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The impact of regulation and payment innovations on acquisition of new imaging technologies.

Increasing concerns about the cost of health care in this country and uncertainties about the marginal benefits of the growing number of diagnostic imaging techniques available to clinicians have resulted in a number of changes in regulatory and payment policies that could have a major impact on the rate at which technologic innovations are adopted in the future. Three of these policies--FDA premarket approval, Medicare's prospective payment system, and state-run capital expenditure review programs--have been examined in this article. Experience with the FDA premarket approval process has been limited. The diffusion of MR imagers, the first imaging devices to have required premarket approval, does not appear to have been constrained by the premarket approval process. In contrast, the existence of certificate-of-need regulations and the institution of prospective payment are likely to restrain the rate at which hospitals acquire new technologies in the future. This impact is likely to be most marked in the case of technologies that increase the cost of patient care. The challenge to manufacturers will be to develop new techniques that improve patient care at an affordable price or that maintain the current quality of care at less cost. Researchers and clinicians, in turn, will need to identify those innovations that are likely to be most beneficial and to develop the data necessary to help utilize limited health care dollars in a fiscally and socially responsible way.

Aged↗

Regulatory hurdles in bringing an in vitro diagnostic device to market.

We discuss the hurdles that developers and manufacturers of in vitro diagnostic devices face in obtaining regulatory approval to market their products in the US. A thorough understanding of medical device regulation and the early planning of a clinical and regulatory strategy are imperative in assuring successful and timely launches of new products. Finally, it is critical for manufacturers to establish a working partnership with the Food and Drug Administration to expedite their new product applications.

Consumer Product Safety↗

Emergency ventricular assist device: better survival rates in non-post cardiotomy-related cardiogenic shock.

OBJECTIVE: The Abiomed BVS 5000 ventricular assist device (VAD) has been approved in Belgium for emergency cardiac support in patients with postcardiotomy failure with the aim of native heart function recovery. Other indications have emerged from world wide experience, but the indication and usefulness of emergency implantation of assist devices is often debated. METHODS: To decide which patients benefit most from emergency ventricular assist device implantation, we retrospectively reviewed our results of mechanical circulatory support with Abiomed in 20 patients over a 4-year period. Fifteen patients with mean age 58 +/- 6 years experienced postcardiotomy failure and underwent biventricular assist device (BVAD) implantation (group A), after elective (n = 9) or after emergency coronary artery bypass grafting (CABG) (n = 6). Five patients (group B), with mean age 35 +/- 19 years, had an implantation for other underlying conditions: hypertrophic cardiomyopathy (n = 3), myocarditis (n = 1) and primary cardiac allograft failure (n = 1). RESULTS: Of these two groups, eight and two patients respectively needed cardiopulmonary resuscitation before VAD implantation. The mean duration of support in both groups was 5.8 (range 12 h-13 days) and 4.4 days (range 2 h-9 days) respectively. Six and two patients could be weaned from the device and nine and one patients respectively, died on the device. Two patients in group B underwent successful heart transplantation and four patients in group A died after weaning. Two patients in the postcardiotomy group and four patients in group B survived (13% and 80%) with an overall survival and discharge rate of 30%. CONCLUSION: Although sample sizes are small, better survival rates with emergency Abiomed BVS 5000 implantation were obtained in the non postcardiotomy group (group B). For patients in the postcardiotomy group, outcome was negatively influenced by cardiac arrest and resuscitation before urgent CABG. Since death is the only alternative for these patients in cardiogenic shock and organ recovery cannot be predicted, we continue to consider emergency VAD implantation in this patient population.

Adolescent↗

Effect of regulatory and professional guidelines on the development and marketing of a dental device: case history.

The FDA encourages organizations such as the ADA to develop voluntary standards for drugs and dental devices. The landmark process of gaining ADA approval of an oral irrigator as the first therapeutic device is described. The process was time consuming and expensive, and obligates the manufacturer to submit all future marketing and advertising claims for ADA review. The ADA should continue to ensure standardized guidelines for all product categories. Education of the dental profession and the consumer concerning the significance of the ADA seal of approval is encouraged.

