Recently at AADE, Courtney Lias from FDA (who gave a similar presentation at D-Data a month ago) gave a presentation talking about AP technology. She addressed both how the FDA is looking at the DIY community (they believe that they have enforcement discretion, even though no one in the DIY community is distributing a medical device, which is legally where FDA has it’s jurisdiction) and how it’s looking at the commercial vendors with products in the pipeline.
Courtney highlighted questions for CDE’s to ask patients of theirs who may be bringing up (or bringing in) DIY closed loops. They are good questions – they’re questions we also recommend people ask themselves and are a critical part of the safety-first approach the DIY community advocates every day.
In fact, we want FDA to ask the same questions of commercial vendors, and we are going to be reaching out to the FDA to ask how they will ensure that we, as patients, can ask and get answers to these questions as end users when the FDA is approving this technology.
Moving forward, I hope to see others do the same when concerns and questions come up. You don’t need to work for a commercial manufacturer, or be a part of a formal initiative, in order to talk to the FDA. Anyone can communicate with them! You can do that by sending an email, submitting a pre-submission, responding to draft guidances, and more. And we can all, in our informal or formal interactions, ask for clarity and push for transparency and set expectations about the features and products we want to see coming from commercial manufacturers.