Implementation of High-Sensitivity and Point-of-Care Cardiac Troponin Assays into Practice: Some Different Thoughts

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Implementation of High-Sensitivity and Point-of-Care Cardiac Troponin Assays into Practice: Some Different Thoughts
Clinical Chemistry 00:0
1–9 (2020)                                                                                                                              Mini-Reviews

    Implementation of High-Sensitivity and Point-of-Care
    Cardiac Troponin Assays into Practice: Some Different
                         Thoughts
     Fred S. Apple,a,* Corinne R. Fantz,b and Paul O. Collinsonc, on behalf of the IFCC Committee on Clinical
                                       Application of Cardiac Bio-Markers†

BACKGROUND:      The primary role of the International                                       hs-cTnT assays (Fig. 1) is found on the IFCC C-CB
Federation of Clinical Chemistry (IFCC) Committee on                                         website (4). This mini-review regarding hs-cTn assays 1)
Clinical Application of Cardiac Bio-Markers (C-CB) is to                                     highlights new IFCC C-CB/AACC Academy laboratory
provide educational materials about cardiac biomarker use,                                   practice recommendations; 2) addresses new/updated con-
emphasizing high-sensitivity cardiac troponin assays.                                        cepts from the Fourth Universal Definition of Myocardial
                                                                                             Infarction (UDMI) recommendations; 3) discusses role
CONTENT: This mini-review, regarding high-sensitivity                                        of point-of-care (POC) assays in practice; 4) identifies
cardiac and point-of-care troponin assays, addresses 1)                                      regulatory challenges concerning POC assays.
new IFCC C-CB/AACC Academy laboratory practice
recommendations; 2) new and updated concepts from                                            IFCC C-CB/AACC Academy Laboratory
the Fourth Universal Definition of Myocardial                                                Practice Recommendations for hs-cTn
Infarction; 3) the role of point-of-care assays in practice
and research; 4) regulatory challenges concerning point-                                     Consensus recommendations by the AACC Academy,
of-care assays; e) testing in the COVID-19 world.                                            in collaboration with the IFCC TF-CB, address conver-
                                                                                             sion of contemporary assays to hs-cTn. Expert opinion
SUMMARY:     Implementation of high-sensitivity cardiac                                      clinical laboratory practice recommendations for hs-cTn
troponin assays makes a difference now and into the                                          assays focused on 10 topics: 1) quality control (QC)
future in clinical practice and research. Providing point-                                   utilization; 2) validation of lower reportable analytical
of-care high-sensitivity cardiac troponin assays and                                         limits; 3) units used in reporting measurable concentra-
optimizing studies to allow clearance of these assays by                                     tions for patients and QC materials; 4) 99th percentile
regulatory agencies, in a timely fashion, may provide im-                                    sex-specific upper reference limits (URLs); 5) criteria
proved patient management and outcomes.                                                      required to define hs-cTn assays; 6) communicating
                                                                                             with and educating clinicians regarding preanalytical and
How to implement high-sensitivity cardiac troponin                                           analytical problems that confound results; 7) how authors
(hs-cTn) assays in practice is not a harmonized process                                      need to document analytical assay details in hs-cTn studies;
(1). The International Federation of Clinical Chemistry                                      8) harmonizing assay results and commutable materials; 9)
(IFCC) Committee on Clinical Application of Cardiac                                          time to reporting of results from sample collection to re-
Bio-Markers (C-CB) provides educational materials                                            ceipt; 10) changes in serial hs-cTn concentrations over
about cardiac biomarkers, emphasizing hs-cTn assays                                          time and role of biological variation in interpreting results.
(2, 3). Growth of regulatory clearances for hs-cTnI and                                      New practices, shown in Table 1, include using QC at
                                                                                             sex-specific URLs, emphasizing not to perform an under-
                                                                                             powered study to establish an URL, role of appropriate sta-
                                                                                             tistics to define 99th percentiles, importance of limit of
                                                                                             detection (LoD) in defining hs-assays measuring 50% of
a
 Department of Laboratory Medicine and Pathology, Hennepin County Medical Center of          normal males and females individually (not combined),
 Hennepin Healthcare and University of Minnesota, Minneapolis, MN; bMedical and
 Scientific Affairs - POC, Roche Diagnostics Corporation, Indianapolis, IN; cDepartment of    and reporting hs-cTn results with whole numbers, desig-
 Clinical Blood Sciences and Cardiology, St George’s University Hospitals NHS Foundation     nated ng/L, to distinguish from contemporary assays.
 Trust and St George’s University of London, London, UK.
*Address correspondence to this author at Hennepin Healthcare/Hennepin County
                                                                                                   A recent study determined overall and sex-specific
 Medical Center, Clinical Laboratories P4, 701 Park Ave, Minneapolis MN 55415. Fax           99th percentiles in 9 hs-cTnI and 3 hs-cTnT assays
 612-904-4229; e-mail apple004@umn.edu.                                                      using a universal sample bank screened by health ques-
 †
   IFCC C-CB Members: Fred S. Apple (Chair), Richard Body, Ola Hammarsten, Pete A.           tionnaire and surrogate biomarkers (5). Subjects were
 Kavsak, Carolyn S.P. Lam, Amy K. Saenger; Consultants: Allan S. Jaffe, Paul O.
 Collinson, Torbojn Omland, Jordi Ordó~nez-Llanos                                           age, ethnic, and racially diverse. Overall and sex-specific
Received July 7, 2020; accepted October 12, 2020.                                            99th percentiles showed substantial differences between
DOI: 10.1093/clinchem/hvaa264                                                                and within both hs-cTnI and hs-cTnT assays. Men had

