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Home/Legal & Regulatory and Reimbursement/FDA to Industry: “Teach Us”
Legal & Regulatory and Reimbursement

FDA to Industry: “Teach Us”

September 4, 2018 1 min read Premium comments

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FDA to Industry: “Teach Us”
Photo creation by RRY Publications, LLC and Pixabay
#fdaSecondary#experimentallearningprogram#premarketreview

The FDA wants device makers to invite the agency’s premarket review staff into their facilities to learn about industry practices.

The agency promises these formal training visits are not intended for agency staff to inspect, assess, judge, or perform a regulatory function such as compliance inspection.

Experiential Learning Program (ELP)

In 2017, the FDA’s Center for Devices and Radiological Health (CDRH) started the Experiential Learning Program (EL), for new and experienced review staff to learn about the real-world problems of device makers. The agency wanted to partner with industry to help reviewers understand the “policies, laboratory and manufacturing practices, and the challenges addressing patient perspective/input, quality system management, and other challenges that impact the device development life cycle.”

The agency said it recognized a knowledge gap between emerging and innovative technology and the pre-market review of the resulting medical devices. “Because technology continuously evolves, it is essential that CDRH review staff members are aware of and understands how medical devices are developed, clinically tested, manufactured, and used.”

CDRH encourages participation from companies, academia, and clinical facilities, medical device incubators and accelerators, health insurers, health technology assessment groups, and others, including those that have previously participated in the ELP or other FDA site visit programs.

Application Process

If you’d like to participate in the program, while establishing great contacts within the agency, you can submit a proposal during the Submission Period for proposal submissions. The Submission Period Status is currently open until noon on September 26, 2018.

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You may submit a proposal to the program by following the instructions on this link.

Typically, one site visit will address one Area of Interest and can last one or more days.

The Areas of Interest include:

  • Biocompatibility
  • Combination products
  • Clinical trials/clinical research
  • Device development/manufacturing/device demonstration
  • Digital health/software
  • Innovation/health technology assessment/market access
  • InVitro diagnostics
  • Quality management/quality systems
  • Standards conformity assessment testing

You may email your proposal to elp@fda.hhs.gov.

If you have any questions regarding submitting a proposal or any ELP related questions, you may contact ELP Management at ELP Inquiries or (240) 402-2246.

React:

Discussion

14
DS
Dr. Sarah MitchellOrthopedic Surgeon · Mayo Clinic

This is a fascinating development. In my practice we've seen similar outcomes with the revised protocol. The key differentiator seems to be patient selection criteria. Has anyone else noticed the correlation with BMI thresholds?

8
JT
James Thornton, MDSpine Fellow · HSS

Great point. I'd push back slightly on the conclusion, the sample size in the cited study is too small to draw population-level inferences. That said, the directional signal is compelling and worth a larger RCT.

5
RP
R. PatelSports Medicine · Stanford

We implemented a similar approach last year. Early results are promising but we're still gathering 12-month follow-up data. Happy to share our protocol if anyone is interested.

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