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Around the Web: Stakeholders seek tweaks to FDA’s voluntary improvement program guidance

August 8, 2022

Stakeholders seek tweaks to FDA’s voluntary improvement program guidance

Regulatory NewsRegulatory News
| 08 July 2022 | By Jeff Craven 3044 The US Food and Drug Administration (FDA) has received comments on its draft guidance on engaging with the Voluntary Improvement Program (VIP) through the Medical Device Innovation Consortium (MDIC), and device companies want to know more about how manufacturers can benefit from participating as well as how the program fits into existing regulatory programs.

FDA’s participation in the VIP means device manufacturers can be assessed by third party appraisers that provide feedback on strengths and areas for improvement as measured by a modified version of the best practices in the Information Systems Audit and Control Association (ISACA) Capability Maturity Model Integration (CMMI) system for the medical device industry across 11 practice areas. Data can then be de-identified and shared with FDA following an appraisal. (RELATED: FDA drafts guidance on medical device voluntary improvement program, Regulatory Focus 9 May 2022)

Site visits and analyses under the VIP are not regulatory inspections or audits, the agency said in the draft guidance, and the appraisers don’t collect evidence of regulatory findings or provide regulatory observations, including a rating or certification.

“Participating manufacturing sites who demonstrate sustained capability and performance, or improvements in the appraisal results, may benefit from several opportunities that the VIP offers, following FDA’s review of the site’s appraisal,” the agency wrote in the draft guidance.

The VIP is a permanent version of the Case for Quality Voluntary Medical Device Manufacturing and Product Quality Pilot Program, which FDA launched with MDIC in 2018 and was well received by a majority of participants in the pilot. (RELATED: FDA Details New Manufacturing Quality Pilot Program, Regulatory Focus 15 January 2018)

Medtronic
In their comments to the FDA, medical device company Medtronic proposed changing the wording in the description of the Medical Device Discovery Appraisal Program (MDDAP) to include “Governance, Implementation Infrastructure and Managing Performance and Measurement” rather than FDA’s proposed practice areas of “Estimating, Planning, and Configuration Management” because the former are three core practice areas, while the latter “may or may not be included in future appraisals.”

Medtronic also suggested FDA change how it describes the ISACA CMMI “to include that firms are encouraged to identify an appraisal scope that applies CMMI best practices to proactively identify opportunities for continuous improvement.”

“We recommend VIP continues the focus on proactive identification of opportunities for improvement. Focusing on an increasing score year over year, could disincentivize firms who, today, are encouraging transparency during appraisals, and who are continuously looking at new areas to find additional opportunities for improvement,” they wrote. “This active search for improvement opportunities could temporarily result in a dip in scores.”

The device manufacturer suggested that a copy of any de-identified, aggregate information sent to the FDA should also be sent to the participating site. Medtronic recommended FDA make it clear that the appraisers don’t retain objective evidence collected during the site visit and remove terms like “rich dataset” that might imply quantitative data are being collected.

MDIC’s VIP Expansion Working Group
The working group responsible for modifying MDIC’s VIP Reappraisal Guidelines also provided a comment to FDA and suggested changes to align with the goals of the working group. They noted the “intent of the program is to shift from a compliance mindset and towards continuous improvement.”

To that end, they suggested adding language to the draft guidance that would allow manufacturers to participate in alternate engagement activities such as focused scope appraisal, continuous improvement event, or a capability benchmark appraisal instead of a standard appraisal when appropriate.

“The intent of this objective is to maintain the requirement for all sites to regularly engage with the program while balancing a core program feature allowing flexibility for individual participant need,” they wrote.

Becton Dickinson
Medical technology company Becton Dickinson asked FDA in their comment to clarify how the program affects surveillance inspections and pre-market inspections.

