Proposed refinements to the requirements for medical device patient information materials

Closed 1 Sep 2021

Opened 17 Aug 2021

Feedback updated 19 Oct 2021

We asked

We asked for feedback on potential refinements to the existing regulatory requirements for patient information materials, including the content and form of the materials and exempt devices.

You said

A total of 34 submissions were received with more than half of the submissions from health care professionals and hospitals who are responsible for providing information to patients. Submissions were also received from consumers, professional health related societies and the medical device sector.

Almost all respondents, including the consumers, agreed with the proposals for providing information in a range of formats. This would allow information to be recorded in electronic formats such as electronic patient records and MyHealth records. Although, several respondents considered that regardless of how the information is kept, patients should also have the option to receive a hard copy.  Most were in favour of flexibility in the way information is provided. There were also suggestions for providing patient information materials in different languages and in audio form. The medical device industry respondents noted that electronic formats would reduce cost and some health care providers considered that costs are offset by benefits. However, there were several concerns raised about the burden on hospital staff and administration times if the system is too demanding or complex.

The majority of respondents agreed that it is unnecessary to provide patient implant cards if the device is going to be absorbed by the body within a certain timeframe. Those that stated they did not agree had concerns over delayed reactions to such implants. The suggested timeframes varied from days to 2 years, but the majority of those who responded opted for periods of 3 to 6 months.

The strong majority of respondents agreed that it is unnecessary to provide patient implant cards for pedicle screws, given that many types of screws could be used in one surgery.  There were suggestions that a system implant card is sufficient (that covers all implanted devices from one system), or that a generic patient information leaflet could be provided. In general, the responses indicate that it is unnecessary to provide patient implant cards for each screw or component, but the requirement for a patient information leaflet should be retained.

Although only a few respondents had comments on other devices which could be exempt from the requirements, there was strong representation for exempting reloads with staple line reinforcement, sutures with pledgets, and pledgets alone from requiring patient implant cards. There was also a recommendation to ensure alignment with the European requirements by exempting spinal rods, suture anchors, wedges (augments), laminar hooks, non-expandable cages, interspinous spacers, and bone screws.

There were also some questions about certain devices such as coronary stents and dental crowns, which indicated that there was still some confusion about the regulatory requirements for these devices.

It was noted that there was a need for increased communication about the implementation including education for hospitals, procurement officers and clinicians in relation to the provision of these materials.

We did

Based on the outcomes from the consultation, agreement will be sought from the Government to consider refinements to the Regulations. These refinements would:

  • allow more flexibility in how patient information materials can be provided including in a range of formats such as electronic format and at either pre or post surgery (i.e. not necessarily supplied with the device in the packaging);
  • exempt devices absorbed by the body within a defined time period from the requirement for a patient implant card but maintain the requirement for a patient information leaflet;
  • exempt pedicle screws from the requirement to have a patient implant card. The requirement for a patient information leaflet will be retained, but could be incorporated into a system patient information leaflet where appropriate; and
  • create the power for a TGA delegate to consider exempting other devices where clinically appropriate to ensure alignment with Europe, where possible.

Guidance documents will be updated to address other concerns raised in the consultation. Continued education will also be provided, including clear messages to relevant groups such as hospitals, surgeons, clinicians and procurement officers in relation to the implementation of patient information materials.          

Guidance will be further updated following a decision from the Government on the proposed refinements.

Results updated 19 Oct 2021

View submitted responses where consent has been given to publish the response. 


It is important that patients have access to information about their implanted medical devices.

Globally, the requirements for medical device patient information materials vary. Implementation of requirements for these materials in Europe is occurring now through to 2024, whilst in USA and Canada there are requirements already in force.

In Australia, in late 2017, the Government approved regulations that require patient information materials to be supplied with implantable and active implantable medical devices.  In 2018, following consultation with health professionals, consumer groups, consumers and the medical device industry, guidance was published on the TGA website setting out detailed requirements for patient information materials.

In 2020, revised guidance was published Guidance document for PICs and PILs, taking into account lessons learnt from two years of implementation, as well as consumer and sponsor feedback to include:

  • further clarification on the content and form of patient information leaflets (PIL) and patient implant cards (PIC);
  • devices that are exempt from the requirements to provide PIC and PIL;
  • specific information about urogynaecological meshes and breast implants.

Why your views matter

Feedback received from consumers, health care professionals, surgeons, hospitals and medical device companies has identified some impracticalities and challenges for how patient information materials are provided to patients.

We are consulting to seek views on potential refinements to how and when patient materials should be available and when they may not need to be provided with certain devices.

What happens next

Your input and feedback will help inform any changes to the Regulations in relation to patient information materials.



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