Global Regulatory Pulse

Industry Survey: FDA’s Focus on Early Feasibility Studies

In FDA, Regulatory by Kristy Katzenmeyer-Pleuss

One of the big trends facing FDA in 2016 is the continuing increase of EFS IDE submissions in the U.S. and how approval rates can improve. Early Feasibility Studies (EFS) are a type of clinical study that involve a small number of patients to investigate a device that may be early in the development process and for which the device design may not yet be finalized. EFS may be used to establish a “proof of concept” for a novel technology or a new clinical use for an existing device. In addition, EFS may provide initial insights into a device’s clinical use and safety.

Due to often burdensome Investigational Device Exemption (IDE) requirements imposed by FDA for these type of studies, early studies were commonly conducted outside of the U.S. In recognition of this shortfall, FDA focused efforts on developing an EFS program as part of their 2014-2015 Strategic Priority to “Strengthen the Clinical Trials Enterprise”. Based on published reports, the Center for Devices and Radiological Health (CDRH) saw an overall 50% increase in EFS IDEs submitted during the first 9 months of FY 2015 compared to FY 2013, and a 100% increase in EFS IDE approvals. FDA also reported 6 out of the 7 review divisions in CDRH’s Office of Device Evaluation (ODE) saw an increase in the number of EFS submissions received in FY 2015 compared to FY 2013.

In 2013, FDA published a final guidance on IDEs for EFS. One key aspect of the guidance is focused on FDA’s flexibility in allowing less nonclinical data to support approval for EFS IDEs compared to traditional feasibility and pivotal studies. Another significant feature of the guidance is communication of new FDA policy to enable more timely device and protocol iterations during patient enrollment in the EFS.

It is reasonable for medical device manufacturers to expect FDA to continue improving the EFS submission process, which may continue to increase the number of studies conducted in the U.S. As the number of EFS submissions increase, FDA review divisions continue to gain additional experience with the EFS program. Specifically, each division has EFS representative members in place to aid the review teams in agreeing on the type and amount of supporting data needed to support the EFS IDE. The EFS guidance, as well as the Early Access Program (EAP), is expected to be revised to capture lessons learned, and to provide additional guidance to the industry on the process.

Another aspect of FDA’s focus may be on submission quality. In the report referenced above, it is not stated how many EFS IDEs are converted to Pre-Submissions during the review, which may be one route for FDA to address significant quality issues. Webinars presented by FDA’s Clinical Trials Program staff have highlighted how many IDE submissions fail to provide basic information needed for FDA’s review. Although it is not anticipated for FDA to institute a formal Refuse-to-Accept policy for IDEs due to their short review time, it is anticipated FDA will focus on other ways to try to improve the quality of IDE submissions.


NAMSA is seeking the help of the medical device industry to gain further insight into conducting EFS in the U.S. As a result of recent discussions with FDA’s EFS Program staff, NAMSA has developed a short, 5-minute multiple-choice survey to help guide a subsequent and more in-depth study of EFS. The intent of our study is to coordinate the industry’s voice by collecting your concerns and sharing the final results with FDA’s EFS Program as well as publishing the results in a public forum. We encourage comments from those who have direct EFS experience as well as from those with no prior EFS experience.

Take the survey at:


Kristy Katzenmeyer-Pleuss, Ph.D, is a former FDA medical device reviewer and currently a Senior Medical Research Manager, Regulatory at NAMSA. She holds a Ph.D. in Bioengineering from the University of Washington and a B.S. in Chemical Engineering from the University of Wisconsin-Madison. Her experience includes developing high-level regulatory strategy and policy, facilitating communications and meetings with regulatory agencies, and drafting premarket submissions and deficiency responses. Kristy has experience with a variety of medical device types and combination products, including general and plastic surgery, wound care, dermatologic, cardiovascular, orthopedic, neural, ophthalmic, ENT, dental, respiratory, infection control, general hospital, digital health, etc. She is also a subject matter expert in biocompatibility and reprocessing (reusable and reprocessed single-use devices).