Back to Explorer

Factors to Consider When Making Benefit-Risk Determinations for Medical Device Investigational Device Exemptions: Guidance for Investigational Device Exemption Sponsors, Sponsor-Investigators and Food and Drug Administration Staff

FinalCenter for Devices and Radiological Health Center for Biologics Evaluation and Research01/13/2017

Description

FDA is committed to improving U.S. patient access to new devices by strengthening and streamlining the clinical trial enterprise so that medical device clinical trials are conducted in the U.S. in an efficient and cost-effective manner, while maintaining appropriate patient and research participant protections.

Scope & Applicability

Product Classes

7
ventricular assist devices

Example of life-saving but high-risk devices

In vitro diagnostic devices

IVDs mentioned regarding clinical decision-making impact

Diagnostics

other noninvestigational trial intervention, e.g., diagnostics

breast implants

Example of devices intended to yield appearance benefits

Medical Device

FDA intends to assess device cybersecurity based on a number of factors; demonstrate or maintain its safety and effectiveness; ensuring cybersecurity has become essential to FDA’s ability to protect the public health; Cyber-resiliency capabilities for medical devices

significant risk devices

clinical investigations requiring IDE applications

IDE device

Investigational device being evaluated in a clinical study

Stakeholders

7
Sponsor

Entity responsible for submitting applications under section 524B

Healthcare Professional

Provides medical confirmation of reactions or events; Identifiable reporter in a safety report; Source of medical record numbers; Role responsible for medical confirmation of events; Person entrusted with the direct or indirect provision of healthcare services

qualified investigators

identification of qualified investigators with adequate training

Data Monitoring Committee

Safety oversight body for interpreting adverse events; Safety oversight body for study design

Sponsor-Investigators

Individuals who both initiate and conduct an investigation

Sponsor-Investigator

A licensed physician who submits an expanded access IND and administers the drug.; Physician acting as a sponsor for an individual patient IND; An individual who both initiates and conducts a clinical investigation.; Role that may authorize expanded access protocols

Institutional Review Board

Governs top dose in clinical studies

Regulatory Context

Attributes

8
Benefit-Risk Determination

The process of weighing probable benefits against probable risks.

Mechanical properties

Device characteristics considered in benefit-risk determinations

Electrical properties

Device characteristics considered in benefit-risk determinations

mechanism of action

Explanation of how the device works/principle of operation; Mechanism of action

Quality of life

Anticipated benefit for subjects in target population

Residual risk

Risk remaining after risk control measures are applied; risk mitigation measures can reduce the residual risk

safety profile

characterization of the device based on data

benefit-risk profile

Evaluation of product safety and effectiveness

Identified Hazards

Hazards

4
unreasonable risk

Risk to safety of subjects that may trigger a clinical hold

Harm

Trials should be designed to rule out a clinically relevant degree of harm

Radiation exposure

Hazardous and unnecessary exposure from electronic products

Microbiological contamination

Potential for contamination of covered produce; Known or reasonably foreseeable hazards in water

Related CFR Sections (7)

Related Warning Letters (10)

  • Clinical Investigator

    Shirish M. Gadgeel, M.D.

    2025-09-09
  • Clinical Investigator

    Mark J. Savant, M.D

    2025-07-15
  • Bioresearch Monitoring Program/Institutional Review Board (IRB)

    United Health Products, Inc.

    2025-05-20
  • Clinical Investigator

    Americo F. Padilla, M.D.

    2025-03-25
  • Institutional Review Board (IRB)

    Armstrong County Memorial Hospital

    2024-11-05
  • Clinical Investigator

    Namita A. Goyal, M.D.

    2024-10-22
  • Institutional Review Board (IRB)

    Louisiana State University Health Science Center IRB

    2024-10-08
  • Bioresearch Monitoring Program/IRB

    Massachusetts Institute of Technology MIT

    2024-07-16
  • Clinical Investigator (Sponsor)

    Angela D. Ritter, M.D.

    2024-06-18
  • Institutional Review Board (IRB)

    New York State Psychiatric Institute IRB

    2024-03-26

See Also (8)