Ensuring Safe Use

Do women deserve choice when it comes to contraception? On September 24th, the FDA will hold a meeting of the Obstetrics and Gynecology Devices Panel of the Medical Devices Advisory Committee to discuss the risks and benefits of Bayer HealthCare’s Essure System for permanent female sterilization. It’ll make for some strange bedfellows.

Essure is a small metal and polyester coil placed into a woman’s fallopian tubes in order to make her permanently sterile. FDA approved Essure after a fast-track review process that prioritized the device because it offered the first alternative to surgical sterilization and promised a quick recovery.

The big picture was lucidly presented by Essure manufacturer, Bayer, in a letter to the New York Times, “Women deserve access to a wide range of contraceptive options, and Essure is an important non-surgical and non-hormonal option for women who have completed their families and want permanent birth control. However, no medical device, procedure, or even drug is completely free of side effects.”

According to Dr. Bill Maisel, deputy director for science and chief scientist at the FDA’s Center for Devices and Radiological Health. “The agency believes the benefits outweigh the risks in appropriately selected patients who are adequately informed.” The FDA adcomm will examine and discuss an extended (5-year) follow up of a phase III trial evaluating the effectiveness, safety, tolerability, and satisfaction of hysteroscopically placed Essure inserts. Hopefully it will also discuss ways to better educate both patients and physicians about which methods of birth control are most appropriate given a woman’s specific situation and medical history.

The FDA’s job is to weigh the risks and benefits of the products it reviews and regulates. Most people only hear about these issues as they relate to pharmaceuticals – but the regulation of medical devices deserve far more attention then they currently receive from the media, physicians, and patients.

At the FDA, there is a program called the “Safe Use of Drugs Initiative.” The theory is that the way you make drugs safer is to ensure they are used as directed. The Safe Use strategy calls for better and more regular education for both healthcare providers and patients. And it works. It strengthens the sinews of safety. Knowledge is Power.

The Affordable Care Act provides universal coverage for female contraception. As more patients avail themselves of the many FDA-approved options, shouldn’t we also be designing strategies and tools to ensure safe use for birth control via medical devices? That should certainly be a key discussion point at the upcoming FDA hearing. But even more urgently, shouldn’t the agency design and implement a more comprehensive Safe Use of Medical Devices program?

Essure is a good example of the broader opportunity. According to Diana Zuckerman and Laurén Abla Doamekpor of the National Center for Health Research, two of the biggest issues with Essure is (1) physicians improperly insert the product and (2) patients do not return for their mandatory hysterosalpingogram. A solid and strategic safe use program could directly address both of these problems. The way to make a medical device “safer” is to ensure that it us used as directed. Not rocket science. Will the National Center for Health Research and women’s health advocates stand up at the FDA adcomm and call for better patient education? Hope springs eternal.

The Essure advisory committee will certainly delve into the details of the data – and that’s their main job – but it’s also a timely and important opportunity for those offering open public comment to call on the agency to develop a Safe Use of Medical Devices initiative. Patients using Essure will benefit – as will the hundreds of millions of Americans (men and woman, children and adults) whose lives are improved through the use of medical devices and technology.

Peter J. Pitts, a former FDA Associate Commissioner, is President of the Center for Medicine in the Public Interest