Friday, June 28, 2024

GRAIL - 300 page filing as spinout company, publicly traded (6 3 2024)

 https://investors.grail.com/static-files/af0d2fd4-9dce-4393-8e9f-a87a8f1b5703


Chat GPT 4

Please summarize this regulatory filing for the genomics comapny GRAIL as a new publicly trading company. Please focus especially on operational considerations like genomic test product sales and FDA approval and reimbursement from third party payors.
ChatGPT

Summary of GRAIL's Regulatory Filing for Public Trading

Operational Considerations

  1. Genomic Test Product Sales

    • Galleri Test: GRAIL's primary product, the Galleri test, is a multi-cancer early detection (MCED) test designed to detect multiple types of cancer from a simple blood draw. The Galleri test has demonstrated clinical validation through extensive studies, detecting cancer signals across over 50 types of cancer. As of March 31, 2024, over 180,000 Galleri tests have been sold commercially​​.
  2. FDA Approval and Regulatory Pathway

    • Current Status: GRAIL has not yet obtained FDA clearance or approval for any of its products, including the Galleri test, which is currently marketed as a Laboratory Developed Test (LDT). GRAIL is seeking Pre-Market Approval (PMA) from the FDA for the Galleri test​​.
    • FDA Submission Plans: The company plans to complete a PMA submission for Galleri in the first half of 2026. The process includes ongoing discussions with the FDA to determine the necessary clinical studies and data to support the PMA​​.
  3. Reimbursement from Third-Party Payors

    • Current Coverage: GRAIL has established private reimbursement for Galleri from various third-party payors in the United States but lacks broader coverage from government healthcare programs such as Medicare​​.
    • Challenges and Strategies: Coverage and reimbursement from third-party payors, including Medicare and Medicaid, are crucial for expanding access to GRAIL's products. The process of obtaining adequate coverage is often time-consuming and requires substantial evidence of medical necessity and cost-effectiveness. GRAIL is also exploring Medicare Advantage plans and other avenues for nearer-term reimbursement while continuing to pursue private payor coverage​​.

Additional Considerations

  • Healthcare Policy and Market Impact: Legislative changes and healthcare reforms, such as the Affordable Care Act (ACA), impact reimbursement rates and policies. GRAIL anticipates ongoing challenges and pressure on medical product pricing due to these factors​​.
  • Clinical and Analytical Studies: GRAIL has conducted various clinical studies, including the foundational CCGA study and the PATHFINDER study, to validate Galleri's performance. Additional studies and data submissions are ongoing to support regulatory approval​​.
  • Future Developments: GRAIL is also developing other products, such as DAC, for which it may seek FDA approval and explore Medicare coverage. The company's long-term strategy includes expanding its product portfolio and securing broader reimbursement and regulatory approvals​​.

In summary, GRAIL is actively working to expand the marketability and accessibility of its Galleri test through rigorous clinical validation, seeking FDA approval, and negotiating reimbursement from both private and government payors. The company's future success heavily depends on these regulatory and reimbursement milestones.

Wednesday, June 26, 2024

Special 510(k)

 See a news item in 6/2024 that Biomerieux has a new device for throat infections via "SPECIAL 510(k)."  What is that?

https://www.360dx.com/regulatory-news-fda-approvals/biomerieux-respiratorysore-throat-mini-panel-gets-fda-special-510k

NEW YORK РBioM̩rieux announced Wednesday that it has received special 510(k) clearance and CLIA waiver from the US Food and Drug Administration for the BioFire SpotFire Respiratory/Sore Throat (R/ST) Panel Mini test.

The SpotFire R/ST Panel Mini will be available in the US in the third quarter of 2024 and is intended to be commercialized along with the company's larger R/ST panel, the firm said in a statement.

SpotFire R/ST Panel Mini is a 15-minute syndromic PCR panel to detect and differentiate five viral and bacterial causes of respiratory or sore throat infections. Samples can be taken from a nasopharyngeal swab when a respiratory tract infection is suspected or from a throat swab when pharyngitis is suspected.....

https://www.fda.gov/regulatory-information/search-fda-guidance-documents/special-510k-program



Chat GPT discusses.


