Joint replacements are the #1 expenditure of Medicare. The process of approving these medical devices is flawed according to the Institute of Medicine. It is time for patients' voices to be heard as stakeholders and for public support for increased medical device industry accountability and heightened protections for patients. Post-market registry. Product warranty. Patient/consumer stakeholder equity. Rescind industry pre-emptions/entitlements. All clinical trials must report all data.
Please share what you have learned!
Twitter: @JjrkCh
Showing posts with label unique device identifier. Show all posts
Showing posts with label unique device identifier. Show all posts

Tuesday, October 24, 2017

Catastrophic FAIL: Easier to Recall Spinach Than Medical Implants



By Joe Carlson OCTOBER 21, 2017 — 2:00PM
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Fictitious medical device label is shown for unique device identifier information.

In March 2015, Target Corp. alerted customers to throw out certain 10-ounce bags of organic chopped spinach because they were potentially contaminated with listeria bacteria, which can cause serious health problems.
The recall notice, filed with the U.S. Food and Drug Administration, urged people who bought the spinach to check UPC codes and a special nine-digit tracking code called the DPCI that Target includes on its sales receipts. The recall was routine, and no illnesses were publicly linked to the incident.
No such system exists for medical device consumers, however.
In fact, proposals to give insurers and patients access to the serial numbers on their implanted medical devices remain controversial.
Manufacturers say it would cost additional time and money with no guarantee of benefit to put the device serial numbers into insurance claim forms. Consumer safety officials and auditors argue the move would improve patient safety and enhance accountability.
To patient advocates like Lisa McGiffert, director of the Consumers Union's Safe Patient Project, omitting device serial numbers from an insurance claim would be like buying a car without getting its VIN number.
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Doesn’t Add up: The medical industry is divided over adding a unique device identifier (UDI) to devices, which would make it easier to locate a device but at a higher cost for companies.
"We don't even have the make and the model" in insurance claims, McGiffert said. "We can put it on a car — why shouldn't we have it on a hip that you're putting in my body?"
Thousands of medical devices are recalled each year, but it can be hard to track them. In 2005, former Minnesota device maker Guidant Corp., now part of Boston Scientific, urgently recalled thousands of pacemakers because excess moisture could seep inside the life-preserving devices and ruin them.
A handful of patients with the devices went into cardiac arrest or experienced heart failure, and one death may have been linked to a pacemaker failure. Yet the Government Accountability Office (GAO) reported in 2011 that 1,732 of these recalled pacemakers were never recovered because there was "no implant record available."
Medicare, which pays hospitals to implant such devices in patients aged 65 and older, had no direct way of tracking down which of its patients may have gotten those 1,732 leaky Guidant pacemakers — nor, for that matter, any of the hundreds of thousands of other heart devices that have been recalled by the medical device industry in the years since then, critics inside and outside the government say.
Congress mandated a system of serial numbers to track medical devices known as UDIs, or unique device identifiers, back in 2007, and the Food and Drug Administration has been rolling out rules for how and when to use them ever since.
The med-tech industry and some doctors have fought hard to keep them out of Medicare claims and private insurance bills.
A two-year investigation by Medicare's inspector general office recently concluded that the publicly funded health insurer spent an estimated $1.5 billion over 10 years on surgeries and follow-up care for patients who had one of seven specific heart devices made by Minnesota manufacturers. The review did not include the Guidant pacemakers mentioned by the GAO and didn't examine other widely recalled types of devices, like metal-on-metal hip implants.
John Boujoulian, senior auditor on the Medicare inspector general investigation, said the lack of UDI numbers in Medicare claims makes it harder to locate patients affected by medical device recalls. But as it stands, Medicare would have to do a detailed review of medical records to find the UDIs to track down devices that it pays to have implanted or replaced.
"We had to go through all the medical records to find out," Boujoulian said in an interview about the audit. Using subpoenas to the device makers, "we had lists of all the people who had the medical devices implanted and the specific models, and we had to go through them all to see which ones had issues."
But going through the detailed medical records of patients is exactly what the medical device industry advocates.
"We support the collection of the UDI in the electronic health record, where it can actually be used to really help track patient outcomes and be used in a more proactive way around postmarket surveillance," said Don May, executive vice president for the Washington-based medical device manufacturer trade group AdvaMed. "If we are really concerned about patient safety, then let's go to the tool that makes the most sense."
Industry officials say the codes are too long and varied to put into insurance claims. AdvaMed says hospitals would have to invest in new bar code scanners and come up with ways to accurately transmit the data to payers. The American Medical Association says reporting UDIs in insurance claims would be cost prohibitive and insufficient for detecting widespread problems.
Organizations including Centers for Medicare and Medicaid Services and the Medicare Payment Advisory Commission have supported adding a short section of the UDI known as the "device identifier," or DI, to Medicare claims forms.
The full UDI, however, can run to 75 characters and comes in three different formats used by three different standards organizations. The full code contains not just model numbers, but batch and lot numbers, dates of manufacture and other information that would identify which specific devices are affected by problems.
AdvaMed Associate Vice President Zach Rothstein, who advocates on medical device regulation involving the FDA, said researchers who use just snippets of the UDI codes may draw inaccurate conclusions about devices that could negatively affect both medical device makers and patients.
"Think about all the food recalls where you go to your freezer and say, 'Well, was this done in that time frame and in that plant?' And the news gives you the code. It's not just this was Tyson chicken," he said. "Without [the full serial number], you just don't know."
Advocates say patient safety would benefit from the added transparency, dismissing arguments that it's too difficult or expensive. Ben Moscovitch, manager, health information technology at Pew Charitable Trusts, noted that the FDA's Sentinel program to root out problems with prescription drugs is based largely on claims data, which incorporates 10-digit National Drug Codes.
"Many of the safety challenges that occur with devices occur across the entire product line," Moscovitch said, "and to evaluate the safety of products in that capacity requires only the brand and model of the device, and not the production information that is included in the [full UDI]."
The three companies that made the recalled or defective heart devices that led to $1.5 billion in Medicare spending documented in the inspector general's report — Boston Scientific, Medtronic and St. Jude Medical owner Abbott Laboratories — all declined to comment for this story.
Asked whether the medical device companies' opposition to including UDIs in Medicare-claims forms was related to financial concerns like lost sales or increased litigation, May noted that product recalls are already costly.
"From a litigation perspective, I think malpractice attorneys are very aggressive in a lot of ways, and this just becomes one additional data source," May said. "But if you've got a product that is recalled, my guess is the company is already feeling a financial impact because it's a product that they've had to recall."


