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What is an IDE? Is Clinical Data Conducted Outside the U.S. Acceptable? Carole C. Carey, BSEE, M.Engineering Director, International.

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Presentation on theme: "What is an IDE? Is Clinical Data Conducted Outside the U.S. Acceptable? Carole C. Carey, BSEE, M.Engineering Director, International."— Presentation transcript:

1 What is an IDE? Is Clinical Data Conducted Outside the U.S. Acceptable? Carole C. Carey, BSEE, M.Engineering Director, International Staff US Food and Drug Administration (USFDA) Center for Devices and Radiological Health (CDRH)

2 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Learning Objectives  To gain an understanding of the Investigational Device Exemption (IDE) regulations. The purpose of the IDE regulation The major regulatory elements that constitute medical device Good Clinical Practices Significant Risk and Non-Significant Risk Studies FDA review criteria Clinical trials outside U.S. and FDA jurisdiction

3 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver What is an IDE?  Investigational Device Exemption To encourage discovery and development of useful medical devices for human use, to the extent consistent with the protection of the public health and safety and with ethical standards, while maintaining optimum freedom for scientific investigators in their pursuit of that purpose.  Allows the use of unapproved devices. statutory authority, FDCA, Section 520(g) 21 CFR Part 812

4 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Definitions a PREMARKET device Investigational Device Is still in the developmental stage Is not considered to be in commercial distribution The object of a clinical investigation is to determine safety and effectiveness a MARKETED device Investigational Use Clinical evaluation of an already legally marketed device for a new intended use

5 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Applicable Regulations (Medical Device Good Clinical Practices)  21 CFR Part 812: Investigational Device Exemptions covers the procedures for the conduct of clinical studies with medical devices including application, responsibilities of sponsors and investigators, labeling, records, and reports.  21 CFR Part 50: Informed Consent, Human Subject Protections  Section elements of IC  Section IC waiver (emergency)  Section IC waiver (emergency research)  21 CFR Part 56: Institutional Review Boards covers the procedures and responsibilities for institutional review boards (IRBs) that approve clinical investigations protocols

6 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Applicable Regulations- cont’d (Medical Device Good Clinical Practices)  21 CFR 54, Financial Disclosure by Clinical Investigators, covers the disclosure of financial compensation to clinical investigators which is part of FDA’s assessment of the reliability of the clinical data.Financial Disclosure by Clinical Investigators  21 CFR 820 Subpart C, Design Controls of the Quality System Regulation, provides the requirement for procedures to control the design of the device in order to ensure that the specified design requirements are met.Design Controls of the Quality System Regulation IDEs are exempt from GMP/QSR (except Design Controls)

7 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver When is an IDE application required?  Research in human subjects conducted in the United States: To support device marketing application: PMA, HDE or 510(k) To collect safety and effectiveness information (e.g., for a new intended use of a legally marketed device) Unapproved devices or new intended use of approved device (even if no marketing application planned) by sponsor-investigator.

8 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver 8 The Regulatory Path 510k PMA IDE !!! MARKET !!! October 7, 2009

9 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Valid Scientific Evidence  Comes from… Well-controlled investigations Well-controlled investigations Partially-controlled investigations Partially-controlled investigations Studies & objective trials without matched controls Studies & objective trials without matched controls Well-documented case histories conducted by qualified experts Well-documented case histories conducted by qualified experts Reports of significant human experience with a marketed device Reports of significant human experience with a marketed device  Valid scientific evidence is NOT… Isolated case reports Isolated case reports Random experience Random experience Unsubstantiated opinions (e.g., testimonials) Unsubstantiated opinions (e.g., testimonials)

10 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Required Elements of an IDE  U.S. Sponsor (manufacturer or investigator)  Prior Investigations  Investigational Plan  Manufacturing Information  Investigator and IRB Information  Labeling  Informed Consent  Sales Information “CAUTION - Investigational device. Limited by Federal (or United States) Law to investigational use.”

11 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Investigational Plan  Purpose Name and intended use of device Objectives and duration of study  Written Protocol & Analysis Methodology and an analysis demonstrating scientific soundness Number of patients and sites Inclusion and exclusion criteria Statistical methods Case Report Forms

12 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Investigational Plan (cont’d)  Risk Analysis Description of all risks Justification for investigation  Description of the Device Each important component Principle of operation Copies of all labeling  Monitoring Procedures Monitor to oversee progress of investigtion

13 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Endpoints: Outcome Variables Parameters that determine study success:  Primary Effectiveness: The most clinically relevant parameters addressed by the clinical trial question  Safety Assessment: What are the expected & unexpected unfavorable outcomes & how can they be avoided?  Secondary effectiveness endpoints: Other parameters that support study success

14 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Strategies: Clinical Considerations For CDRH:  US studies must be conducted in compliance with the IDE regulations (21 CFR Part 812) Proper Informed Consent (21 CFR Part 50) Proper Informed Consent (21 CFR Part 50) IRB Regulations (21 CFR Part 56) IRB Regulations (21 CFR Part 56) Adequate monitoring Adequate monitoring  Dependent upon the data present & device characteristics, feasibility study often necessary prior to pivotal study Support proof of concept Support proof of concept Assist with refining inclusion/exclusion criteria Assist with refining inclusion/exclusion criteria Refine surgical technique Refine surgical technique Recommendation of pilot study with control group Recommendation of pilot study with control group