Please help me undestand what's special about "SPECIAL 510k". I can't tell. it seems to be close to a regular 510k. Please use also your general knowledge abou the FDA 510(k) process.
ChatGPT

The Special 510(k) Program offers an efficient review process for certain well-defined modifications to a manufacturer’s own legally marketed device. Here’s a summary of its key aspects and differences from the Traditional 510(k) process:

Special 510(k) Program:

  1. Scope:

    • Applicable only to modifications of a manufacturer's own legally marketed device.
    • Used for certain changes where design control procedures can produce reliable results to support a substantial equivalence (SE) determination.
  2. Submission Requirements:

    • Must include a coversheet identifying the submission as a Special 510(k).
    • A description of the modified device, comparison to the legally marketed device, and indications for use.
    • Clean and redlined copies of updated documents.
    • A concise summary of design control activities and verification/validation testing.
  3. Evaluation Criteria:

    • Changes should be supported by well-established methods, with results that can be reviewed in a summary or risk analysis format.
    • No new performance data are generally needed, or if required, the data must be reviewable in a summary format.
  4. Review Process:

    • Aims for FDA review within 30 days, compared to 90 days for Traditional 510(k) submissions.
    • Focuses on leveraging existing data and minimizing the need for detailed test reports.
  5. Limitations:

    • Not suitable for significant changes to intended use or fundamental scientific technology.
    • Generally excludes changes needing new clinical data, significant reprocessing validations, or introducing new safety concerns.

Traditional 510(k) Program:

  1. Scope:

    • Applicable to both new devices and modifications of existing devices.
    • Broader range of changes can be considered, including more complex modifications.
  2. Submission Requirements:

    • Detailed information including complete test reports, clinical data if needed, and comprehensive descriptions of the device and its intended use.
  3. Evaluation Criteria:

    • Thorough evaluation of all performance data, including new clinical or non-clinical data as required.
  4. Review Process:

    • Standard review time of 90 days.
    • Requires detailed documentation and often a more extensive review process.
  5. Flexibility:

    • More flexible in terms of the types of changes that can be evaluated.
    • Suitable for significant modifications or when new safety and efficacy data are needed.

Key Differences:

  • Review Time: Special 510(k) aims for a quicker 30-day review versus the Traditional 510(k)’s 90 days.
  • Data Requirements: Special 510(k) relies on existing data and well-established methods, whereas Traditional 510(k) often requires new, detailed performance data.
  • Scope of Changes: Special 510(k) is limited to specific modifications, primarily within the same intended use and technological framework. Traditional 510(k) can handle more substantial changes.

The Special 510(k) process is designed to streamline the review of minor changes to an already cleared device, leveraging the manufacturer’s existing design controls and previous FDA evaluations to ensure that the device modifications are safe and effective without needing extensive new testing or data submission.

For more detailed information on the Special 510(k) Program, you can refer to the FDA guidance document uploaded titled "2019 FDA SPECIAL 510K PROGRAM guidance.pdf"​​.

Isn't there any way to update a 510(k) device anyway? I thought there was some way to update a 510(k) without calling it "a special 510(k)"?
ChatGPT

Yes, there are ways to update a 510(k) device without specifically using the Special 510(k) pathway. The primary methods are:

Traditional 510(k)

  • Traditional 510(k): This is the most common pathway and is used for new devices or significant changes to existing devices. It requires a comprehensive submission, including detailed descriptions, performance data, and sometimes clinical data. This pathway can be used for any modifications to a device, regardless of their scope.

Abbreviated 510(k)

  • Abbreviated 510(k): This pathway relies on conformity to FDA-recognized consensus standards, special controls, and/or FDA guidance documents. If a device modification conforms to these standards, the submission can reference the standards and provide summary reports, reducing the amount of data that needs to be submitted. This pathway can be used to demonstrate substantial equivalence through a reliance on established standards.

Special 510(k)

  • Special 510(k): As mentioned before, this is for minor modifications to a manufacturer’s own legally marketed device. It leverages design control activities and relies on well-established methods for evaluation, aiming for a quicker review process.

