SAMD (Software as a medical device): Examples and Trends

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SAMD (Software as a medical device): Examples and Trends

Table of contents

  1. What is Software as a Medical Device?
  2. Examples of Software as a Medical Device
  3. Benefits of Software as a Medical Device
  4. Difficulties in using software as a medical device
  5. FDA Regulation of SaMD
  6. SaMD at the market
  7. App development company
  8. Conclusion
  9. Final Words


In today's rapidly evolving technological landscape, software has found its way into various sectors, including medical care. 

Now software is innovating diagnostic methods, improving the way treatments are applied, and as a result it gives more opportunities to people when it comes to dealing with health problems. Software itself is becoming a product, known as Software as a Medical Device (SaMD).

SaMD is designed for medical use, and it works independently of a hardware medical device. Here we are going to find out what SaMD is, provide examples of its applications, discuss its benefits, carefully examine the fundamentals of legislation by the FDA, highlight market statistics and key functionalities, examine the development costs, explore monetization strategies, advise tips for choosing an app development company, give answers to frequently asked questions, and conclude with final thoughts on the subject.


What is Software as a Medical Device?

According to Software as a Medical Device (SaMD) denominates software that performs medical functions, provides clinical data and aids in coming to right decisions regarding health. It is meant for autonomous use, separately from hardware device. SaMD includes programs from mobile health applications to complex algorithms that analyze medical data and provide diagnostic insights.


Examples of Software as a Medical Device

a) Health Monitoring Apps: Mobile applications that track signs of life, sleep patterns, exercise routines, and give individualized medical recommendations.

b) Diagnostic Tools: Algorithms that analyze medical images, as for example X-rays or MRIs, to detect abnormalities or assist in diagnosis.

c) Clinical Decision Support Systems: Software that integrates information about patients and medical guidelines to help health workers to arrive to good decisions regarding diagnoses and treatment guidelines.

d) Telemedicine Platforms: Web or mobile applications that enable health counsel and patient care over a distance.

e) Personalized Treatment Apps: Software that exploits intra-patient information to recommend individual medical care programs and medication management.

Not every piece of software used in healthcare facilities or hospitals is a SaMD. Examples of goods that the FDA does not classify as SaMD include as follows:

  1. Software that controls the motors and pumping actions of an infusion pump
  2. software for controlling an implantable pacemaker
  3. software for transmitting encrypted data from medical devices
  4. software for registering patients, making voice and video calls, and arranging appointments
  5. software that keeps track of medical equipment performance for maintenance purposes.

Benefits of Software as a Medical Device:

a) Improved facility of access: SaMD makes it possible to use medical services from a distance, thus saving time and energy on receiving face-to-face appointments.

b) Ameliorated Performance Capability: SaMD streamlines healthcare processes, therefore steps like malady recognition, medical therapy and solution taking process take less time.

c) Personalized Care: With SaMD, medical professionals can tailor therapeutic settings to every person depending on their unique characteristics and information about the health condition.

d) Continuous Monitoring: SaMD makes it possible to control health signs and conditions of a patient in real time, facilitating early intervention and preventive care.

Therefore, as a result:

a) Patients can manage their own health more actively. For instance, individuals with asthma can utilize data from smart sensors to pinpoint and steer clear of flare-up causes.

b) When it comes to making medical diagnosis and earlier disease detection, potent SaMD tools may even surpass skilled clinicians. For instance, a research team from Google Health and Imperial College London developed an AI model that has been shown to be more accurate than clinicians at detecting breast cancer from mammograms.

c) Software developers may quickly iterate on a product and promote innovation thanks to SaMD products. Quick data collection and user feedback from developers speeds up the feedback loop and time to market.


Difficulties in using software as a medical device.

Additionally, SaMD products present a number of difficulties for users, regulators, and developers. Several of these difficulties include:

a) Creating items may take developers longer than usual. The current product development techniques have become more sensitive due to patient safety and regulatory issues.

b) Regulators must balance protecting patient safety with fostering innovation. Companies may be discouraged from making investments in innovative products if laws are too onerous, but authorities cannot jeopardize patient safety.

c) SaMD product consumers and developers are at danger due to cybersecurity flaws. Attackers may compromise products, take private information, and interfere with the operation of software.


FDA Regulation of SaMD

The FDA regulates SaMD according to risk grading. They assess factors like intended use, functionality, and possible influence on patient safety. SaMD may qualify for Class I (low risk), Class II (moderate risk), or Class III (high risk). Compliance with FDA regulations guarantees the reliability and high performance level of SaMD before it reaches the market.


Difficulties at regulating SaMD

It has become a fact that for the FDA controlling SaMD is rather difficult. 

