Slide 1 HL7 SPL SUBMISSION OPTION April 24, 2018 Varsha Thakar Technical/HL7 Specialist Food And Drug Administration
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HL7 SPL SUBMISSION OPTIONApril 24, 2018
Varsha ThakarTechnical/HL7 Specialist
Food And Drug Administration
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Submission of medical device information as HL7 SPL message
o One device record data per xml file
GUDID HL7 SPL submissions are submitted via the FDA ESG
Testing required prior to submitting data to Production GUDID
Ideal for labelers with large volume of submissions
GUDID HL7 SPL Submission Option
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FDA Electronic Submissions GatewayESG is a conduit of receiving and delivering submissions to the appropriate center for further processing
Two Options for submissiono WebTradero Applicability Statement 2 (AS2) System to System
GUDID does NOT use the eSubmitter tool
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Acknowledgements
LabelersESG
CDRH
Ack1Ack2
Ack3
Center = CDRHSubmission Type = GUDID
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Acknowledgement 1(Ack1)
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Acknowledgement 2 (Ack2)
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Acknowledgement 3 (Ack3)
HL7 SPL Implementation Guide 122
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Acknowledgement 3 (Ack3)
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Inquiries
Ack1/2 Issues [email protected] Ack1 – Provide info Ack2 – Provide messageIDContact appropriate help desk regarding issues prior to retransmitting
Ack3 Issues [email protected] Provide coreID
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FDA ESG Process
GUDID ProcessTime NeededWebTrader 1-2 weeksAS2 – 2-4 weeks
Gather Data, Generate GUDID HL7 SPL XML
Time Needed6-8 weeks
PROCESS
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ESG and GUDID ESG serves the entire FDA ESG and GUDID have Test and Production areas
Submissions sent via ESG Test Account
Submissions sent via ESG Production
Account
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GUDID HL7 SPL Pointers Read FDA Guidance and other resources to gather and prepare your GUDID
submissions https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/UniqueDeviceIdentification/ChangesbetweenUDIProposedandFinalRules/default.htm
Allow adequate time for testing – ESG and GUDID
GUDID testing completion criteria is the bare minimum– Do thorough internal testing to ensure scenarios appropriate for your products
are accounted for– Do not submit sample message in the HL7 SPL implementation package as a
test submission – it is not validated
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DI Records Records can be submitted as
o Unpublished = DI Record Publish Date is in the futureo Published = DI Record Publish Date is today’s date or earlier
Review your submission via the Web Interfaceo Login into the GUDID Web Interface
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Third-PartiesThird-Parties may:
Provide software solution/tool to labeler to generate HL7 SPL XML files; labeler sends submission via ESGo Labeler obtains ESG account
Provide end-to-end solution: use labeler data to generate GUDID HL7 SPL XML files AND send submissions via ESG on behalf of labelero Third-party has the ESG accounto Labeler sends a letter of non-repudiation indicating third-party is
authorized to submit on their behalf
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Using Third-Party Submitters Provide Third-Party information during GUDID account request
o If third-party is not associated to labeler’s GUDID account, submission from third-party will be rejected
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Labelers and Third-Party Submitters Labelers who intend to use the HL7 SPL submission option:
o Must complete GUDID testingo Testing required even if using a third-party submitter
Labelers are responsible for fulfilling GUDID submission requirements: o Ensure submissions are received and processed by FDA.o Login to GUDID and review your submissionso Report within the required timeframeo Maintain proper records
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Third-Party Solution ProvidersMay test GUDID HL7 SPL submission solution independently of Labelers
Request a GUDID test Account: indicate it is for HL7 SPL testing Dummy data for certain required attributes provided for testing
purposes ONLY, upon request GUDID Web Interface and Production Accounts NOT provided
Must complete GUDID HL7 SPL testing with each labeler Labelers must establish their own separate test GUDID account
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Web vs HL7 SPL
HL7 SPL67%
Web33%
HL7 SPL Web
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Switching from Web to HL7 SPL OR VICE VERSA
• Only one GUDID account is needed • Keep your account information updated• Testing is required if switching to HL7 SPL submission method• Prior to sending updates in Production, test to ensure you are
able to maintain and update your web created records through SPL
• Make sure your data is synced up with your source system to avoid any issues with updating records via HL7 SPL
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Editing DI RecordsInitial submission
DI Record Status DI Record Edit Status Editing allowed via
Web Unpublished All Fields Editable WebWeb Published In Grace Period WebWeb Published After Grace Period Web or HL7 SPL
HL7 SPL Unpublished All Fields Editable HL7SPL or WebHL7 SPL Published In Grace Period HL7 SPL or WebHL7 SPL Published After Grace Period HL7 SPL or Web
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Thank You