EU MDR PMCF evidence pathway from CER gap to PMCF Evaluation Report
EU MDR • POST-MARKET CLINICAL FOLLOW-UP

PMCF Built Around the Clinical Evidence Gap

Bioexcel helps medical device manufacturers determine what clinical uncertainty remains after market introduction and which PMCF method is most appropriate to address it.

Our PMCF services cover strategy, study design, sites, retrospective data, prospective follow-up, registries, data management, biostatistics, medical writing and integration of results into CER, PMS, PSUR and Risk Management.

HomePMCF

Does Bioexcel Provide PMCF Services?

Yes. Bioexcel supports the complete PMCF lifecycle, including PMCF strategy, PMCF Plan development, prospective and retrospective PMCF studies, registries, real-world evidence, data management, biostatistics, PMCF Evaluation Reports and integration of the resulting evidence into CER, PMS, PSUR and Risk Management.

Bioexcel Lifesciences & Research LLP is a specialized medical device and IVD clinical research organization supporting PMCF strategy, PMCF Plans, prospective and retrospective PMCF studies, registries, real-world evidence, data management, biostatistics and PMCF Evaluation Reports.

Content Managed By: Bioexcel Clinical Evaluation & PMCF TeamReviewed By: Amandeep Kaur, Director – Clinical OperationsLast Updated: 26 August 2026
Purpose of PMCF

PMCF Should Address Residual Clinical Uncertainty

PMCF should not be treated as a routine administrative exercise. A meaningful PMCF strategy should answer questions such as:

  • Are the device's safety outcomes still consistent with expectations?
  • Is clinical performance maintained in routine use?
  • Are there long-term complications?
  • Are rare risks emerging?
  • Is reintervention occurring?
  • Is performance different in specific subgroups?
  • Are new indications or populations being used?
  • Are clinical claims still supported?
  • Has the state of the art changed?
  • Does the benefit-risk conclusion remain valid?

Bioexcel uses these questions to define the most appropriate PMCF activity.

The Bioexcel PMCF Model

From Clinical Uncertainty to Post-Market Evidence

01

Evidence Review

  • CER
  • CEP
  • PMS
  • PSUR
  • Risk Management
  • Existing PMCF
  • Complaints
  • Literature
  • Clinical studies
  • Notified Body findings

Output: PMCF Evidence-Gap Map

02

PMCF Objective

  • Long-term safety
  • Long-term performance
  • Revision rate
  • Reintervention
  • Rare complications
  • Performance in new populations
  • Real-world clinical benefit

Output: PMCF Objective

03

Method Selection

  • Prospective study
  • Retrospective study
  • Registry
  • Survey
  • Real-world evidence
  • Literature
  • Hybrid approach

Output: PMCF Strategy

04

PMCF Plan

  • Activity
  • Rationale
  • Methodology
  • Endpoints
  • Population
  • Timeline
  • Analysis
  • Reporting

Output: PMCF Plan

05

Evidence Generation

  • Patient follow-up
  • Hospital record abstraction
  • Registry collection
  • Survey
  • Literature review
  • Other approved PMCF activity

Output: Clinical PMCF Data

06

Analysis & Evaluation

  • Data cleaning
  • Statistical analysis
  • Clinical interpretation
  • Benefit-risk assessment

Output: PMCF Conclusions

07

Lifecycle Integration

  • CER
  • PMS
  • PSUR
  • Risk Management
  • SSCP
  • Future PMCF strategy

Output: Lifecycle Clinical Evidence

What Is PMCF?

Post-Market Clinical Follow-Up is a continuous process used to collect and evaluate clinical data from a medical device after market introduction in order to confirm continued safety, performance and clinical benefit, identify emerging risks and address residual clinical uncertainties.

Method Selection

Which PMCF Method Is Right for Your Device?

Prospective PMCF

  • New clinical data are required
  • Specific endpoints must be collected
  • Follow-up needs to be standardized
  • Historical records are insufficient
  • Longitudinal assessment is needed
Explore Prospective PMCF

Retrospective PMCF

  • The device has already been used
  • Historical clinical records exist
  • Long-term outcomes are available
  • Existing data can answer the evidence question
Explore Retrospective PMCF

Registry

  • Long-term surveillance is required
  • Real-world use across sites is relevant
  • Ongoing follow-up is needed
Explore Registry

Survey

  • User experience
  • Physician feedback
  • Selected clinical use information

Survey-only strategies require scientific justification and may not be sufficient for every evidence gap.

