Findings
Fragmented and inconsistent measurement approaches currently hinder the generation of decision-grade evidence for pediatric rare diseases. Small and geographically dispersed patient populations make traditional site-based clinical assessments operationally difficult and burdensome for families. Digital health technologies can capture subtle functional changes and "functional fingerprints" in home settings that are often missed during infrequent clinic visits. Standardized core digital measures across conditions allow for the aggregation of data and the creation of a shared evidence base for rare disorders. Meaningful aspects of health identified by patients and caregivers include motor function, communication, sleep quality, and autonomic stability.

Recommendations
Sponsors should adopt the core set of digital clinical measures to reduce trial timelines, lower development costs, and decrease participant burden. Researchers should prioritize passive and objective data collection to minimize the need for manual tracking by caregivers. Clinical trial designs should transition toward decentralized or hybrid models to improve access for children and families regardless of their location. Stakeholders should use the project's conceptual model to identify and customize digital measures that align with the specific health priorities of their target population. Developers should focus on human-centered design to ensure digital tools are usable and sustainable for pediatric patients and their support networks.

Regulatory Considerations
The FDA and EMA provide specific pathways and interaction opportunities to accelerate the acceptance of digital endpoints in rare disease trials. Digital measures must be validated as "decision-grade" endpoints to meet the evidentiary requirements for regulatory submission and marketing approval. Alignment with industry standards for data elements and interoperability is necessary to ensure data integrity across multi-site studies. Early engagement with regulatory bodies through meetings and formal submissions is critical for confirming the suitability of new digital biomarkers. Compliance with data privacy and ethical standards is paramount when collecting continuous, real-world data from vulnerable pediatric populations.

Findings
General wellness products are defined by two factors: they are intended only for general wellness use and present a low risk to user safety. The FDA categorizes wellness uses into those relating to a general state of health (e.g., weight management, physical fitness, sleep) and those relating to chronic diseases where lifestyle choices are well-accepted to play a role in health outcomes. Products are not considered low risk if they are invasive, implanted, or involve technologies like lasers or radiation that require specific regulatory controls. Software functions intended for maintaining a healthy lifestyle that are unrelated to the diagnosis or treatment of a disease are explicitly excluded from the statutory definition of a medical device.

Recommendations
Manufacturers should ensure that claims for general wellness products are limited to sustaining or improving general health functions or encouraging healthy lifestyle choices for living well with chronic conditions. Disease-related claims must be supported by peer-reviewed scientific publications or official statements from healthcare professional organizations. Labeling and marketing communications must be consistent with and not exceed the product's stated intended use. For products using non-invasive sensing to estimate physiologic parameters, manufacturers should validate these outputs if they mimic values used clinically. If a product includes notifications to see a doctor, these should not name specific diseases or characterize outputs as pathological.

Regulatory Considerations
For products meeting the low-risk general wellness criteria, the FDA does not intend to enforce requirements such as registration and listing, premarket notification, or Quality Management System regulations. The FDA may coordinate with the Consumer Product Safety Commission to determine jurisdiction over specific products. If a product targets the diagnosis, screening, or management of a disease through alerts or clinical thresholds, it is generally not considered a general wellness product and is subject to standard medical device regulations. Industry members may contact the Digital Health Center of Excellence or use the Q-Submission process to discuss alternative approaches or clarify the regulatory status of a specific product.

Findings
The quality of evidence for the analytical validation of sensor-based digital health technologies (sDHTs), which is the evaluation of algorithms converting sensor data into a clinically interpretable measure, is often inconsistent and insufficient. The existing V3+ framework codifies the overall evaluation process, which includes verification, usability validation, analytical validation, and clinical validation. To improve the scientific rigor of analytical validation, a hierarchical framework for selecting reference measures is needed because not all potential reference measures are of equal quality. The framework classifies reference measures based on attributes that contribute to reduced measurement variability, with defining and principal measures being the most rigorous due to objective data acquisition and the ability to retain source data.

Recommendations
The proposed framework sequentially moves the investigator through four steps: (1) Compile preliminary information, including the digital clinical measure, context of use (COU), algorithm requirements, and sensor verification evidence . (2) Select an existing reference measure, develop a novel comparator, or identify a set of anchor measures, prioritizing measures with the highest scientific rigor (defining → principal → manual → reported) . (3) Consider the impact of the data collection environment to determine if the analytical validation study can be conducted in the intended use environment with the highest-order measure, or if in-lab validation is necessary, ensuring the results are generalizable . (4) Describe the rationale for key study design decisions to encourage transparency for evaluators, regulators, and payers . Investigators must justify passing over a higher-ranked reference measure, generally only acceptable if the higher-ranked measure poses unacceptable risk or is not applicable to the context of use.

