In vitro diagnostic (IVD) tests that have been traditionally performed in laboratories (labs) are becoming increasingly performed outside of labs, which leaves those tests untethered from their usual data collection and reporting systems. Over the past several years, we have seen a rapid increase in point-of-care (POC), at-home, and over-the-counter (OTC) tests (“non-lab-based”) for SARS-CoV-2, and it is expected that these and other non-laboratory-based tests will continue to increase in the coming years.
Without capture and transmission of the increasing volumes of data from non-lab-based tests, federal and state public health leaders and physicians will have less information available to make evidence-based decisions for individual clinical care as well as population health using diagnostic data. New and emerging technology and innovation in SARS-CoV-2 diagnostics is presenting both opportunities and challenges with regards to data capture, harmonization, transmission, and use for addressing the pandemic at both individual and population levels. Technologies developed and lessons learned from highly-distributed testing during the COVID-19 pandemic will usher in both new expectations and new technological ways of accessing testing and using diagnostic data for years to come – and for conditions beyond infectious disease.
Data from Over-the-Counter (OTC) and Point-of-Care (POC)
While diagnostic testing has been traditionally used to assist in guiding medical decisions at the individual level, the use of diagnostic data from tests for infectious diseases is also essential for informing the public and decision-makers during a public health emergency. Diagnostic testing data provides the earliest and most immediate actionable information regarding a virus’s location and spread, allowing for proactive, targeted intervention to stop transmission and quell outbreaks. Leveraging the combination of diagnostic technologies with digital health tools, apps, software, and wireless transmission facilitates the capture, transmission, aggregation, and analysis of the comprehensive, population-level diagnostic data needed to guide evidence-based policy and public health decision-making.
Barriers to capturing diagnostic data from OTC and POC tests are not technological – developers and innovators are rapidly rolling out solutions that will potentially enable far better data harmonization, capture, and reporting than traditional lab-based systems. However, these developers need regulatory support and guidance that is timely and specialized to bring their innovations to market.
As premarket submissions to market IVDs combine an assay, hardware (for example, an instrument), software, and/or digital applications and tools, a dedicated interdisciplinary review team composed of FDA staff provides support to developers to manage and expedite the review processes when indicated. Interdisciplinary expertise and collaboration are critical to address the device review needs during a pandemic as well as to prepare for new, emerging technologies that will increasingly combine hardware and software systems with wireless connectivity and transmission of data. This collaboration between physicians and scientists at FDA brings together essential expertise in IVDs, microbiology, virology, medicine, public health, software, digital health, cybersecurity, information technology, computing, and research and development.
The FDA is prepared to support developers who present the FDA with innovative, cross-cutting technological solutions and new types of tests – the volume of which will likely increase. The FDA also anticipates that a broad expansion of software integration with IVDs beyond COVID-19 will accelerate moving forward.
Testing in the COVID-19 Pandemic
The Coronavirus Aid, Relief, and Economic Security (CARES) Act specified that data elements be reported for COVID-19 diagnostic tests performed in laboratories. The Department of Health and Human Services (HHS) further defined these data elements through guidance and technical specifications for lab-based tests and non-lab-based tests. The reporting requirement and implementation strategies helped ensure critical diagnostic testing data was collected and reported to state and federal public health officials to inform the pandemic response at every level across the U.S.
As the availability of “rapid tests” administered at POC and sold OTC dramatically increased between late 2020-2022, the volume of testing increased rapidly while the percentage of diagnostic data being collected and reported dropped dramatically. Over this period of time, many stakeholders raced to build integrated hardware-software solutions for diagnostic data capture and reporting, as well as the data collection and analytical systems to support the new highly-distributed diagnostic data ecosystem. However, the rapidly evolving landscape of testing options and surge in volume created challenges regarding diagnostic data that have been partly addressed in real-time but will require collaborative effort and investment by many stakeholders for years to come. Without the ability to capture, analyze, and utilize high quality data from non-lab-based tests, all stakeholders as well as patients and the general public will not be able to maximally benefit from more accessible testing. Ensuring the quality and performance of highly-distributed tests, as well as the ability to protect patient privacy and security, will be crucial features of the ecosystem as it expands.
To address these issues, the FDA’s Diagnostic Data Program – including the Digital Diagnostics (OTC/POC) focus area – within CDRH is working to support the testing community to develop innovative methods for collection, harmonization, transmission, and analysis of diagnostic data originating from tests, including those performed outside laboratories. It will be critical that these non-lab-based data streams are harmonized and aggregated with lab-based data streams for similar diagnostic tests. This program is also working with stakeholders to inform regulatory review processes that will ensure safe, effective, and accurate diagnostics arising from new, emerging, and convergent technologies are first to market in the U.S.
Another way CDRH is supporting innovation in diagnostics is through collaboration with other federal agencies, such as with NIH’s Independent Test Assessment Program (ITAP) and Rapid Acceleration of Diagnostics (RADx) Program. ITAP has facilitated the authorization of at-home tests by developing standardized evaluation protocols and data reporting mechanisms along with targeted outreach to developers of rapid antigen tests that were authorized in other markets. RADx has worked with the IVD community to accelerate the volume and variety of SARS-CoV-2 testing technologies available in the U.S.
- HHS Diagnostic Data & Reporting FAQ
- HHS Guidance: COVID-19 Pandemic Response, Laboratory Data Reporting: CARES Act Section 18115
- RADx® MARS - Mobile Application Reporting through Standards | National Institute of Biomedical Imaging and Bioengineering (nih.gov)
- HHS Protect Public Data Hub (arcgis.com)
- RADx | National Institutes of Health (NIH)
- The Opportunity Project (census.gov)
- COVID-19 At-Anywhere Diagnostics Design-a-thon and TOPx Sprint
- 2023 TOPx Diagnostic Data Exchange Sprint (FDA)
- NIH Make My Test Count