Explore Survey

Real-World Evidence

  • Hospital records
  • Registries
  • Clinical databases
  • Routine care data
Explore Real-World Evidence

Literature-Based Follow-Up

  • Useful where relevant published evidence can address specific clinical questions.
Explore Literature-Based Follow-Up
Hybrid PMCF

Hybrid PMCF

Combines multiple methods.

Retrospective Records + Prospective Follow-Up + LiteratureOne Integrated PMCF Conclusion

Does Every PMCF Requirement Need a Prospective Study?

No. The appropriate PMCF method depends on the identified clinical evidence gap, device risk, available data, residual uncertainty and regulatory context. Some questions may be addressed using retrospective records, registries, real-world evidence or other justified PMCF methods, while others may require prospective clinical follow-up.

What PMCF services does Bioexcel provide?

Bioexcel provides PMCF gap assessment, PMCF strategy, PMCF Plans, prospective and retrospective PMCF studies, registries, data management, biostatistics, PMCF Evaluation Reports and CER integration.

Where can Bioexcel support PMCF?

Bioexcel supports PMCF programs through suitable clinical resources in India and Europe, with centralized clinical, data, statistical and medical writing support.

Can Bioexcel support both the study and the documentation?

Yes. Bioexcel can support PMCF study execution as well as the associated protocol, data management, statistics, PMCF Evaluation Report and CER update.

PMCF Gap Assessment

Start With the Evidence Gap, Not the Study Type

Bioexcel can assess:

  • Existing clinical data
  • Current CER conclusions
  • Residual risks
  • State-of-the-art benchmarks
  • PMS findings
  • Complaint trends
  • Long-term evidence
  • Clinical claims
  • Prior PMCF
  • Notified Body feedback

Example: Evidence Gap Prioritization

Evidence QuestionExisting EvidenceResidual GapPMCF ActivityPriority
Long-term safetyLimited 12-month data3–5 year uncertaintyRetrospective / registryHigh
Device performanceAdequateNoneRoutine surveillanceLow
Rare complicationLow event exposureInsufficientMulti-site PMCFMedium
PMCF Plan

PMCF Plan Development

Bioexcel can prepare or remediate a PMCF Plan.

  • Device identification
  • Intended purpose
  • PMCF objectives
  • Clinical evidence gaps
  • Planned PMCF activities
  • Rationale for each activity
  • Methodology
  • Population
  • Clinical endpoints
  • Timeline
  • Data sources
  • Statistical methods
  • Reporting schedule
  • Link to CER
  • Link to PMS
  • Link to Risk Management

Can Bioexcel Prepare a PMCF Plan?

Yes. Bioexcel can develop or revise PMCF Plans that connect identified clinical evidence gaps with specific post-market activities, methodology, endpoints, timelines and planned integration into the broader clinical evaluation.

Prospective PMCF

Prospective PMCF Studies

Prospective PMCF may be appropriate when predefined clinical information must be collected directly from patients after market introduction.

Prospective PMCF study

Potential Objectives

  • Confirm long-term safety
  • Confirm clinical performance
  • Evaluate device durability
  • Assess reintervention
  • Assess revision
  • Evaluate quality of life
  • Study specific subgroups
  • Generate longer follow-up

Bioexcel Support

  • Protocol
  • Site feasibility
  • Investigator selection
  • Ethics coordination
  • Site initiation
  • Recruitment
  • Follow-up
  • Monitoring
  • EDC
  • Data management
  • Statistics
  • PMCF reporting

Can Bioexcel Conduct Prospective PMCF?

Yes. Bioexcel supports prospective PMCF studies from protocol development and site feasibility through recruitment, monitoring, EDC, data management, biostatistics and final PMCF reporting.

Retrospective PMCF

Use Existing Hospital Records as Clinical Evidence

Retrospective PMCF can be useful where the device has already been used and relevant clinical outcomes are documented.

Retrospective PMCF study using historical hospital records
  • Procedure records
  • Implant records
  • Hospital medical records
  • Follow-up notes
  • Imaging
  • Reintervention records
  • Revision records
  • Complications
  • Readmissions
Device UseHospital FeasibilityPatient IdentificationEligibilityData AbstractionMonitoringEDCStatisticsPMCF Report

Can Hospital Records Be Used for PMCF?

Potentially yes. Existing hospital records can support retrospective PMCF when the data are relevant to the PMCF objective, sufficiently complete and reliable, ethically accessible and suitable for meaningful clinical analysis.