Regulatory Considerations
The principles of the framework for analytical validation apply regardless of the regulatory status of the sDHT (regulated medical device, low-risk general wellness apps, or research product) or its intended use (clinical care or clinical research). The framework is intended to help investigators support the most rigorous claims regarding sDHT performance, which is important for acceptance by evaluators, peer-reviewers, regulators, and payers. The categorization of the digital clinical measure as a digital biomarker or an electronic clinical outcome assessment also does not change the framework's applicability.

Findings
In a progressive neurodegenerative illness like Alzheimer's disease, slowing the rate of disease progression is considered a clinically meaningful outcome for patients and their caregivers.
The assessment of what constitutes a clinical benefit is highly dependent on the specific stage of AD being studied, the drug's mechanism of action, and the symptoms present in that patient population.
Direct input from patients and caregivers is critical for understanding disease burden and defining treatment benefits that are truly meaningful from their perspective.
The interpretation of score changes on Clinical Outcome Assessments (COAs) requires full context; an absolute point difference must be considered relative to the study's duration, the expected placebo decline, and the specific disease stage.
Evidence from biomarkers that show an effect on underlying disease pathology provides additional support and increases the persuasiveness of the changes observed on clinical endpoints.

Recommendations
Drug developers should implement multiple "fit-for-purpose" COAs that use different reporters (e.g., clinicians, observers) and methods to generate broad and diverse evidence of a drug's clinical benefit.
Sponsors should utilize both qualitative and quantitative methodologies to explore clinical meaningfulness, including assessing "meaningful within-patient change" throughout the development process.
Developers are encouraged to create and validate new COAs and leverage innovative approaches, such as digital health technologies, to better capture concepts that are relevant to patients, especially in the earliest stages of AD.
Throughout the drug development lifecycle, stakeholders should systematically collect and incorporate patient experience data to ensure that the perspectives, needs, and priorities of patients are meaningfully captured.

Regulatory Considerations
For a drug to gain approval, it must meet the regulatory standard of "substantial evidence of effectiveness," which is typically derived from adequate and well-controlled investigations designed to minimize bias.
The FDA defines clinical benefit as a clinically meaningful effect of a drug on how an individual feels, functions, or survives.
An assessment of clinical benefit is not limited to the primary endpoint; the consistency of findings across multiple endpoints (primary and secondary) is a key consideration during regulatory review.
The accelerated approval pathway may be used for serious conditions with unmet needs based on a surrogate endpoint, but traditional approval requires verification of clinical benefit in confirmatory trials.
The FDA's evaluation includes a benefit-risk analysis, which considers the severity of the disease and the availability of alternative therapies, recognizing that patients and physicians may accept greater risks for life-threatening illnesses.

Findings
Digital endpoints must not only support regulatory approval but also provide evidence that meets payer expectations for reimbursement and value-based care. The lack of early engagement with payers and health technology assessment (HTA) agencies is a key barrier to the adoption of digital clinical measures. Digital measures can enhance value-based care models by capturing patient-centered outcomes, reducing healthcare costs, and improving early disease detection. The scalability and generalizability of digital endpoints remain challenges, particularly for diverse populations and real-world healthcare settings. Technical and systematic barriers—such as data heterogeneity, stakeholder knowledge gaps, and inconsistent regulatory-payer alignment—are slowing the adoption of digital endpoint data for reimbursement decisions.

Recommendations
Pharma and medical product developers should engage early with payers and regulators to ensure digital endpoints align with reimbursement expectations. Payers and HTA bodies should establish clear evidence thresholds for digital endpoint validation, ensuring consistency in market access decisions. Digital endpoints should be validated against health-related quality of life (HRQoL) measures and patient-reported outcomes (PROs) to demonstrate clinical relevance. Real-world evidence (RWE) should be incorporated into clinical trials alongside digital endpoints to strengthen reimbursement applications. Stakeholders should prioritize scalable, patient-centered digital measures that capture disease progression over time and across different care settings.

Regulatory Considerations
Integrated Evidence Plans (IEPs) should be developed early to align digital endpoint evidence with regulatory and payer requirements. Digital endpoints should be assessed through multi-stakeholder collaboration, ensuring validation across pharmaceutical, regulatory, and reimbursement frameworks. Payers and regulators should work together to create aligned pathways for digital measure acceptance, reducing delays in market access. Data security, privacy, and interoperability must be addressed to support regulatory approval and patient trust in digital health solutions. The industry should leverage international regulatory-payer collaboration models, such as the HTA-EMA partnership and the FDA Payor Communication Task Force, to accelerate global digital endpoint adoption.

Findings
Patient experience data provides critical context for regulatory review by illuminating disease burden, unmet medical needs, and the aspects of a condition that matter most to patients.
A systematic approach is necessary to ensure patient experience data is robust enough for regulatory consideration, moving beyond anecdotal evidence to scientifically rigorous data collection.
Early engagement between sponsors and the FDA is a key factor for successfully incorporating patient perspectives into a drug development program.
The value of patient-reported outcomes (PROs) and other clinical outcome assessments (COAs) is highly context-dependent, varying significantly across different diseases and patient populations.

