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FDA SummaryFDA SummaryCardioSEAL® STARFlex™

Septal Occlusion System with Qwik Load

NMT Medical

P000049/S3

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FDA SummaryFDA Summary

• FDA Review Team

•Background

•Device Description

•Nonclinical Evaluation

•Clinical Evaluation

•Panel Questions

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FDA Review TeamFDA Review TeamFDA Review TeamFDA Review Team

• ODE - Donna Buckley

John E. Stuhlmuller, M.D.

• OSB - Gerry Gray, Ph.D.

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BackgroundBackgroundBackgroundBackground

• STARFlex™ has the same design as the CardioSEAL® device except that a nitinol centering spring has been added

• CardioSEAL®

• PMA approved (12/01); closure of high risk VSDs

• HDE approved (2/00); closure of PFO in patients with recurrent cryptogenic stroke who have failed medical therapy

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STARFlex™ Device DescriptionSTARFlex™ Device DescriptionSTARFlex™ Device DescriptionSTARFlex™ Device Description

• Occluder• Double umbrella design

• Sizes: 23mm, 28mm, and 33mm

• Device size : Stretched defect diameter ratio is 1.7-2.0 : 1

• Delivery Catheter• Size: 10F

• Qwik Load device - used to collapse and load occluder into the delivery catheter

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Nonclinical EvaluationNonclinical EvaluationNonclinical EvaluationNonclinical Evaluation

• In Vitro Testing

• Biocompatibility Testing

• In Vivo (Animal) Testing

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Clinical EvaluationClinical Evaluation

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Clinical Data SetsClinical Data Sets

•Pivotal Cohort – STARFlex™ PFO

•Non-pivotal•CardioSEAL® (PFO)

•Clamshell I F/U (PFO)

•STARFlex™ (non-PFO)

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Pivotal Cohort - PFOPivotal Cohort - PFO

• Patient subset of High-Risk Registry

• Open-label, single arm

• No control group

• Meets criteria for “Compassionate Use”

• Primarily single-center study

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Pivotal Cohort - PFOPivotal Cohort - PFO

• 49 patients

•Devices placed in 49 of 49 patients attempted

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Patient Outcome AssessmentPatient Outcome AssessmentPatient Outcome AssessmentPatient Outcome Assessment

• Effectiveness

• Primary: Complete Defect Closure by Echocardiographic Assessment

• Secondary: Occurrence of Potential Neurological Events after Device Placement

• Safety

• Adverse Events

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PFOPFO - Effectiveness - EffectivenessPFOPFO - Effectiveness - Effectiveness

• Primary Efficacy determined at 6-month F/U

• 44 of 49 implanted patients

• Complete closure reported in 43 of 44 patients evaluated

• Technical errors were reported in 9 of 49 patients

• Secondary Efficacy

• No strokes and 4 transient neurological events were reported

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PFOPFO - Safety - SafetyPFOPFO - Safety - Safety

• Assessment at 1, 6, 12, and 24 months

• Characterization of adverse events

• Device related

• arm fractures

• Implantation related

• Catheterization related

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PFOPFO - Safety - SafetyPFOPFO - Safety - Safety

• Serious or moderately serious adverse events in 13 of 49 patients

• Device-Related - 7

• Implantation-Related - 1

• Catheterization-Related - 5

• Arm fractures in 7 of 49 devices

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Panel Questions

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Question 1Question 1Question 1Question 1

1a. Please discuss the use of “Procedural Success” as the primary efficacy outcome measure for assessment of clinical benefit.

1b. Please discuss the use of the occurrence of potential embolic neurological events after device placement as a secondary efficacy outcome measure for assessment of clinical benefit.

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Question 2Question 2Question 2Question 2

2a. Please discuss the use of “Serious and Moderately Serious Adverse Events” (that were definitely, probably or possibly related to the device, implantation or catheterization procedure) as the primary safety outcome measure for assessment of clinical benefit versus risk.

2b. Please discuss whether the echocardiographic evaluation and clinical evaluation (definitions for occurrence of neurological events) allow adequate assessment of device-related clinical events.

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Question 2 (cont)Question 2 (cont)Question 2 (cont)Question 2 (cont)

2c. Please discuss whether adequate information has been provided to allow assessment of the risk of recurrent cryptogenic stroke versus risk of device-related neurological event.

2d. Please discuss whether adequate information has been provided to characterize the appropriate post-device placement antiplatelet regimen (duration and single versus combination therapy) or anticoagulation regimen (duration and target INR).

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Question 3Question 3Question 3Question 3

3. Please comment on the lack of a pre-specified control group, pre-specified outcome measures, and pre-specified sample size.

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Question 4a and 4bQuestion 4a and 4b

4a. Please clarify if additional analyses on the current data set could be performed to provide adequate

information to support safety and effectiveness.

4b. Please clarify if the collection of additional data using the current patient selection criteria and outcome measures would be adequate to support safety and effectiveness.

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Question 4cQuestion 4c

4c. Alternatively, if you believe that a new trial is required, please address the following clinical trial design questions:

i. Given our current understanding of the causal relationship of the presence of PFO and stroke (presumed paradoxical embolism), please discuss whether a randomized trial is necessary to evaluate safety and effectiveness. If so,

1. Can a randomized trial be completed at this time?2. What is an appropriate control group?

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Question 4c (cont)Question 4c (cont)

ii. Please discuss whether adequate trials can be designed with historical controls or objective performance criteria.

iii. Based on the type of study design proposed, please address the following issues:

1. Please characterize the appropriate patient population for study enrollment.2. Please discuss the appropriate primary and s secondary outcome measures for evaluation of effectiveness and safety. As part of this discussion, please comment on the use of clinical versus surrogate endpoints.

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Question 4c (cont)Question 4c (cont)

3. Please discuss the appropriate duration of patient follow-up.

4. Please comment on what would be a clinically relevant sample size.

5. Please discuss the criteria for a successful trial.

6. Please comment on whether adjunctive antithrombotic medication regimens should

be left to the operator or prospectively outlined in the protocol.

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Question 5Question 5

5. Please discuss any improvements that could be made to the training program.

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Question 6Question 6

6a. Please comment on the

INDICATIONS FOR USE section as to

whether it identifies the appropriate

patient populations for treatment with

this device.

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Question 6 (cont)Question 6 (cont)

6b. Please comment on the CONTRAINDICATIONS section as to

whether there are conditions under which the device should not be used because the risk of use clearly

outweighs any possible benefit.

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Question 6 (cont)Question 6 (cont)

6c. Please comment on the WARNING/PRECAUTIONS section as to whether it adequately describes how the device should be used to maximize benefits and minimize adverse events.

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Question 6 (cont)Question 6 (cont)

6d. Please comment on the OPERATOR’S INSTRUCTIONS as to whether it adequately describes how the device should be used to maximize benefits and minimize adverse events.

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Question 6 (cont)Question 6 (cont)

6e. Please comment on the remainder of the device labeling as to whether it adequately describe how the device should be used to maximize benefits and minimize adverse events.

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Question 7Question 7Question 7Question 7

7. Based on the clinical data provided in the Panel

Package, do you believe that additional follow-up

data or post market studies are necessary to

evaluate the chronic effects of the implantation

of the STARFlex™ device. If so, how long

should patients be followed and what endpoints

and adverse events should be measured?