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Initial interactions with the FDA on developing a validation dataset as a medical device development tool.

Steven Hart1, Victor Garcia2, Sarah N Dudgeon3

  • 1Department of Laboratory Medicine and Pathology, Mayo Clinic, Rochester, MN, USA.

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|October 5, 2023
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Summary

Quantifying tumor-infiltrating lymphocytes (TILs) in breast cancer is challenging. This study proposes an FDA-qualified dataset to streamline computational model validation, reducing regulatory burdens for developers and enabling fair performance comparisons.

Keywords:
artificial intelligencecomputational pathologymachine learningmedical device development toolmodel validationregulatory sciencetriple-negative breast cancertumor-infiltrating lymphocytes

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Area of Science:

  • Computational pathology
  • Digital pathology
  • Biomedical imaging analysis

Background:

  • Quantifying tumor-infiltrating lymphocytes (TILs) in breast cancer is crucial but challenging for pathologists.
  • Whole slide imaging enables computational models for TIL quantification, but their development is resource-intensive.
  • Standardized validation is needed for computational models used in breast cancer diagnostics.

Purpose of the Study:

  • To propose a dataset for validating computational models that quantify TILs in breast cancer.
  • To reduce the regulatory burden for developers of TIL quantification models through FDA's Medical Device Development Tool (MDDT) program.
  • To facilitate open, fair, and consistent performance evaluation of computational models.

Main Methods:

  • Preparation and submission of a dataset to the FDA's MDDT program.
  • Engaging with the FDA to understand requirements for qualifying validation datasets.
  • Discussing the MDDT process and its implications for computational model validation.

Main Results:

  • The study outlines the process of preparing and submitting a dataset for MDDT qualification.
  • It details initial feedback received from the FDA regarding the submission.
  • The proposed qualified dataset aims to enable head-to-head comparisons of multiple computational models.

Conclusions:

  • A qualified MDDT validation dataset can standardize and simplify the regulatory process for computational pathology tools.
  • This approach can foster trust and consistency in the performance assessment of TIL density estimation models.
  • Sharing experiences with the FDA MDDT process aids the broader community in developing and validating AI-driven pathology tools.