American Dental Association↗

Results of the phase I food and drug administration clinical trial of duct-occlud device occlusion of patent ductus arteriosus.

The purpose of this study was to evaluate the safety and the efficacy of transcatheter patent ductus arteriosus (PDA) occlusion with the Duct-Occlud device. Six centers participated in this phase I U.S. Food and Drug Administration-approved clinical trial with investigational device exemption. Patients with restrictive PDA (less than 4-mm minimum diameter) were eligible for the study. Sixty-two patients were enrolled. Forty-eight patients had successful implantation of Duct-Occlud devices. Patient follow-up evaluations were conducted at hospital discharge and after 2 and 12 months. At discharge and after 1 year, all patients had clinical PDA closure. Closure assessed by color flow Doppler was 55% at discharge, 88% at 2 months, and 94% at 1 year. There were no complications related to implantation or noted in follow-up evaluations. The Duct-Occlud device is safe and efficacious for the closure of small- to moderate-size patent ductus arteriosus.

Cardiac Catheterization↗

The Ancure endografting system: an update.

The Ancure endografting system (Guidant Cardiac and Vascular Division, Menlo Park, Calif) features a unibody, nonsupported woven polyester graft designed to treat abdominal aortic aneurysms. It is constructed in tube, bifurcated, and aortoiliac configurations. The attachment system consists of a frame with four independent V-shaped double hooks that penetrate the arterial wall for fixation. There are separate attachment systems at the proximal and distal ends of the endoprosthesis. In September 1999, the Food and Drug Administration (FDA) approved the tube and bifurcated devices for general use. The aortoiliac device is under present consideration of the FDA. Phase II and III clinical trials of the system enrolled over 870 patients from the end of 1995 to the summer of 1999. The device was deployed successfully in 90% to 96% of cases, depending on the configuration and the phase of the trial. Mortality rates were similar to those of concurrent open surgical control rates, but serious morbidity was reduced. Long-term follow-up of the bifurcated group from phase II showed only one migration and no ruptures. Aneurysm size reduction in this group was noted in 51.3% of patients at 1 year and 68.5% at 2 years. In the same subset, type I endoleaks were noted in 2.7% at 1 year and 1.3% at 2 years. All postoperative imaging studies were reviewed by a core laboratory facility. The advantages of the ancure system include solid fixation, flexibility in accommodating morphologic changes, and excellent long-term clinical performance. The disadvantages include a large introducer system and the potential for limb obstruction by compression or angulation. However, limb compromise responds well to intraluminal stenting. The expected FDA approval of the aortoiliac device and a larger variety of graft sizes should expand the number of patients who can be treated with this system.

Angioplasty↗

Long-term mechanical circulatory support system reliability recommendation: American Society for Artificial Internal Organs and The Society of Thoracic Surgeons: long-term mechanical circulatory support system reliability recommendation.

Jointly developed by members of the American Society for Artificial Internal Organs and the Society of Thoracic Surgeons along with staff from the Food and Drug Administration, the National Heart, Lung and Blood Institute and other experts, this recommendation describes the reliability considerations and goals for Investigational Device Exemption and Premarket Approval submissions for long-term, mechanical circulatory support systems. The recommendation includes a definition of system failure, a discussion of an appropriate reliability model, a suggested in vitro reliability test plan, reliability considerations for animal implantation tests, in vitro and animal in vivo performance goals, the qualification of design changes during the Investigational Device Exemption clinical trial, the development of a Failure Modes Effects and Criticality Analysis, and the reliability information for surgeons and patient candidates. The document will be periodically reviewed to assess its timeliness and appropriateness within five years.

Animals↗

Regulatory issues for computerized electrocardiographic devices.