http://www.startribune.com/effort-to-improve-tracking-of-medical-devices-divides-industry-consumer-groups/451942493/#comments

Wednesday, February 27, 2013

Joint Replacement Survey: Consumers Union

https://stori.es/share/your-joint-replacement-experience

If you or a loved one have an implanted joint replacement, please go to the link above and fill in the survey.

Consumers Union is actively advocating for patients with implanted medical devices.  Today, CU Safe Patient Project, Senior Director, Lisa McGiffert participated by Brookings Institute webinar with FDA Jay Carney and NWHN Kate Ryan in a discussion on implementing UDI's.  Unique device identifiers are the first step in providing patients with accurate and timely information about the composition, origin and producer of their implant.  This information will be uniform and shared in the electronic health record, with the insurer and the FDA.  This will allow researchers to analyze which devices are safe and effective and provide the patient with a portal to determine which devices have been recalled.  The federal government is still working on implementation, so Consumers Union is providing this survey as a preliminary "registry" for patients until the national program is fully instituted.

Thank you!



Saturday, November 10, 2012

UDI's will reduce patient harm


http://www.dotmed.com/news/story/19856?p_begin=0
November 09, 2012
by Brendon Nafziger , DOTmed News Associate Editor (FiDA highlight)
Group purchasing organizations want the Food and Drug Administration to hurry up its timeline for implementing new medical device labels and a tracking system that could make recalling products easier and more efficient, while medical device companies fret that the process needs more time.

The groups submitted comments to the FDA this week as the comment period for the new unique device identifier (UDI) proposed regulation ended Wednesday.
Janet Trunzo, a senior executive of regulatory affairs for AdvaMed, a medical device manufacturer trade group, called the project "one of the most extensive and complex regulations to be issued in recent memory."