C American Association for Clinical Chemistry 2020. All rights reserved. For permissions, please email: journals.permissions@oup.com.
V                                                                                                                                                        1
Mini-Reviews

Roche hs-cTnT         Abbott hs-cTnI        Roche Gen 5            Siemens hs-cTnI: CE, FDA          Ortho hs-cTnI: CE
CE Mark               CE Mark               FDA                    Beckman hs-cTnI: CE, FDA          Abbott hs-cTnI: FDA
                                                                   ET Healthcare hs-cTnI: cFDA

2007                 2013                   2017                           2018                      2019                  2020

  Fig. 1. Representative timeline for regulatory clearance for clinical use of hs-cTn assays.

       Table 1. New and updated IFCC C-CB and AACC Academy recommendation for practice utilizing high sensitivity cardiac
                                                      troponin assays.

 1. Quality control materials need to be implemented at concentrations consistent with both the male and female sex-
    specific upper reference limits.
 2. Quality control materials should be considered at concentrations consistent with the limit of detection (LoD) of each
    hs-cTnI and hs-cTnT assay to provide ongoing confidence when used for rule out protocols.
 3. Avoid implementing upper reference limits that use underpowered subject numbers to establish 99th percentiles.
 4. Appropriate statistical analyses to define 99th percentiles include the non-parametric and Harrell Davis methods, with
    the Robust method not acceptable.
 5. High sensitivity assays are now defined base on measuring 50% of normal males and 50% normal females individu-
    ally, not combined.
 6. Beware of contemporary assays that report results using whole numbers, designated ng/L, that are only designated
    for high sensitivity assays.

higher 99th percentiles than women (Fig. 2: A-cTnI; B-                 UDMI assists clinicians in a common focus on how to
cTnT). Both overall and sex-specific 99th percentiles                  utilize biomarkers in alignment with IFCC C-CB and
varied according to statistical method and assay used.                 AACC Academy guidelines (7). First, it recommends
Not all assays provided a high enough percentage of                    myocardial injury be used when there is evidence of
measurable concentrations in women to qualify as hs-                   increased cTn with at least one value above the 99th
assays, and the surrogate exclusion criteria used to define            percentile sex-specific URL (3). Myocardial injury is
normality tended to lower the 99th percentiles.                        considered acute with a rise and/or fall of cTn between
      Following a meeting between US laboratory medi-                  serial samplings. Fig. 3 shows representative myocardial
cine, emergency medicine, and cardiology biomarker                     injury. Complexity of clinical circumstances may make
experts and FDA, guidelines for uniform analytical and                 it difficult to discriminate specific individual mecha-
clinical standards for studies performed by manufacturers              nism(s) of injury. Second, greater attention was placed
seeking cTn 510k assay clearance were published (6).                   on recognition of type 2 MI, defined in settings with ox-
Recommendations addressed 1) number of reference                       ygen demand and supply imbalance unrelated to acute
individuals for determination of 99th percentiles; 2) limit            coronary thrombosis (8). If myocardial injury is not
of quantification; 3) total imprecision requirements; 4)               acute and related to chronic structural heart disease, se-
enrollment of subjects for diagnostic studies; 5) patient              rial cTn values may be stable and unchanging. Third,
adjudication processes; and 6) clinical end points and out-            cTnI and cTnT remain standard biomarkers for ruling
comes. The focus was to ensure common protocols applied                in/out MI and myocardial injury. cTn release into the
to hs-cTn assays. Unfortunately, published recommenda-                 circulation is dependent on blood flow around injured
tions were not endorsed by the FDA.
                                                                       myocardium, and kinetics of increasing, peaking, and
Recommendations of Fourth Universal                                    falling values are assay dependent (9) since cTn assays
Definition of Myocardial Infarction                                    are not standardized. Utilizing hs-cTn assays, most rule
                                                                       in/rule out decisions are made within 3 hours of initial
For global harmonization of care in patients presenting                sampling, based on assay-dependent algorithms (10).
with symptoms suggestive of myocardial injury, the                     Fourth, analytical sensitivity provided by hs-cTn assays

