Abstract
Medical technology in gastroenterology spans devices, point-of-care diagnostics, digital health and artificial intelligence. We conducted a narrative review of US Food and Drug Administration-reviewed medical technology on the available evidence base to support uptake in clinical practice. 713 new GI devices were FDA-approved or cleared between 2013 and 2023. The most frequent technologies had indications for use in general endoscopy (442 or 62.0% of all new technologies) with advanced endoscopy technologies being the second most common (172 or 24.1%). Ninety-nine new technologies had indications for use outside of the endoscopy suite. 99% of new technologies were FDA-cleared against existing technologies via the 510(k) pathway rather than approved on new clinical data. Among the 19 devices with clinical trial data, trials were limited in sample size and generally evaluated disease-related changes or technical success rather than patient-reported outcomes that anchor drug trials. Twelve devices (63.2%) had favorable, published cost-effective data. To promote evidence-based discussion and uptake of new technology, and especially disruptive or high-risk technology, we propose a practical framework informed by balancing probable efficacy and safety and considering cost-effectiveness.
Keywords: medical device, endoscopic device, machine learning, digital health, point-of-care
INTRODUCTION
The scope of medical technology in gastroenterology
Medical technology is essential to gastroenterology, with colonoscopy and endoscopy being among the most performed procedures. Over the past two decades, interventional endoscopy has become a recognized subspecialty spanning a clinical footprint across bariatrics, gastrointestinal luminal disease, and hepatobiliary/pancreatic disease. Outside of the endoscopy suite, the usage of digital tools and artificial intelligence has been emerging across many gastroenterology subspecialities including inflammatory bowel disease, hepatology, and motility.
Limited awareness of med tech regulation
Despite daily reliance on medical technology, >80% of physicians (including gastroenterologists) remain largely unaware that FDA’s required scientific data for medical technology differs from the expected scientific data for drugs.(1) For example, the most recent colonoscopes used for colon cancer screening in every day practice were FDA cleared without requiring clinical trial data.(2-4) While the colonoscope was cleared by the FDA via the 510(k) pathway as it was compared to a precedent device, this reality stands at odds with the regulations required for drug approval, as every new drug is evaluated based on systematic reviews of large clinical trials to set the standard for shared decision-making, evidence-based medicine, and practice guideline development. Despite medical technology being integral to gastroenterology, little is known about the FDA medical device approval/clearance pathways and the clinical data required.
Med tech regulatory pathways
There are five main pathways for FDA approval/clearance of medical devices. Each new medical device is assigned one of three regulatory classes: Class I, II, and III. As devices increase in class, the level of regulatory control also increases.(5) Most Class I devices and some of Class II devices can become exempt from the 510(k) pathway if the FDA determines that the device is safe and effective.(6) A 510(k) premarket submission is used for Class I and Class II devices that have a substantially equivalent legally marketed device.(7) A Premarket Approval (PMA) is required for Class III devices, which are defined as devices that can support or sustain human life but can pose potential and unreasonable risk or injury.(8) De Novo devices are novel medical devices that have never been marketed in the US. They are compared to controls, and the use of these controls can provide reasonable assurance of safety and efficacy. These devices are also classified into regulatory classes based on their risks.(9) Lastly is the Humanitarian Device Exception pathway, which are all Class III devices intended to be used in patients with rare diseases or conditions (<4,000 patients per year).(10)
Purpose of this review
We performed a review to synthesize and summarize the available evidence on medical technology development in gastroenterology. However, we recognize that many factors influence the utilization of new medical devices in the clinical practice, such as device cost, device efficacy, and even clinician exposure and familiarity. Additionally, we reviewed the cost-effectiveness of these new devices with supported clinical data. Our goal is to provide physicians with further insights into the approval processes of new medical devices and to assess whether the cost of the device is justified by its effectiveness. We aim to empower physicians to make practical recommendations that support benefit and risk discussions surrounding utilization of medical technology in health care, as well as inform them of the potential economic benefits associated with each device utilization.