Computerized electrocardiogram (ECG) devices are regulated in the U.S. by the FDA Center for Devices and Radiological Health (CDRH). This article aims to highlight the salient points of the FDA regulatory review process, including the important distinction between a "tool" claim and a "clinical" claim in the intended use of a computerized ECG device. Specifically, a tool claim relates to the ability of the device to accurately measure a certain ECG parameter, such as T-wave alternans (TWA), while a clinical claim imputes a particular health hazard associated with the identified parameter, such as increased risk of ventricular tachyarrhythmia or sudden death. Given that both types of claims are equally important and receive the same regulatory scrutiny, the manufacturer of a new ECG diagnostic device should consider the distinction and regulatory pathways for approval between the two types of claims discussed in this paper.

Death, Sudden, Cardiac↗

Can minimum separation criteria ensure electromagnetic compatibility in hospitals? An experimental study.

Electromagnetic interference (EMI) from radiofrequency (RF) sources can cause medical device malfunction. It has been proposed that such EMI be minimized by only operating sources of given RF powers when sufficiently separated from medical devices of given immunities. Such minimum separation criteria are estimated assuming free-space propagation, which is only valid in the ideal case. Yet proposed medical device EMC standards will require that minimum-separation criteria be listed in equipment manuals accompanying all new medical devices. It is essential that the practical utility of such minimum-separation criteria be evaluated. Fields due to an 800-MHz-type cellphone were measured in various rooms and corridors within an urban hospital, having both new (gyprock) and old (clay-block) wings. Data obtained from a calibrated antenna attached to a spectrum analyzer were repeatedly measured and averaged. Results were compared to those predicted by free-space propagation. Free-space predictions tended to overestimate measured fields in gyprock rooms and along corridors of both gyprock and clay-block construction. However, the free-space model tended to underestimate field levels predicted in clay-block rooms and in below-ground corridors. Usage of separation criteria to ensure EMC appeared useful in gyprock rooms and hospital corridors, but less so in rooms with clay-block walls or in below-ground sections of the hospital. This suggested that the latter regions should be considered as being special zones where side-by-side operation of RF sources and medical devices would require more conservative management (e.g., restriction or special approval of particular source or medical device).

Electric Conductivity↗

The impact of patient self-testing of prothrombin time for managing anticoagulation: rationale and design of VA Cooperative Study #481--the Home INR Study (THINRS).

BACKGROUND: Anticoagulation (AC) with warfarin reduces the risk of thromboembolism (TE) in a variety of applications, yet despite compelling evidence of the value and importance of high quality AC, warfarin remains underused, and dosing is often suboptimal. Approaches to improve AC quality include (1) an AC service (ACS), which allows the physician to delegate day-to-day details of AC management to another provider dedicated to AC care, and (2) incorporating into the treatment plan patient self-testing (PST) under which, after completing a training program, patients perform their own blood testing (typically, using a finger-stick blood analyzer), have dosage adjustments guided by a standard protocol, and forward test results, dosing and other information to the provider. Studies have suggested that PST can improve the quality of AC and perhaps lower TE and bleed rates. The purpose of Department of Veterans Affairs (VA) Cooperative Studies Program (CSP) #481, "The Home INR Study" (THINRS) is to compare AC management with frequent PST using a home monitoring device to high quality AC management (HQACM) implemented by an ACS with conventional monitoring of prothrombin time by international normalized ratio (INR) on major health outcomes. PST in THINRS involves use of an INR monitoring device that is FDA approved for home use. STUDY DESIGN: Sites are VA Medical Centers where the ACS has an active roster of more than 400 patients. THINRS includes patients with atrial fibrillation (AF) and/or mechanical heart valve (MHV) expected to be anticoagulated indefinitely. THINRS has two parts. In Part 1, candidates for PST are evaluated for 2 to 4 weeks for their ability to use home monitoring devices. In Part 2, individuals capable of performing PST are randomized to (1) HQACM with testing every 4 weeks and as indicated for out of range values, medication/clinical changes, or (2) PST with testing every week and as indicated for out of range values, medication/clinical changes. The primary outcome measure is event rates, defined as the percent of patients who have a stroke, major bleed, or die. Secondary outcomes include total time in range (TTR), other events (myocardial infarction (MI), non-stroke TE, minor bleeds), competence and compliance with PST, satisfaction with AC, AC associated quality of life (QOL), and cost-effectiveness. To assess the effect of PST frequency on TTR and other outcomes, at selected sites patients randomized to perform PST are assigned one of three test frequencies (weekly, twice weekly, or once every four weeks).