2 Clinical Chemistry 00:0 (2020)
Implementation of High-Sensitivity and Point-of-care

A

B

    Fig. 2. Men have higher 99th percentile URLs for multiple hs-cTnI (A) and cTnT (B) assays compared to most women.
    Reproduced with permission from Apple et al. (5).

is critical for early rule out and assists in defining assay   measure normal subjects above the LoD in 50% of
dependent deltas. Recommendations emphasize that               measurements in both males and females, separately (2,
clinicians become educated about details of the specific       3), differentiating hs assays from contemporary and
assay used in their practice. Fifth, the UDMI supports         POC assays that are generally analytically and clinically
IFCC guidelines for defining hs-cTn assays based on            inferior for diagnostic use and unable to define biologi-
imprecision (10%CV at sex-specific URL) and ability to         cal variation (1).

                                                                                   Clinical Chemistry 00:0 (2020) 3
Mini-Reviews

  Fig. 3. Conceptual model for myocardial injury and myocardial infarction. Reproduced with permission from Sandoval and
  Thygesen (8).

CLINICAL ROLE OF POC TESTING IN ERA OF LABORATORY HS-           methods with comparable analytical sensitivity to those
CTN                                                             in the central laboratory at the time trials were per-
Rationale for POC testing The basic assumption for use          formed; using diagnosis based on exceeding a diagnostic
of POC testing is that rapid provision of results will          cutoff in use or the 99th percentile. Although these
have a direct impact on clinical decision-making.               studies support a role for POC testing, they are not
Evidence is limited. Randomized controlled trials               compatible with current clinical diagnostic strategies.
comparing POC with central laboratory testing are sum-          Two key requirements for any study are that POC test-
marized in Table 2 (11–15), showing inconsistent                ing has 1) comparable analytical performance with the
results. Some studies demonstrated a clear improvement          central laboratory cTn assay, which is now hs-cTn, and
in outcome as judged by treatment impact or length of           2) provision of test results is demonstrably the rate-
stay, while some had no impact. One consistent finding          limiting step in the diagnostic pathway.
is that to have impact on clinical decision-making, bio-
marker measurements had to be integrated within a de-           CLINICAL DECISION-MAKING IN ERA OF HS-CTN AND RAPID
fined clinical pathway. A detailed analysis of the patient      DIAGNOSTIC ALGORITHMS
flow within the Randomized Assessment of Treatment              Introduction of hs-cTn assays into routine clinical prac-
using Panel Assay of Cardiac Markers trial revealed clear       tice has led to a transformation in the way cTn measure-
differences between length of stay directly due to the          ments are used in decision making. No longer are
clinical pathways being used in different hospitals (16).       diagnostic pathways based solely upon serial sampling
A systematic evidence-based review of POC testing               over a 6 (or more) hour period post admission until
identified the need for integration of POC within the           the value exceeds the 99th percentile with a significant
decision-making pathway as a key requirement to dem-            change between consecutive measurements (delta value).
onstrate benefit (17). Studies utilized cTn POC                 Diagnostic pathways now exploit 2 key features of hs

4 Clinical Chemistry 00:0 (2020)
Implementation of High-Sensitivity and Point-of-care

                           Table 2. Clinical trials of point-of-care testing predicated on cardiac troponin monitoring.