“The guidance explains how participating in VIP can offer ‘risk-based inspection planning’ and potentially reduce the cadence of inspection. However, it is unclear specifically how it could potentially spare a manufacturer from a surveillance and/or premarket inspection,” they wrote. “Removing the need for surveillance and/or premarket inspections could be major incentives of participating in VIP, thus, how these inspection types are specifically impacted by VIP participation should be explained.”

W. L. Gore & Associates
Manufacturing company W. L. Gore & Associates used their comment to FDA to ask for clarity on what the agency expects in terms of “sustained capability and performance” and whether a manufacturer needs to achieve a certain maturity level to qualify for risk-based inspection planning.

Gore also requested that Office of Health Technology (OHT) officers within CDRH’s Office of Product Evaluation and Quality (OPEQ) receive training on the VIP program and features, particularly the 30-Day Change Notice submission template. They cited their experience with inconsistencies in the program.

“For example, one OHT reviewer would not accept the template during the Pilot Program because the submission included biocompatibility data. They asked that the manufacturer instead submit as a ‘traditional 30-day Notice.’ Another OHT reviewer accepted the format under the program for a similar change,” they wrote.

Boston Scientific
Medical device manufacturer Boston Scientific provided a brief comment to FDA about the VIP, asking the agency to “avoid specifying that appraisals be required annually, but instead at least leave it open to possibility that the frequency be tailored as companies/sites remain active in the program year-on-year.”

Bringing Real-world Insight for Device Governance and Evaluation (BRIDGE) Coalition
The BRIDGE Coalition emphasized in their comment that the permanent program should be as flexible and responsive as the pilot program. “We support quality measures and believe VIP can prove to be beneficial for some products and manufacturers,” they wrote.

However, they questioned how the program would apply to participants with multiple sites. “The program, as currently structured, works well for small entities with one facility, or large manufacturers who only designate one or two sites for certification. The biggest gain for large manufacturers with multiple sites would be an enterprise program that could simultaneously cover more than one designated site,” they said.

The coalition also expressed concerns about third-party auditors. “It must be clear that this program exists outside of MDIC. Stated differently, participation in this program must be permitted outside of any specific third party. The benefits should be applicable to assessments done outside of the MDIC system,” they said. “Likewise, FDA should be open to assessments system similar to CMMI. FDA should not endorse one entity or one system for the VIP program.”

They also raised concerns about legal liability for products in the program, and the discoverability of information within the program in litigation. They suggested protections be built into the program that state submissions are not admissions of liability as well as limiting discovery of information from the program in third-party litigation. “Including similar protections in this pilot program will encourage participation and avoid disadvantaging companies that do partake in the pilot,” the group said.

The Coalition also suggested a “re-scoping” of the program to include pre-market incentives for 510(k) manufacturers in addition to pre-market approval (PMA) devices. “This program will have limited effect if it is limited to PMA devices. In many ways, this program may better fit into the Class II/special controls approach. We believe that FDA should seek public input on including Class II/special control in this program,” they wrote.

Draft guidance

© 2022 Regulatory Affairs Professionals Society.

This story was originally published by RAPS.

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Around the Web: Calidi Biotherapeutics Announces FDA Authorization of IND for a Phase 1 Clinical Trial of NeuroNova in Patients with Recurrent High-Grade Glioma

August 2, 2022

LA JOLLA, Calif.–(BUSINESS WIRE)– Calidi Biotherapeutics, Inc. (Calidi), a clinical-stage biotechnology company that is pioneering allogeneic cell-based platforms to revolutionize oncolytic virus therapies, is pleased to announce that City of Hope has received U.S. Food and Drug Administration (FDA) authorization to proceed with a phase 1 physician-sponsored clinical trial that will use Calidi’s licensed oncolytic virotherapy platform, NSC-CRAd-S-pk7 (NeuroNova), a cutting-edge therapeutic candidate comprising tumor-tropic neural stem cells delivering an oncolytic adenovirus selectively to tumor sites in patients with recurrent high-grade glioma (Calidi’s NNV-2 program).