Let’s have a look at the most common challenges FDA faces today:

Constant upgrades:

The government is accustomed to examining medical equipment that stay unchanged by their producers after being placed on the market, which is one explanation. For example, a stent approved by the FDA is inserted into the patient without altering any of its properties. SaMD, however, operates differently. Whether it's security upgrades, new functions, or product evolutions, software developers can constantly change their products. Should the FDA first approve each of these changes? Depending on whether developers file a 510(k) application, self-register, or a Premarket Approval (PMA) application, the FDA can require as long as eight months to approve medical devices.

The FDA realizes that holding up the approval process for products can harm consumers and manufacturers. The FDA warns that taking too long to approve updates for SaMD products may hinder patients from accessing vital technology according to its Digital Health Innovation Action Plan.

Lack of developers’ experience:

Many SaMD developers haven’t got enough experience when it comes to working with the FDA. According to studies, it requires approximately three to seven years to sell a medical gadget. As a result of their difficulties with having their goods approved and deployed on schedule, inexperienced developers may become disillusioned and stop working on SaMD products. Products that pose medium- to high-risk levels to patients' health may require an evaluation process that is more thorough.

Cyber saferty:

SaMD gadgets can continuously collect medical information including body temperature, heart rate, lab results, and more. Therefore, these goods and the patient data they contain need to be adequately safeguarded against possible cybersecurity attacks. For instance, in the U.S. alone in 2021, internet attacks revealed approximately 40 million patient records. The development of SaMD products and procedures should also adhere to HIPAA regulations. Neglecting to do so might give hackers access to private data, subjecting healthcare providers to heavy fines and perhaps jail time.


FDA draft guidance

The FDA published a draft of their proposed guidance on premarket filings regarding SaMD and SiMD products in November 2021. In February 2022, the agency finished collecting comments on this recommendation. The FDA issued Guidance on the Content of Premarket Submissions for Software Contained in Medical Devices in May 2005. The final guidance is expected to be delivered within a year of the conclusion of the comment period.

Risk level evaluation.

A risk-focused approach regarding the paperwork stage, which can be basic or advanced, is laid out in the draft. Products will be divided into four categories by the FDA. Products in the Level I and Level II categories, such as a stress evaluating app that doesn't offer a diagnosis, have the least negative effects on the safety of patients or public health and only call for minimal documentation. Software Developers of Level III and IV products, for instance, software that tracks and analyzes blood pressure and heart rate data in intensive care units, will need to submit expanded documentation for their premarket applications because failure to do so could result in patient death or serious injury. If items are meant for being employed in testing for transfusion-transmitted illnesses in blood, more thorough documentation is also required.

Required documentation.

Product developers are required to produce different sorts of documents depending on the degree of their documentation, such as:

  1. A list of the features in software
  2. Detailed schematics</li >
  3. Data flow to enable user involvement</li >
  4. Plan for managing risks</li >
  5. History of revisions</li >
  6. A list of open bugs</li >

The suggested legal structure represents a significant improvement in the FDA's perspective on SaMD and SiMD products. However, when drafting their premarket proposals, product developers can refer to other sources. For instance, the IMDRF has made available a number of resources on important concepts, a framework for categorizing risks, Quality Management Systems, and the medical assessment of SaMD products.


FDA’s prospects about regulating of medical devices with an AI/ML focus

The FDA published a discussion paper in April 2019 that outlines potential premarket review strategies for SaMD products that are powered by AI/ML. The government wants to enhance the premarket review process it now uses, which calls for numerous software improvements.

Change control plan

The discussion paper's concept is built on the idea of a "predetermined change control plan." Companies will need to explain how an algorithm is to learn while still being safe to use, as well as how certain parts of a product may change as a result.

The FDA would demand that developers continuously examine their SaMD products under this paradigm. They would also be required to give the agency regular reports on the modifications made in accordance with the protocols and specifications that had been authorized.

Five-point action plan

SaMD product developers gave FDA comments on its discussion paper. As a result of this, the agency has created a five-point action plan to help it do a better job of regulating SaMD products that are based on AI/ML from 2022 and afterward. The following actions are part of the plan:

  1. Updating the suggested framework for regulating SaMD products based on AI/ML
  2. Encourage IT communities to abide by the principles of Good Machine Learning Practice (GMLP)
  3. Promote openness in how businesses label and advertise SaMDs powered by AI/ML
  4. Encourage the development of techniques for detecting and removing algorithmic bias.
  5. Clarify the way SaMD developers should keep track of the efficiency of their goods in real-world settings.