  Type                               Methodology                    Diagnosis               Outcome measure                         Result                     Author

  Single center RCT –             Roche cTnT CLT             Troponin testing               Duration of                 Positive—Reduced                   Collinson
    CCU admissions                  vs. POCT                   at 12 hours from              length of stay               LOS for non-CCU                   et al. (11)
                                                               admission.                    (LOS).                       and total hospital
                                                               Diagnostic cut                                             stay in pre-specified
                                                               off 0.2 mg/L                                               rule out group.
  Multicenter RCT in              iSTAT cTnI vs.             Serial testing over            Time to dis-                Inconclusive – the                 Ryan
   the ED                           central                    6 hours or serial              charge home                 bedside troponin                   et al. (12)
   Disposition                      laboratory                 testing at 8-                  or transfer to              group had varying
   Impacted by                      cTnI                       12 hours (1 site)              inpatient care              and inconstant
   Serial Point-of-                                                                                                       changes in ED
   care Markers in                                                                                                        length of stay
   Acute Coronary                                                                                                         compared with the
   Syndromes                                                                                                              central laboratory
   (DISPO-ACS)                                                                                                            group. Reduction in
                                                                                                                          one site and in-
                                                                                                                          crease in another
  Single center RCT               Stratus CS vs.             Testing post ran-              Time to treat-              Positive—Reduced                   Renaud
    in the ED                       Dimension                  domization.                    ment Length                 time to commenc-                   et al. (13)
                                    RxL                        Protocol not                   of stay in the              ing anti-ischemic
                                                               stated.                        ED                          treatment No re-
                                                               Diagnostic cut                                             duction in ED stay
                                                               off 0.1 mg/L
  2 Center Cluster                iStat vs.                  Protocol not                   Length of ED                Inconclusive –                     Loten
    randomized con-                  Beckman                   stated                         stay                        Reduced LOS but                    et al. (14)
    trolled trial in the             Coulter Accu I                                                                       not significant.
    ED. One center                                                                                                        Increased propor-
    did not have                                                                                                          tion of patients dis-
    24 h on site                                                                                                          charged
Mini-Reviews