 

The phase 1 physician-sponsored clinical trial will be an open-label, non-randomized, multicenter study. Once the phase 1 trial is funded, it will address the safety and tolerability of administering serial doses of NeuroNova in adult patients with recurrent histologically confirmed high-grade gliomas (WHO grade III or IV). Secondary endpoints will evaluate treatment efficacy, including progression-free and overall survival as well as any immune response to NeuroNova. This physician-sponsored study will be led by principal investigator Jana Portnow, M.D., Professor in City of Hope’s Department of Medical Oncology & Therapeutics Research and Co-Director of the Brain Tumor Program at City of Hope, a National Cancer Institute-designated comprehensive cancer center and a founding member of the National Comprehensive Cancer Network. City of Hope is one of the largest cancer research and treatment organizations in the United States.

 

A previously completed phase 1 dose escalation clinical trial, in newly diagnosed glioma patients, of a single dose of NSC-CRAd-S-pk7 (NeuroNova) given as an adjunct to radiation and temozolomide (Calidi’s NNV-1 program) demonstrated that NeuroNova was well tolerated in the patient population and showed promising preliminary results of efficacy [J Fares et al, Lancet Oncology, 2021, 22(8):1103-1114].

“Worldwide, an estimated 270,000 people were diagnosed with a primary brain tumor in 2020, with a five-year survival rate of only 5%. Recurrent glioma patients have poor prognosis with a median survival of less than one year. Developing our drug candidate for this indication represents a significant milestone that will empower us to help more individuals survive this devastating disease,” said Calidi Biotherapeutics CEO and Chairman of the Board Allan J. Camaisa. “As Calidi undertakes this endeavor, we are pleased to have exclusive commercialization rights to this technology and thrilled to collaborate with two scientific trailblazers who have worked together on this project for over a decade: Dr. Karen Aboody, Professor in the Department of Stem Cell Biology and Regenerative Medicine, Scientific Leader of the Neuro-oncology Disease Team at City of Hope, and Dr. Maciej (Matt) Lesniak, Chair of the Department of Neurological Surgery, at Northwestern University Feinberg School of Medicine.”

“Our team at City of Hope is excited to be a part of the development of NeuroNova. Despite their potential, the first-generation oncolytic virus therapies given as free virus were not very effective — most likely due to rapid inactivation by the patient’s immune system. Our new platform uses stem cells like a ‘Trojan horse’ to shield the oncolytic viral particles from immune inactivation and deliver them to the tumor sites. This results in significantly more virus distributed at the tumor sites, inducing a greater self-amplifying anti-tumor response. This may also result in a secondary anti-tumor immune response,” said City of Hope’s Dr. Karen Aboody. “In addition to significant experience with this technology, City of Hope has a proven track record in GMP manufacturing of cell and gene therapy agents.”

About NeuroNova

The NeuroNova platform, NSC-CRAd-S-pk7, is an allogeneic, “off-the-shelf” therapy comprised of an immortalized Neural Stem Cell (NSC) line loaded with an engineered oncolytic adenovirus. Upon surgical resection of a tumor, NSC-CRAd-S-pk7 is injected into the walls of the resection cavity, resulting in viral infection and destruction of any remaining tumor cells. Calidi holds an exclusive worldwide licensing agreement for patents covering the NSC-CRAd-S-pk7 technology.

About Calidi Biotherapeutics

Calidi Biotherapeutics is a clinical-stage immuno-oncology company with proprietary technology that is revolutionizing the effective delivery and potentiation of oncolytic viruses for targeted therapy against difficult-to-treat cancers. Calidi Biotherapeutics is advancing a potent allogeneic stem cell and oncolytic virus combination for use in multiple oncology indications. Calidi’s off-the-shelf, universal cell-based delivery platforms are designed to protect, amplify, and potentiate oncolytic viruses currently in development leading to enhanced efficacy and improved patient safety. Calidi Biotherapeutics is headquartered in La Jolla, California. For more information, please visit www.calidibio.com.

