The FDA Early Feasibility Study Pilot and the Innovation Pathway

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Andrew Farb, MD and Dorothy Abel, BSBME Division of Cardiovascular Devices

Center for Devices and Radiological Health (CDRH)

andrew.farb@fda.hhs.gov

Medical Device Innovation 2013: The FDA Town Hall CRT 2013Washington, DCFebruary 26, 2013

Disclosures

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No conflicts of interest to report.

Climate Change at FDA

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FDA recognizes:•Advantages for the device development process with US clinical studies (including FIH and early feasibility studies)

– Opportunity for close contact between developers & investigators

– Early access to promising novel technology– Continuity of clinical investigations

•Human costs associated with delaying access to new technology, in the context of the limitations of current treatment alternatives

•A need for a cultural change to shift the focus from not only protecting public health but also to promoting public health

Words into Deeds

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The core principle in meeting these priorities is the application of benefit/risk principles throughout regulatory decision‐making•The Innovation Program

– Priority review program for innovative devices with promising and potentially far reaching benefits

– Entrepreneurs‐in‐Residence Program to enhance regulatory science

•Early Feasibility Study Guidance– Use of benefit/risk principles to justify study initiation

Allow regulators to consider:•The totality of the benefit/risk profile for the device, for example:

– Disease condition (e.g., life limiting‐ , life threatening)‐

– Limitations of and risks associated with currently available therapies

•Patient tolerance for risk & perspective on benefits

•Risk mitigation strategies when balancing risks and benefits

Benefit Risk‐ Principles

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INNOVATIONPAT H WAY

The Innovation Pathway

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• Priority review program launched February 2011 intended to:– Shorten the total time to market– Transform the FDA/innovator experience

• Targeted for pioneering technologies that address unmet clinical needs and have the potential to revolutionize patient care or health care delivery

• Early and intensive investment of resources– Sponsor/FDA collaboration early in the device development

process to identify the appropriate and least burdensome pathway to market

Innovation Pathway 2.0:End Stage Renal Disease Innovation Challenge(32 Applications Received, 3 Chosen)

CreatiVasc Hemoaccess Valve System

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UCSFbioimplantable artificial kidney

BPTiWearable artificial kidney

Entrepreneurs‐In Residence‐ (EIR) Program

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• Recruitment of entrepreneurs and innovators working with government employees

• Time‐limited (6 months) participation• Intended to deliver transformational change

via principles of lean engineering in rapidly testing, validating and scaling new approaches

Current EIR Projects at CDRH

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1. Streamlining clinical trials: Find ways to reduce the time and cost of clinical trials in support of FDA approval or clearance of medical devices

2. Streamlining the FDA approval‐to‐CMS coverage pathway: Find ways to reduce the inefficiencies and delays in data collection to support FDA approval and CMS coverage

3. Striking the right balance between pre and‐ post ‐market evidentiary requirements: Find ways to allow efficient use of pre‐market studies to allow for timely approvals, with greater emphasis on capturing informative real world‐ data in post‐market studies

EFS Pilot Program

• Pilot program of 8 innovative device technologies is underway to implement and evaluate the draft EFS guidance

• Purpose of the Pilot– Identify strengths and

weaknesses of the guidance document

• Assess whether adequate guidance is provided toward targeting IDE approval

• Status of the Pilot– Pre IDE‐ and IDE FDA/sponsor

interactions are ongoing

FDA

Sponsor

FDA EFS Guidance RevisionsBased on Pilot Experience and Comments

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• Emphasized benefit/risk concepts throughout the document• Improved the Report of Prior Investigations section to clarify

the information that will be useful to justify study initiation– Expanded on the Device Evaluation Strategy

• Included device design information and clinical protocol risk mitigation strategies in the table to provide the appropriate context when considering benefit/risk

• Added a Design Control section• Included more guidance on drafting the informed consent form

for an EFS• Suggested pre submissio‐ n topics for discussion between the

sponsor and FDA

FDA EFS Guidance Update

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• Although new pilot projects are not being accepted, EFS IDEs may be submitted prior to the publication of the final guidance.

• Many sponsors have committed to conducting EFS studies in the US.

• Publication is anticipated soon.

Parting Thoughts

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• Early and continuous interaction between FDA and sponsors will be instrumental in FDA’s efforts to facilitate innovation

• Accelerating innovation involves getting to the answers quicker and not just shortening the time to market or reducing regulatory requirements

Contacts

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• Early Feasibility Study

Guidance Dorothy.Abel@fda.hhs.gov

Andrew.Farb@fda.hhs.gov

• Innovation PathwayMurray.Sheldon@fda.hhs.gov

Associate Director for Technology & Innovation, CDRH