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From Idea to Approval: What Sponsors Must Know Before Their First Trial

Bioexcel News

Quality Assurance

  • In the US, understand FDA’s expectations. Many new device sponsors engage with the FDA via the Q-Submission (Pre-Sub) process to get feedback on their trial plans. You will also need an Investigational Device Exemption (IDE) approval from the FDA for a significant risk device trial. Preparing an IDE means compiling preclinical data, the clinical protocol, risk analysis, and other information to convince FDA your study can proceed safely.

  • In the EU (and other regions), ensure you know the rules for starting a device trial. Under EU MDR, you must notify or obtain authorization from national competent authorities and ethics committees. For example, a first-in-human trial of a high-risk device in Europe will require an application with a detailed Clinical Investigation Plan (CIP) and supporting data (e.g. bench testing, perhaps animal study results) to show the device is ready for human testing.

  • Regardless of region, don’t skip the preclinical homework. Make sure you have sufficient bench testing, biocompatibility assessments, and possibly animal study data to justify testing in humans. Regulators will expect to see this in your submissions.

  • Objectives and Endpoints: Define what you’re trying to demonstrate. Is it safety? Performance compared to a predicate or standard of care? Clearly state primary and secondary endpoints that align with these objectives.

  • Study Design: Choose an appropriate design (randomised controlled trial, single-arm observational, etc.) for your goals. For an early feasibility study, a single-arm design might be fine; for a pivotal efficacy trial, a controlled design is often expected.

  • Inclusion/Exclusion Criteria: Decide who qualifies for the study. These criteria should ensure you enroll the right population ethically and that results will be relevant to your intended users.

  • Sample Size and Statistics: As covered in the previous section, justify how many participants you will enroll and how you’ll analyze the data. Regulators and ethics boards will look for a sound statistical rationale.

  • Safety Monitoring Plan: Outline how you will monitor and report adverse events. For a first-in-human trial, safety oversight is paramount – you might even consider an independent Data Monitoring Committee to review safety data periodically.

  • Investigator Selection: You’ll need qualified clinical investigators and trial sites to carry out the study. Start identifying experienced clinicians in your device’s field who are interested in research. Evaluate sites for their patient population (can they recruit your target patients?), facilities (do they have the required equipment?), and research experience (familiarity with GCP and device trials).

  • Training: Plan to train your investigators and site staff on the protocol and the device usage. Even a well-designed device may have a learning curve. Provide device manuals, simulation sessions if needed, and ensure everyone understands the trial procedures. As sponsor, you must ensure the trial is conducted by competent professionals under high ethical and scientific standards.

  • CRO Support: Consider whether you will run the trial in-house or hire a Contract Research Organisation (CRO). For many first-time sponsors, a CRO can handle logistics, monitoring, data management, and regulatory compliance tasks that you may not have experience with. If you choose a CRO, do your due diligence: look for one with device trial experience and knowledge of your therapeutic area. A good CRO can guide you through each step and help avoid rookie mistakes.

  • Data Management Systems: Set up a system for capturing trial data (often an Electronic Data Capture, EDC, system). Ensure you have a database designed for your study, and that site personnel are trained to use it. Good data practices from day one will save headaches later when analyzing results or during audits.

  • Monitoring Plan: Develop a monitoring plan for the study. This involves how you (or your CRO monitors) will verify data accuracy and protocol compliance at sites. As a sponsor, you have an obligation to oversee the trial’s conduct. This typically means periodic monitoring visits or remote monitoring to review source data, informed consents, device accountability, etc.

  • Ethics Committee/IRB Approval: Every site’s Institutional Review Board (IRB) or Ethics Committee must approve the study protocol, consent forms, and any recruitment materials. Prepare a thorough submission including the protocol, investigator brochures, and risk information. Be ready to address questions about patient safety, risk/benefit, and how you’ll obtain informed consent. For a first-in-human device trial, ethics committees will be particularly careful – make sure your risk mitigation strategies are clear.

  • Regulatory Approval/Notification: As discussed, ensure any regulatory body approvals are in hand (e.g., FDA IDE letter, EU regulatory notification acknowledgement, Health Canada ITA, etc., depending on where you conduct the trial). Do not initiate any trial activities until you have these approvals in writing.

  • Trial Registration: Plan to register your trial on a public registry (like ClinicalTrials.gov or an EU registry) before starting enrollment, if required. This is legally mandated in many jurisdictions and is considered best practice for transparency.

  • Informed Consent Process: Develop clear informed consent documents for participants, in lay language. As sponsor, you should ensure the consent form covers all required elements (purpose, procedures, risks, rights, etc.) and is approved by IRBs. Also ensure site teams are trained to obtain informed consent properly.

  • Work with a biostatistician to create a statistical analysis plan (SAP) before the trial starts. This plan should detail how each endpoint will be analyzed (what statistical tests or models), how missing data will be handled, etc.

  • Consider what outcome would be “success” for your trial and what the next step would be. If this is a pilot study and it goes well, will you immediately plan a pivotal trial? If it’s a pivotal trial, are you prepared to compile the results into a regulatory submission (e.g., a PMA or Technical Documentation for CE marking)? Knowing the context can shape aspects of trial design – for instance, collecting certain data that regulators will expect in an approval application (like device performance in various subgroups, or user feedback).

  • Regulatory consultants who specialize in medical devices,

  • Seasoned clinical trial project managers or advisors,

  • Engaging a CRO (as mentioned) or at least consulting one for specific tasks,

  • Reading relevant guidance documents (FDA’s Guidance for Clinical Trial Sponsors is a good primer on sponsor responsibilities).

  • Talking to other device entrepreneurs who have gone through first trials.]

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