 

Forward-Looking Statement

This press release contains forward-looking statements for purposes of the “safe harbor” provisions under the United States Private Securities Litigation Reform Act of 1995. Terms such as “anticipates,” “believe,” “continue,” “could,” “estimate,” “expect,” “intends,” “may,” “might,” “plan,” “possible,” “potential,” “predicts,” “project,” “should,” “would” as well as similar terms, are forward-looking in nature. The forward-looking statements contained in this discussion are based on the Calidi’s current expectations and beliefs concerning future developments and their potential effects. There can be no assurance that future developments affecting Calidi will be those that it has anticipated. These forward-looking statements involve a number of risks, uncertainties (some of which are beyond Calidi’s control) or other assumptions that may cause actual results or performance to be materially different from those expressed or implied by these forward-looking statements. Factors that may cause actual results to differ materially from current expectations include, but are not limited to: the occurrence of any event, change or other circumstances that could give rise to the termination of negotiations and any subsequent definitive agreements with respect to the business combination (the “Business Combination”) with Edoc Acquisition Corp. (“Edoc”); the outcome of any legal proceedings that may be instituted against Edoc, Calidi, the combined company or others following the announcement of the Business Combination, the private placement financing proposed to be consummated concurrently with the Business Combination (the “PIPE”), and any definitive agreements with respect thereto; the inability to complete the Business Combination due to the failure to obtain approval of the shareholders of Edoc, the possibility that due diligence completed following execution of the principal definitive transaction documents for the Business Combination and PIPE will not be satisfactorily concluded, the inability to complete the PIPE or other financing needed to complete the Business Combination, or to satisfy other conditions to closing; changes to the proposed structure of the Business Combination that may be required or appropriate as a result of applicable laws or regulations or as a condition to obtaining regulatory approval of the Business Combination; the ability to meet stock exchange listing standards following the consummation of the Business Combination; the risk that the Business Combination disrupts current plans and operations of Calidi as a result of the announcement and consummation of the Business Combination; the ability to recognize the anticipated benefits of the Business Combination or to realize estimated pro forma results and underlying assumptions, including with respect to estimated shareholder redemptions; costs related to the Business Combination; changes in applicable laws or regulations; the evolution of the markets in which Calidi competes; the inability of Calidi to defend its intellectual property and satisfy regulatory requirements; the ability to implement business plans, forecasts, and other expectations after the completion of the proposed Business Combination, and identify and realize additional opportunities; the risk of downturns and a changing regulatory landscape in the highly competitive pharmaceutical industry; the impact of the COVID-19 pandemic on Calidi’s business; and other risks and uncertainties set forth in the section entitled “Risk Factors” and “Cautionary Note Regarding Forward-Looking Statements” in Edoc’s preliminary prospectus dated May 25, 2022, in the Amended Registration Statement on Form S-4 filed with the Securities and Exchange Commission (“SEC”) on May 26, 2022.

Important Information About the Business Combination Transaction and Where to Find It

This press release relates to a proposed business combination between Edoc Acquisition Corp. a Cayman Islands exempted company, EDOC Merger Sub Inc., a Nevada corporation and Calidi Biotherapeutics, Inc., a Nevada corporation. A full description of the terms and conditions Agreement and Plan of Merger constituting the business combination is provided in the registration statement on Form S-4 filed with the U.S. Securities and Exchange Commission (SEC) by Edoc Acquisition Corp., that includes a prospectus with respect to the securities to be issued in connection with the merger, and information with respect to an extraordinary meeting of Edoc Acquisition Corp. shareholders to vote on the merger and related transactions. Edoc Acquisition Corp. and Calidi Biotherapeutics, Inc. urges its investors, shareholders and other interested persons to read the proxy statement and prospectus as well as other documents filed with the SEC because these documents will contain important information about Calidi Biotherapeutics, Inc., Edoc Acquisition Corp., and the business combination transaction. After the registration statement is declared effective, the definitive proxy statement and prospectus to be included in the registration statement will be distributed to shareholders of Edoc Acquisition Corp. and Calidi Biotherapeutics, Inc., as of a record date to be established for voting on the proposed merger and related transactions. Shareholders may obtain a copy of the Form S-4 registration statement, including the proxy statement and prospectus, and other documents filed with the SEC without charge, by directing a request to: Edoc Acquisition Corp. at 7612 Main Street Fishers, Suite 200, Victor, New York 14564. The preliminary and definitive proxy statement and prospectus included in the registration statement can also be obtained, without charge, at the SEC’s website (www.sec.gov).