Registry-Based PMCF

Medical Device Registries

A registry may support long-term real-world follow-up across:

Medical device registry used for long-term post-market clinical follow-up

Scope

  • Multiple sites
  • Large patient populations
  • Extended follow-up
  • Routine clinical practice

Potential Registry Data

  • Implantation
  • Device performance
  • Clinical outcomes
  • Complications
  • Revision
  • Reintervention
  • Survival
  • Patient-reported outcomes
Real-World Evidence

Real-World Clinical Evidence for PMCF

RWE may include information generated during routine clinical care.

Potential Sources

  • Hospital databases
  • Clinical registries
  • Electronic records
  • Device registries
  • Routine follow-up data

Suitability Depends On

  • Data quality
  • Endpoint availability
  • Completeness
  • Bias
  • Confounding
  • Relevance to intended use
PMCF Surveys

Physician & Patient Surveys

Surveys may support specific PMCF objectives such as:

Device-use patternsSatisfactionHandlingUser experienceSelected outcomesReal-world practice

A survey should not be selected merely because it is easier to execute. The method must be capable of addressing the clinical evidence gap.

PMCF Endpoints

Endpoints Should Match the Residual Uncertainty

Potential PMCF endpoints include:

Safety

  • Adverse events
  • Serious events
  • Device-related complications
  • Revision
  • Reintervention
  • Hospitalization
  • Mortality

Performance

  • Technical success
  • Device success
  • Functional performance
  • Durability
  • Anatomical outcomes

Clinical Benefit

  • Symptom improvement
  • Functional scores
  • Quality of life
  • Reduced interventions

Long-Term

  • Implant survival
  • Reintervention-free survival
  • Revision-free survival
  • Late complications
PMCF Sample Size

Statistical Planning for PMCF

PMCF sample size should depend on the actual objective. Potential approaches include:

Precision around event ratePrecision around device successExpected complication rateConfidence interval widthLong-term survival estimateComparison with benchmarkSubgroup analysis

Can Bioexcel Calculate PMCF Sample Size?

Yes. Bioexcel can support PMCF sample-size calculations based on the intended clinical objective, expected event or performance rate, required statistical precision, follow-up assumptions and anticipated loss to follow-up.

Long-Term PMCF

Long-Term Evidence for Implantable Devices

For implantables, PMCF may need to address:

Device durabilityStructural integrityLate complicationsRevisionReinterventionDevice survivalPatient outcomesLong-term benefit-risk
Site Feasibility

Finding Sites With Existing Device Experience

Site feasibility may assess:

  • Number of devices used
  • Number of treated patients
  • Historical follow-up
  • Record completeness
  • Investigator experience
  • Prospective patient flow
  • Data accessibility
  • Ethics pathway
  • Long-term follow-up capability
India

PMCF Studies in India

Bioexcel supports PMCF programs in India through suitable hospitals and investigators.

  • Retrospective hospital records
  • Prospective follow-up
  • Multi-site studies
  • Registries
  • Hybrid approaches

Can Bioexcel Conduct PMCF in India?

Yes. Bioexcel supports prospective and retrospective PMCF programs in India through suitable clinical sites, with centralized study management, monitoring, data management, biostatistics and medical writing.

Europe

European PMCF Programs

Bioexcel supports European PMCF programs through suitable local clinical resources combined with centralized Bioexcel evidence functions.

  • European site feasibility
  • Prospective PMCF
  • Retrospective PMCF
  • Registry strategy
  • Monitoring
  • Data management
  • Statistics
  • Reporting

Can Bioexcel Support PMCF in Europe?

Yes. Bioexcel supports European PMCF programs through appropriate local clinical resources combined with centralized clinical strategy, project management, data, biostatistics and medical writing.

Data Management

Convert Post-Market Experience Into Structured Data

Bioexcel can support:

PMCF clinical data analysis workflow
  • CRF/eCRF
  • EDC
  • Data abstraction forms
  • Query management
  • Data validation
  • Missing-data review
  • Safety reconciliation
  • Database lock
Hospital RecordData AbstractioneCRFMonitoringQueriesDatabase Lock
PMCF Biostatistics

Statistical Interpretation of Post-Market Evidence

Potential analyses include:

Descriptive statisticsEvent ratesConfidence intervalsDevice successRevision ratesReinterventionSurvival analysisSubgroupsLongitudinal analysisBenchmark comparisonsSensitivity analyses
PMCF Evaluation Report

PMCF Evaluation Report Development

The PMCF Evaluation Report should convert the collected evidence into a clear clinical conclusion.

PMCF Evaluation Report development
  • PMCF objective
  • Methodology
  • Data source
  • Study population
  • Results
  • Safety findings
  • Performance findings
  • Clinical benefit
  • Statistical interpretation
  • Limitations
  • Residual uncertainty
  • Impact on CER
  • Impact on Risk Management
  • Impact on PMS
  • Future PMCF needs

Can Bioexcel Prepare a PMCF Evaluation Report?