Deciding When to Submit a 510(k) for a Change to an Existing Device

  • The FDA provides guidance on deciding when a new 510(k) is necessary for changes to an existing device. Not all modifications require a new 510(k) submission. The key is to determine whether the change could significantly affect the safety or effectiveness of the device.

Key Considerations:

  1. Risk-Based Assessment: Manufacturers should perform a risk-based assessment to decide if a new 510(k) is needed. Minor changes that do not significantly affect the device's performance or safety might not require a new submission.

  2. Documentation: Even if a new 510(k) is not needed, manufacturers must document the changes, rationale, and any testing conducted to ensure continued compliance with FDA regulations.

  3. Changes That Generally Do Not Require a New 510(k):

    • Editorial changes to the labeling that do not alter the indications for use.
    • Changes in manufacturing processes or facilities that do not affect the device's safety or effectiveness.
    • Minor changes in design, such as software updates that do not affect the intended use or performance.
  4. Changes That May Require a New 510(k):

    • Changes in indications for use.
    • Changes in design that affect the device’s safety or effectiveness.
    • Changes in materials that could affect biocompatibility.
    • Changes requiring clinical data to demonstrate substantial equivalence.

21 CFR 807.81(a)(3):

  • According to 21 CFR 807.81(a)(3), a new 510(k) submission is required for any change or modification that could significantly affect the safety or effectiveness of the device, including changes to the indications for use.

Guidance Documents:

  • The FDA has issued guidance documents such as “Deciding When to Submit a 510(k) for a Change to an Existing Device” which provides a flowchart and detailed explanations to help manufacturers determine if a new submission is necessary.

Summary:

  • Special 510(k) is just one pathway, specifically designed for minor changes with a streamlined review process.
  • Traditional and Abbreviated 510(k) pathways are available for more significant changes or when leveraging recognized standards.
  • Not all changes require a new 510(k); manufacturers should perform a risk-based assessment and consult FDA guidance to determine the appropriate action.

These options provide flexibility for manufacturers to update and modify their devices while ensuring continued compliance with FDA regulations and maintaining device safety and effectiveness.

What are the main differences between Abbreviated 510(k) and Special 510(k)?
ChatGPT

The main differences between the Abbreviated 510(k) and Special 510(k) pathways lie in their requirements, purpose, and the types of modifications they address. Here's a comparison of the two:

Abbreviated 510(k):

  1. Purpose:

    • Utilized to streamline the submission process by relying on conformance with FDA-recognized consensus standards, special controls, and FDA guidance documents.
  2. Submission Requirements:

    • Requires the submitter to provide summary reports and declarations of conformity to recognized standards.
    • May include less detailed information compared to a Traditional 510(k), focusing on demonstrating conformance to applicable standards and controls.
  3. Scope:

    • Suitable for new devices or modifications that are covered by existing consensus standards and special controls.
    • Often used when well-established standards exist for the device type or specific aspects of its performance.
  4. Evaluation Criteria:

    • The FDA evaluates whether the device conforms to recognized standards and special controls.
    • Reduced emphasis on providing detailed performance data, as the focus is on conformity to standards.
  5. Review Process:

    • Aims to streamline the review process by leveraging standards and guidance documents.
    • The review time can vary but is generally intended to be more efficient due to reliance on established standards.

Special 510(k):

  1. Purpose:

    • Intended for modifications to a manufacturer's own legally marketed device.
    • Designed to streamline the submission and review process for well-defined, minor changes.
  2. Submission Requirements:

    • Requires a coversheet identifying it as a Special 510(k).
    • A detailed description of the change(s), comparison to the cleared device, updated labeling, and a concise summary of design control activities and verification/validation testing.
    • Performance data should be reviewable in a summary or risk analysis format without complete test reports.
  3. Scope:

    • Suitable for minor modifications to an existing device that are well-defined and where the design control procedures produce reliable results.
    • Not appropriate for significant changes to intended use, fundamental scientific technology, or those requiring new clinical data.
  4. Evaluation Criteria:

    • Focuses on whether the modification can be supported by well-established methods and if the results can be reviewed in a summary or risk analysis format.
    • Emphasizes leveraging previous FDA reviews and existing design control documentation.
  5. Review Process:

    • Aims for a quicker review time, typically within 30 days.
    • If the submission is not appropriate for a Special 510(k), the FDA may convert it to a Traditional 510(k), potentially extending the review time.