Participation in the Solicitation

Edoc Acquisition Corp., Calidi Biotherapeutics, Inc., and their respective directors and executive officers may be deemed to be participants in the solicitation of proxies or consents from Edoc Acquisition Corp. and Calidi Biotherapeutics, Inc. shareholders in connection with the proposed transaction. A list of the names of the directors and executive officers of Edoc Acquisition Corp. and Calidi Biotherapeutics, Inc. and information regarding their interests in the business combination transaction is contained in the proxy statement and prospectus. You may obtain free copies of these documents as described in the preceding paragraph.

No Offer or Solicitation

This press release will not constitute a solicitation of a proxy, consent or authorization with respect to any securities or in respect of the proposed business combination. This press release will also not constitute an offer to sell or the solicitation of an offer to buy any securities of Calidi Biotherapeutics, Inc., nor will there be any sale of securities in any states or jurisdictions in which such offer, solicitation or sale would be unlawful prior to registration or qualification under the securities laws of any such jurisdiction. No offering of securities will be made except by means of a prospectus meeting the requirements of section 10 of the Securities Act of 1933, as amended, or an exemption therefrom.

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Around the Web: iRhythm receives FDA clearance for ZEUS System for Zio watch

August 1, 2022

iRhythm Technologies has received FDA 510(k) clearance for its ZEUS (Zio ECG Utilization Software) System for the Zio Watch. 

Produced in partnership with Verily, an Alphabet precision health company, the ZEUS System combines deep learned algorithms with a proven and trusted cardiac arrhythmia service. The ZEUS System is the AI algorithm and solution component of the Zio Watch: a sensor-based wearable for non-invasive, clinical grade, long-term continuous monitoring for atrial fibrillation (AFib). Verily also received FDA 510(k) clearance for the Zio Watch (Study Watch with Irregular Pulse Monitor).

The Zio Watch with the ZEUS System is an integrated, prescription-based solution that addresses clinician workflows, care pathways and the patient experience. The cleared Zio Watch is a wrist-worn solution that not only detects AFib, but also characterises the amount of AFib over time, thus aiding a clinician in diagnosis. The Zio Watch uses a continuous photoplethysmography (PPG), AI-based algorithm to detect AFib and calculate an AFib burden estimate. A preliminary report is then sent to the patient’s clinician for review, potentially leading to diagnosis and clinical intervention.

Quentin Blackford, CEO and president of iRhythm, said: “We are incredibly excited about this important milestone as we make progress in bringing a new monitoring platform to patients who can benefit from it. There is a clear need in the market today for a clinical grade, long-term and non-invasive monitoring solution. iRhythm is focused on redefining the standard of care with earlier insight to predict and prevent disease, and the Zio Watch with ZEUS System provides clinicians a platform that has the potential to meaningfully improve patients’ lives.”

Dr. Jessica Mega, chief medical and scientific officer and co-founder of Verily, added: “Our partnership with iRhythm advances our shared mission of delivering more efficient care for patients with AFib. The industry is ripe for a clinical grade wearable to not only improve how we monitor cardiovascular health, but also develop precision health interventions that could ultimately prevent more serious cardiac events before they can occur.”

