FDA’s Patient Preference Initiative: The Need for Evolving Tools and Policies
By: Nina L. Hunter, Ph.D., and Robert M. Califf, M.D.
Last week we announced FDA’s first-ever Patient Engagement Advisory Committee, which will provide advice to the FDA Commissioner on complex issues relating to medical devices, the regulation of devices, and their use by patients. We thought it would be good to step back and fill you in about our Patient Preference Initiative.
In 2013, the FDA launched the Patient Preference Initiative, now led by Kathryn O’Callaghan, (Acting) Associate Director for Science and Strategic Partnerships at FDA’s Center for Devices and Radiological Health (CDRH). With this initiative, FDA’s CDRH expanded upon the current approach for capturing patient-centered perspectives in itsstructured benefit-risk framework, to outline a way of incorporating patients’ views on benefits and risks together with those of FDA’s health care professionals, scientists, and engineers during regulatory decision-making about certain medical devices.
This approach incorporates scientific, empirical evidence from different patients who, as a group, may have a range of views about the degree and types of risks associated with a medical device and how risks should be weighed against the anticipated benefits. When circumstances are appropriate and the data meets the requisite standard, device reviewers at the FDA can consider patient preference data in the overall evaluation of certain devices along with evidence from clinical and nonclinical testing.
If the device is ultimately cleared or approved, the product labeling could include a description of the range of patient preferences and characteristics described by those data, providing patients and healthcare practitioners with key information to make well-informed decisions. It is important to reiterate that FDA would not approve a device if it determines the device would expose patients to an unreasonable or significant risk of illness or injury, or that the benefits do not outweigh the risks for a defined target population.
As we increasingly work to incorporate the perspectives of patients when evaluating technologies for regulatory approval, we will also need better tools in order to accurately capture and characterize patient views on acceptable balances of benefits and risks. And as this new science of patient preferences continues to evolve, policies must likewise continue to be adapted as approaches are refined.
The FDA, through CDRH and the Center for Biologics Evaluation and Research (CBER), released Draft Guidance on patient preference information this spring. When finalized, this will help device-makers and other stakeholders assess patient valuations of benefit and risk related to relevant device types, illnesses, and conditions. It will also facilitate more systematic consideration of patient views as part of structured benefit-risk assessments for new medical devices. In time, as patient groups, industry, and others conduct more patient preference studies, the FDA and others will better understand patients’ perspectives on benefits and risks, and tradeoffs they are willing to make. This research has the potential to drive more patient-centered device innovation, assessment and access.
The draft guidance provides a case study for such patient-centered device regulation. A recent study conducted by FDA scientists Drs. Martin Ho and Telba Irony and researchers at RTI Health Solutions demonstrated that robust empirical data can be successfully elicited from patients and used to inform deliberations surrounding the approval of a medical product—in this case, the first device for treating obesity to beapproved by the FDA since 2007. This pioneering work was a fundamental step forward in our efforts to develop the best methods and practices for systematically incorporating patient preferences into device development and assessment.
As part of the Patient Preference Initiative and other activities to better integrate patient views into our decision making, the FDA is working with others to advance the science of patient input. In our next FDA Voice blog post we will expand on this growing dimension.
The FDA recognizes the potential benefit to be gained from understanding and applying patient input to spur patient-centered medical product innovation and inform patient-centered regulation. We believe that by better understanding patients’ experiences, needs, and views, we will be able to improve the development of medical products and enhance the safe and effective use of those products.
Nina L. Hunter, Ph.D., is a Regulatory Scientist in the Center of Devices and Radiological Health, currently on detail as a Special Assistant for Medical Policy to the Office of Medical Products and Tobacco.
Robert F. Califf, M.D., is FDA’s Deputy Commissioner for Medical Products and Tobacco.
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