Key Differences:

  • Purpose and Focus:

    • Abbreviated 510(k) relies on conformance with recognized standards and is suitable for both new devices and modifications.
    • Special 510(k) is specifically for minor modifications to an existing device by the same manufacturer.
  • Submission Content:

    • Abbreviated 510(k) requires summary reports and declarations of conformity.
    • Special 510(k) requires detailed descriptions of changes, summaries of design control activities, and performance data in summary format.
  • Scope and Appropriateness:

    • Abbreviated 510(k) can be used for a broader range of devices and modifications covered by standards.
    • Special 510(k) is limited to specific, well-defined modifications that can be supported by existing design controls and well-established methods.
  • Review Time:

    • Special 510(k) generally aims for a quicker 30-day review.
    • Abbreviated 510(k) review time varies but is intended to be efficient through the use of standards.

Both pathways offer streamlined alternatives to the Traditional 510(k) process but serve different purposes and types of device modifications.

Sunday, June 23, 2024

Bien Willner Talk April 30 War College

 Posted open access -- https://www.darkdaily.com/2024/05/20/moldx-and-z-identifier-codes-why-and-how-and-the-future/

Brief AI Summary

Dr. Gabe Bien-Wililner, the Chief Medical Officer of Palmetto GBA and director of the MolDx program, provided an insightful discussion about the challenges and solutions in molecular diagnostic testing, particularly focusing on the implementation of Z codes in billing and claims processing.

Key points from his lecture include:

  1. Necessity of MolDx: MolDx was created to address specific issues in molecular diagnostics, such as the complexity of the tests, which are based on molecular genetics, and deficiencies in the coding system which complicate claims processing.

  2. Challenges in Coding and Reimbursement: There is a lack of well-defined billing codes, making it difficult for payers to understand what services were rendered and whether they should be covered or reimbursed. For example, a single code could represent multiple tests or procedures, which adds ambiguity to the claims.

  3. MolDx Program Creation and Goals: Established in 2012, MolDx was designed to create payer controls, establish policy, and handle pricing. It involves a unique identifier code system that helps automate and adjudicate claims, ensuring tests meet Medicare’s criteria for being reasonable and necessary.

  4. Technical Assessment Process: This involves determining if a test is reasonable, necessary, and meets medical necessity criteria. It includes validating analytical accuracy, clinical relevance, and clinical utility of the test. Each service must demonstrate these three aspects independently.

  5. Registry and Claim Submission: Laboratories must register their tests with detailed information about the test, methodology, and intended use. This enables automated claims processing, where each test is linked to a specific identifier used in billing, allowing precise assessment of the test’s appropriateness for the specific clinical scenario.

  6. Expansion to Commercial Plans: The system developed under MolDx is now being adapted for use in commercial insurance plans, not just Medicare. This aims to streamline pre-authorization and claims processing, making it more efficient and less prone to fraud, waste, and abuse.

Dr. Bien-Wililner emphasized the importance of these systems in improving the accuracy and efficiency of healthcare billing and reimbursement, especially in the complex field of molecular diagnostics.



Sunday, June 9, 2024

WaPo Home Complex LDT

 Doctors couldn’t help. They turned to a shadow system of DIY medical tests.

Buoyed by regulatory vacuums, Silicon Valley is building a booming online wellness market that aims to leave the doctor’s office behind.


By Elizabeth Dwoskin, Daniel Gilbert and Tatum Hunter

June 9, 2024 at 6:02 a.m. EDT

 

 

Angelika Sharma was desperate. An array of basic first foods — from bananas to sweet potatoes — caused her six-month old Annika to vomit uncontrollably, so many times in one night that she landed in the hospital for dehydration.


Half a dozen pediatric specialists largely dismissed her daughter’s ailments, Sharma said, forcing her to leave her job as a hospitality executive, because "you can’t just have any babysitter looking after a child” with such serious reactions to food.



