February 19, 2014
The Center for Devices and Radiological Health or CDRH will focus on encouraging medical device innovation and speeding clinical trials in the coming years, according to its 2014-2015 Strategic Priorities report released Feb. 5.
To help encourage that innovation, CDRH says it’s going to work to improve the consistency of the Investigational Device Exemption (IDE) process, especially in the areas of consistency and speed with which it handles applications. CDRH also pledges to find ways to encourage more early IDE studies — especially for those with medical devices aimed at the U.S. patient marketplace.
The report also says CDRH will try to find a better balance between premarket and postmarket data requirements.
CDRH sets measurable metric goals for improving IDE cycles:
- By September 30, 2014, reduce the number of IDEs requiring more than two cycles to an appropriate full approval decision by 25 percent compared to FY 2013 performance.
- By September 30, 2014, for disapproved IDEs, offer all sponsors a teleconference or in-person meeting to occur within 10 business days of the IDE decision.
- By June 30, 2015, reduce the number of IDEs requiring more than two cycles to an appropriate full approval decision by 50 percent compared to FY 2013 performance.
Time to IDE Approval:
- By September 30, 2014, reduce the overall median time to appropriate full IDE approval by 25 percent compared to FY 2013 performance.
- By June 30, 2015, reduce the overall median time to full appropriate IDE approval to 30 days.
- In FY 2013 (as of 12/11/2013), 45% of IDEs received a full approval decision within 2 cycles and a median time to full IDE approval was 174 days.
By June 30, 2015, the report says CDRH intends to increase the number of early feasibility/first-in-human IDE studies submitted to each premarket division compared to FY 2013 performance. CDRH promises several action steps here, including:
- Establish in the Office of Device Evaluation a premarket clinical trials program responsible for the oversight and performance of the IDE Program and the development and implementation of policies that contribute to the timely initiation and successful execution of medical device clinical trials.
- Formalize the incorporation of our benefit-risk framework, including patient-specific factors such as tolerance for risk and perspective on benefit, into the IDE process.
- Establish a process to efficiently and objectively resolve application-specific IDE issues to reduce the number of multi-cycle IDEs.
- Develop a clinical trials education and training program for CDRH review staff, managers, and industry.
- Develop real-time metrics to track CDRH and industry IDE and clinical trial performance.
Turning to premarket and postmarket data requirements, the CDRH call to arms lays down more goals:
- By December 31, 2014, review 50 percent of device types subject to a PMA that has been on the market to determine whether or not to shift some premarket data requirements to the postmarket setting or to pursue down the classification and communicate those decisions to the public.
- By June 30, 2015, review 75 percent of device types subject to a PMA that has been on the market to determine whether or not to shift some premarket data requirements to the postmarket setting or to pursue down the classification and communicate those decisions to the public.
- By December 31, 2015, review 100 percent of device types subject to a PMA that has been on the market to determine whether or not to shift some premarket data requirements to the postmarket setting or to pursue down the classification and communicate those decisions to the public.
CDRH plans several specific actions to help attain those targets, including:
- Develop and seek public comment on a framework for when it is appropriate to shift premarket data collection to the postmarket setting.
- Conduct a retrospective review of all PMA device types to determine whether or not to shift some premarket data requirements to the postmarket setting or to down classify device types in light of our current understanding of the technology.
- Implement a mechanism to prospectively assure the appropriate balance of premarket and postmarket data requirements for new devices subject to a PMA.
- Using existing authorities, develop and seek public comment on a new pathway to market for devices subject to a PMA that address an unmet public health need by shifting appropriate premarket data needs to the postmarket setting and incorporating features of the Innovation Pathway pilots.
The medical device industry no doubt applauds the majority of these goals. Now it’s time for CDRH to roll up its sleeves and get them done.
