Brava breast reconstruction study stopped taking new patients
I am wondering if anyone has any positive info for me. I was scheduled for a Diep I didn't really want in Sept 2013, 6 months post radiation, and found out about Brava for fat grafting for breast reconstruction. I had an appt to see a plastic surgeon in Seattle who does it as I can't afford to go to Dr Khouri at the Miami Breast Center.The FDA then irrationally closed the study to any new patients. I am desperate to get going with Brava, but it seems now that there is no way to get the Brava device for fat grafting. My surgeon has said things might change by the end of the summer. He also said that if I had the fat graft surgery type of Brava he would be willing to use it off label for me for Breast reconstruction. Anyone have any ideas how I can get the Brava device?
Comments
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What do you mean the FDA "irrationally" closed the study to new patients? Do you mean as part of the approved investigation plan submitted to the FDA, the total number of patients allowed for that stage of the study was reached and the enrollment stopped while the data was analysed and submitted for review? Or was there such big problems with complications that the FDA stopped the study to avoid putting additional study subjects at risk?
If it is the first scenario, then additional test subjects will be enrolled as the study goes on to its next stage or the device will be approved and openly marketed. If the second scenario is the case, the device will never be legally available for use.
In any case, you can not get the device. Your surgeon may be willing to try and get the device for use outside the study, but I doubt he will find it easy to obtain one.
And no, there is no such thing as compassionate use of the device for you. The IDE regulations have no provision for such use and you don't qualify for an "emergency" use (basically defined as a last ditch effort to save a patient's life although it has been stretched by the Agency to include saving the function of an organ. It has never included anything cosmetic, which as much as we may yell and scream, is what breast reconsruction is). In any case, such a use would still need to be submitted to the FDA and approved by the Agency.
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I found the history of the study changes. The study was stopped in May by the sponsor, not FDA, because the number of subjects approved for enrollment had been reached. The new submissiuon includes enrollment changes and changes to the protocol (how the study is conducted). If the submission is under the IDE (Investigational Device Exemption application), the Agency has 90 days from the date of receipt to review and approved, diapproval, or give conditional approval. If the submission was a final report under the IDE, a PMA (Pre Market Approval application) will have to be submitted, reviewed, any Agency questions answered, brought to the Advisory Panel, a decsion made to then allow marketing or not. The PMA process can take years.
The sponsor can asked in the final IDE submission that X number additional subjects be allowed to enroll while the PMA is prepared and reviewed. The request may or may not be appoved.
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macb,
Sorry to hear about your frustrating situation. To finally find a method that would work for you and then hit this brick wall! Ugh! In many ways it seems uneccesary to do the study as there is a lot of supporting evidence through the study Brava did, but I guess in the long run it's a good idea to have an independent study done. Hopefully, will open the way for many more women to do this option!
Looks like you should be able to get this from Brava for simple augmentation and then your MD can decide to use it as an off label indication.
Here is a statement by Dr. Khouri about the recent situation:
The status of the FDA and BRAVA - UPDATED* (as of May 13, 2013)
received via Dr. Khouri"It is important to clarify that the FDA has not recalled the Brava device. The FDA has asked Brava to stop enrollment into Clinical Protocol 2004-03, the current IRB study, until they can review the protocol that is in place. This is a safety study that has been going on for a number of years with several hundred patients enrolled and no significant complications.
There have not been any complications or reports of any problem to prompt this FDA position.
Brava as a stand-alone device to enlarge the breast without surgery has a well established safety record. It has been used by tens-of-thousands of women for over the past 10 years with no significant complications whatsoever.
However, to everybody’s surprise, and for unknown reasons, the FDA suddenly decided that when used in preparation for fat grafting, that very same Brava device should now be classified in the same high risk category as life sustaining implantable heart and brain devices. This certainly made no sense to anybody, but the FDA’s decision cannot be put into question.
When placed into this high-risk category of devices, Brava needs an Investigational Device Exemption (IDE) filed and approved before starting a clinical study (or resuming the current one with possible modifications).
BRAVA filed an application for an Investigational Device Exemption (IDE). The FDA had time to review the data and recently concurred that if used as we are now, Brava poses no significant risk. They therefore allowed the IRB study to continue but asked Brava to limit enrollment to only 5 centers and 60 more patients.
The FDA therefore no longer questions the safety of Brava when used in preparation for fat grafting. But they asked Brava to design a study that will prove efficacy. A study that will require a few centers to enroll patients in a randomized study where half would be grafted after Brava expansion and half the patients would be grafted without Brava. This is the only kind of study that will prove to the FDA that Brava truly has a significant beneficial effect.
It is important to note that the FDA controls the sale of medical devices. The FDA does not regulate the practice of medicine. Medical societies regulate the practice of medicine.