METHODS
Search Strategy and Eligibility Criteria
Our research librarian team developed our search strategy, and included FDA databases for 510(k) clearance, De Novo classification, and pre-market approval (PMA) to identify medical device applications that were FDA-cleared or approved with decision dates between 2013 and 2023.11-13 Search terms included limiting results to the Gastroenterology/Urology Panel or the Gastroenterology/Urology Advisory Committee. Results were extracted to Excel 365 (Microsoft Corporation, Redmond, WA). We excluded devices receiving Humanitarian Device Exemption and those indicated for use outside gastroenterology and hepatology.
Review
Three research team members (MH, SX, RS) independently and manually reviewed all device applications, and discrepancies in eligibility were resolved by consensus with the senior investigator (ES). Applications related to the same device were consolidated for reporting purposes.
Data Extraction and Analysis
Devices were classified as general endoscopy (including endoscopic devices or accessories), advanced endoscopy (including devices used for advanced endoscopic procedures), and non-endoscopic gastroenterology devices (including devices used for motility, nutrition, or transplant). Extracted information for 510(k) devices included device name, 510(k) or PMA or de novo registration number, decision date, presence of FDA-reviewed clinical data in the approval letter, and predicate device (when applicable).
Clinical trials used to support FDA clearance or approval were cross-linked using PubMed and EMBASE directly from FDA databases to complete data extraction. For applications containing clinical data, we extracted data from published clinical trials to assess the quality of evidence in the study conducted according to the CONSORT statement, which reflects the gold standard for drug trial reporting. These data included study type, trial length, patient population, recruitment strategy, number of patients, randomization method (if used), comparator (if present), study outcomes/endpoints, and statistical plan.
To assess risk profiles for new gastroenterology technologies, the number and types of adverse and serious adverse events were extracted as reported by the study authors.
To assess the cost-effectiveness of the devices with supporting clinical trials, we conducted a literature search using PubMed. The search utilized keywords such as the proprietary and non-proprietary names of each device, "cost-effectiveness analysis," and "cost-benefit analysis." For each relevant analysis, we reviewed the abstract and full article to extract data, including whether the study adhered to the PRISMA-ScR checklist, cost of the device, patient population, time horizon, primary economic savings, and primary health outcome.
THE MED TECH PIPELINE
Seven-hundred and thirteen new gastroenterology technologies received FDA approval or clearance between 2013 and 2023.(11-13) Of this total, seven were FDA-approved via the PMA pathway and fifteen were approved via the De Novo pathway. The other 691 new technologies were FDA-cleared through the 510(k) pathway as substantially equivalent to an existing device.
Technology development across sub-specialties of gastroenterology
More than half of the technology via the 510(k) pathway (433 or 62.7%) and the De Novo pathway (8 or 53.3%) were intended for use in general endoscopy. In the PMA pathway, almost all devices are intended to be used outside of the endoscopy suite (6 or 85.7%) (Table 1). Across gastroenterology subspecialties, almost one-half of technologies were intended for use in general gastroenterology (347 or 48.7% of all new technologies), with endoscopic accessory devices being second-most common (117 or 16.4% of all new technologies) and hepatic/hepatobiliary technologies being third most common (105 or 14.7% of all new technologies).
Table 1:
Number of new FDA-approved or FDA-cleared technologies in gastroenterology between 2013 and 2013, stratified by sub-specialty and availability of clinical data evaluating intended use.
