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FDA Public Meeting: Device Improvements and Reporting. Lawrence B. Marks, M.D. University of North Carolina at Chapel Hill, NC. Summary. Thank you: There is a problem Utility Devices/Processes : Must Consider Context Incorporate QA/monitoring tools into devices -sometimes
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FDA Public Meeting:Device Improvements and Reporting Lawrence B. Marks, M.D. University of North Carolina at Chapel Hill, NC
Summary Thank you: There is a problem Utility Devices/Processes : Must Consider Context Incorporate QA/monitoring tools into devices -sometimes Human factors engineering UNC
Acknowledge context: competing demands/concerns/distractions Documentation-Legal/Billing Log in/out repeat Dueling EMRs Residents/Nurse-Documentation Distractions UNC
QA Initiatives and Deviation Rates (36/28,523) Overall Deviation Rate (23/24,937) (25/31,019) (29/23,764) Deviation Rate % Standardized physicist pre-RT chart check (11/32,136) Pre-RT verbal timeout: 2 therapists Color-coded field marks Pre-RT Timeout: 1 therapist Pre-RT physicians port-film review Dosimetry calculation time-outs Pre-RT Checklist QA measures appear effective UNC
QA Initiatives and Deviation Rates (36/28,523) Overall Deviation Rate (23/24,937) (25/31,019) (29/23,764) Deviation Rate % Standardized physicist pre-RT chart check (11/32,136) Pre-RT verbal timeout: 2 therapists Color-coded field marks Pre-RT Timeout: 1 therapist Pre-RT physicians port-film review Dosimetry calculation time-outs Pre-RT Checklist QA: External to Product!! UNC
Specifics 1. Incorporate QA measures into systems; where reasonable e.g. checklists, time-outs, patient ID 2. Standardization (e.g. display screens), connectivity expert committees to determine 3. Reporting “near misses” Culture change Rules on what to report: ambiguous Reporting tools within existing products (as option) Facilitate reporting !! Make it easy to report. 4. Human Factors considerations UNC
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Summary Thank you: There is a problem Utility Devices/Processes : Must Consider Context Incorporate QA/monitoring tools into devices -sometimes Human factors engineering UNC
FDA Public Meeting:User Training Lawrence B. Marks, M.D. University of North Carolina at Chapel Hill, NC
Summary Vendors --> good user training Challenge: Why is so much training needed? usability suboptimal lack of standardization Training usability Pace of software evolutionary Rapid FDA-review? Limited items Continuing education Paper to Electronic Medical Record-User expectation UNC
More intuitive systems Need for Training Standardization Usability UNC
User Training Vendor Knowledge User Knowledge Improve Usability UNC
Vendor Training FDA Approval User Feedback Clinical Use Product Modified Product Improvements UNC
Vendor Training FDA Approval User Feedback Clinical Use Product Software monitors its own use: “Big Brother” Focused Re-Training: automatic? Modified Product Improvements UNC
Vendor Training FDA Approval User Feedback Clinical Use Product “Fast FDA Review” Software monitors its own use: “Big Brother” Focused Re-Training: automatic? Modified Product Improvements More Evolutionary Cycles --> Better Product UNC
Deviation increase: Need for continued training/reinforcement Low Tech 0.16 Deviation Rate % High Tech 0.10 0.09 0.06 0.11 Learning Curve 3 Low Tech 1 High Tech 4 High Tech 1 Low Tech 4 High Tech Years UNC Low Tech = No MLC High Tech = MLC
UNC User Expectations Habits/practice evolved in a paper-world The power of paper!
Paper: easily edited, annotated, corrected, highlighted, emphasis FEV1 1.3 L
UNC Patient is a 56 year old man with a T5 N0 left breast cancer. He initially presented with a rapidly enlarging mass….. Electronic record is NOT easily edited- Errors readily propagate
Miscommunication --> source of error, and Communication is MORE challenging in electronic world UNC
Summary Vendors --> good user training Challenge: Why is so much training needed? usability suboptimal lack of standardization Training usability Pace of software evolutionary Rapid FDA-review? Limited items Continuing education Paper to Electronic Medical Record- User expectation UNC