Anticoagulants↗

Medical devices; substantial equivalence; 510(K) summaries and 510(K) statements; class III summaries; confidentiality of information--FDA. Final rule.

The Food and Drug Administration (FDA) is issuing this final rule to implement the provisions of the Safe Medical Devices Act of 1990 (the SMDA) that require all persons who submit a premarket notification (510(k)) to provide to FDA, as part of the submission, an adequate summary (510(k) summary) of any information respecting safety and effectiveness or a statement (510(k) statement) that such information will be made available upon request by any person. This rule also implements the requirement of the SMDA that 510(k) submitters claiming substantial equivalence to a class III preamendments device for which FDA has not yet called for premarket approval submit a class III summary and certify that they have conducted a search of safety and effectiveness data. In addition, this rule amends the device regulations governing the confidentiality of certain premarket notification submissions to conform to the SMDA. This rule also provides that persons who submit a premarket notification must certify that, to the best of their knowledge, all information is truthful and accurate and that no material fact has been omitted.

Confidentiality↗

Medtronic, Inc.; premarket approval of the Interstim Sacral Nerve Stimulation (SNS) System--FDA. Notice.

The Food and Drug Administration (FDA) is announcing its approval of the application by Medtronic, Inc., Minneapolis, MN, for premarket approval, under the Federal Food, Drug, and Cosmetic Act (the act), of the Interstim Sacral Nerve Stimulation (SNS) System. After reviewing the recommendation of the Gastroenterology and Urology Devices Panel, FDA's Center for Devices and Radiological Health (CDRH) notified the applicant, by letter of September 29, 1997, of the approval of the application.

Device Approval↗

Toward a treaty on safety and cost-effectiveness of pharmaceuticals and medical devices: enhancing an endangered global public good.

Expert evaluations of the safety, efficacy and cost-effectiveness of pharmaceutical and medical devices, prior to marketing approval or reimbursement listing, collectively represent a globally important public good. The scientific processes involved play a major role in protecting the public from product risks such as unintended or adverse events, sub-standard production and unnecessary burdens on individual and governmental healthcare budgets. Most States now have an increasing policy interest in this area, though institutional arrangements, particularly in the area of cost-effectiveness analysis of medical devices, are not uniformly advanced and are fragile in the face of opposing multinational industry pressure to recoup investment and maintain profit margins. This paper examines the possibility, in this context, of States commencing negotiations toward bilateral trade agreement provisions, and ultimately perhaps a multilateral Treaty, on safety, efficacy and cost-effectiveness analysis of pharmaceuticals and medical devices. Such obligations may robustly facilitate a conceptually interlinked, but endangered, global public good, without compromising the capacity of intellectual property laws to facilitate local product innovations.

Journal Article↗

Approval process for implants in otolaryngology.

As the reader can see, the regulatory approval process for implant devices, especially those intended for use in otolaryngology, is complex. The procedural steps in filing IDE and PMA applications require an understanding of clinical trial design, sponsor responsibilities, investigator requirements and IRB oversight as well as concern for subject safety and welfare. For the most part, once these building blocks are in place and the events and procedures are understood, one can proceed in a fairly straightforward and efficient manner through the review and approval process.

Consumer Product Safety↗

Automated external defibrillators used by emergency medical technicians: report of the 1992 experience in Kentucky.