| Setting for intended use |
510(k) | Pre-Market Approval | De Novo | |||
|---|---|---|---|---|---|---|
| Number of Technologies |
Technologies with Clinical Data |
Number of Technologies |
Technologies with Clinical Data |
Number of Technologies |
Technologies with Clinical Data |
|
| Advanced Endoscopy | 169 | 1 | 0 | 0 | 3 | 3 |
| General Endoscopy | 433 | 6 | 1 | 1 | 8 | 5 |
| Non-Endoscopic Gastroenterology | 89 | 1 | 6 | 6 | 4 | 4 |
| Sub-specialty of intended use |
Number of Technologies |
Technologies with Clinical Data |
Number of Technologies |
Technologies with Clinical Data |
Number of Technologies |
Technologies with Clinical Data |
| General gastroenterology | 333 | 6 | 4 | 4 | 9 | 6 |
| Advanced Endoscopy | 40 | 0 | 0 | 0 | 0 | 0 |
| Endoscopy Accessory | 117 | 0 | 0 | 0 | 0 | 0 |
| Esophageal | 28 | 0 | 1 | 1 | 1 | 1 |
| Hepatic/Hepatobiliary | 103 | 1 | 0 | 0 | 2 | 2 |
| Motility | 20 | 1 | 0 | 0 | 1 | 1 |
| Nutrition | 36 | 0 | 0 | 0 | 0 | 0 |
| Pancreas | 14 | 0 | 0 | 0 | 2 | 2 |
| Transplant | 0 | 0 | 2 | 2 | 0 | 0 |
| Total | 691 | 8 | 7 | 7 | 15 | 12 |
Availability of clinical evidence
Clinical trial data included in an application to the FDA are rigorously evaluated during the regulatory process because these data can be used in FDA decision-making and in marketing claims for FDA-approved or FDA-cleared products. Eight of the 691 510(k) devices that came to market between 2013 and 2023 had clinical data supporting intended use, representing 1.1% of all new 510(k) devices. 98.9% of all new 510(k) devices did not include clinical data in their FDA application. Among devices that are first-of-its-kind for intended use, all PMA devices (including the highest level of risk to patients) and most de novo devices (low or moderate risk) included clinical data to evaluate their intended use.
Quality of clinical evidence
Among the 27 clinical trials conducted between 2013 and 2023 to support FDA approval or clearance of new, non-drug technologies in gastroenterology, 18.5% were randomized controlled trials of adequate sample size to detect statistical change on a primary endpoint.(14-18) Apart from four motility devices(19-22), only one other trial(23) used patient-reported outcomes as a primary endpoint (Supplemental Table 1 for a description of clinical trials). Instead, most trials targeted objective endpoints such as objective disease improvement or technical success of device deployment (such as biliary stent placement, lumen opposing stents for pancreatic pseudocysts, or direct endoscopic necrosectomy).
Safety
Among the 1.1% of 510(k) devices with clinical data accompanying their FDA application for clearance as being substantially equivalent to existing technology, seven of the eight device trials reported no adverse events.(15,16,23-27) Minor and transient adverse events with one 510(k) device intended for hepatobiliary use for stenting of malignant obstructions (percutaneous intraductal RFA followed by dual stent placement) that received 510(k) clearance.(28)
Adverse events were common in clinical trials evaluating first-in-class technologies and intended-use applications. For example, adverse events occurred in eight (72.7%) of the 11 clinical trials for de novo devices deemed to have a low or moderate risk to patients, and serious adverse events occurred in two of these trials for devices intended for use in advanced endoscopy. One occurred in a trial device intended for use in general endoscopy. These serious adverse events represented known complications of endoscopic pancreatic pseudocyst drainage, colonoscopy, and stenting of biliary strictures, leading these devices to ultimately receive de novo classification.(29,30) All trials that supported pre-market approval (i.e., devices with the highest level of risk to patients) of new technologies reported serious adverse events in clinical trials. No device-related deaths were reported in clinical trials that supported any FDA approval or clearance (Tables 2 and 3 for description of adverse events in gastroenterology medical technology clinical trials over the past decade).
TABLE 2:
Overview of adverse events (AE) and serious adverse events (AE) across new gastrointestinal technologies in the United States between 2013-2023 for the De Novo pathway, Pre-Market approval pathway, and 510(k) pathway.