Principles of Good Machine Learning Practice for SaMD-based AI/ML products

Ten principles that can direct the development of GMLP have been recognized by the FDA, Health Canada, and the UK's Medicines and Healthcare Products Regulatory Agency (MHRA). These ideas are as follows:

  1. A diverse team will develop the products.
  2. Product teams adhere to best practices for software development
  3. The intended patient population should be reflected in the study's participants and results.
  4. Product teams will choose and maintain separate test and training data sets.
  5. Companies will create a reference dataset using the best techniques currently available.
  6. The product is designed by the creators to assist users in accomplishing the stated aim.
  7. When appropriate, the effectiveness of the human-AI team will be the main focus.
  8. The product is put through medically relevant testing by the developers.
  9. Users are provided with clear instructions on how to utilize the product.
  10. Product teams will keep an eye on the performance and dangers of deployed products.

Following the above FDA-endorsed recommendations can make it simpler for SaMD developers to obtain approval from the FDA for medical devices, even if they are not a requirement for SaMD developers to follow.


Being aware of modifications to regulation

SaMD products have a promising future. Software has the potential to enhance the detection and treatment of many diseases as well as provide individuals more control over their own health. Additionally, the data that these goods collect may speed up innovation and enhance algorithms.

But the safety of patients and medical effectiveness shouldn't be compromised in the name of innovation. The FDA is working harder to prevent this from happening. The agency has made available a number of draft best practices and guidance documents, which will be further considered in 2022 before becoming regulations. SaMD businesses must keep up with these advances. Entrepreneurs who are well-informed can plan future creative ventures better and get their items FDA-cleared more quickly.


SaMD at the market

SaMD Market Stats:

According to industry reports, the SaMD sales is experiencing significant growth, with increasing adoption across healthcare organizations. The market is anticipated to reach billions of dollars by the end of the decade, driven by technological advancements, rising demand for medical consultation from a distance and for efficient and accurate diagnostics.

Key SaMD Functionality:

a) Information Evaluation and Processing: SaMD utilizes complex patterns to process health condition data and provide a picture with valuable information.

b) Decision Making Support: SaMD assists medical staff in coming to carefully weighed decisions by providing evidence-based recommendations.

c) Monitoring and Tracking: SaMD allows to regularly control patient’s condition, facilitating timely delivery of individualized care.

How Much Does It Cost to Develop SaMD?

The development cost of SaMD depends on various factors, including complexity, functionality, code requirements, and the development team's expertise. It typically involves expenses related to software design, development, testing, regulatory compliance, and ongoing maintenance. Costs can range from tens of thousands to millions of dollars.

How to Monetize Your App?

Monetization strategies for SaMD can include upfront purchases, subscription models, in-app purchases for additional features or data, or partnerships with healthcare providers for integration into their services. The choice of monetization model should align with the target market, value proposition, and long-term sustainability.


App development company

How to Choose an App Development Company?

When selecting an app development company for SaMD, factors such as experience in healthcare software development, compliance with regulatory standards, understanding of security and privacy requirements, and a track record of successful projects should be considered. Thoroughly evaluating portfolios, client testimonials, and engaging in detailed discussions can help make an informed decision.

Cost estimation at Magora and Case Studies

The Average Cost Breakdown May Look like this:

Defining a product, strategy and reachable minimum expectations - 16 hours

UX and visual design - 64 hours

Programming - 80 hours and QA - 24 hours

Release - 16 hours

Total - 200 hours

As you can see, a "primary" application takes 5 weeks of work (excluding preliminary conversations). Development organizations put the cost at between £500 and £1,000 a day. For a 25-day project, the budget is £12,000 to £25,000. The same project carried out at Magora will cost about £10,000. Adding additional functions and skills obviously requires more time from everyone involved and costs will increase accordingly.

Frequently Asked Questions:

This section can address commonly asked questions regarding SaMD: normative requirements, data privacy, interoperability, and possible hazard when it comes to exploitation of medical software.



Software as a Medical Device (SaMD) has emerged as a transformative force in medical service, offering numerous benefits in terms of accessibility, efficiency, and personalized care. With the growing demand for remote healthcare solutions, SaMD presents substantial market potential. However, careful adherence to regulatory frameworks, choosing the right development partner, and implementing robust monetization strategies are essential for success in this rapidly evolving landscape. By leveraging SaMD, healthcare can be revolutionized, providing advanced productivity and better patient feedback.


Final Words

While technology keeps developing, the importance of SaMD in medical service will only expand. Its capacity to improve diagnostic assessment, medical therapy and attendance, holds tremendous promise. By embracing SaMD responsibly, medical staff and software developers can collaboratively shape a future where technology and medicine converge to create a healthier and more connected world.


And if you need some development support, here are links to some of our services:


Need more information about our services? Here are some links:

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Healthcare Software Development Full Guide

Healthcare App Development: The Ultimate Guide

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Marketing and Business Development Manager
Meet Andrey - Marketing and Business development manager at Magora! With a keen eye for market trends and a knack for relationship-building, Andrey spearheads initiatives that propel Magora to the forefront of innovation and success in the tech industry.
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