FDA Science Board, April 2003
Committee Chair: Robert M. Nerem, Ph.D.Parker H. Petit Distinguished Chair for Engineering in Medicine,
Georgia Institute of Technology
June: Organizational MeetingProvide Internal Review DocumentsGo Over Interactive Assignment materials
July: CDRH Site VisitDay 1: Focus on early life cycle (Twinbrook facilities)Day 2: Focus on mid life cycle (Corporate Blvd)Day 3: Focus on late life cycle (Piccard Blvd)
Science Review RecommendationsQuality Systems:
CDRH should develop and implement a quality evaluation and improvement program, and as part of this, the evaluation system should develop metrics for the assessment of quality as well as the timeliness of results. The focus of these activities should be to achieve high quality product reviews in a timely manner. Management should implement a system for recognizing, rewarding, and encouraging high quality product reviews and investigations.
Performance Based Budgeting
Review Performance 2001 - 2002
Performance Scorecards
Key Results Areas and Key Indicators1. Public Health Protection
Monitoring Index: Identifying HazardsFollow-up and Resolution Index: Timely and effective
2. Public Health PromotionTimely Availability of Novel Products
3. Operational Accountability and QualityApplication ActivitiesConformity AssessmentBusiness Accountability
Performance Scorecards
Key Results Areas and Key Indicators
4. Stakeholder CollaborationCollaborative Meeting Activities
5. Workforce ExcellenceScientific Development External Expertise Engagement
6. Strategic InitiativesTotal Product Life CycleGlobal Products — Global Quality
SAMIE™ Model
EVALUATE9. Assess impact
of processimprovements
10. Standardize processand monitor ongoing improvement
IMPROVE7. Set process
improvement goal(s)
8. Develop and implementimprovements on a “trial run” basis
MEASURE5. Gather “baseline”
process performancedata
6. Identify processperformance “gaps”
ContinuousProcess
Improvement
ANALYZE
3. Document “as is”process
4. Establish processmeasures
SELECT1. Define key
requirements for “core” customers
2. Determine process to improve
PMA Filing Process
Database: PMA Filing Decisions(FY'02 & 1st Q FY'03)
11%
89% Filed 63
Not Filed 8
PMA Filing Process
Peer Review Analysis - Filed PMAs (Clear, Not Clear, Not Analyzed)
62%
17%
21%
Clearly filed 39
Not clearly filed 11
Not Analyzed 13
Peer Review
PMA Filing Process
Peer Review Analysis: Reasons why PMAs were "Not C learly Filed"
18%
18%
64%
InadequateClinical Study 7
Disorganized 2
Poor/MissingDevice Descript 2
Peer Review
Cause and Effect Diagram
CONTINUOUS PROCESS IMPROVEMENT
Policy Internal Customers
Since FY 02 the interpretation of the minimum filing criteria varies among internal customers
ExternalCustomers
Education
Pressures Agency to file all
Insufficient Training
Staff unaware of policy
Infrequent Training
Culture to file all PMAs
Vague/unclear criteria
Not known to staff
Brainstorm:Possible Solutions
Options CommentSpecify Minimum Filing Criteria
Updated Filing Blue Book Guidance and Checklist (draft)
Provide feedback to external customers regarding submission content at time of filing
Include completed checklist with each FILE/NOFI letter
Create a rating system to score submissions based on content at time of filing
Education Increase frequency and adequacy of training of staff and industry
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Brainstorm:Possible Solutions
Options CommentTurbo Filing Design a template for electronic
completion of filing requirements
Operational Accountability Consistency Ratings
Institute assessment through quarterly Peer Review Analysis
Add measures to ODE/OIVD score cards
Stakeholder Collaboration Satisfaction Ratings
Finalize questionnaires to obtain additional feedback from internal and external customers
Add measures to ODE/OIVD score cards
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Science Review Recommendations
ExpertiseCDRH should encourage and facilitate the use of internal but non-ODE expertise and also external expertise, including the development of operational and budget policies that promote a more liberal use of external experts.
CDRH Medical Device Fellowship ProgramPhysicians
Visiting Scholar – senior level clinicians, surgeonsFellow - physician during fellowship trainingResident – physician during residency trainingMedical studentConsultant – generally off-site experts available for consultation
EngineersVisiting Scholar – senior level engineerConsultant – generally off-site experts available for consultationStudentsBiomedical Engineering Co-op ProgramEngineering internships
OthersContact information:Susan A. Homire, [email protected]
Examples of expertise needed at CDRH
Orthopedics / NeurologyClinical issuesMechanical testing issuesSpine/biomaterials, novel spine
productsBone void fillers and scaffolds for
tissue engineeringEngineering
ElectricalMechanicalSoftwareReliability engineering and quality
systemsHuman factorsBiocompatibilitySterilization
Surgery Cardiothoracic surgeryNeurosurgery - stroke management,
stereotactic brain surgery, epilepsy procedures, cooling and brain injury
Pediatric surgeryPlastic surgery - materials, skin
replacement, glues/sealants
Vascular SurgeryNoncardiac thoracic surgery - lung
volume reduction procedures, thermal ablation of pulmonary lesions
General surgery - robotic, minimally invasive, breast
Urology - prostate surgeryBariatric surgery
General medicalClinical trial designPediatric clinical trial designCardiovascular
CardiologyElectrophysiologyHeart failureInterventional cardiologyInterventional pediatric cardiology
NephrologyDialysis
Implementation