diagnostic algorithms (22). Support for rapid diagnosis       POC technologies, will hopefully provide diagnostic
based on hs-cTn algorithms underwent systematic re-           data to be utilized in practice soon.
view by the UK National Institute for Health and Care
Excellence (23). When admission measurement exceeds           ROLE OF CTN POC TESTING
the 99th percentile, serial testing needs to be carried out   cTn POC testing does have a clinical role, but it is com-
to determine whether myocardial injury is acute (rising       plimentary to hs-cTn laboratory measurements. When
pattern) or chronic (static, flat pattern) to allow appro-    timely access to laboratory facilities for decision-making
priate triage, and may require a further 6-hour sample.       is not possible, POC testing may be a solution. This is
     Rapid diagnostic algorithms seem to be ideally           particularly the case in rural healthcare where sample
suited for POC testing. The absolute caveat is cTn            transportation time may impact turnaround time and
POC testing must demonstrate high-sensitivity analyti-        where the decision to move a patient to a more central-
cal performance. Currently, the majority of POC cTn           ized facility, which performs intervention, may require a
assays have, at best, performed as contemporary assays.       long land journey or air evacuation. POC cTn measure-
Such systems are perfectly adequate for ruling in myo-        ment has been shown to significantly improve manage-
cardial injury but require repeat sampling, typically at 3    ment of patients with suspected acute coronary
to 6 hours post admission, to achieve adequate clinical       syndromes in the rural Australian environment (33). In
sensitivity for rule out. Admission measurement of cTn        the Randomized Assessment of Treatment using Panel
by POC may in fact be diagnostically inferior to an           Assay of Cardiac markers trial, with a contemporary
admission risk score alone (24). When sampling over           POC assay and diagnosis based on the 99th percentile,
6 hours is compared with the possibility of immediate         measurements on admission and 90 min were diagnosti-
discharge based on a single measurement or the possibil-      cally accurate and safe in low risk patients. This study
ity of complete diagnostic categorization within 1–           did not evaluate single sample rule out, but did demon-
3 hours from admission, the advantages of central             strate serial testing performed well by POC. However,
laboratory-based hs-cTn assays are obvious, even with         there can be downsides with diagnoses missed by overre-
60-min turnaround time. Diagnosis within 1 to 3 hours         liance on test measurement which is insufficiently sensi-
of admission outweighs having to wait 3–6 hours by            tive (34). POC cTn limitations must be appreciated
POC testing, even where a whole blood sample can be           (potential for false negative results on admission because
used with results available in 10–15 min.                     lack of analytical sensitivity) and the need for repeat
                                                              testing (up to 6 hours) are built into the diagnostic
POC TESTING—ANALYTICAL VERSUS CLINICAL EVIDENCE               protocol for rule out. However, a positive test by POC
Independent analytical validation of performance claims       testing would allow immediate patient characterization
of a putative hs-cTn POC assay is important, but is           and expedite management (35). There are risks if POC
only the background to clinical implementation and            and central laboratory testing are mixed within a single
use. POC testing must have the ability to permit imme-        health system. Degradation of diagnostic sensitivity
diate safe discharge by single sample rule out or support     may occur as a result of attempting to harmonize differ-
a rapid diagnostic, serial testing algorithm. The majority    ent assays by arbitrarily matching diagnostic cut offs
of POC assay studies claiming comparability to a hs-          (36) since cTn assays are neither standardized or
cTn assay for diagnostic clinical utility and adverse out-    harmonized.
comes (25, 26) have not been performed appropriately.
POC assay studies that evaluated rapid rule out algo-         POC REGULATORY INNOVATION     & REGULATION
rithms utilized stored, plasma samples, not fresh ‘whole      Innovation and investments in research and develop-
blood, which will be required for a universally, accept-      ment have led to disruptive technologies that fundamen-
able validation’ (27–29). To date, there have been no         tally change patient management and/or yield
whole blood or prospective studies, either observational      incremental improvements in assay performance (37).
or randomized controlled trials, that have demonstrated       Innovations must prove their value before there can be
that POC testing with high sensitivity analytical perfor-     widespread acceptance with stakeholders (physicians,
mance is clinically reliable, safe, and confers patient       regulators, payers). Potential harm when introducing
benefit. This is in contrast with central laboratory hs-      new products to market is real, and regulatory bodies
cTn methods, demonstrated by meta-analysis of trials          are tasked with ensuring safety and efficacy of devices.
(30, 31). While one assay (Pathfast) has FDA clearance              It took nearly a decade after regulatory clearance
for POC with preliminary data that meets hs-criteria          outside the USA, supported by numerous publications,
along IFCC guidelines (32), in practice users of this         for manufacturers to convince the FDA that hs-cTn
large instrument are often laboratorians and not desig-       tests were not only more analytically sensitive than con-
nated POC operators. Several novel, in development            temporary and POC assays but also safe and effective

