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Author:Susan Gardner, PhD Director, Office of Surveillance and Biometrics, CDRH FDLI Annual Meeting 4/08/05
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Postmarket Surveillance: Medical DevicesSusan Gardner, PhDDirector, Office of Surveillance and Biometrics, CDRHFDLI Annual Meeting 4/08/05
Office of Surveillance and Biometrics: Basic Functions
Premarket reviewStatisticiansEpidemiologists
Signal detection via monitoring tools including MDR, MedSunRisk characterization (analysis)Coordination of nonregulatory responseInterpretation of MDR regulation
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Pre-Postmarket Balance
Use premarket data to make initial decisions about safety and effectiveness and gain understanding of device benefits and risksUse postmarket data to improve our understanding of the risk benefit profile; disseminate timely safety information or take regulatory action as appropriate
Need for Postmarket Studies and Surveillance
Limited size of premarket studies cannot detect or characterize events that occur at a low rateNeed for long term follow-up (issues of durability/biocompatibility etc.)Use errorUse of device in community practice or home care Concerns for selected patient groupsDevice/device or device/drug interactionsDevice failureOff label use
Condition of Approval StudiesImmediate Postapproval Concerns
Postapproval requirements can include
“continuing evaluation and periodic reporting on the safety, effectiveness, and reliability of the device for its intended use.” 21 CFR 814.82 (a) (2).
Indications for CoA Studies
Need to refine risk estimates or better characterize safety issues, particularly uncommon and seriousNeed to study specific population subgroupsNeed to study long term effectsNeed to study use of device under conditions of general use
CoA Quality Study: 2002-3
1998 through 2000: 127 PMAs approved with 45 CoA orders. CDRH had limited procedures for tracking progress or resultsTurnover of lead reviewers resulted in lack of follow-upNo results received for 22%Two studies had not been started at all
Strategy for Change
Transfer CoA tracking and follow-up to OSB
Develop and institute automated tracking systemAcknowledge the receipt of study reportsFollow-up when reports are not received
Strategy for Change
Add epidemiologist to PMA review team
Tasked with the development of a postmarket monitoring planLead design of postmarket study developmentLead the development of well formulated postmarket questionsLead in evaluation of study progress and resultsWill continue to work with PMA team
Strategy for Change
Develop guidance for industry and FDA to provide clear guidelines for content, format and due datesPeriodically report the results of CoA to Advisory PanelsCDRH may post periodic status reports of CoA on Agency website
Least burdensome Approach
Least burdensome principles apply Acknowledged in FDA guidance“integrated in premarket…, as well as postmarket…as they relate to premarket…The “way” to Least burdensome is to discuss pre/postmarket balance as early as possible in the approval process.
Elements of Protocols for Analytic Studies
Study objective – reason for doing the studyDefine study groupOutcomes of interest – safety issuesStudy design and proceduresStudy sizeAnalysis planReporting requirements
Elements of Protocols for Analytic Studies
Our goal is to have these elements of the study protocol agreed upon before product approval.
Adverse Event Reporting
Medical Device Reporting (MDR)Approximate 130k reports/yearHalf are Summary Reports After initial triage, individual reports are monitored by analysts Look for rare, unexpected events, increase in events, seriousness of event, population affected, preventabilitySummary reports are monitored for change in trends Primarily manufacturer reports (90%)
MDR Reports: 1998-2004
020000400006000080000
100000120000140000160000180000
1998 2000 2002 2004
IndividualSummaryTotal
Medical Device Safety Network (MedSun)
300 hospitals and other facilities trained to recognize and report device related adverse events; goal to reduce barriers to reportingReports include “close calls”; emphasis on preventionProvides CDRH with connection to device usersReports and actions tend to focus on user issues, “everyday safety issues”Provides laboratory for quick surveys and other research projects
Postmarket Surveillance: Section 522
Allows CDRH to order postmarket surveillance studies for:
Class ll or Class lll productsIntended to be implanted for more than one year, orLife sustaining/life supporting and used outside user facility, orFailure would likely cause serious health consequences
Postmarket Surveillance: Section 522
CDRH poses public health question to industryIndustry develops plan to address questionWide variety of study methods acceptableGenerally limited to three year studies
Other Surveillance Tools
Observational Studies – de novo or existing cohortsMedical care claims dataRegistries – real world use International vigilance Rapid Response surveys
Future Directions
Goal: To improve our postmarket toolkit to allow us to make reasonable science-based decisions in evaluating the benefits and risks of medical devices