15 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Significant Risk Study is… a study that presents a potential serious risk to the health, safety, or welfare of a subject An implant for use in supporting or sustaining human life for a use of substantial importance in diagnosing, curing, mitigating, or treating disease or otherwise preventing impairment of human health  FDA and IRB Approval is required  Cardiac catheters  Surgical tissue adhesives  Vascular and arterial graft protheses  Dental endosseous implants  Cochlear implants  Implantable infusion pumps  Implantable pacemaker

16 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Non-significant Risk Study  Do not pose significant risk to research subjects  Sponsor presents protocol to IRB and a statement why investigation does not pose significant risk  If IRB approves the investigation as NSR, it can begin.  No IDE submission requirement to the FDA  Abbreviated IDE  Daily wear contact lenses  Glucose monitor  Magnetic resonance imaging (MRI)  Pulse oximeter  Ob/Gyn diagnostic ultrasound

17 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Abbreviated IDE  No formal FDA approval is needed  IRB is required to meet all aspects of: 21 CFR Part 50 (protection of human subjects) 21 CFR Part 56 (IRB)  Labeling requirements

18 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Studies Exempt from Part 812  Preamendments (pre-1976) devices  510(k)-cleared and HDE- or PMA-approved devices, If used in accordance with approved label  In vitro diagnostic devices (most)  Consumer preference testing of marketed devices  Combinations of legally marketed devices  Custom devices (are narrowly defined)  Studies outside the US: Declaration of Helsinki

19 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Approved IDEs are Exempt from… Registration Performance Standards 510(k) regs PMA regs Misbranding regs GMPs (except Design Controls) Color Additive requirements Banned Devices regs Restricted Device requirements

20 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Approved IDEs are NOT Exempt from…  Adulteration regs  Labeling regs  Prohibition on: promotion/marketing, commercialization, prolonging the investigation, representing the device as safe and effective  Import/Export Regs

21 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Bioresearch Monitoring (BIMO) Program  To ensure the quality and integrity of data and information submitted in support of research and marketing permits that include IDE, PMA, and 510(k) submissions, and  To ensure that human subjects taking part in investigations are protected from undue hazard or risk.

22 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Differing levels of regulatory control depending on the level of risk

23 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver FDA Review Criteria  Scientifically sound  Reasonably believed to be able to provide the desired results  Data from non-clinical studies support the proposed human research  Research conducted by qualified investigators

24 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver FDA Review Criteria (cont’d)  Expected benefit outweigh any expected risks  Research subjects fully informed to the risks involved in the research, understand these risks and freely volunteer to participate  IRB approval of the research

25 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver FDA Review Times and Decision  FDA review time for IDE is 30 days.  Within 30 days, FDA will approve, approve with conditions, or disapprove an IDE application.  For disapproved IDE, the sponsor can respond to the deficiencies and/or request hearing.

26 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Clinical Trials Outside U.S. (OUS)  “Acceptance of Foreign Clinical Studies: Guidance for Industry - Acceptance of Foreign Clinical Studies”, March 2001  FDA will accept a foreign clinical device study only if the study conforms to the ethical principles of the Declaration or with the laws and regulations of the country, whichever provides greater protection of the human subjects.  Subject to Human Subject Research Protections laws applicable in that country  Studies performed by clinical investigators of recognized competence

27 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Same scientific and data integrity standards  FDA does not have legal authority/jurisdiction outside of the United States  But FDA has authority to set conditions for accepting non-U.S. data that is used to support marketing (PMA, 510(k), HDE, etc.) in the U.S.  Once accepted for review, the same scientific and data integrity standards are applied as for studies conducted in the U.S.

28 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Early Consultation with FDA  If intended to support eventual marketing application in US, should: Reflect US medical practice patterns Reflect US medical practice patterns Reflect US patient population Reflect US patient population Ensure adequate documentation of good study conduct, availability of raw data Ensure adequate documentation of good study conduct, availability of raw data  Therefore: It is beneficial to consult with FDA (e.g., Pre-IDE) on clinical protocol beforehand if intended to support US marketing application

29 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver FDA Jurisdiction  FDA has jurisdiction over the export of unapproved devices exported for use in foreign studies.  FDA does not have jurisdiction over the manner in which the investigational study is conducted outside the U.S.  An IDE is not necessary for a study conducted entirely at foreign sites.  FDA has authority to accept or deny data that has been collected during a study at a foreign site that is submitted to support a research or marketing application.

30 FDA Regulatory Framework and Medical Device Workshop 2009 Sep 29 Edmonton 2009 Oct 1 Vancouver Summary  All clinical investigations subject to the regulation must be approved before they can begin.  All subjects in the investigation must give informed consent – human subject protection.  The basics of good clinical studies and good clinical practices are the same worldwide.


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