Harvard Analysis Backs Bills for New Device Regulatory Scheme
A new Harvard analysis lends support to recent bills introduced in the House and Senate that propose shorter “pre-market” clinical testing and better “post-market” surveillance than current standards for certain devices. The analysis is limited to coronary stents, and the researchers note their theoretical model “provides guidance on how to consider extrapolating to policy in other cases, doing so should be done with care.”
The researchers find that “if post-approval learning rates approach those we observe from clinical trials at a comparable cost, the benefits from such a policy change are substantial. In the extreme case where post-approval learning is fully informative and not too costly, the optimal policy is to require no pre-approval trials at all...”
The researchers find merit “to the argument that requiring shorter trials with enhanced post-approval testing could improve consumer welfare, but the gains from this policy critically depend on the rate and cost of learning via post-market surveillance,” according to the analysis. “For some products, observational learning from real world use may make it difficult to infer product quality (i.e., not having the randomization built into treatment and the control available in clinical trials). For other products, though—and likely for those in our sample—the problem is simply a lack of systematic data collection and sharing of information.”