                                  Investigation

                                                  More Info (Products)

                                                  H5

                                                  Labeled Single Use

                                                  More Info (Products)

                                                  Investigation

                                                  H6

                                                  Conclusion Codes

                                                  Investigation

                                                  H6

                                                  Method Codes

                                                  Investigation

                                                  H6

                                                  Result Codes

                                                  Investigation

                                                  H7

                                                  Inspection

                                                  Investigation

                                                  H7

                                                  Modification

                                                  Investigation

                                                  H7

                                                  Notification

                                                  Investigation

                                                  H7

                                                  Other

                                                  Investigation

                                                  H7

                                                  Patient Monitoring

                                                  Investigation

                                                  H7

                                                  Recall

                                                  Investigation

                                                  H7

                                                  Relabeling

                                                  Investigation

                                                  H7

                                                  Repair

                                                  Investigation

                                                  H7

                                                  Replace

                                                  Investigation

                                                  H8

                                                  Usage of Device

                                                  Investigation

                                                  H9

                                                  Correction #

                                                  Investigation

                                                  H10

                                                  Mfg Narrative

                                                  Investigation

                                                  MDV

                                                  H11

                                                  Corrected Data

                                                  Investigation

                                                Field Mapping for the MDV Report

                                                The following table shows how the fields in the Regulatory Reports screen map to the fields in the MDV report.

                                                Table Mapping of Fields from Siebel AECM UI to the MDV Report

                                                Regulatory Reports Screen UI Field Name View (Applet) on the Regulatory Reports and the Product Issues screen Text on MDV Report

                                                Report Header

                                                Report #

                                                MDV Report #

                                                More Info

                                                MDV

                                                MDV Report #

                                                Report Header

                                                Affiliate Ref #

                                                MDV

                                                Affiliate Ref #

                                                Report Header

                                                Type

                                                More Info

                                                Report Type

                                                MDV Determination

                                                Determination

                                                MDV

                                                MDV Determination

                                                Destination

                                                Authorities

                                                MDV

                                                Competent Authority Name

                                                Destination

                                                Address

                                                Address 2

                                                City

                                                State

                                                Postal Code

                                                Country

                                                MDV

                                                Address

                                                General

                                                Report Date

                                                More Info, Regulatory Reports screen only

                                                Report Date

                                                General

                                                Received

                                                More Info

                                                Manufacturer Awareness Date

                                                General

                                                Affiliate Acct

                                                MDV

                                                Reporting Firm Name

                                                General

                                                Auth Rep

                                                First Name

                                                MDV

                                                Authorized Representative

                                                General

                                                Address

                                                City

                                                State

                                                Postal Code

                                                Country

                                                MDV

                                                Address

                                                General

                                                Phone #

                                                MDV

                                                Telephone

                                                General

                                                Fax #

                                                MDV

                                                Facsimile

                                                Event Information

                                                Patient Identifier

                                                Patient

                                                Patient Identifier

                                                Event Information

                                                Gender

                                                Patient

                                                Gender

                                                Event Information

                                                Age

                                                Patient

                                                Age

                                                Event Information

                                                Weight

                                                Patient

                                                Weight

                                                Event Information

                                                Date of Birth

                                                Patient

                                                Date of Birth

                                                Event Information

                                                Account

                                                More Info

                                                Health Care Facility Name

                                                Event Information

                                                Site

                                                More Info

                                                Site

                                                Event Information

                                                Contacts, First Name

                                                More Info

                                                Contact Name

                                                Event Information

                                                Address

                                                More Info

                                                Address

                                                Event Information

                                                Phone #

                                                More Info

                                                Contact Phone Number

                                                Event Information

                                                Event Date

                                                More Info (Event Detail)

                                                Event Date

                                                Event Information

                                                Description

                                                More Info (Event Detail)

                                                Event Description

                                                Event Information

                                                # Occurrences

                                                More Info (Event Detail)

                                                Number of Occurrences

                                                Event Information

                                                Labeled Single Use

                                                More Info (Products)

                                                Investigation

                                                Device Labeled for Single Use

                                                Event Information

                                                Patient Codes

                                                MDV

                                                Importer

                                                Patient Outcomes

                                                Event Information

                                                Device Codes

                                                MDV

                                                Importer

                                                Device Outcomes

                                                Event Information

                                                Usage of Device

                                                MDV

                                                Investigation

                                                Usage of Device

                                                Event Information

                                                Authorities

                                                MDV

                                                Competent Authorities Already Notified

                                                Device Information

                                                Mfg Name

                                                MDV

                                                Manufacturer Name

                                                Device Information

                                                Contact

                                                First Name

                                                MDV

                                                Manufacturer Contact Name

                                                Device Information

                                                Address

                                                City

                                                State

                                                Postal Code

                                                Country

                                                MDV

                                                Address

                                                Device Information

                                                Phone #

                                                MDV

                                                Telephone

                                                Device Information

                                                Fax #

                                                MDV

                                                Facsimile

                                                Device Information

                                                Product

                                                More Info (Products)

