Innovative Health Wants NSS-2 Bridge Restrictions

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Innovative Health Solutions is petitioning FDA not to make a determination of certain subject devices’ substantial equivalence to its NSS-2 Bridge nerve stimulator without preclinical studies and at least one clinical trial establishing non-inferiority of the subject device to the NSS-2 Bridge in head-to-head evaluations.

The petition notes that on 2/5/18 FDA classified percutaneous nerve stimulators for substance use disorders under Class 2 and promulgated special controls for clearance of the devices. “While we applaud FDA’s commitment to reducing regulatory burden through use of the de novo process, and paving the way for improved patient access to new, beneficial devices,” the company says, “we are concerned that the special controls promulgated for this classification are inadequate to assure the performance of any proposed device within this classification that is not essentially identical to the NSS-2 Bridge (the only current predicate) in terms of product design, labeling, and indications for use.”

The petition says that even seemingly minor differences in indication or design from the NSS-2 Bridge could negatively affect the performance of subject devices that will likely claim the NSS-2 Bridge as a predicate. It says that such performance effects are particularly problematic considering the vulnerability of the target population (individuals undergoing opioid withdrawal), who may be relying on the device as part of an overall treatment program to address addiction.

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