6 Clinical Chemistry 00:0 (2020)
Implementation of High-Sensitivity and Point-of-care

for patient care. To remedy this, the 21st Century             providers (nurses, clinicians, residents, technologists),
Cures Act, signed into US law in 2016, is designed to          rarely would a CLIA-waived operator with another job
help accelerate medical product development and bring          class know what to do with these results unless driven
new innovations and advances to patients who need              by protocol within the institution. Technology has
them faster and more efficiently (38). It provides new         advanced such that simplicity of testing is seldom a con-
authority to the FDA to 1) improve recruitment and re-         cern for these devices. Performing the testing in whole
tention of scientific, technical, and professional experts,    blood with limited knowledge on the part of the end
2) receive alternative sources of data for regulatory          user, and little to no interaction with calibration and
approvals such as real-world evidence, provided ade-           quality control is a baseline expectation for POC devi-
quate quality of the data are maintained and 3) establish      ces. Manufacturers are tasked with demonstrating that
new expedited product development programs, includ-            typical end users can perform testing and results are
ing the Breakthrough Devices program. This allows              comparable to a predicate device. For POC hs-cTn, the
opportunities for manufacturers to expand claims for           expectation is that manufacturers compare their POC
on-market devices if technologies exist to capture quality     device to a 510 K cleared laboratory cTn instrument.
real-world data. Introduction of In Vitro Diagnostic           Analytical precision, linearity, accuracy, and reportable
Medical Device Regulation is strengthening the over-           range need to be demonstrated because only quantita-
sight and review process in the European Union (39).           tive assays are recommended for hs-cTn (3). POC
Manufacturers of currently approved in vitro diagnostic        devices will need to establish their own 99th percentile
medical devices will have a transition time of 5 years to      URL studies. Diagnostic accuracy needs to be per-
meet the requirements of the In Vitro Diagnostic               formed, meaning analytical accuracy is not enough to
Medical Device Regulation. Some of the key changes             demonstrate safety and effectiveness for FDA clearance.
are more stringent documentation, rigorous clinical evi-       POC hs-cTn testing is expected to be validated no dif-
dence, and reclassification of devices according to risk.      ferent than a central laboratory method. However, in
      As technology advances, the ability to offer POC
                                                               the US, the FDA requirements for POC assay clearance
hs-cTn assays has been developed. New guidance from
                                                               are more difficult than a central laboratory method.
regulatory bodies demand manufacturers conduct their
clinical studies for registration in the intended care envi-
                                                               STRATEGIES FOR REGULATION GOING FORWARD
ronment or as similar to the intended care environment
                                                               Globally, 2 important questions must be considered: 1)
as possible (40). In the US, if a manufacturer desires to
                                                               are clinical studies still necessary if analytical validity can
achieve a CLIA waiver for a POC device, that device
                                                               be demonstrated from one platform to the next, and 2)
must be challenged in the environment where it will be
used and operated by typical end-users found in that           do matrix studies that demonstrate similar performance
environment. FDA studies are extremely difficult to exe-       with plasma and whole blood need to be repeated in
cute and are expensive because most applied research           fresh whole blood collections for POC studies? It is
sites prefer to provide dedicated research personnel, who      unclear what more regulation will bring in terms of cost,
qualify under CLIA as operators, to separate research          timelines, and innovation in relation to balance
from clinical staff. It is a misconception by the FDA          improvements in safety and efficacy of in vitro diagnos-
that research staff may not be under the same stressors        tic products.
as a typical end-user managing patient care aspects while            A regulatory system that allows well-characterized
performing testing. Yet, the FDA mandates these POC            tests to be evaluated for modifications to occur without
studies be performed by typical end-users (such as             having to submit new evidence of performance, waiting
nurses) who are responsible for routine clinical duties        years to bring the next generation test to market, is
rather than allow research personnel focused only on           needed. Trust in the system to allow for regulation with-
testing. This adds burden to nurses, in an already finan-      out stifling innovation could bring devices to market
cially stressed, FTE-short workplace, in the pandemic          more efficiently and safely. The ‘risk’ of bringing new
COVID-19 world hospitals are living through, and is            hs-cTn devices to market is substantially lower today,
not realistic.                                                 based on evidence-based analytical and clinical literature
      Currently, there are no CLIA-waived POC hs-cTn           amassed for known intended uses. Post market analysis
assays on the market. The challenge for cTn in                 can help serve to mitigate risks for new intended uses or
obtaining CLIA waiver lies with the interpretation and         incremental improvements over previous generations,
judgement aspects of testing. CLIA waiver requires the         without having to refile for new regulatory clearances.
operators to be able to run the test without formal train-     Being able to mitigate these risks with innovative
ing. The test must be designed so a lay person can run it      regulatory processes will balance the need for improved
with only the instructions packed in the kit and to be         products without compromising patient safety. Adverse
able to easily interpret the result. With the exception of     patient outcomes will be better predicted, with