Physicians often use in their practice devices for indications other than the ones specifically approved by the FDA. This is called off label use. (For example, Botox was FDA approved for the treatment of muscle spasm but it was used off label for many years for the treatment of wrinkles until the FDA finally approved that new application.)
This off label use and the practice of Medicine is regulated by medical societies. The American Society of Plastic Surgeons, the most important plastic surgery society condones Brava + Fat grafting. The Society just promoted it with a large teaching course with live surgery out of the Miami Breast Center operating room. The Society has organized many courses where Dr. Khouri is invited to teach it and promote it as a major advance in the care of our patients.
Dr. Khouri and a few other surgeons across the world have used the very same Brava device that was approved for sale by the FDA as an off label indication to prepare the breast for fat grafting. Initially, before we really knew the full benefits and the potential risks, all patients were enrolled in a clinical study approved by an Institutional Review Board (IRB), an independent ethics committee that reviews any research work involving human subjects and gives its stamp of approval.
Over the past 8 years several hundred women were enrolled in this IRB study sponsored by Brava. Results show that fat grafting after Brava expansion allows us to successfully graft much more fat and achieve much better augmentation and breast reconstruction results than if Brava was not used. Most importantly, there were essentially no complications. Certainly less than the implant and flap alternatives. Nonetheless, the FDA is not accepting this data because it is not derived from a prospective randomized study where half the patients of a particular surgeon are randomly assigned to having Brava and half assigned to no Brava.
Plastic surgeons like Dr. Khouri who after years of using Brava on hundreds of patients are convinced of its safety and efficacy have decided to continue offering it to their patients as an off label use. They consider fat grafting after Brava preparation is no longer experimental and therefore now offer it as part of their regular practice. No need for the IRB anymore.
However, in the near future, a small group of select surgeons will need to enroll patients into a prospective randomized +/- Brava study that will be monitored by the FDA. It is not until the results of this study are out and reviewed by the FDA that Brava will become approved . On a positive note, when that happens, Brava will be reimbursable by Medicare and most insurance companies.
Till then, only a few patients from a few doctors will be able to get Brava from the company as patients in the IRB study. The others will have to obtain the devices as women seeking simple non-surgical augmentation as it is currently approved by the FDA. It is their plastic surgeon’s decision to then have them use Brava as an off label indication."
Roger Khouri, MD
from fatgraftpatients.com (discussion section)Hope this helps!
Wishing you all the best! -
It is a bad sign when Dr Khouri sends out such misleading information.
First his misuse of the term IRB: IRB is the abreviation for Institutional Review Board. An IRB is a local group specific for each study site. It is responsible for determining if a clinical trial meets the local standards for the ethical conduct of a trial and also ensures the protection of any human subject in the trial. The FDa does not run the IRBs. It does, however, have regulations outlining the standards for membership, function, and records for studies under FDA jurisdiction.
Second, his promoting the circumventing of the investigational study by the "practice of medicine" has led to other MDs that have tried the same slimy trick to be given a warning letter (an intent to procede with criminal charges) if the behavior does not stop. Many times, the state will also become involve with any disciplinary actions.
Third: the intent of an IDE is to prove a device safe AND effective for its intented use. The BRAVA trial did not meet both conditions in the original study and, therefore, must still continue to have a controlled study to prove efficacy.
Fourth: the sponsor of the IDE is in control of if the study proceeds. The study was stopped by the sponsor because the study has reached the original enrollment. The plan to continue the study would be the result of a back and forth discussion between FDA and the sponsor. FDA, however, would have to give the final go ahead for the study plan.
What does this mean for someone who is interested in the BRAVA procedure outside the study? For one, the device for this use is still considered investigational by FDA. That means insurance companies, Medicare and Medicaid will not pay for reconstruction using this method.
Second, if a woman has the procedure and somethings goes wrong, she would be hard pressed to sue as legally the procedure is experimental and the results are not proven as safe and effective.
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Fair enough. However, if someone is interested in this procedure, how do you find out what the current status is of the FDA review process?
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Raerlan,
It is difficult to find out the status on a study from FDA as the Agency is restricted by law to treating such information as confidential and a trade secret. FDA will not publicly acknowledge that study exists.
The sponsor of the study, however, can and often will make public statements about the study. Usually in glowing terms such as "groundbreaking" or a "possible cure," blah, blah, blah.
The various NIH institutes has websites that lists studies going on for various medical conditions. There is also a link for each study that tells the current status of each study in general terms.
I followed such a link for the BRAVA study, and given my years of professional experience in dealing with clinical trials under FDA jurisdiction, could interpret exactly what the status of the study was.
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Does anyone know the status of having the Brava approved for reconstruction so insurance will cover the cost?
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