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Informed consent and compulsory medical device registries: ethics and opportunities
Daniel B Kramer1,2, Efthimios Parasidis3
1Harvard Medical School, Boston, Massachusetts, USA dkramer@bidmc.harvard.edu.
Insights
Many cardiovascular device registries enroll patients without informed consent, raising ethical questions. Obtaining consent could improve postmarket surveillance and patient understanding of medical device risks.
Area of Science:
- Medical Device Regulation
- Clinical Research Ethics
- Cardiovascular Medicine
Background:
- High-risk medical devices in the US often receive marketing approval with limited premarket clinical data.
- Postmarket surveillance, including patient registries, is crucial for monitoring device performance and safety.
- Some cardiovascular device registries mandate enrollment for reimbursement without explicit patient informed consent.
Purpose of the Study:
- To examine the ethical obligation of cardiovascular device registries to obtain informed consent from enrollees.
- To identify potential losses incurred by not obtaining informed consent.
- To explore how informed consent processes could enhance US postmarket surveillance.
Main Methods:
- Ethical analysis of informed consent requirements in medical device registries.
- Review of current practices in prominent cardiovascular device registries.
- Discussion of the implications of consent for patient engagement and data quality.
Main Results:
- Registries may have an ethical duty to seek informed consent, beyond legal mandates.
- Lack of consent can lead to diminished patient autonomy and potential data limitations.
- Implementing informed consent can foster greater transparency and trust in postmarket surveillance.
Conclusions:
- Informed consent is ethically imperative for cardiovascular device registries, even when not legally required.
- Seeking consent can strengthen the integrity and effectiveness of postmarket surveillance systems.
- Ethical considerations in data collection are vital for patient safety and regulatory oversight.
Abstract:
Many high-risk medical devices earn US marketing approval based on limited premarket clinical evaluation that leaves important questions unanswered. Rigorous postmarket surveillance includes registries that actively collect and maintain information defined by individual patient exposures to particular devices. Several prominent registries for cardiovascular devices require enrolment as a condition of reimbursement for the implant procedure, without informed consent. In this article, we focus on whether these registries, separate from their legal requirements, have an ethical obligation to obtain informed consent from enrolees, what is lost in not doing so, and the ways in which seeking and obtaining consent might strengthen postmarket surveillance in the USA.
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