Premarket Approval Research Articles

Diversity in Medical Device Clinical Trials: Do We Know What Works for Which Patients?

Demographic differences can influence the safety and effectiveness of medical devices; however, clinical trials of devices for adults have historically underrepresented women, people of color, and patients over age 65. The US Food and Drug Administration (FDA) Safety and Innovation Act became law in 2012, encouraging greater diversity and subgroup analyses. In 2013, the FDA reported that there was diversity in clinical trials considered "pivotal" for approval decisions and that subgroup analyses were conducted for most applications for the highest-risk medical devices. However, the FDA's report did not specify whether analyses included sufficient numbers to be meaningful, whether analyses were conducted for most major subgroups, or whether analyses included safety, effectiveness, or accuracy. We examined publicly available documents for all 22medical devices that the FDA designated "highest risk" or "novel,"were reviewed through the premarket approval pathway, and were scrutinizedat FDA public meetings from 2014 to 2017. We evaluated patient demographics and subgroup analyses for all pivotal trials. Only 3 (14%) of the devices provided subgroup analyses for both effectiveness and safety or both sensitivity and selectivity for gender, race, and age. However, 55% of the devices reported both of those subgroup analyses for at least 1 of the 3 subgroups. Whether analyses were reported or not, the number of patients in most subgroups was too small to draw meaningful conclusions. Subgroup analyses were more likely to be reported to the FDA's Advisory Committees than in the FDA's public reviews or labeling. Despite a law encouraging more diversity and subgroup analyses in pivotal trials used as the basis for FDA approval, the results of our study indicate relatively few subgroup analyses are publicly available for the highest-risk and novel medical devices. The lack of subgroup analyses makes it impossible to inform patients or physicians as to whether many newly approved medical devices are safe and effective for specific demographic subgroups defined by gender, race, and age.

Assessment of Clinical Trial Evidence for High-Risk Cardiovascular Devices Approved Under the Food and Drug Administration Priority Review Program

This study uses publicly available FDA summaries to analyze the quality of evidence in pivotal studies that support cardiovascular premarket device approval under FDA priority review from 2007 to 2017.

An Analysis of Foot and Ankle Device Recalls by the Food and Drug Administration.

IntroductionOrthopaedic devices represent 12% of all medical device recalls. Products are approved through pre-market approval (PMA) or the 510(k) premarket notification process. No previous evaluation was found in the literature evaluating foot and ankle device recalls. The field of foot and ankle subspecialty has seen a rapid growth in innovation related to implants in recent years.MethodsThe Food and Drug Administration (FDA) Device Recall database was evaluated for all foot and ankle devices from 2007 through 2017 for the manufacturer, process of approval, type of implant, recall class, dates of initiation and termination of the recall, manufacturer determined reason, quantity affected, and distribution within the United States or internationally.ResultsA total of 161 products from 33 companies were identified with 158 (98.1%) approved through the 510(k) process. The most common reason for device recall was due to the device breaking intraoperatively or postoperatively. The average length of the recall was 487.5 days. ConclusionsDevice recall is not an uncommon event with the majority of products approved through the less demanding 510(k) process.

Premarket Approval Through the 510(k) Process: Lessons from the Translation Process of Magnetic Resonance Elastography

Premarket Approval Through the 510(k) Process: Lessons from the Translation Process of Magnetic Resonance Elastography

First granted example of novel FDA trial design under Expedited Access Pathway for premarket approval: BeAT-HF