Recommendations
Drug sponsors should leverage the FDA's meeting process to discuss their strategies for collecting and submitting patient experience data early in the development lifecycle.
Sponsors should utilize the repository of meeting reports as a learning resource to understand best practices and common challenges in patient-focused drug development for specific conditions.
Patient advocacy groups should actively participate in these discussions to ensure the full spectrum of patient experiences is captured and communicated to both regulators and developers.
Researchers should develop and validate novel tools and methodologies for capturing and analyzing patient experience data that are meaningful for both clinical and regulatory purposes.

Regulatory Considerations
Patient experience data is a key component of the benefit-risk assessment, providing evidence that can inform regulatory decisions regarding a drug's approval and labeling.
The FDA's review of patient experience data is guided by a commitment to patient-focused drug development, as mandated by the 21st Century Cures Act and supported by user fee agreements like PDUFA.
The scientific rigor of data collection and analysis is paramount; for patient experience data to be influential, it must meet high standards of validity and reliability.
Transparency is a core principle, and the publication of these meeting reports is intended to provide clear examples of how patient input can be effectively integrated into regulatory submissions.

Findings
Cybersecurity is an integral part of medical device safety and effectiveness, and manufacturers are responsible for addressing it throughout the entire device lifecycle. The FDA considers a device's cybersecurity as part of its benefit-risk assessment for both premarket and postmarket activities. A lack of robust cybersecurity controls can lead to patient harm, compromised device functionality, and breaches of data privacy. The dynamic nature of cybersecurity threats requires ongoing monitoring, risk management, and timely implementation of mitigation strategies.

Recommendations
Manufacturers should build cybersecurity into devices from the design phase ("secure by design") and conduct a thorough risk analysis to identify and mitigate potential vulnerabilities. Premarket submissions should include comprehensive documentation of the device's cybersecurity controls, a risk management plan, and a plan for postmarket surveillance and response. Manufacturers should establish a robust postmarket surveillance program to monitor for, identify, and address new cybersecurity threats in a timely manner. Clear and informative labeling is essential to help users understand and manage cybersecurity risks.

Regulatory Considerations
The FDA has the authority to take action against devices with inadequate cybersecurity that pose a risk to public health. The agency recommends that manufacturers use the Q-submission process to discuss specific cybersecurity questions related to their device submissions. Compliance with recognized standards and best practices for cybersecurity is strongly encouraged. Manufacturers must report certain cybersecurity incidents to the FDA as part of their postmarket reporting requirements. The FDA collaborates with other government agencies and stakeholders to promote a coordinated approach to medical device cybersecurity.

Findings
The DHCoE works to strategically advance science and evidence for digital health technologies (DHTs).
Key areas of focus include Artificial Intelligence / Machine Learning (AI/ML) in Software as a Medical Device (SaMD), Cybersecurity, Augmented Reality (AR) and Virtual Reality (VR), and Wireless Medical Devices.
The DHCoE develops and publishes Guidances with Digital Health Content and maintains a Digital Health Policy Navigator to provide clarity on regulatory policies.
Digital health technologies are acknowledged as having the potential to facilitate decentralized clinical trial activities and allow for continuous or frequent measurements of clinical features remotely.
Programs and initiatives include the Software Precertification (Pre-Cert) Pilot Program, the Regulatory Accelerator, and the Diagnostic Data Program.
The center is also involved in international harmonization on device regulatory policy and standards.

Recommendations
The DHCoE recommends that stakeholders, including sponsors and DHT manufacturers, engage with the agency early to discuss the use of DHTs in drug development or for decentralized clinical trials (DCTs).
Stakeholders are encouraged to use the Digital Health Policy Navigator tool to assess whether a particular software function meets the device definition and is the focus of FDA oversight.
The DHCoE emphasizes the need for a patient-centered approach for AI/ML-enabled devices that considers issues like usability, equity, trust, and accountability, and promotes transparency.

Regulatory Considerations
The DHCoE's work includes innovating the regulatory paradigm for digital health, moving towards models that may include shifting scrutiny from the pre-market to the post-market phase and focusing on the capability of firms (Software Pre-Cert Pilot Program).
The FDA has committed, as part of PDUFA VII, to activities such as publishing a Framework for the Use of DHTs in Drug and Biological Product Development and establishing a DHT Steering Committee.
The center provides information to help determine the regulatory status of various digital health products, such as Software as a medical device (SaMD), mobile medical applications (MMA), and General Wellness products.
Submissions for products with device software functions must include recommended documentation for the FDA's evaluation of safety and effectiveness.
For questions regarding upcoming premarket submissions, stakeholders are directed to contact the appropriate review division through a Q-submission.

