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Author Spotlight: Microbial Control and Monitoring Strategies for Cleanroom Environments and Cellular Therapies
Published on: March 17, 2023
FMT and Microbial Medical Products: Generating High-Quality Evidence through Good Governance
1Pilar N. Ossorio, Ph.D., J.D., is Professor of Law and Bio-ethics at the University of Wisconsin-Madison and the Bio-ethics Scholar-in-Residence at the Morgridge Institute for Research. Yao Zhou, S.J.D., is a Research Assistant at the Morgridge Institute for Research in the Bioethics group.
Abstract:
This article argues that current data for the safety and efficacy of fecal microbiota transplants as a treatment for any indication, including recurrent Clostridioides difficile infection, is low-quality. It develops a governance proposal that encourages production of high-quality evidence by incentivizing well-designed RCTs of stool and stoolderived microbial products. The proposal would require that FDA change its current enforcement approach, but it would not require any change in statutes or regulations.
Insights
Current fecal microbiota transplant (FMT) data is low-quality, necessitating better evidence. A new governance proposal incentivizes high-quality randomized controlled trials (RCTs) for FMT products, requiring FDA policy changes.
Area of Science:
- Microbiology
- Gastroenterology
- Regulatory Science
Background:
- Fecal microbiota transplantation (FMT) shows promise for various conditions, notably recurrent Clostridioides difficile infection.
- However, the existing evidence base for FMT's safety and efficacy is largely considered low-quality.
- This limits its widespread adoption and regulatory clarity.
Purpose of the Study:
- To critique the current quality of evidence supporting fecal microbiota transplants.
- To propose a novel governance framework for generating high-quality clinical evidence.
- To outline necessary adjustments to regulatory approaches, specifically the FDA's enforcement strategy.
Main Methods:
- Analysis of the existing literature on fecal microbiota transplant safety and efficacy data.
- Development of a governance proposal focused on incentivizing rigorous research.
- Examination of current Food and Drug Administration (FDA) regulations and enforcement policies.
Main Results:
- Current data supporting fecal microbiota transplants (FMT) for any indication, including recurrent Clostridioides difficile infection, is of low quality.
- A governance proposal is presented to stimulate the creation of high-quality evidence.
- The proposal advocates for incentivizing well-designed randomized controlled trials (RCTs) for stool and stool-derived microbial products.
Conclusions:
- The current evidence landscape for FMT is insufficient to support its broad clinical application.
- A shift towards incentivizing high-quality RCTs is crucial for advancing the field.
- The proposed governance model necessitates a modification of the FDA's current enforcement approach without altering existing statutes or regulations.
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