The Food and Drug Administration (FDA) initiated the Expedited Access Pathway (EAP) to accelerate approval of novel therapies targeting unmet needs for life-threatening conditions. EAP allows for the possibility of initial FDA approval using intermediate end points with postapproval demonstration of improved outcomes. Describe the EAP process using the BeAT-HF trial as a case study. BeAT-HF will examine the safety and effectiveness of baroreflex activation therapy (BAT) in heart failure patients with reduced ejection fraction using an Expedited and Extended Phase design. In the Expedited Phase, BAT plus guideline-directed medical therapy (GDMT) will be compared at 6 months postimplant to GDMT alone using 3 intermediate end points: 6-minute hall walk distance, Minnesota Living with Heart Failure Questionnaire, and N-terminal pro-B-type natriuretic peptide. The rate of heart failure morbidity and cardiovascular mortality will be compared between the arms to evaluate early trending using predictive probability modeling. Sample size of 264 patients randomized 1:1 to BAT + GDMT versus GDMT alone provides 81% power for the Expedited Phase intermediate end points. For the Extended Phase, the heart failure morbidity and cardiovascular mortality end point is based on an expected event rate of 0.4 events/patient/year in the GDMT arm. With an adaptive sample size selection design for robustness to inaccurate assumptions, a sample size of 480-960 randomized patients followed ≥2 years allows detecting a 30% reduction in the primary end point with a power of 97.5%. Through a unique collaboration with FDA under the EAP, the BeAT-HF trial design allows for the possibility of approval of BAT, initially for symptom relief and subsequently for outcomes improvement.

The Use of a Synthetic Cartilage Implant for Hallux Rigidus

Category: Other Introduction/Purpose: Hallux rigidus is one of the most common pathologies afflicting the foot. Various joint salvage techniques have been described with a multitude of different implants. Recently, a synthetic cartilage implant composed of polyvinyl alcohol (PVA) received FDA premarket approval for treatment of arthritis of the great toe and has been used in over 4,000 cases. The purpose of this study was to systematically review the clinical evidence supporting the use of a PVA implant in hallux rigidus. Methods: A systematic review was performed according to the Preferred Reporting Items for Systematic Reviews and Meta-Analysis (PRISMA). Using the terms “cartiva OR polyvinyl alcohol OR synthetic cartilage OR hemiarthroplasty AND hallux rigidus OR great toe arthritis OR first toe arthritis “ we searched the PubMed/Medline database in December 2017. In addition, the reference list of publications were scanned for further relevant studies. Results: 4 studies met the inclusion criteria, all of which were derived from a single randomized controlled trial. At short-term follow-up (2 years), patients undergoing placement of a PVA implant had significant improvement in Foot and Ankle Ability Measure (FAAM) sports and activity of daily living, as well as VAS pain scores. The outcomes of the surgery were found to be noninferior compared to arthrodesis. At intermediate follow-up (5 years), the improvement in clinical outcomes persisted and implant survivorship was 96%. Conclusion: There are limited studies available detailing the outcomes of a PVA implant for hallux rigidus, however the results that are available demonstrate a high level of evidence. There are no long-term publications assessing the outcomes of a PVA implant for hallux rigidus.

Too Much Carrot and Not Enough Stick in New Stem Cell Oversight Trends.

Regulators are now more often distinguishing between perceived good citizens and "bad actors" in stem cell and regenerative medicine clinical research, resulting in relatively more polar, carrot-and-stick oversight approaches. Here, I discuss why there may be too much carrot and not enough stick by regulators for effective enforcement.

FDA-CMS Parallel Review – a failed attempt at spurring innovation

Purpose The purpose of this paper is to analyze the Parallel Review program that offers simultaneous review of the Food and Drug Administration premarket approval submissions and the Centers for Medicare and Medicaid Services (CMS) national coverage determinations (NCDs) of medical devices. Design/methodology/approach The paper analyzes the impact of Parallel Review on medical device innovation, focusing in particular on the causes for low popularity of the program among medical device manufacturers. Program outcomes are evaluated in the light of its intended goals. Findings The paper identifies four reasons for the program’s limited impact. First, few devices are eligible to participate. Second, most manufacturers prefer to seek Medicare reimbursement at the local level as less risky than the CMS NCDs. Third, participation in the Parallel Review might actually delay the marketing of the device. Fourth, the program does not address numerous obstacles that device sponsors currently encounter. While giving the appearance of support for the medical device innovation, the policy falls short on its intended goals. Originality/value This paper elucidates the challenges to internal reform and serves as a reminder to political economists and health care researchers that to make disruptive innovation possible, we must continue to illuminate the otherwise unseen cost of marketing delays and document the ability of emergent market mechanisms to protect consumer safety.

Perspective: Structure-Function Claims on Infant Formula.

