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”.
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.
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.