| De novo technologies (low or medium risk to patients) | ||||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Device | Total number of patients in device trials (N) |
Number of patients experiencing at least 1 AE |
Total number of AEs during trials |
Total number of SAEs during trials |
Deaths Related to Device |
Deaths Unrelated to Device |
||||
|
Axios Stent (Endoscopic drainage of pancreatic pseudocyst) |
33 | 16 (48.5% of total) | 45 | 25 | 0 | 0 | ||||
|
Pillcam Colon 2 (Colon capsule imaging system) |
884 | 101 (11.4%) | 143 | 1 | 0 | 0 | ||||
|
Eclipse (Rectal control system for fecal incontinence) |
61 | 61 (100.0%) | 93 | 0 | 0 | 0 | ||||
|
Wallflex Biliary RX (Metallic stent for benign biliary strictures) |
127 | 53 (41.7%) | -- | 86 | 0 | 10 | ||||
|
IB-Stim (Non-implanted nerve stimulator for functional abdominal pain) |
115 | 10 (8.7%) | 10 | 0 | 0 | 0 | ||||
|
Echotip Insight (Endoscopic transhepatic venous access needle) |
28 | 0 (0.0%) | 0 | 0 | 0 | 0 | ||||
|
Mucosal Integrity Conductivity (MI) Test (Esophageal tissue characterization system) |
112 | 1 (0.9%) | 1 | 0 | 0 | 0 | ||||
|
NaviCam Capsule Endoscope System (Magnetically maneuvered capsule endoscopy system) |
353 | 5 (1.4%) | 9 | 0 | 0 | 0 | ||||
|
GI Genius (GI lesion software detection system) |
700 | 0 (0.0%) | -- | 0 | 0 | 0 | ||||
|
Spyglass DS Direct Visualization System (Platform to visualize and treat biliary disease) |
||||||||||
|
AccuMeasure System (Endoscopic light-projecting measuring device) |
Redacted | 0 (0.0%) | 0 | 0 | 0 | 0 | ||||
|
Vibrant Ltd. (Orally ingested device for constipation) |
349 | 62 (17.8%) | 74 | 0 | 0 | 0 | ||||
| Pre-market approval technologies (includes devices with high risk to patients) | ||||||||||
| Device | Total number of patients in device trials (N) |
Number of patients experiencing at least 1 AE |
Total number of AEs during trials |
Total number of SAEs during trials |
Deaths Related to Device |
Deaths Unrelated to Device |
||||
|
Acticon Neosphincter (Implantable device for treatment fecal incontinence) |
112 | 102 (91.1% of total) | 395 | Unknown | 0 | 0 | ||||
|
Axonics Sacral Neuromodulation (SNM) System (Implanted electrical device for treatment of fecal incontinence) |
129 | 80 (62.0%) | 181 | 7 | 0 | 1 | ||||
|
Interstim (Implanted electrical device for treatment of fecal incontinence) |
120 | 88 (73.3%) | 237 | 20 | 0 | 0 | ||||
|
LINX (Implanted device for the treatment of gastroesophageal reflux disease) |
100 | 76 (76.0%) | 162 | 12 | 0 | 0 | ||||
|
Organ Care System (OCS®) Liver (Perfusion system for the preservation of donor livers) |
299 | 82 (27.4%) | Unknown | 150 | 0 | 0 | ||||
|
OrganOx metra System (Perfusion system for the preservation of donor livers) |
266 | 95 (35.7%) | Unknown | 275 | 0 | 0 | ||||
|
SOLESTA (Injectable bulking agent for the treatment of fecal incontinence) |
206 | 97 (47.1%) | 238 | 2 | 0 | 0 | ||||
| 510(k) technologies (substantially equivalent) | ||||||||||
| Device | Total number of patients in device trials (N) |
Number of patients experiencing at least 1 AE |
Total number of AEs during trials |
Total number of SAEs during trials |
Deaths Related to Device |
Deaths Unrelated to Device |
||||
|
Elra Electrode (Endoscopic bipolar radiofrequency ablation electrode used to ablate tissue in the common bile duct) |
30 | 3 (10.0% of total) | 3 | 0 | 0 | 0 | ||||
Note: Twelve devices reported clinical data in their FDA submissions. Data for one device (Endorotor) was not made available in the public domain.