Based on a recent survey commissioned by the group, AdvaMed estimates UDI implementation could cost manufacturers millions in setting up new production equipment and possibly billions if they were forced to recall and destroy lots of old devices.

"Because of the cost and impact of this rule for companies we believe it is imperative that FDA get it right the first time," she told reporters on a press call Thursday.

What is the UDI?

The UDI itself is a two-part system, wtih an alphanumeric code that identifies the device model and and production identifier that gives the serial, lot or batch number, and an expiration date. The UDI would appear on device labels and packaging in plaintext, intelligible to humans, and a machine readable format, such as a barcode. The other major element is the Global UDI Database, an under-construction public online database that could help the government or providers track products during a recall.

The UDI rule, long championed by patient advocates, has been in the works for several years, but was given a push this summer when Congress passed an FDA user fee renewal bill that included language forcing the FDA to come up with proposed rules by the end of the year. The FDA released those rules in July.

Timeline

For stakeholders involved in this immense, multi-year project, one of the key issues is when they'll have to comply with the final rules, which are expected next year.

Under its proposed rules, published this summer, FDA put in place a staggered timeline, with higher-risk (Class III) devices expected to have UDI labeling on packaging or devices within one year of the publication of the final rule, intermediate-risk devices (Class II) within three years, and lower-risk (Class I) and unclassified devices in five years.

Some products, like implantable devices and software, require the UDI printed directly on the device itself, in a process called direct marking. This will be required from three to seven years after the final rule is published, with riskier devices getting direct marking first.
Too fast

Medical device manufacturers, perhaps unsurprisingly, disagree, and they stress the expense and cost of switching over to the new system: they will have to buy and install new labeling machines in factories, implement and validate production software and train staff.

In its comments submitted to the FDA, AdvaMed urged the agency to delay Class III requirements by one year, for a two-year post-final rule effective date. "There is no direct device safety and effectiveness issue that is compromised by extending the effective date for Class III devices by one year, and doing so will assist regulated persons and those in the health care community to integrate the UDI into their daily practices effectively," the group wrote.

The lobby also wants to clarify what they say could be one of the biggest troublemakers with implementing the system: what to do about devices that were created before the regulations take effect. That's why AdvaMed is asking that the rules be prospective, and only apply to devices produced after the effective date.

"The cost of applying UDI requirements to existing inventory once an effective date is reached is huge," AdvaMed said in its comments. "For example, sterilized devices cannot, in all cases, be safely and economically re-labeled, re-packaged and re-sterilized, and therefore, must be destroyed. Other devices that arguably could be reprocessed would present such large expense that doing so would be impractical. More importantly, such massive reprocessing would interfere with other device production, thus threatening potential shortages and an endangerment to public health."

Financial impact

AdvaMed has tried to come up with some figures to show how costly implementing UDIs would be to the industry, specifically focusing on the impact of direct marking.

According to an Accenture survey of 18 companies commissioned by the lobby and released Thursday, three-quarters expect significant costs for switching production lines to direct marking. The total associated costs per packaging line averaged around $125,000, according to the survey. All told, about 44 percent of respondents said they'd have to spend upwards of $1 million to purchase new manufacturing equipment, and the complete one-time cost of putting the system in place for all respondents was nearly $80 million.
n addition, respondents estimated they'd have to spend $2.8 billion in total to recall and reconfigure non-compliant equipment.

Retail exceptions
In addition to the timeline, GPOs and manufacturers are also somewhat split on the issue of medical products sold at drug stores. The FDA's proposed rules contain an exception for requiring UDI labels to products sold at retail outlets.

AdvaMed thinks the FDA should keep the rule as-is, and that all non-prescription retail products should be able to use the ubiquitous Universal Product Code "as an adequate unique device identifier." The group says that the UPC does what the UDI is meant to do and enables products to be accurately tracked.

But GPOs seem wary, at least in part. "Some of these retail products include automatic external defibrillators, insulin syringes and glucometers," Premier said. While Premier said the UPC could count as a UDI, they should still be subject to the UDI requirements, such as reporting to the product database.

