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1 Medical Device Registries: Multiple Applications Thomas P. Gross, MD, MPH Director Division of Postmarket Surveillance Office of Surveillance & Biometrics Center for Devices & Radiological Health AHRQ Annual Conference Registries for Evaluating Patient Outcomes Bethesda, Md. September 9, 2008
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2 Registry as a Vehicle: Regulatory Applications Registry as a Vehicle: Regulatory Applications Pre- & Postmarket Safety &/or Effectiveness Discretionary & Mandatory Surveillance & Observational Study Descriptive & Analytic Pre- & Postmarket Safety &/or Effectiveness Discretionary & Mandatory Surveillance & Observational Study Descriptive & Analytic
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3 Registries: Premarket Perspective Potential Applications Provide data to support development & design of clinical trials Provide historical comparator data (if rigorous) Enhance safety assessments via broader analysis of adverse events Provide access to product (outside of IDE trial) Expedite approval of device modifications or labeling
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4 Registries: Premarket Perspective Safety Assessment Registries: Premarket Perspective Safety Assessment Adhesion Barrier Device Registry Voluntary, European experience, 4K patients Adjunct to U.S. pivotal, randomized trial Assess safety profile Self-reported events, “reassuring” profile
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5 Registries: Premarket Perspective Product Access Registries: Premarket Perspective Product Access PFO Occluder Device Registry Withdrawal of Humanitarian Device Exemption status Submission of Premarket Approval Applications required (supported by clinical trials) Access to device for those outside of clinical trials Voluntary, U.S., 2K patients
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6 Registries: Premarket Perspective Device/Labeling Changes Registries: Premarket Perspective Device/Labeling Changes Intra-ocular Lens Registry Assess performance of IOLs in adults < 60 years Established by American Academy of Ophthalmology Post-IOL acuity & adverse events on 7K eyes Indications changed allowing for younger age use
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7 Registries: Postmarket Perspective Potential Applications Provide surveillance for “real-world” events Assess generalizability of new technologies Expedite time to market with reliable postmarket data Provide vehicle for Post-approval Studies (PAS) Promote evidence development for CMS’ national coverage decisions (NCDs)
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8 INTERMACS: Enhanced Surveillance FDA Reports INTERMACS Complete information No Yes Validated data No Yes Adjudicated data No Yes Standard definitions No Yes Representative No We hope so Under-reported Yes We hope not Denominator data No Yes
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9 INTERMACS: Post-approval Studies Provides the necessary infrastructure Patient consent, IRB sign-off, data acquisition & quality Is cost efficient & allows for enhanced oversight Accommodates different study designs Temporary total artificial heart: single-arm registry; 30-day & 1 year survival, time on device, transplant rates, adverse events & product problems Left ventricular assist device: cohort design (recipients of designated device vs. concurrent recipients of other LVADs); similar outcome measures & including quality of life
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10 Registries: Postmarket Perspective Early “Real-World” Experience & PAS Registries: Postmarket Perspective Early “Real-World” Experience & PAS Drug-eluting Coronary Stent Registry Assess “real-world” experience Multiple sites (~50), 2K patients Sites vary by private/academic, implanting volume, geographic distribution Outcomes of interest: MACE, unanticipated events Descriptive findings Periodic follow-up at 1, 6, 12 months
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11 Registries: Postmarket Perspective FDA PAS & CMS NCD Carotid Stent Registry Carotid Stents: Initial Vehicle for post-approval study Assess “real-world” experience & training (3 levels) Multiple sites, 1K patients, 30-day follow-up Adjudicated neurological events Carotid Stents: Extension Expand under CMS coverage Explore risk factors associated with stenting Multiple sites, 10K patients, 30-day follow-up
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12 Registries: Postmarket Perspective Discretionary Study Hemostasis Device Registry Collaborative effort with American College of Cardiology (use of National Cardiovascular Data Registry) ~60 sites, 14K patients Assess gender differences & device-specific risk of hemorrhagic complications
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13 Registries: From a Disease Perspective Toxic Anterior Segment Syndrome (TASS) Non-infectious inflammation post-surgery (mostly cataract removal) Results in blurred vision to glaucoma or corneal transplant Outbreaks periodically reported Device relatedness is an issue viscoelastics? surgical instruments? Registry maintained at University of Utah & cases also accrued via ASCRS website Augment TASS registry with spontaneous reports & assess utility for identifying suspect causative agents
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14 FDA Registry Initiatives Expand existing registries National ICD registry (ACC NCDR & HRS): add lead safety fields (lead revision, extraction, abandonment & reasons for failure) Conduct linkage studies with Medicare data Society of Thoracic Surgeons National Cardiac Database: study long-term morbidity & mortality of transmyocardial revascularization ACC NCDR: study long-term cardiac morbidity & mortality of drug-eluting coronary stents
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15 FDA Registry Initiatives Compare registry performance Medicare claims vs. prospectively collected registry data from the Vascular Disease Study Group of Northern New England Morbidity & mortality associated with endovascular vs. open surgical repair of abdominal aortic aneurysm Nest investigational study within registry Uses PAS to expand indications Rigorous investigational study design
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16 FDA Registry Initiatives Sentinel Initiative*: an effort to develop a national, integrated infrastructure of electronic healthcare data systems for medical product safety surveillance Identify & characterize existing U.S. orthopedic implant registries. Explore potential for establishing distributed system. * http://www.fda.gov/oc/initiatives/advance/sentinel
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17 Thanks for Your Attention! For further information: thomas.gross@fda.hhs.gov
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