A recent survey of voting members serving on the FDA's Medical Devices Advisory Committee (MDAC) indicates potential improvements to the FDA's premarket approval (PMA) process. The study, published in JAMA Network Open, highlights the perspectives of device panel members on pivotal trial design, evidence quality, and internal deliberation processes.
The survey, conducted in 2017, included 64 of 92 panel members and revealed that only 46% believed pivotal trials were frequently well-designed. A significant majority (88.7%) suggested the FDA should consult panel members preemptively regarding trial design, and 84.4% recommended panel review of device labels. These findings suggest a desire among panel members for greater involvement in the early stages of device evaluation.
Panelist Recommendations for Process Improvement
Panelists identified several areas for improvement in the PMA process. Key recommendations include:
- Early Consultation: A strong consensus (88.7%) favored preemptive consultation with panel members on pivotal trial design.
- Device Label Review: 84.4% of respondents suggested panel members should review device labels to ensure accuracy and relevance.
- Executive Sessions: Nearly 90% (89.7%) supported the implementation of executive sessions involving only panel members to promote more candid discussions.
Data and Evidence Considerations
The survey also shed light on the types of evidence panel members find most influential. Written information (83.3%), live presentations (74.1%), and prior professional knowledge (68.3%) were rated as the most important sources. In contrast, public comments were considered less influential (16.6%).
When evaluating devices, 62.9% of respondents indicated they would be more likely to recommend approval for a device already approved in another industrialized country with comparable regulatory regimes, such as Canada or Europe. Additionally, 69.4% would be more inclined to approve a device with prior FDA approval for a similar medical purpose.
Concerns and Limitations
Despite the generally positive view of the FDA's impartiality, panelists expressed concerns about the depth of information provided on specific topics. A significant percentage felt that information was too superficial regarding serious adverse events (34.4%), patients who did unusually poorly (34.4%), and long-term use considerations (42.4%).
The study acknowledges limitations, including potential social desirability bias and the fact that the survey was conducted in 2017. The authors also note that the panels could be made more diverse, as voting members appear to be mainly male, White individuals, and in academic practice.
Implications for the FDA
The findings suggest that incorporating panel member expertise earlier in the PMA process could enhance the quality of device evaluations. While implementing changes such as executive sessions may face legislative hurdles under the Federal Advisory Committee Act (FACA), the study underscores the value of ongoing dialogue between the FDA and its advisory panels to optimize the device approval process.