Findings from the Verily Study: Watch AFib Detection At Home, revealed at HRS, show that interval-level sensitivity and specificity of the AFib Context Engine (ACE) algorithm within the ZEUS System were 93.6% and 99.1% respectively. Zio XT was used as a reference for computing performance. AFib episodes occurred in 30.4% of subjects, and median AFib burden was 9.3%. The Zio Watch PPG-derived AFib burden estimate was an accurate measure when compared to the Zio XT reference. iRhythm’s ACE algorithm utilises a novel convolutional neural network architecture designed to operate on a cloud-enabled system compatible with a battery-constrained device. The results of ACE are presented in clinical preliminary reports summarising AFib presence over the monitoring period. This process enables clinicians to receive clinically meaningful data on AFib presence/absence, rather than just a single data point in time.

Mark Day, chief technology officer at iRhythm, said: “We’re proud to introduce a clinical grade wearable that has the potential to fill an important gap in patient care by enabling the early detection and long-term monitoring of atrial fibrillation. This technology is fundamental to growing a disruptive new monitoring platform for iRhythm.”

The Zio Watch will be complementary to Zio monitors by adding a modality with longer wear times for patients who require long-term monitoring to detect, characterise and manage AFib. The Zio Watch is designed to be a cost-effective, non-invasive monitoring solution and will fully integrate with the Zio service. iRhythm plans to introduce the ZEUS System for a limited market evaluation in 2023.

This story originally appeared in MedTech News.

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Around the Web: The revolutionary portable ultrasound tech could transform the healthcare space

August 1, 2022

Ultrasounds are a huge milestone for a mother-to-be. It is a health check-up, a confusing picture, but most importantly a first chance to see the child with whom one will spend the rest of their life. It is also a huge hassle. In today’s age of overcrowded hospitals, highly infectious diseases and general uncertainty, just scheduling an appointment can be an ordeal. What if one didn’t have to?

MIT has just published a paper promising a revolution in the field of ultrasound imaging, not just for expectant mothers but for diagnostics as a whole. The researchers have developed a set of 48-hour stickers that when applied to the body can give continuous ultrasound imaging of the body. Unfortunately, this currently needs to be connected to a huge ultrasonic imaging machine to get pictures, but the team is working on artificial intelligence (AI) tool that allows these stickers to communicate directly to a user’s phone instead.

Depending how this technology develops, this could be a game-changer in several fields of medical devices. Not only does this provide a smaller, more compact method of ultrasound imaging, but if these stickers could be packaged and sent to remote locations, a doctor could perform an ultrasound screening of a patient from thousands of miles away. This would make diagnostics of organ health, disease, or pregnancy much more accessible in the world of remote patient monitoring (RPM).

Investors will be chomping at the bit to see the results and efficacy of clinical trials coming out in the future. The results of these trials will determine whether these stickers can revolutionize healthcare. Currently, this technology sits in the intersection of two dynamic fields in healthcare: RPM and diagnostic imaging.The RPM and diagnostic imaging markets are some of healthcare’s largest markets, and GlobalData estimated 2022 market sizes of $11.0m and $30.3m, with expected growth of 3.4% and 4.8%, respectively. With the advent of Covid-19, the usefulness of RPM has been made clear and GlobalData expects its growth to skyrocket in coming years with renewed government reimbursement support.

Should the ultrasound technology prove to be cheap and portable enough, it could cannibalize a significant portion of both of these technologies, but it could also carve out its own new, sizable niche. Currently, one of the largest untapped patient populations is those living in remote areas. These patients will often live very far from the nearest hospital. However, their medical needs are no less diverse, and the closest specialized hospital could be hundreds of miles away. This technology could counteract this setback. By being able to mail these diagnostic stickers to patients in remote areas, healthcare professionals could conduct diagnostic images ranging from pregnancy ultrasounds to checking organ health to looking for cancerous tumours. This opens up a huge range of possibilities in the diagnostic space and thus, a large potential market.

The post The revolutionary portable ultrasound tech could transform the healthcare space appeared first on Medical Device Network.

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