Changes in Sequencing Guidances Explained
A 5/24 CDRH Webinar on two precision medicine guidances outlined major changes between the 2016 draft guidances and the final documents issued 4/13. During the Webinar, Adam Berger from the CDRH precision medicine staff, said the scope of the final guidance on design, development, and analytical validation of next generation sequencing (NGS)-based in vitro diagnostics was clarified in response to comments on the draft that say the guidance only specifically applies to NGS-based tests that FDA continues to believe could form the basis of future FDA-recognized standards and/or special controls that could reasonably assure the tests’ safety and effectiveness.
The final guidance lays out a potential pathway whereby NGS-based tests intended to aid in the diagnosis of suspected germline diseases could be considered as candidates for down-classification to Class 2 devices, since all novel tests are Class 3 by default.
Berger said commenters were generally supportive of the proposed regulatory approach and asked for clarification of the background, scope, and certain technical recommendations. The guidance title was revised to better reflect scope and content, to acknowledge that currently there are no applicable standards that FDA can recognize, and to support community engagement in developing standards by standards-developing organizations.
He also explained that the analytical performance thresholds were removed from the final guidance, which now recommends that test developers pre-define, justify, and report minimum acceptable overall and target threshold metrics such as accuracy, precision, and coverage. Finally, clarifications in accuracy metrics, performance evaluation studies, and other technical recommendations were made in the guidance.