TABLE 3:
Overview of cost-effective analyses for new medical devices approved or cleared with clinical trial data between 2013-2023.
| Device | Non-Proprietary name | Study | Use of PRISMA |
Patients Criteria | Time Horizon | Cost of Device | Economic Savings | Health Savings |
|---|---|---|---|---|---|---|---|---|
| Axios Stent or Wallflex Biliary Rx | Lumen-apposing metal stent; metal biliary stent | Chen et al (2018)(42) | Yes | Endoscopic ultrasound-guided drainage of pancreatic walled-off necrosis | 6 months | $20,029 for metal stent |
|
|
| Chen et al (2018)(43) | No | Endoscopic ultrasound management of pancreatic pseudocyst | 6 months | Unknown |
|
|
||
| Roberts et al (2021)(44) | No | Preoperative biliary drainage prior to a pancreatoduodenectomy | Unknown | $2900 AUD for metal stent |
|
|
||
| Elshimi et al (2020)(45) | No | All patients ≥18 years with obstructive jaundice caused by hepatocellular carcinoma | 1 year or until re-obstruction or death | Total cost for an ERCP procedure with metal stent: 14,000 EGP |
|
|
||
| Farani et al (2021)(34) | No | Patients with malignant obstructive jaundice who underwent palliative biliary stent insertion | 6 months | Median initial cost IDR 93 998 886 in the metal stent group |
|
|
||
| Martinez et al (2017)(46) | No | Adult patients in the USA with nonresectable, locally advanced (stage III/IV) pancreatic carcinoma | Unknown | Unknown |
|
|
||
| Gardner et al (2016)(47) | No | Patients with extrahepatic malignant biliary obstruction from newly diagnosed pancreatic adenocarcinoma | Unknown | Fully covered self-expandable metal stent (fcSEMS): $4,274 Uncovered self-expandable metal stent (uSEMS): $3,446 |
|
|
||
| Barkun et al (2015)(48) | No | Patients with extrahepatic biliary obstruction by any malignant process | 12 months | Metal stent: $6,701 |
|
|
||
| Almadi et al (2021)(49) | No | Adult patients with borderline resectable pancreatic cancer | Up to 1 year | Metal stent: $9,304 |
|
|
||
| Yoon et al (2009)(50) | No | Patients with obstructive jaundice caused by unresectable malignant biliary obstruction | End of study was either patient death or 06/2007 | Metal stent: $563.98-810.86 |
|
|
||
| Pillcam Colon 2 or NaviCam | Colon capsule or video capsule | Palimaka et al (2015)(51) | No | Patients aged 18 to 100-plus years who had been referred for CT colonography for known or suspected colonic disease | Life time horizon | CA $650 for the capsule Average cost of colon capsule endoscopy: CA $1,120.42 |
|
|
| Barré et al (2020)(52) | No | French population entering the colorectal cancer screening program: individuals aged 50 years with no prior history of screening, and no familial history of colorectal carcinoma, inflammatory bowel disease, familial adenomatous polyposis or Lynch syndrome | Unknown | Cost for capsule: 152.61 euros |
|
|
||
| Saunders et al (2019)(53) | No | Simulated patients with Crohn disease | 5-20 years | Unknown |
|
|
||
| Jawaid et al (2020)(54) | No | Adult patients at least 18 years old, able to provide informed consent, hemodynamically stable, and admitted for evaluation of new onset, non-hematemesis gastrointestinal bleeding | Unknown | Unknown |
|
|
||
| Lobo et al (2020)(55) | No | Simulated patients with Crohn disease | 20 years | 800.75 GBP |
|
|
||
| Meltzer et al (2014)(56) | No | 65-year-old patient with GI bleed | Unknown | USD $700 |
|
|
||
| Eclipse | No cost analysis study | |||||||
| IB-Stim | Percutaneous electrical nerve field stimulation | Shah et al (2024)(57) | No | Adolescent patients with IBS who have failed at least one common empirical treatment modality for abdominal pain | 1 year | Unknown |
|
|
| Echotip Insight | No cost analysis study | |||||||
| Mucosal Integrity Conductivity (MI) Test | No cost analysis study | |||||||
| GI Genius | Computer- aided detection of adenoma | Barkun et al (2023)(58) | No | Patients 50 years of age and older undergoing colonoscopy as a result of positive FIT | Life time horizon | Cost for overall case: $2,990.74 |
|
|
| Hassan et al (2023)(59) | No | Simulated cohort of patients aged 50 undergoing colonoscopies after positive FIT results | Life time horizon of 70 years | Average cost of €43,500 for each GI Genius Module |
|
|
||
