FDA Flexible in Weighing Medical Device Uncertainty

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CDRH Office of Gastrorenal, OBGYN, General Hospital and Urology Devices clinical deputy office director Charles Viviano says CDRH uses a flexible approach in assessing the impact of uncertainty on benefit-risk determinations for PMAs, de novo submissions, and HDEs. Speaking on a 10/16 Webinar on a new “uncertainty guidance,” Viviano said the agency’s approach “is tailored to the type and intended use of the device and the type of decision we are making. To provide clarity on how FDA will assess for the appropriate extent of uncertainty when planning the collection of clinical data, we have identified factors to consider during this process.”

According to Viviano, there are some circumstances in which the agency may accept greater uncertainty about a medical device’s probable benefits and risks because of the greater probable health benefits of earlier patient access. And, he said, it may be appropriate to collect additional data in the post-market setting, rather than pre-market, to address the greater uncertainty about a device’s probable benefits and risks, provided that the statutory standards for pre-market approval are met.

Factors considered in determining the extent of uncertainty in clarifying the clinical evidence needed to support pre-market decisions includes device type, patient population characteristics, the device’s intended use, and the type of decision FDA is making, among others, Viviano said.

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