Tuesday, January 20, 2015

Obama's Precision Medicine Initiative


Despite the fact that President Obama spent the last week spilling the beans on the content of his State of the Union address, he had one little surprising tidbit for those of us who are passionate about Health IT: a Precision Medicine Initiative!  In his own words:
"21st century businesses will rely on American science, technology, research and development. I want the country that eliminated polio and mapped the human genome to lead a new era of medicine — one that delivers the right treatment at the right time. In some patients with cystic fibrosis, this approach has reversed a disease once thought unstoppable. Tonight, I’m launching a new Precision Medicine Initiative to bring us closer to curing diseases like cancer and diabetes — and to give all of us access to the personalized information we need to keep ourselves and our families healthier."
All I can say is, "Amen to that!"

We're currently at a critical juncture of the need for personalized and precision medicine and the availability of technology to support exactly that.  Patients can - right now - share their own health information in real time with their physicians via novel technologies such as Apple's HealthKit, which we've implemented here at Duke.

Plus, technologies such as the SMART Platform (about which I'll have much more to say very soon ...) will enable a new generation of standardized medical apps that can scale to every EHR and every hospital in the country ... and eventually the world.

I couldn't be more excited to be surrounded by such talented and creative folks here at Duke working to make all of these things (and more!) a reality.  Apparently for the past year we've been working to make the President's vision a reality ... we just didn't know it!

FDA Draft Guidance for General Wellness Devices

Today the FDA released draft guidance on regulation of low-risk "general wellness" devices.  Draft guidance is nonbinding and subject to change, but it does provide a window into the FDA's thinking on a topic of increasing relevance.  This guidance will be part of a compliance policy of the Center for Devices and Radiological Health (CDRH).

This draft guidance continues the FDA's recent trend to state explicitly what they will not be regulating.  In September 2013 the FDA issued final guidance on mobile medical applications where they stated that "The agency intends to exercise enforcement discretion (meaning it will not enforce requirements under the Federal Drug & Cosmetic Act) for the majority of mobile apps as they pose minimal risk to consumers. The FDA intend to focus its regulatory oversight on a subset of mobile medical apps that present a greater risk to patients if they do not work as intended."  My thoughts on that report can be found here.

Then, in August 2014 the FDA issued a draft document detailing their "Intent to Exempt Certain Class II and Class I Reserved Medical Devices from Premarket Notification Requirements" - my thoughts are here.

So it comes as no surprise that this latest draft proposes that "CDRH does not intend to examine low risk general wellness products to determine whether they are devices within the meaning of the FD&C Act."

The document goes on to define "general wellness products as products that:
  1. are intended for only general wellness use, as defined in this guidance, and
  2. present a very low risk to users' safety."
Examples of device categories covered by this guidance include:
  • weight measurement
  • physical fitness, including products intended for recreational use
  • relaxation or stress management
  • mental acuity
  • self-esteem (e.g., devices with a cosmetic function that make claims related only to self-esteem)
  • sleep management
  • sexual function
However, any devices falling into the above categories that are not low risk would not be covered by this guidance.  The risk is determined by whether or not the product:
  1. is invasive
  2. involves an intervention or technology that may pose a risk to a user's safety if device controls are not applied, such as risks from lasers, radiation exposure, or implants
  3. raises novel questions of usability
  4. raises questions of biocompatibility
Finally, to be very clear, the document gives several examples of low risk products, such as a mobile app that plays soothing music to manage stress; a mobile app that monitors daily energy expenditure to increase self-awareness to maintain good cardiovascular health; a mobile app that records food consumption help the user manage dietary activity; a device that monitors pulse during exercise or hiking; and a product that mechanically exfoliates the skin (to increase self-esteem).

I continue to applaud the FDA for giving clear guidelines for mobile apps and devices to help foster an environment ripe for innovation while keeping patients safe.