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38     CHAPTER 2 Analytical performance of SMBG systems




                         of study design, this study evaluated meter analytical performance against the then-
                         latest widely accepted BGM accuracy standard, which was the ISO 15197:2013
                         guideline.
                            To further reduce the risk of bias, the study was triple-blinded such that in-clinic
                         BGM operators did not know plasma reference measurements, the reference lab did
                         not know BGM readings, and the data analysis team worked only with BGMs desig-
                         nated by a code number that blinded the identity of the BGMs whose accuracy was
                         being assessed.
                            Every subject had a capillary BG level reading measured by six different BGM
                         devices (in random order), three before and three after a simultaneous reference
                         capillary sampling was performed. Each of the three sites tested all 18 FDA-
                         approved BGM systems by testing a new set of six BGMs across three separate
                         studies in a round-robin fashion. 1032 of 1035 subjects completed the study, and
                         each BGM was tested on 115 subjects, on average. The average number of strip
                         lots per study was 2.1.
                            Of the 18 meters that were evaluated, only six (33%) met the predetermined
                         accuracy standard in all three studies; five met it in only two studies; two met it
                         in only one study. This left four FDA-cleared BGMs that did not meet the ISO
                         15197:2013 standard in any of the three studies.
                            In November 2018, the FDA released a statement promising to establish an alter-
                         native 510(k) approval “Safety and Performance Based Pathway” evaluated on
                         objective safety and performance criteria rather than on a predicate device [15].
                         This new approval process could potentially give the FDA more flexibility to
                         respond swiftly to safety concerns that arise and perform postmarket surveillance
                         through programs such as the recently announced National Evaluation System for
                         Health Technology [16].




                         Advances in analytical performance of SMBG devices
                         The previously mentioned 2018 review article [14] determined that newer BGMs
                         were statistically significantly more likely to meet both the ISO 15197 2003
                         (OR 1.06, CI 1.06e1.07, P <.001, odds ratio reported for a 1-year period) and
                         ISO 15197 2013 guidelines (OR ¼ 1.06, CI 1.03e1.06, P < .01, odds ratio reported
                         for a 1-year period). Which advances in technology best correlate temporally with
                         this improved analytical performance in more recently developed BGMs?
                            Pfutzner proposed that several technological advances in BGMs contribute to the
                         improved analytical performance in more recently developed BGMs [17]. First,
                         device manufacturers have been able to eliminate hematocrit interference by using
                         mathematical correction algorithms that have been refined over the course of time.
                         In addition, changes in test strip chemistry, changes in electrode design, and other
                         algorithmic improvements have contributed to improved accuracy in newer meters.
                            When analyzing the test strip enzyme in meters over time and their analytical
                         performance, King and colleagues demonstrated that glucose dehydrogenase
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