Andrew,

> As far as I know, medical record systems are not medical devices!! Is this
> contrary to anyone's understanding?
It is contrary to my understanding of the respective German
law.

I understand that there is a fine line whether or not it
applies. Let me give an example:

As long as the system uses its drug database solely for
letting doctors select drugs for a prescription without giving
any further information about them (like a specialized word
list) it wouldn't be considered a medical device. However, as
soon as the system starts supporting the medical decision making
process (be that by suggesting equivalent drugs of lower price,
be it by cross checking patient allergies/gravidity/drugs, be it
by offering advice on dosage based on age/weight etc.) it
would then be considered a medical device.

It can be argued, of course, whether the medical _record_
system in toto needs to meet the FDA specs or rather just the
medically-augmented prescription application.

Karsten
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