| Thiruvengadam et al (2023)(60) | No | Patients undergoing screening colonoscopy at age 45, and continued surveillance or screening colonoscopies | Up until age 100 or death | Monthly unit cost of $3000 with 40 colonoscopies per unit for a per-procedure cost of $75 |
|
|
||
| AccuMeasure | No cost analysis study | |||||||
| Vibrant | No cost analysis study | |||||||
| Acticon Neosphincter | No cost analysis study | |||||||
| Axonics or Interstim | Sacral neuromodulation or sacral nerve stimulator | de Miguel Valencia et al (2023)(61) | No | Patients with severe fecal incontinence between who did not respond to previous treatments | Unknown | Cost/unit: 3354.59€ |
|
|
| van Wunnik et al (2012)(62) | No | Theoretical patients with fecal incontinence | 5 years | Cost of device: €12698 |
|
|
||
| Hounsome et al (2018)(63) | No | Patients with fecal incontinence who failed conservative therapy | 5 years | Total temporary sacral nerve stimulator cost: £1,612.94 Total permanent sacral nerve stimulation cost: £12,216.43 |
|
|
||
| Tipsmark et al (2016)(64) | No | Patients with diarrhea-predominant or mixed irritable bowel syndrome (IBS) according to the Rome III criteria and a baseline Gastrointestinal Symptom Rating Scale – IBS version score of at least 40 points | 4-20 years | £9,919 |
|
|
||
| Indinnimeo et al (2010)(65) | No | Patients with fecal incontinence | 5 years | €2,500 for sacral neuromodulation test €10,000 for final implantation |
|
|
||
| van der Wilt et al (2017)(66) | No | Children and adolescents aged 10-18 years with constipation refractory to conservative management | 3 years | €8,739 for device and €2,303 for tined lead |
|
|
||
| Hetzer et al (2006)(67) | No | Patients who had more than one episode of fecal incontinence per week for at least a year and failed medical therapy | Unknown | €15,345 per patient for the first year and €997 annually thereafter |
|
|
||
| Dudding et al (2008)(68) | No | Adult patients with fecal incontinence who have failed conservative treatment | Unknown | Cost per device: £7,896·00 |
|
|
||
| Linx | Magnetic sphincter augmentation | Harper et al (2023)(69) | No | Patients who were refractory to PPI therapy | Life time horizon | Cost per device: £3,000 |
|
|
| Pandolfino et al (2020)(70) | No | Simulated patients with gastroesophageal reflux disease refractory to medication management | 1 year | Inpatient: $21,817 Outpatient: $8,273 |
|
|
||
| OrganCare System or OrganOx | Normothermic machine perfusion | Wehrle et al (2024)(71) | No | Patients undergoing primary deceased donor liver transplantation | Unknown | Organ acquisition and preservation with normothermic machine perfusion: $88,923 |
|
|
| Webb et al (2022)(72) | No | Patients undergoing liver transplantation | 5 years | Normothermic machine perfusion per run is $15,359 to $16,720 |
|
|
||
| Javanbakht et al (2020)(73) | No | Hypothetical cohort of patients awaiting liver transplantation | Life time horizon | Cost of disposables and solutions: £6,000 |
|
|
||
| Solesta | Fecal incontinence bulking agent | Bernstein et al (2014)(74) | No | Adult patients who have had fecal incontinence for at least 12 months and did not respond adequately to conservative therapy | Unknown | Cost of device: $4,900 |
|
|
| Elra Electrode | No cost analysis study | |||||||
Cost-effectiveness
Among the 19 devices with clinical trial data, twelve devices (63.2%) had published cost-effectiveness data. A total of 35 cost-effectiveness analyses were identified (Table 3 for published cost-effectiveness data available for each gastroenterology device). 27 (79.4% of 35) analyses demonstrated the device to be more effective than the alternative device or treatment strategy. Out of these 27 studies, 12 showed that the devices were more costly, 12 showed that the devices were less costly, and 3 showed that the devices were of similar cost to their compared devices or treatment strategy. Five studies (14.7%) showed that the device was less effective when compared to their alternative devices, with four devices being more costly and one device was of unknown cost when compared to their alternative device or treatment strategy. Lastly, two studies (5.8%) showed that the studied device demonstrated similar effectiveness when compared to the alternative device or treatment, but was notably at lower cost.