Yes. Bioexcel can prepare PMCF Evaluation Reports using finalized PMCF data and statistical outputs, with interpretation linked to the original clinical evidence gap and relevant lifecycle documentation.

CER Integration

PMCF Should Feed Back Into the Clinical Evaluation

PMCF and CER integration
CERResidual Evidence GapPMCFNew Clinical EvidencePMCF Evaluation ReportCER Update
Confirms previous conclusionsChanges clinical performanceIdentifies new riskChanges benefit-riskCloses an evidence gapCreates a new PMCF question
Lifecycle Integration

PMCF Across the Post-Market Evidence System

PMCF Is Part of the Broader Post-Market System

PMCF should not operate independently from PMS. Potential PMS inputs:

  • Complaints
  • Serious incidents
  • FSCA
  • Literature
  • User feedback
  • Sales/exposure
  • Trend data

PMCF Results and Periodic Safety Reporting

Where applicable, relevant PMCF conclusions may inform:

  • Exposure
  • Safety trends
  • Clinical performance
  • Emerging risks
  • Benefit-risk
  • Planned corrective actions
  • Future PMCF

PMCF Should Test Residual Clinical Risk

PMCF may be used to investigate:

  • Known residual risks
  • Uncertain event frequency
  • Rare harms
  • Long-term complications
  • New clinical signals

Keeping Public Clinical Information Current

Where applicable, new PMCF evidence may affect:

  • Clinical benefit summary
  • Safety information
  • Residual risks
  • PMCF summary
  • Clinical evaluation summary
RiskClinical QuestionPMCF EndpointObserved OutcomeRisk EvaluationBenefit-Risk
Notified Body PMCF Findings

Received a PMCF Nonconformity?

Common issues may include:

EU MDR PMCF evidence pathway from CER gap to PMCF Evaluation Report
  • Generic PMCF Plan
  • No clear evidence gap
  • No specific objectives
  • Weak methodology
  • Inadequate follow-up
  • Survey-only strategy without justification
  • PMCF not linked to CER
  • Results not incorporated
  • Insufficient long-term evidence
NB FindingInterpretationEvidence GapPMCF StrategyPlan / Study / Analysis UpdatePMCF EvaluationCER / PMS / Risk Management Update

Can Bioexcel Help With a Notified Body PMCF Finding?

Yes. Bioexcel can review the finding, identify the underlying PMCF or clinical evidence gap, revise the PMCF strategy and documentation, and support additional evidence generation where necessary.

Cross-Document Consistency

PMCF Should Not Contradict the Rest of the Technical Documentation

Check alignment across:

CERPMCFPMSPSURRisk ManagementSSCP

If PMCF identifies a new complication, its impact may need to be considered across several documents.

PMCF Medical Writing

Documentation Across the PMCF Lifecycle

Bioexcel can support:

  • PMCF strategy
  • PMCF Plan
  • Study protocol
  • Retrospective protocol
  • Registry documentation
  • CRF content
  • PMCF Evaluation Report
  • CER updates
  • Notified Body responses

Why Medical Device Manufacturers Use Bioexcel for PMCF

Evidence-Gap First

The PMCF methodology is selected according to the clinical question.

Prospective + Retrospective Capability

Bioexcel can support multiple evidence-generation models.

India + Europe

Flexible geographic execution.

Clinical + Data + Statistics

PMCF is managed as an evidence program rather than a standalone document.

CER Integration

The final evidence can flow directly into the clinical evaluation.

Regulatory Remediation

Bioexcel can support PMCF-related Notified Body findings.

Frequently Asked Questions About PMCF

PMCF is the ongoing collection and evaluation of clinical data after a medical device is placed on the market to confirm continued safety, performance and clinical benefit and to address residual clinical uncertainties.

HIPAA Compliant
ICH-GCP Compliant
FDA 21 CFR Part 11
ISO 9001
ISO 14155
ISO 27001 Certified
EU MDR 2017/745
EU IVDR 2017/746
US FDA Requirements
ISO 20916

Bioexcel designs PMCF around the clinical question—not around a generic template.

CER / PMS / Risk ManagementResidual Clinical UncertaintyPMCF ObjectiveMethod SelectionProspective / Retrospective / Registry / RWEClinical DataEDC / Data ManagementBiostatisticsPMCF Evaluation ReportCER / PMS / PSUR / Risk Management UpdateNext PMCF Cycle