Abstract

IntroductionHIV self‐testing (HIVST) is being introduced as a new way for more undiagnosed people to know their HIV status. As countries start to implement HIVST, assuring the quality and regulating in vitro diagnostics, including HIVST, are essential. We aimed to document the emerging regulatory landscape and perceptions of key stakeholders involved in HIVST policy and regulation prior to implementation in three low‐ and middle‐income countries.MethodsBetween April and August 2016, we conducted semi‐structured interviews in Malawi, Zambia and Zimbabwe to understand the relationships between different stakeholders on their perceptions of current and future HIVST regulation and the potential impact on implementation. We purposively sampled and interviewed 66 national‐level key stakeholders from the Ministry of Health and the regulatory, laboratory, logistical, donor and non‐governmental sectors. We used a thematic approach to analysis with an inductively developed common coding framework to allow inter‐country comparison of emerging themes.ResultsIn all countries, the national reference laboratory was monitoring the quality of HIVST kits entering the public sector. In Malawi, there was no legal mandate to regulate medical devices, in Zambia one regulatory body with a clear mandate had started developing regulations and in Zimbabwe the mandate to regulate was overlapping between two bodies. Stakeholders indicated that they had a poor understanding of the process and requirements for HIVST regulation, as well as lack of clarity and coordination between organizational roles. The need for good collaboration between sectors, a strong post‐market surveillance model for HIVST and technical assistance to develop regulators capacity was noted as priorities. Key informants identified technical working groups as a potential way collaboration could be improved upon to accelerate the regulation of HIVST.ConclusionRegulation of in vitro diagnostic devices, including HIVST, is now being recognized as important by regulators after a regional focus on pharmaceuticals. HIVST is providing an opportunity for each country to develop similar regulations to others in the region leading to a more coherent regulatory environment for the introduction of new devices.

Highlights

  • HIV self-testing (HIVST) is being introduced as a new way for more undiagnosed people to know their HIV status

  • HIVST kits are classed as in vitro diagnostic (IVD), that is tests on specimens taken from the body, and are considered medical devices by the International Medical Device Regulation Forum [5]

  • We developed topic guides informed by literature on regulation, global and national policies on HIV testing and HIVST and implementation experience related to HIVST and based on the policy triangle framework

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Summary

Introduction

HIV self-testing (HIVST) is being introduced as a new way for more undiagnosed people to know their HIV status. In Malawi, there was no legal mandate to regulate medical devices, in Zambia one regulatory body with a clear mandate had started developing regulations and in Zimbabwe the mandate to regulate was overlapping between two bodies. Stakeholders indicated that they had a poor understanding of the process and requirements for HIVST regulation, as well as lack of clarity and coordination between organizational roles. Due to the potentially severe outcomes of an incorrect result and its use by lay persons, regulators would likely consider HIVST kits as a Class D (highest risk) medical device and subject to the greatest degree of regulation [6].

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