CDRH Seeks Public Comment on How to Increase Patient Access to At-Home Use Medical Technologies

On June 1, CDRH announced that it is seeking public comment on questions regarding how CDRH can facilitate access to medical technologies designed for use outside of traditional clinical settings, particularly in the home.  According to the announcement, enabling patients to access medical devices beyond traditional clinical settings can help close the healthcare gap by delivering care “directly to patients, wherever they are – at home, at work, in cities, in rural communities.”

Background – Strategic Priority to Advance Health Equity

In CDRH’s 2022-2025 Strategic Priorities, “Advance Health Equity” is listed as one of the three strategic priorities along with “Promote a Modern and Diverse Workforce” and “Enhance Organizational Agility and Resilience.” Embracing a sweeping vision, CDRH foresees that medical technologies, including digital health technologies, have the potential to bridge the healthcare gap and promote improved healthcare, enhanced quality of life, and overall wellness for everyone.  To advance health equity, CDRH states “Technology, including digital health technology, should be designed and targeted to meet the needs of diverse populations.”

As acknowledged in the Strategic Priorities document, certain demographic groups may have limited access to necessary treatments and diagnostics.  CDRH recognizes in the Strategic Priorities document that “Lack of access exists for a variety of reasons, including that necessary treatments and diagnostics are not available to the specific demographic groups, or treatments and diagnostics needed by those groups simply do not exist.”  As noted by CDRH, there are “innovation deserts” when it comes to conditions that primarily affect diverse populations.

At-home medical technologies hold promise in advancing health equity, because they can bring healthcare to patients wherever they are located, lowering healthcare costs and advancing access.  These technologies can also enable the participation of diverse populations in clinical studies and other initiatives aimed at collecting public health data.

FDA defines a Home Use Device as “a medical device intended for users in any environment outside of a professional healthcare facility. This includes devices intended for use in both professional healthcare facilities and homes.”  At-home medical technologies include, but are not limited to, monitoring and wearable devices (e.g., measure and track vital signs such as continuous glucose monitor, ECG monitor, blood pressure monitor, fall detector, actigraphy, etc.), telemedicine and telehealth solutions (e.g., enable individuals to have virtual consultations with healthcare providers through video calls or online platforms), at-home diagnostics (e.g., pregnancy tests, blood glucose monitoring systems, COVID-19 tests, etc.), and remote or wearable patient monitoring devices (e.g., non-invasive remote monitoring devices that measure or detect common physiological parameters and non-invasive monitoring devices that wirelessly transmit patient information to their healthcare provider or other monitoring entity).

The CDRH Strategic Priorities state that CDRH will “take steps to leapfrog the development of high-quality, safe, and effective health technologies, including digital health technologies.”  CDRH seeks to advance health equity, with a focus on medical technologies, by:

• Facilitating availability of and access to medical technologies for all populations,
• Empowering people to make informed decisions regarding their healthcare,
• Supporting innovation of novel and existing technologies that address health inequities, and
• Reducing barriers to increase participation by diverse populations in evidence generation.

To accomplish these goals, CDRH says it will aim to increase opportunities for participation by diverse populations in clinical trials; develop a framework for when a device should be evaluated in diverse populations to support a device premarket submission; and collaborate with patients, healthcare providers, industry, and payers to advance solutions that promote equity and access to care.  Implementation of these objectives would be welcome, given that in practice CDRH reviewers have not, in our experience, been particularly receptive to arguments that home use devices provide significant benefits precisely because they can improve access to health care.

CDRH’s Request for Public Comment

CDRH is now taking the first step to collaborate with stakeholders, as stated in the Strategic Priorities, by seeking comments from the public on the following questions:

• How can the FDA support the development of medical technologies, including digital health technologies and diagnostics, for use in non-clinical care settings, such as at home?
• What factors should be considered to effectively institute patient care that includes home-based care?
• What are ways that digital health technologies can (a) foster the conduct of clinical trials remotely and (b) support local or home-based healthcare models?
• How can the FDA facilitate individuals accessing medical technologies in remote locations when they are unable or unwilling to access care in clinical settings?
• What processes and medical procedures, including diagnostics, do you believe would be ideal for transitioning from a hospital and/or healthcare setting to non-clinical care settings, for example, home use or school/work use?
  • What medical technologies could be ideal to transition to use in non-clinical settings? What aspects of those technologies could potentially benefit from modifications to optimize use in non-clinical settings?
• What design attributes and user needs would facilitate the use of medical technologies, including diagnostic and therapeutic devices, for use in a non-clinical setting, for example home use?
• For digital health technologies, what design attributes could better facilitate their use by diverse patient populations outside of a clinical setting? What other factors are important to consider which may improve use and acceptance of different digital health technologies by diverse patient populations (for example, older adults, non-English speakers, lower literacy)?
• What potential methods and strategies for evidence generation and data analysis could facilitate the regulatory review of medical technologies intended to be used in non-clinical settings, for example home use or school/work use?

We encourage stakeholders with medical technologies – including existing products that can be used in non-clinical settings – that have the potential to increase access to care, to provide their perspectives on these questions.  FDA may consider the public comments in developing a regulatory framework or policy to increase patient access to at-home use medical technologies.  We also note this CDRH’s effort aligns with the FDA-wide effort to utilize digital health technologies that are discussed in recent draft guidance documents as follows:

• Draft Guidance on Decentralized Clinical Trials for Drugs, Biological Products, and Devices. We previously blogged on the draft guidance here. For those who are interested in learning more about the decentralized clinical trial draft guidance, please check out the FDA’s webinar on June 20, 2023.
• Draft Guidance on Digital Health Technologies for Remote Data Acquisition in Clinical Investigations.
• Draft Guidance on Electronic Systems, Electronic Records, and Electronic Signatures in Clinical Investigations Questions and Answers

The public comments for the questions posed by CDRH above may also inform FDA’s finalization of these draft guidances.

For those who are interested, comments should be submitted to the docket (FDA-2023-N-1956) by August 30, 2023.