Cost-effectiveness analyses of new medical devices can help healthcare systems navigate how to maximize health outcomes relative to available resources.(31) Of the devices with clinical trial data, the majority demonstrated increased effectiveness when compared to the alternative device or treatment strategies. While nearly half of these devices were more costly upfront, their increased effectiveness may eventually offset these initial costs by reducing indirect medical costs, such as those incurred from treating residual symptoms, time lost from work, or additional required procedures. However, there were a few studies which did show that these novel devices were not only more costly, but were also less efficacious. Practicing gastroenterologists should be aware of the studied indications in these cost-effectiveness analyses and whether these studies can be applied to their patient populations. In addition, such studies can further guide risk-benefit discussions with patients when considering utilization of such novel medical devices.
Barriers and realities in innovation
The worldwide regulatory and intellectual property protection climate constantly evolves, and with that, where the newest innovations might originate across the world. For example, the FDA process enables marketing in the United States while CE mark enables marketing in the European Union (EU).(32) The barrier to EU entry comparatively increased with new Medical Device Regulation (MDR) requirements for clinical data in 2017 [(EU) 2017/745]. Whether the intended outcomes of these increased requirements were successfully achieved has remained unclear.(33) The costs and perceived rigor of intellectual property protection across the world also affects the likelihood and timing in which industry will bear the risk of bringing new technologies to market.
With these considerations in mind and in contrast to years past, the United States may be positioned as the first market to receive new medical technologies over the next decade. Recent examples of devices that come to market without needing clinical data include the Spyglass DS and DS II direct visualization system to diagnose and treat biliary duct disease and the Overstitch device that has enabled endoscopic sleeve gastroplasty. Neither of these devices appear in our tables, because FDA did not require clinical data in their 510(k) applications, yet both of these devices have successfully reshaped the field of advanced endoscopy.
Trends and directions in the past decade
In the last decade, almost two-thirds of new medical technologies (n = 442 or 62.0%) in gastroenterology have been developed for use in general endoscopy. Most gastroenterology technologies came to market through the 510(k) regulatory pathway for devices, in which the FDA clears a device as being substantially equivalent to an existing device and with low or moderate risk to patients. Over 98% of these 510(k) devices came to market without clinical data. Among new technologies that were first-of-its-kind in terms of intended use or technology, clinical trials were generally performed to support FDA approval and published in the medical literature. Notably, of those devices with clinical trials, only a small minority were randomized control trials with adequate sample size. Adverse events were also common, especially in devices with first-in-class and first of intended use technologies.
Gaps in knowledge
The quality of clinical evidence inherently differs between medical technology trials and drug trials. For example, new drugs are expected to be supported by two phase III randomized clinical trials powered to detect change in a primary outcome measure. Patient-reported outcome measures should also be incorporated into primary outcome measures in drug trials. Medical technology trials that are successfully incorporated into regulatory applications do not necessarily require binary endpoints as might be expected in drug trials.(34) For medical technology, over 85% of trials did not use a randomized, placebo-controlled design and were not adequately powered to detect changes in clinical outcomes. Only two trials were powered by RCT and included patient-reported outcome assessments in the primary endpoint.(16,20) Our findings contrast with physician expectations; in one study, 35% of physicians believed that medical technology approvals were based on two or more randomized controlled trials, 66% thought they were based on a single RCT, and 12% felt that they were approved based on registries or other nonrandomized studies.(1) Medical technology trials might also use methods other use binary endpoints as might be expected in drug trials.(34)
This discrepancy broadly relates to differences in the regulatory bar for new medical technology compared to new drugs. For first-of-its-kind medical technology or high-risk technology, the FDA weighs probable benefit against any probable injury or illness related to the technology, in contrast to more stringent definitions of safety and effectiveness in drug regulation that demand more extensive clinical trials. Where this becomes crucial is in understanding the nature of pathology that new technology addresses, with a prime example being the poo stent to treat pancreatic walled-off-necrosis. Regulators consider the inherent complication rates and natural history if left untreated. along with comparison to other available alternatives such as open or laparoscopic surgical necrosectomy. The adverse events from using the Axios stent might seem high at first glance without proper context to the risk reduction offered by this device compared to alternatives.(35) Unlike drugs, most lower-risk technologies are cleared as substantially equivalent without needing new clinical data instead of being approved based on safety and effectiveness.(36) As with drug trials, clinical data for medical technology (when available) are relevant only to the target population and according to intended use and adequate instruction.