In the context of a food product label, the term "claim" refers to information that attributes value to the product. The term extends to many different types of information, from product identity, descriptors of intended use, and identification of characteristic properties to the physiologic effects in the body of substances in the food, including the reduction of risk of disease. Food labeling, which includes claims, provides information that consumers want and use to improve their diets. Consumers prefer short statements on the front label claims to longer, more detailed information, including ingredients statements and a nutrition panel. Three types of claims are permitted in the United States. Nutrient content claims describe the level of the nutrient in the food relative to an established daily value, e.g., "Excellent source of choline," and are subject to composition limits for other nutrients, such as total fat, saturated fat, and cholesterol. Health claims describe the relation between a food substance and the risk of disease, e.g., "Adequate calcium and vitamin D throughout life, as part of a well-balanced diet, may reduce the risk of osteoporosis." They must undergo a premarket evaluation by the FDA to ensure that there is significant scientific agreement about the relation in question. The third type of claim, structure-function (SF) claims, has recently come under scrutiny, particularly regarding their use on infant formula. Such claims represent a food's effect on the structure or function of the body for maintenance of good health and nutrition. These claims must be truthful and not misleading, but are not subject to premarket approval before use. The purpose of this perspective is to describe the origins and unique niche of SF claims, and to comment on recent proposals to further regulate such claims on infant formula.

Assessment of Obstetric and Gynecologic Food and Drug Administration Device Approvals and Recalls

Study ObjectiveTo evaluate and compare the recall rates of obstetric and gynecologic devices approved via the Food and Drug Administration's 510(k) and premarket approval (PMA) processes. DesignA retrospective observational study (Canadian Task Force classification II-2). SettingClinical settings in the United States that use obstetric and gynecologic devices. SubjectsTwo thousand two hundred forty-nine Food and Drug Administration–approved obstetric and gynecologic devices that were recalled between November 1, 2002, and December 31, 2017. Measurements and Main ResultsThe class of device, class of recall, date of recall, and original approval process were obtained for each device. These were compared against the total number of approved devices during this time period in the PMA and 510(k) processes. Recall proportions of each process were calculated and compared. A total of 685 devices were approved via the PMA process, and 1564 devices were approved via the 510(k) process in the observed time period. Of these, 1.17% of the PMA-approved devices and 15.98% of the 510(k)-approved devices were recalled (p < .001). There was an overall increase in absolute device recall numbers over time in the 510(k) process, whereas the number of recalls in the PMA process did not change with time. ConclusionThe recall event rate for the 510(k) approval process is 13.6 times the rate for the PMA approval process for obstetric and gynecologic devices. Analysis of the results suggests improper device risk classification, inappropriate assignment of the approval process, increased device malfunctions, recalls by the 510(k) process and, therefore, increased risk to patients by these devices. This warrants a call for improvement and increased scrutiny in the 510(k) approval process for devices used in obstetrics and gynecology.

Abstract 280: Strength of Clinical Trial Evidence for High-Risk Cardiovascular Devices Approved Through Food and Drug Administration (FDA) Priority Review

Importance: There is increasing emphasis on getting medical devices to market more quickly by use of priority review pathways, promoted in recent US Food &amp; Drug Administration (FDA) guidance documents and the 21 st Century Cures Act of 2016. Objective: To evaluate the impact of priority review pathways for high-risk cardiovascular devices by analyzing the quality and characteristics of premarket clinical studies in support of their approval and the frequency of postmarket recalls. Design and Setting: Descriptive study of premarket clinical studies supporting all high-risk cardiovascular devices approved via the priority review premarket approval (PMA) pathway between January 1, 2005 and June 15, 2017. Exposure: Priority Review PMA Main Outcome(s) and Measure(s): For all clinical studies which supported priority review PMAs we analyzed: number of patients enrolled, number of patients analyzed for each primary endpoint, demographic information, randomization, blinding, use and type of controls, use of training patients, number and location of study sites, and time of FDA review to approval. We also determined if a post hoc analysis was conducted. We counted all Class 1 and Class 2 recalls and examined FDA expert device panel recommendations. Results: There were 16 priority review cardiovascular devices approved, with mean 1.4 (SD 0.6, range 1-3) pivotal studies per device. Eleven of 16 (69%) were approved based on a single pivotal study. Of 23 pivotal studies, ten (43%) were randomized, 3 (13%) were single-blinded, and none were double-blinded. Twelve (52%) used a noninferiority primary endpoint hypothesis for at least one endpoint and 18 (78%) used a surrogate endpoint. Of the 11 votes on device effectiveness by FDA expert panels, 6 (55%) voted devices were effective. There were a total of 18 Class 1 and 2 recalls for 7 of these devices. Conclusions and Relevance: Most priority review pathway high-risk cardiovascular devices are approved without a randomized or blinded trial. Noninferiority design and use of surrogate endpoints are common. These devices are frequently subject to recalls.