Novation also backs limiting or doing away with the retail exception. "Novation does not believe a blanket exception of Class I devices sold in a retail setting is appropriate, nor in the best interest of patients," the GPO said in its release.

More exemptions

The manufacturers also want the FDA to create a specific list of devices that would ordinarily require direct marking, such as implantable devices, but are exempted from the requirement. Under the proposed rule, companies can "self-exempt" products that can't be directly marked, but the manufacturers worry that without a clear, explicit list of exempted devices they could be challenged by FDA field inspectors and receive citations or warning letters.

"We're requesting and have submitted a list of devices that are intrinsically unmarkable, and we go into details of what that would entail," Jeff Secunda, AdvaMed's VP of technology and regulatory affairs, said on a press call. Examples would include small dissolvable objects like absorbable sutures or amorphous ones like bone putty.

They also want to expand an exemption for lower-risk products sold in dispensing packs. Under the proposed rule, Class I items sold in boxes need a UDI for the box, but not each individual product. AdvaMed wants to expand this to all devices.

More broadly, the group questions the wisdom of direct marking implantable products in general, arguing that it makes more sense to have the packaging labeled, which would then be scanned before the device is implanted, with the scanned information getting logged into a patient's electronic health record.
"During, or just prior to, surgical implantation of the device the UDI is entered into the patient's EHR providing a permanent link between the patient and the implanted device," the group said in its comments. "This information will be available to all those who are authorized to access the patient's EHR and will not require a surgical procedure to extract the device and scan the UDI. Postmarket surveillance is conducted non-invasively on EHRs databases."

Under the FDA user fee renewal bill, final UDI rules would have to be issued within six months of ending the comment period -- that is, in May. 

Tuesday, September 4, 2012

Register by September 5: FDA Medical Device UDI webinar



The Food and Drug Administration (FDA) is announcing a public meeting entitled: “Strengthening the National Medical Device Postmarket Surveillance System.” The purpose of this meeting is to solicit public feedback regarding FDA’s proposal to strengthen the national medical device postmarket surveillance system.
•                Date, Time and Location 
•                Federal Register Notice
•                Agenda
•                Registration
•                Contact Us
Date, Time and Location
This meeting will be held September 10, 2012, beginning at 9:00 a.m. - 4:00 p.m. at the following location:
Greenbelt Marriott
6400 Ivy Lane,
Greenbelt, MD 20770
301-614-8202
The meeting will be available by Webcast.
Agenda
Available soon.
Registration to Attend the Meeting
If you wish to attend this meeting in person, you must register online by September 10, 2012. If you wish to view this meeting by Webcast, you must register by close of business on September 5, 2012.
There is no fee to register for the meeting and registration will be on a first-come, first-served basis. Early registration is recommended because seating is limited.
If you wish to make an oral presentation during an open comment session at the meeting you must indicate this at the time of registration. FDA requests that presentations focus on the areas defined in the Federal Register Notice. You should also identify which discussion topic you wish to address in your presentation and you must submit a brief statement that describes your experience and/or expertise relevant to your proposed presentation. In order to keep each open session focused on the discussion topic at hand, each oral presentation should address only one discussion topic. FDA will do its best to accommodate requests to speak.
If you require special accommodations due to a disability, or need additional information regarding registration, please contact Joyce Raines, Office of Communications, Education, and Radiation Programs, Center for Devices and Radiological Health, Food and Drug Administration, 10903 New Hampshire Avenue, WO-66 Room 4319, Silver Spring, MD 20993, 301-796-5709, FAX: 301-847-8142, email: Joyce.Raines@fda.hhs.gov, no later than September 5, 2012.
Contact Us
For questions regarding workshop content please contact:
Anita Rayner 
Center for Devices and Radiological Health 
Food and Drug Administration 
10903 New Hampshire Avenue, WO-66 Room 3316 
Silver Spring, MD 20993 
301-796-6002 
email: anita.rayner@fda.hhs.gov
or
Danica Marinac-Dabic
Center for Devices and Radiological Health 
Food and Drug Administration 
10903 New Hampshire Avenue, WO-66 Room 4110 
Silver Spring, MD 20993
301 - 796-6689
e-mail: danica.marinac-dabic@fda.hhs.gov
Page Last Updated: 09/04/2012