Findings
Cytokine Release Syndrome (CRS) is a common and potentially life-threatening adverse event of immunotherapies, particularly in Oncology, complicating patient care and increasing healthcare costs. Standard-of-care inpatient monitoring for CRS is manual, intermittent, costly, and restrictive, providing an incomplete view of the syndrome’s development and progression. The use of Digital Health Technologies (DHTs) for continuous, remote monitoring of vital signs (like heart rate, respiratory rate, skin temperature, SpO2, and activity) can capture early indicators of CRS up to two hours earlier than standard episodic monitoring. This ability to collect multivariate continuous data is valuable for informing robust model development for CRS risk prediction.

Recommendations
Investigators should deploy DHTs available today to monitor vital signs and symptoms currently observed in the hospital setting, but in an outpatient or home environment. The goal is to develop Early Warning Products that assess the probability of developing CRS, providing clinical decision support. Product developers should follow a strategic roadmap that outlines milestones for building products that are clinically relevant and commercially viable. Researchers should use a common set of digital clinical measures to gather high-quality datasets and ensure comparability across studies to build more robust predictive models. Predictive algorithms should be built on a robust reference measure for analytical validation and be clinically validated with sufficient data.

Regulatory Considerations
The resources are designed to help developers build products that are clinically appropriate, regulatory-acceptable, and commercially viable. Future regulatory submissions for CRS de-risking products will benefit from aligning with this industry-wide dialogue that is being built in collaboration with the FDA. Developing a robust CRS safety biomarker could enhance the safety profile of clinical trials, increase trial access, and streamline regulatory decision-making, possibly through a qualification pathway. Products that aim for a higher level of autonomy, such as a Diagnostic that redefines current CRS grading classes, may require very high clinical evidence and likely stringent regulatory review.

Findings
Existing guidelines lack pragmatic application and systematic approach for device selection.
Device choice is dependent on measurement objectives, user population, and available resources.
Current frameworks do not systematically consider verification, validation, feasibility, and protocol design.
Rapid obsolescence of digital devices due to technological advancements.
Need to incorporate social/psychological factors into device selection.

Recommendations
Develop a practical guide with a systematic approach for selecting wearable devices.
Use five core criteria: continuous monitoring capability, device suitability and availability, technical performance, feasibility of use, and cost evaluation.
Prioritize feasibility of use to ensure user needs are incorporated into the selection process.
Adapt guide criteria to accommodate novel innovations.
Foster clarity and transparency in decision-making among researchers, HCPs, and device users.

Regulatory Considerations
Follow FDA guidance for digital health technology usage in clinical investigations.
Consider CTTI recommendations for improving clinical trial quality and efficiency.
Use ePRO Consortium's factors for device suitability in regulatory trials.
Apply international guidelines for specific measurements when available.

Findings
Challenges in patient adherence and acceptability of digital endpoints.
Issues with algorithm validation and use in diverse populations.
Barriers due to proprietary software and lack of transparency.
Vast heterogeneity in digital endpoints and lack of standards.
Need for ongoing ethical support and consideration of environmental impact.

Recommendations
Foster multi-stakeholder cooperation and open-forum discussions.
Integrate patient needs into the design of digital health technologies.
Include implementation science expertise in research proposals.
Develop standards for selecting and reporting digital endpoints.
Provide ongoing ethical support throughout the research lifecycle.

Regulatory Considerations
Early engagement with regulators is crucial.
Understanding regulatory requirements for clinical trials versus clinical care.
Need for harmonised terminology and guidelines for digital endpoints.

Findings
The Library of Human Factors Resources compiles external documents related to human factors, human-centered design, and usability in the context of Digital Health Technologies (DHTs), especially sensor-based DHTs (sDHTs). The resources in the library are categorized by usability validation activity:
Use-related risk assessment (topics include user tasks, use-errors, use-related hazards, and risk mitigation).
Design considerations (topics relate to product design).
Formative evaluation (topics related to usability evaluation of a prototype product).
Summative evaluation (topics related to usability evaluation of a final-version or marketed product).

Recommendations
The page recommends that users, developers, and evaluators utilize the library's interactive index to find relevant documents to their DHT:
Use the Search by Activity tab to filter by one of the usability validation activities listed above.
Use the human factors topic column to further narrow the search.
Review the document name, issuing body, and product of focus columns to identify the most relevant document.
Click the hyperlink to access the selected document, then use the information in the relevant sections column to locate the specific topics of interest.

Regulatory Considerations
The library is a collection of resources for accelerating sDHT adoption, and it specifically includes documents like regulatory guidance and industry standards. This emphasizes the importance of understanding and applying human factors principles for validation and achieving regulatory acceptance for sDHTs.