Optimizing outcomes with polymethylmethacrylate fillers.

The ideal filler should be long-lasting, biocompatible, chemically inert, soft and easy to use, and have a long history of safety. This review focuses on the evolution and development of the PMMA-collagen gel, Bellafill, and the 10years of postmarketing experience of Bellafill since it received premarket approval (PMA) from the FDA as Artefill in 2006. Artefill was rebranded to Bellafill in 2015. The authors conducted a literature search on PubMed for key articles describing the steps in which Arteplast, a PMMA filler developed in 1989, led to the development of Bellafill, the only PMMA filler approved by the US FDA for the treatment of nasolabial folds and acne scar correction. The factors governing efficacy and safety were also evaluated for the major PMMA fillers available in the world. The process of manufacturing and purifying PMMA has played a major role in minimizing adverse events for Bellafill. Postmarketing surveillance data for the 2007-2016 period show that for more than 530000 Bellafill syringes distributed worldwide, 11 confirmed granulomas (excluding clinical trial data) (0.002% of syringes sold) have been reported. Data on other PMMA fillers are limited and inconsistent. The authors suggest that adverse events are often attributable to lack of proficiency in treatment technique and other factors. Bellafill has demonstrated an excellent safety and effectiveness profile in multiple clinical studies, customer feedback, and 10years of postmarketing surveillance experience. Adverse events occur with all fillers for a variety of reasons. In addition to quality of the product, injector skill and technique are critical to ensuring good clinical outcomes.

Abstract P5-02-04: Opto-acoustic imaging of breast masses: Correlation with breast biopsy prognostic indicators