Automated external defibrillators (AED) have been authorized for use by Emergency Medical Technicians (EMT) in Kentucky since March 1991. Emergency Medical Services (EMS) which use these devices are required to submit annual reports to the EMS Branch. During 1992, 17 services were approved to use AEDs. The device was used by 12 services on 93 victims of out-of-hospital cardiac arrest. Of the 93 victims, 27 were defibrillated, eight were resuscitated to hospital admission, and three survived to hospital discharge. The overall survival rate was 3/93 (3.2%). For patients receiving defibrillatory shocks, the survival rate was 3/27 (11%). This percentage is comparable with the survival rates reported from other predominately rural states where AEDs have been used by EMTs. Possible protocol violations and inadequate documentation were also identified from these reports. In summary, EMTs in predominately rural Kentucky can use AEDs to achieve survival rates for out-of-hospital cardiac arrest comparable with other rural states.

Adult↗

Summary and Comparison of Patent Ductus Arteriosus Closure Devices.

A number of patent ductus arteriosus (PDA) occluding devices have been studied in an attempt to develop a transcatheter method of closure of PDA. Some devices were tested in only animal models, whereas others progressed to clinical trials in human subjects. Some devices have been discontinued, some received approval for general clinical use, and many have not yet received approval by regulatory authorities. No prospective randomized clinical trials have been undertaken and, therefore, data on separate clinical trials are used to determine relative efficacy of the devices. Selection of a method of PDA closure depends largely on its minimal diameter and to some degree on its shape. Silent PDAs do not need occlusion. Very small to small PDAs may be occluded by free or detachable Gianturco coils (Cook Cardiology, Bloomington, IN). Moderate-to-large PDAs require closure by devices, conventional surgery, and videothoracoscopic interruption. The choice in the latter group depends largely on the availability of a given method at a given institution at that particular time. Approval of several of the devices by regulatory authorities may result in conduct of prospective randomized clinical trials and use of a device or method most appropriate to the size and shape of the PDA.

Journal Article↗

Drugs, devices, diagnostics, and policies: the year's review.

Throughout 1999, the Food and Drug Administration approved several new drugs and medical devices. The agency also took an active role in defining public policies regarding pharmacologic issues for the American consumer. This article provides an overview of these topics.

Drug and Narcotic Control↗

Future options for aerosol delivery to children.

There is an increasing awareness of the importance of reliable aerosol delivery, with emphasis on the dose delivered to the lungs, optimal clinical control, cost-effectiveness, and safety in children. Dose prescription should relate to the expected lung dose rather than the factory-dispensed dose, as at present. The device determines the lung dose. Clearly, therefore, the device should be considered an integral part of the prescription. Drug approval processes should clearly specify the device, and discourage the use of other devices. This would rationalize the choice of devices. Important new insights into factors essential for drug delivery to the airways have been acquired in recent years. Nasal inhalation increases systemic bioavailability, reduces lung dose, and adds to its variability; hence, face masks to prevent nasal breathing have been developed. Similarly, dead space in the inspiratory line causes a proportional reduction in lung dose; hence, attention should be paid to reducing such dead space. Plastics in spacers cause a rapid loss of drug due to electrostatic attraction of the aerosol. The residence time of the aerosol, i.e., the time available for inhalation, is increased in nonelectrostatic spacers, allowing less compliant children enough time to obtain a full dose. Eliminating the electrostatic charge can change the lung dose by several times; hence, nonelectrostatic materials should be used in future spacer devices. Compliance is the biggest problem in drug delivery to children. The inhaler design process should be reversed, adapting technology to the child. Interactive microchip technology should provide intelligent devices that react to correct handling and breathing maneuvers. An intelligent nebulizer has been developed that adapts nebulization to the child's breathing pattern, nebulizing only during inhalation and avoiding loss of aerosol during exhalation. An automatic device (AirPac) has been developed that transforms a dry-powder inhaler, Turbuhaler, into a spacer. In addition to the general advantages of spacer treatment, this device offers the advantage of a drug aerosol delivered without use of propellants or additives. The mechanical actuation ensures highly repeatable drug delivery. Finally, a nonelectrostatic, tower-shaped spacer provides a stable aerosol, which remains airborne for a prolonged period. The spacer is equipped with a face mask that prevents nasal breathing. Such features should improve our ability to treat young children with inhaled drug aerosols.

Aerosols↗