                                                Device Name

                                                Device Information

                                                Device Type

                                                More Info (Products)

                                                Type of Device

                                                Device Information

                                                Lot #

                                                More Info (Products)

                                                Device Lot #

                                                Device Information

                                                Part #

                                                More Info (Products)

                                                Device Part #

                                                Device Information

                                                Asset #

                                                More Info (Products)

                                                Device Asset #

                                                Device Information

                                                Serial #

                                                More Info (Products)

                                                Device Serial #

                                                Device Information

                                                Model #

                                                More Info (Products)

                                                Model #

                                                Device Information

                                                Catalog #

                                                More Info (Products)

                                                Catalog #

                                                Device Information

                                                Approval Org

                                                MDV

                                                Device Approval Body

                                                Device Information

                                                Approval #

                                                MDV

                                                Approval #

                                                Device Information

                                                Qty Involved

                                                More Info (Products)

                                                Quantity of Devices Involved

                                                Device Information

                                                Device Available

                                                More Info (Products)

                                                Device Disposition

                                                Device Information

                                                External Products

                                                More Info (Event Detail)

                                                Associated Products

                                                Results of Investigation

                                                Evaluation

                                                MDV

                                                Investigation

                                                Device Evaluation Result

                                                Results of Investigation

                                                Remedials

                                                MDV

                                                Remedial Action

                                                Results of Investigation

                                                MFG Narrative

                                                MDV

                                                Investigation

                                                Manufacturer’s Narrative

                                                About Configuring Buttons in Regulatory Reports

                                                There are three buttons associated with regulatory reports. You can configure the workflows for these buttons.

                                                You can modify workflows to suit your own business model using Siebel Business Process Designer. For more information, see Siebel Business Process Framework: Workflow Guide.

                                                  LS Medical Product Issue Populate Report Workflow

                                                  This workflow is initiated from the Populate button on the Regulatory Reports view of the Product Issues screen.

                                                  The workflow appears in the following figure.

                                                  LS Medical Product Issue Populate Report Workflow

                                                  Workflow Description

                                                  This workflow performs the following actions:

                                                  1. Checks if current record has already been populated. If it has, the workflow ends.

                                                  2. Sets the data map object according to the report type.

                                                    The data map objects are:

                                                    • LS Medical PI Populate Report - 3500A

                                                    • LS Medical PI Populate Report - 3500 Supplemental

                                                    • LS Medical PI Populate Report - MDV Initial

                                                    • LS Medical PI Populate Report - MDV Follow-up

                                                  3. Populates the report from the product issue according to the data map object.

                                                    LS Medical Product Issue RR Submit Workflow

                                                    This workflow is initiated from the Generate button on the Regulatory Reports screen.

                                                    The workflow appears in the following figure.

                                                    LS Medical Product Issue RR Submit

                                                    Workflow Description

                                                    This workflow performs the following actions:

                                                    1. Checks if the application is running on a server database. If not, the workflow ends.

                                                    2. Checks if the user is the primary owner. If not, the workflow ends.

                                                    3. Checks if the record has already been processed. If it has, the workflow ends.

                                                    4. Calls the LS Medical User Verification workflow. If the authentication does not pass, the workflow ends.

                                                    5. Checks if the parent product issue already has a report number.

                                                      If the product issue. . . and the Report Type Is. . . Then. . .

                                                      Has a report record with a report number

                                                      Use the same number for the report being submitted.

                                                      Does not have a report record with a report number

                                                      3500A or MDV

                                                      Generate a new report number.

                                                      3500A Supplemental or MDV Follow-up

                                                      The workflow ends.

                                                    6. Sets the status of the report to Submitted.

                                                      LS Medical Product Issue RR Reopen Workflow

                                                      This workflow is initiated from the Reopen button on the Regulatory Reports screen.

                                                      The workflow appears in the following figure.

                                                      LS Medical Product Issue RR Reopen

                                                      Workflow Description

                                                      This workflow performs the following actions:

                                                      1. Checks if the user is the primary owner. If not, the workflow ends.

                                                      2. Checks if the record has already been processed. If it has, the workflow ends.

                                                      3. Calls the LS Medical User Verification workflow. If the authentication does not pass, the workflow ends.

                                                      4. Sets the status of the report to Reopen.