Abstract Purpose: The Imagio™ OA/US breast imaging system, a diagnostic opto-acoustic (OA) imaging device bearing the CE Mark, is in the U.S. FDA Premarket Approval process. OA/US provides both functional (relative oxygenation/de-oxygenation) and anatomic (angiogenesis) information that is co-registered and temporally interleaved in real time with gray-scale ultrasound that may improve discrimination between benign and malignant masses. We recently reported correlation studies demonstrating tumor-zone specific OA attributes in histopathologic grade I versus grade III malignancies. The relationship between OA attributes (individual feature scores or summed feature results) and pathologically-determined prognostic markers (PDPM) in malignant lesions is the subject of this report. Materials and Methods: In this HIPAA-compliant, IRB-approved prospective multi-center trial across 16 U.S clinical sites; 1,808 masses in 1,739 subjects assessed as BI-RADS 3, 4 or 5 were imaged with OA/US. Of these, 655 were invasive malignancies and the subject of this analysis. Each mass was scored by 8 blinded readers on 3 internal zone features of the tumor nidus and 2 external features (0-5, 6) of the tumor boundary and peripheral zones (OA attributes). Pathologic diagnoses were confirmed by an experienced central breast pathologist blinded to the OA assessment. Tumor histologic classification and grading was performed in all subjects.Evaluation of tumor estrogen receptor (ER) and progesterone receptor (PR) were performed at each site by immunohistochemistry (IHC) and was reported as percent of tumor cells expressing the receptor or, as positive if greater than 1%. Tumor HER2-neu expression was reported by IHC as 0, 1+ (negative, not over-expressed), 2+ (indeterminate) and 3+ (over-expressed). All 2+ results reflexed to fluorescence in-situ hybridization (FISH) and reported as over-expressed or not over-expressed. Tumor Ki-67 expression was evaluated with IHC and reported as percent of tumor cells positive for the antigen. Statistical analysis of categorical measures of PDPM is in process and will be performed using a two-way Analysis of Variance (ANOVA) and Tukey HSD (honest significant difference) test for pairwise comparisons. This ANOVA will be repeated for each PDPM to test which specific PDPM sub-categories are related to OA attributes. Correlation coefficients will be generated for PDPM that are continuous, not categorical. All statistical testing will be done at a 5% significance level. Results: A total of 655 invasive and 22 DCIS were scored for internal (nidus) and external (boundary and periphery) OA attributes and compared with PSBC as defined by ER, PR, Her2 and Ki-67 expression. Of these, 108 were Luminal-A (LA), 153 Luminal-B (LB), 80 Triple-negative (TN), 23 Her2-enriched (HER2) and 314 unclassified (including 22 DCIS). OA attributes differentiated LA (99%CI 2.8,3.1) from TN (99%CI 3.1,3.4), p=0.027 and HER2 (99%CI 3.1,3.6), p=0.036. OA features strongly suggested LA vs. LB (99%CI 3.1,3.3) subtype, p=0.060. LB vs.TN(p=0.59) and HER2(p=0.41) were non-significant. TNBC vs. HER2 was p=0.62. Citation Format: Grobmyer SR, Butler R, Neuschler EI, Stavros AT, Aitchison RD, Lavin PT, Tucker FL. Opto-acoustic imaging of breast masses: Correlation with breast biopsy prognostic indicators [abstract]. In: Proceedings of the 2017 San Antonio Breast Cancer Symposium; 2017 Dec 5-9; San Antonio, TX. Philadelphia (PA): AACR; Cancer Res 2018;78(4 Suppl):Abstract nr P5-02-04.

Transparency and Dermatologic Device Approval by the US Food and Drug Administration

The US Food and Drug Administration approves Class III medical devices via the premarket approval pathway, often requiring clinical data on safety and efficacy. Manufacturers can submit incremental device changes via supplemental applications, which are not subjected to such vetting measures and can cause understudied changes that lead to drift from a device's original design. To characterize the postapproval changes to Class III dermatologic devices and to evaluate inconsistencies in the use of the premarket approval pathway. This study was a cross-sectional retrospective cohort analysis of a public US Food and Drug Administration database for premarket approval of devices. Included were dermatologic devices approved by the US Food and Drug Administration between January 1, 1980, and November 1, 2016, through the premarket pathway for device approval. Original devices were identified, and their supplements were characterized chronologically, by review track, and by modification category. The 27 dermatologic devices studied consisted of 14 injectables, 11 photodynamic therapies, a dermal replacement matrix, and a diagnostic imaging instrument. Supplemental applications are increasingly used: the data-requiring panel-track pathway was the least common approach (2.8% [16 of 562 supplements]), while the 30-day track, which does not require clinical data, was most frequently used (42.5% [239 of 562 supplements]). Four devices (14.8%) underwent low-risk recalls (Class II or Class III), and 10 devices (37.0%) were voluntarily withdrawn. As manufacturers make increasing use of supplemental applications, minor device changes may occur without supporting clinical data, which could pose a safety risk to patients.

Invited commentary

Invited commentary

510(k) Premarket Notification

Premarket approval application is not essential but 510(k) must submit to FDA to market medical device in the U.S for human use. To conclude or to determine the device is substantially equivalent to the device which is already marketed. After getting a 510(k) clearance immediately device can be marketed by submitter. In such case where already marketed device is changed in its safety or effectiveness it might affect the manufacturer and there is essential to file a 510(k) submission by manufacturer. Manufacturer should submit 510(k) to FDA in case of modifications or changes in use, chemical composition, design, energy source etc,.510(k) submission depends upon the comparison between the already marketed device and new device in the U.S, to ascertain whether the device is safety and effectiveness.2

The Importance of Verifying Reference Intervals for Calculated Results.

