1. Considerations from the College of American Pathologists for Implementation of an Assay for SARS-CoV-2 Testing after a Change in Regulatory Status
- Author
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Isabella W. Martin, Marc Roger Couturier, Marie-Claire Rowlinson, David R. Peaper, Romney M. Humphries, Frederick S. Nolte, Elitza S. Theel, Rosemary C. She, Daniel D. Rhoads, Patricia J. Simner, Kaede V. Sullivan, and Christina Wojewoda
- Subjects
musculoskeletal diseases ,0301 basic medicine ,Microbiology (medical) ,medicine.medical_specialty ,Emergency Use Authorization ,2019-20 coronavirus outbreak ,Coronavirus disease 2019 (COVID-19) ,Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) ,030106 microbiology ,Declaration ,In vitro diagnostic ,03 medical and health sciences ,COVID-19 Testing ,0302 clinical medicine ,Humans ,Medicine ,Medical physics ,030212 general & internal medicine ,Diagnostic laboratory ,health care economics and organizations ,SARS-CoV-2 ,United States Food and Drug Administration ,business.industry ,COVID-19 ,Drug administration ,musculoskeletal system ,United States ,Pathologists ,Commentary ,business - Abstract
The U.S. Food & Drug Administration (FDA) regulates the marketing of manufacturers’ in vitro diagnostic tests (IVDs), including assays for the detection of SARS-CoV-2. The U.S. government’s Clinical Laboratory Improvement Amendments (CLIA) of 1988 regulates the studies that a clinical diagnostic laboratory needs to perform for an IVD before placing it into use. Until recently, the FDA has authorized the marketing of SARS-CoV-2 IVDs exclusively through the Emergency Use Authorization (EUA) pathway. The regulatory landscape continues to evolve, and IVDs will eventually be required to pass through conventional non-EUA FDA review pathways once the emergency declaration is terminated, in order to continue to be marketed as an IVD in the United States. When FDA regulatory status of an IVD changes or is anticipated to change, the laboratory should review manufacturer information and previously performed internal verification studies to determine what, if any, additional studies are needed before implementing the non-EUA version of the IVD in accordance with CLIA regulations. Herein, the College of American Pathologists’ Microbiology Committee provides guidance for how to approach regulatory considerations when an IVD is converted from EUA to non-EUA status.
- Published
- 2021
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