                                                                                      Clinical Chemistry 00:0 (2020) 7
Mini-Reviews

improved patient management providing considerable                                              pandemic (review times days to weeks vs the normal
cost savings to hospitals and patients.                                                         months to years). We feel the FDA should also find
     We propose the FDA consider the following pro-                                             more efficient paths to 510k clearances. The FDA
cess for patient enrollments into manufacturers’ 510 K                                          should consider Emergency Use Authorization for novel
submissions.                                                                                    hs-cTnI and hs-cTnT POC devices and assays, without
1. Regulatory agencies, including the FDA, should write a
                                                                                                sacrificing quality during the COVID-19 pandemic.
   guidance document describing the minimal requirements                                        While it is understood that when the Emergency Use
   needed to submit for clearance as they have done for glu-                                    Authorization period is over, the test will require a 510k
   cose POC testing. With guidance, manufacturers would                                         clearance to remain on the market; this period would al-
   have more consistent study protocols, populations, and po-                                   low manufacturers the ability to collect data for 510k
   tential use of predicate devices. Presently, there is too much                               submissions. This would assist inner-city and rural pro-
   variation between study protocols, and the feedback manu-                                    viders to rapidly measure of hs-cTn, the cardiac bio-
   facturers receive is inconsistent.                                                           marker that makes a difference now and into the future;
2. Revise the inconsistent and biased enrollment of subjects                                    “the times they are a-changin’.”1
   identified in the ED using the IRB informed consent process
   based on new blood draws. This practice is time consum-
   ing, expensive, and misses over 70% of eligible patients                                     Nonstandard Abbreviations: hs-cTn, high-sensitivity cardiac tropo-
   who would qualify for enrollment, making the study popu-                                     nin; cTnT, cardiac troponin T; cTnI, cardiac troponin I; IFCC,
   lation biased compared to the real practice.                                                 International Federation of Clinical Chemistry; C-CB, Committee on
3. Obtain IRB approved waste specimen use from patients’                                        Clinical Application of Cardiac Bio-Markers; UDMI, Universal
   orders from their clinical indications by the provider that                                  Definition of Myocardial Infarction; POC, point-of-care; QC, qual-
   are already in the laboratory for testing for plasma and se-                                 ity control; URL, upper reference limits; LoD, limit of detection;
   rum, and likely EDTA whole blood remnant samples, ex-                                        ESC, European Society of Cardiology
   cept for capillary samples that would need to be fresh.
4. As patients present for treatment and are registered before                                  Author Contributions: All authors confirmed they have contributed to
   entering the hospital system, provide the patient with an                                    the intellectual content of this paper and have met the following 4 require-
   authorization and consent form that includes a section that                                  ments: (a) significant contributions to the conception and design, acquisi-
   clearly defines that the institution conducts research. The                                  tion of data, or analysis and interpretation of data; (b) drafting or revising
   patient can, at their choice, agree or not to agree to partici-                              the article for intellectual content; (c) final approval of the published arti-
   pate in medical research to allow for better understanding                                   cle; and (d) agreement to be accountable for all aspects of the article thus
   of diseases and how care is provided, and by signing the                                     ensuring that questions related to the accuracy or integrity of any part of
                                                                                                the article are appropriately investigated and resolved.
   document agrees that investigators may use health informa-
   tion and waste specimens already collected. This will allow                                  F.S. Apple, financial support, statistical analysis, administrative sup-
   for consecutive enrollment of patients, 24/7, without the                                    port, provision of study material or patients.
   bias of time delays of blood draws by informed consent,
   testing whole blood in real time with matched plasma or                                      Authors’ Disclosures or Potential Conflicts of Interest: Upon manu-
                                                                                                script submission, all authors completed the author disclosure form.
   serum specimens allowing rapid sample processing, and use
                                                                                                Disclosures and/or potential conflicts of interest:
   of fresh specimens that match real practice testing instead
   of freezing and thawing for analysis, often in batches.                                      Employment or Leadership: F.S. Apple, Clinical Chemistry, AACC;
5. This novel practice will allow manufacturers to enroll over                                  C.R. Fantz, Roche Diagnostics Corporation; P. Collinson, The Journal
   2500 patients in >3 selected institutions in 3 to 4 months,                                  of Applied Laboratory Medicine, AACC.
                                                                                                Consultant or Advisory Role: F.S. Apple, HyTest, LumiraDx, Brava
   allow more rapid acquisition and compilation data, creat-
                                                                                                Dx.
   ing draft documents more quickly for submission to FDA                                       Stock Ownership: C.R. Fantz, Roche Diagnostics Corporation.
   for review, and provide substantial financial savings by cut-                                Honoraria: F.S. Apple, Siemens Heathineers, Instrumentation
   ting a 2 to 3-year process to < 1 year.                                                      Laboratory.
                                                                                                Research Funding: None declared.
    Finally, the FDA is capable of rapid review and has                                         Expert Testimony: None declared.
been extremely flexible during the COVID-19                                                     Patents: None declared.

                                                                                  References
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                                                                                                1 Song and album by Bob Dylan (1964).

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