Reference intervals are the basis for interpreting laboratory test results. Therefore, establishing or verifying appropriate reference intervals is an essential component of proper test utilization as the reference limits define the bounds of a healthy population. While it is an accepted clinical laboratory practice to establish or verify reference intervals for measured analytes, this practice can be overlooked for calculated values such as the anion gap ([Na+] − [Cl−] − [HCO3−]), the globulin fraction ([total protein] − [albumin]), and other calculations involving measured quantities. Although manufacturers establish reference intervals for measured analytes as part of the premarket approval process, they are …

The cVAD registry for percutaneous temporary hemodynamic support: A prospective registry of Impella mechanical circulatory support use in high-risk PCI, cardiogenic shock, and decompensated heart failure

The current catheter-based ventricular assist devices registry is an international database documenting outcomes with temporary Impella hemodynamic support. The registry has supported 8 publications and 4 Food and Drug Administration premarket approvals since its inception in 2009. The current registry is more robust containing outcomes up to 1 year postprocedure.

Major FDA medical device recalls in ophthalmology from 2003 to 2015

ObjectiveTo assess recent high-risk ophthalmic medical device recalls. MethodsThe publicly available Food and Drug Administration Center for Devices and Radiological Health database was mined for Class I (high-risk) ophthalmic device recalls from January 1, 2003 to December 31, 2015. The number of Class I ophthalmic device recalls was quantified. Additionally, recall characteristics and market entry data were determined for each device. ResultsTwelve Class I ophthalmic device recall events were identified, collectively affecting over 68 million units in distribution. A median of 147,491 units (range 20 to 57,252,581) were recalled per event. 9 out of 12 recalls (75%) had at least one documented occurrence of an adverse event to a patient. Pre-market related issues accounted for one device recall (8%), post-market related issues accounted for nine device recalls (75%), and two device recalls (17%) were indeterminate. 510(k) clearance was the most common pathway to market, accounting for 50% of Class I recalls. Three devices were approved through pre-market approval (PMA) pathway, two devices were exempt from review, and one device failed to register with the FDA. ConclusionClass I recalls surrounding ophthalmology are relatively infrequent compared to other medical specialties. However, given the impact of Class I recalls in the field, ophthalmologists have an impetus to advocate for stronger device regulation particularly in the context of post-marketing surveillance.

Characteristics of Clinical Studies Used for US Food and Drug Administration Approval of High-Risk Medical Device Supplements

High-risk medical devices often undergo modifications, which are approved by the US Food and Drug Administration (FDA) through various kinds of premarket approval (PMA) supplements. There have been multiple high-profile recalls of devices approved as PMA supplements. To characterize the quality of the clinical studies and data (strength of evidence) used to support FDA approval of panel-track supplements (a type of PMA supplement pathway that is used for significant changes in a device or indication for use and always requires clinical data). Descriptive study of clinical studies supporting panel-track supplements approved by the FDA between April 19, 2006, and October 9, 2015. Panel-track supplement approval. Methodological quality of studies including randomization, blinding, type of controls, clinical vs surrogate primary end points, use of post hoc analyses, and reporting of age and sex. Eighty-three clinical studies supported the approval of 78 panel-track supplements, with 71 panel-track supplements (91%) supported by a single study. Of the 83 studies, 37 (45%) were randomized clinical trials and 25 (30%) were blinded. The median number of patients per study was 185 (interquartile range, 75-305), and the median follow-up duration was 180 days (interquartile range, 84-270 days). There were a total of 150 primary end points (mean [SD], 1.8 [1.2] per study), and 57 primary end points (38%) were compared with controls. Of primary end points with controls, 6 (11%) were retrospective controls and 51 (89%) were active controls. One hundred twenty-one primary end points (81%) were surrogate end points. Thirty-three studies (40%) did not report age and 25 (30%) did not report sex for all enrolled patients. The FDA required postapproval studies for 29 of 78 (37%) panel-track supplements. Among clinical studies used to support FDA approval of high-risk medical device modifications, fewer than half were randomized, blinded, or controlled, and most primary outcomes were based on surrogate end points. These findings suggest that the quality of studies and data evaluated to support approval by the FDA of modifications of high-risk devices should be improved.