The FDA can require post-marketing studies or clinical registries to address this knowledge gap and capture information on safety and effectiveness. Robust post-marketing surveillance mechanisms are used at the FDA to monitor device safety, but their effectiveness hinges on gastroenterologists reporting adverse clinical or technical performance events.(37) Lastly, the FDA does not regulate the practice of medicine. The FDA’s stance on off-label use of devices is that “If physicians use a product for an indication, not in the approved labeling, they have the responsibility to be well informed about the use and effects of the product.”(38)
Future directions in the next decade
The shortage of clinical data for new medical technologies does not imply that such data are unnecessary. Recognizing that large placebo-controlled medical technology trials might be unviable, the FDA allows qualitative or quantitative patient preference studies to inform the comparative assessment between probable benefit and risk.(39) Such studies can be beneficial in cases of uncertainty and medical device industry should consider the needs of gastroenterologists and patients in designing outcome measures relevant to practice. Finally, gastroenterologists and patients should be aware that majority of clinical devices in use were approved or cleared without clinical data, and its use largely hinge on the experience and familiarity of the practicing gastroenterologist. Therefore, future trials for new medical technology should consider the probable benefits and risks that are of interest to practicing gastroenterologists and patients, rather than focusing on the core requirements of regulators.
Framework to consider medical technology in development and clinical practice
From a technology development standpoint, a unified framework with the needs of clinical practice ensures that new medical technologies are designed from the start to reflect how they will eventually be used (Figure 1). From a gastroenterologist’s standpoint, a shared framework enables their practice to appropriately mitigate the risk of being an early adopter of new technology. When safety data are limited, clinicians should transparently consider, communicate and document the risks, benefits and alternatives with patients. Given alternatives that can be unfavorable (such as in our example of open necrosectomy), patients might reasonably choose care options informed directly by the clinician’s own experience. FDA’s Manufacturer and User Facility Device Experience (MAUDE) database is the most up-to-date resource for gastroenterologists to look up and report device complications, and it inherently relies on gastroenterologists to report adverse events to industry or directly to FDA.(40) Newer procedures may not be covered by insurance, therefore practices should ask industry representatives to present the business case adapted to the local practice to justify cost equity. Practices should be equipped to routinely handle pre-authorizations for unlisted procedures (e.g. Computerized Procedural Terminology code 91299) along with supporting clinical evidence.(41) To assist others in supporting insurance coverage, gastroenterologists should monitor and publish on their own real-world outcomes and safety events regardless of perceived positive or negative results.
Figure 1:

Framework to evaluate new medical technologies from patient, gastroenterology and society perspectives.
TAKE-HOME POINTS
In conclusion, the gastroenterology pipeline is robust and expanding within and beyond the endoscopy suite. The lack of clinical data before the market availability of new medical technologies should be considered in context: regulators deem most devices to be no more than minimal risk, and device/technology trials are inherently different from drug trials. This reality stresses the balance between reasonable timing to have access to beneficial technologies on the market without delaying care with a reasonable clearance process to ensure safety given that the clinical real world experience have many confounders and variables unlike regulated conditions in laboratories and clinical trials. Our findings should also encourage gastroenterology innovators to think “outside the box” in demonstrating that successful gastroenterology innovations can absolutely have various levels of clinical use and reach in practice.
Supplementary Material
Financial support:
Dr. Shah was supported by NIH 1K23DK134752.
Footnotes
Potential competing interests: Dr. Shah consulted for Ardelyx, Laborie, Mahana, Mylan, Neuraxis, Salix, Sanofi, and Takeda. The other authors do not have relevant conflicts.
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