Old news alert: FDA is monitoring the DIY community

There was a news article today that got a lot of people to react strongly. In that sense, the article did it’s job, to get people talking. But that doesn’t mean it got all the details right, as an insider to the DIY community would know.

What am I talking about?

There was an article posted today in “Clinical Endocrinology News” with the titillating headline of “FDA Official: We’re monitoring DIY artificial pancreas boom”.

Guess what, though? This is NOT news. We’ve been talking to the FDA, and they’ve in fact been “monitoring” us (especially if monitoring includes reading this blog, DIYPS.org ;)) since the summer of 2014, before we even turned our eyes toward closing the loop. Definitely since we, while they were in the room at a D-Data in 2015, announced we would close the loop. And even more so after we closed the loop and then decided to go the #OpenAPS route and find a way to make closed loop technology open source. And others from the community, like Ben West, have been talking with the FDA for even longer than we have.

What the article got right:

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.

(It was not mentioned in this article, but Aaron Kowalski’s presentation at AADE also highlighted some critical truths that I think are key about setting and managing expectations regarding closed looping. I often talk about these in addition to pointing out that it should be a personal, informed choice in choosing to closed loop. I hope these points about setting expectations and our points about the stages of switching from standard diabetes tool to closed looping becomes a bigger part of the conversation about closed loop safety and usability in the future.)

Where the article linked together some sentences that caused friction today:

The end of the article had a statement along the lines of an FDA concern about what happens if an AP breaks and you have a newly diagnosed person who doesn’t have old school, manual diabetes methods to fall back on. The implication appeared to be that these concerns were solely about the DIY looping “boom”. However, we know from previous presentations that Courtney/FDA usually brings this up as a concern for commercial/all AP technology – this isn’t a “concern” unique to DIY loops.

And that’s the catch – all of the concerns and questions FDA has, the DIY community has, too!

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.

Because that’s the missing piece.
Right now, with the current technology on the market, we don’t get answers or insight into how these systems and devices work. This is even MORE critical when we’re talking about devices that automate insulin delivery, as the #OpenAPS community has learned from our experiences with looping. Getting the right level of data access and visibility is key to successful looping, and we expect the same from the commercial products that will be coming to market – so the FDA has a role to play here.

What we can do as a result
And we have a role, too. We’ll play our part by communicating our concerns and questions directly to the FDA, which is the only way they can officially respond or react or adjust what they’re doing. They unfortunately can’t respond to tweets. So I’m drafting an email to send to FDA, which will include a compilation of many of the questions and concerns the community has voiced today (and previously) on this topic.

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.

Why you should post that in Gitter

“You should post that question in Gitter.” –something @DanaMLewis says a lot

I realize it’s not always obvious to those who are newer to #WeAreNotWaiting or #OpenAPS why I am often pointing people to ask their questions in Gitter.

Let me explain:

There is a Gitter chat channel where most of the #OpenAPS and other DIY development conversations happens. (There are several other channels, so if you pop onto the main OpenAPS one, we’re happy to point you to another if there’s another one already built for another or related project.)

Gitter connects with Github, so you can use the same username to log in and ask a question. And very importantly, it’s public, so *anyone* can see the conversations in channel – even if you decide not to log in. See for yourself – click here to view the chat channel. This is very key for an open source project: anyone can jump in and check things out.

Transparency & archiving community knowledge
It also means that questions can be asked – and answered – openly, so that when someone has the same question, they can often find an existing answer with a little bit of searching.

(Tip: there’s a Gitter app for your phone, and for your desktop, both of which I use on the go – but for searching back in the channel, the web Gitter interface has a better search experience, or you can also use Google to search through the archives.)

Faster responses from a smarter, broader, worldwide community
There’s another key reason why asking a question in an open channel is helpful for Q&A. Two words: time zones. There are now (n=1)*104+ people around the world with DIY closed loops, and a lot of them pay it forward and provide guidance and also help answer questions.

If you send one individual a question in a private channel, you have to cross your fingers and hope they’re a) awake b) not working and c) otherwise available to respond.

But if you ask your question openly in a public channel, anyone out of the large community with the answer can jump in and answer more quickly. Given that we have a worldwide community and people across many time zones, this means faster answers and more “ah-ha’s” as people collaboratively work through new and already-documented-sticky-points in the build process.

So if you ask an individual a question in a private channel, you might get a “You should ask that in Gitter!” response. And this is why. :) You’re welcome as always to ping me across any channel, but often when there’s a good question, I’m going to want you to re-post in Gitter, anyway, so people can benefit from having the knowledge (including any answers from the community) archived for the next person who has the same or similar question.
4 reasons to post OpenAPS questions in Gitter