After a year and a half, an answer came finally in the form of a Facebook ad for Tiny Health, a Silicon Valley start-up that could test her baby’s gut microbiome. Using a bead of stool swabbed from a diaper, the company diagnosed the problem: Annika’s gut was overcrowded with P. vulgatus, a common bacteria. A company nutritionist recommended a probiotic, sauerkraut and exposure to animal microbes through daily visits to the petting zoo.


Within months, Annika’s food reactions were normal. More tests showed a gut transformed.



Sharma has a meal with her daughter. (Melanie Landsman for The Washington Post)

A new world of DIY testing is changing the relationship between physicians and patients, allowing people like Sharma to bypass the doctors office and take medical tests on their own. Buoyed by a growing network of independent labs, Silicon Valley start-ups now offer tests for a battery of conditions including menopause, food sensitivity, thyroid function, testosterone levels, ADHD and sexually-transmitted diseases. The growth is fueled by a growing distrust of Big Medicine and confidence in home-testing borne from the Covid pandemic.

A public eager for answers is swarming this parallel medical ecosystem. The home diagnostics market generates $5 billion annually and is expected to nearly double by 2032, according to the market research firm Precedence Research.

Venture capitalists and entrepreneurs told The Post that they envision a world where frequent at-home testing is a routine part of life, enabling everyone to become “the CEO of their own health," said Luca Springer, who co-founded a Silicon Valley start-up that aims to make cancer testing as simple as a home-pregnancy test.


Patients in remission from cancer, for example, could use urine strips to check if the disease has returned, he said, confirming the results with their doctor. He noted that at one time home pregnancy tests were considered scandalous and that most cancers are still detected way too late.


But the boom angers some doctors, who argue that circumventing their offices can lead to questionable remedies, misdiagnosis or delayed medical care.


While many home tests are standard diagnostics — shifted from a lab to the living room — others straddle the line between medicine and wellness. In this gray zone, incremental scientific innovations can be quickly funded, brought to market and peddled to consumers online before their health benefit has been proved.


Patients said the testing industry offers a rare path to relief, but many see a dangerous Wild West of medical information.


“Home-testing companies and influencers are creating a market preying on people’s very normal concerns about their health,” said Karen Tang, a gynecologist in Pennsylvania who has urged caution around home hormone and fertility tests to her large following on TikTok.


The tests often fall into a regulatory gap. While the U.S. Food and Drug Administration generally reviews all but the lowest-risk medical tests, it doesn’t supervise “wellness” tests marketed directly to consumers. Other start-ups avoid stringent FDA review by having physicians oversee some part of the testing process — creating what experts call a two-track system of standards.


It’s likely that some companies break the rules entirely, evading the agency and betting it won’t police a fast-growing market, said Alberto Gutierrez, a former senior FDA official.


Some professional societies have cautioned against taking certain home tests. The American Gastroenterological Association says data on the health benefit of biome tests is “lacking.” The American Diabetes Association says that no off-the-shelf glucose tests for measuring signs of diabetes meet “nationally standardized criteria for accuracy.”


Yet the draw of these companies is that they offer options to those feeling let down by conventional doctors. Sharma credits Tiny Health’s gut biome test, which was developed by a Mayo Clinic microbiologist but not approved by the FDA, with providing “a mind-blowing tool you can’t get from the traditional medical establishment."


The FDA is starting to pay attention: Regulators finalized a contentious rule in April to begin holding lab-made tests to the same standards as conventional ones, phasing out a historically hands-off position in response to the ballooning industry.


Still, businesses are charging ahead. Y Combinator, the prominent start-up incubator, funded Springer’s Cleancard last year. Function Health, a start-up founded by a Cleveland Clinic doctor in 2022, sells a $499 out-of-pocket membership offering more than 100 different lab-drawn tests, including for heart health, immunity and toxins. CVS and Walgreens enlisted San Francisco start-up ixlayer in 2022 to offer home tests for sexually-transmitted diseases, kidney function, diabetes and cardiovascular disease. Testing giant LabCorp recently launched a line of basic home-test kits called LabCorp OnDemand.



A bevy of lifestyle and wellness influencers help the companies promote their products online. Everlywell, an eight-year-old start-up offering more than two-dozen home tests, has a dedicated team to analyze Americans’ Google searches, determining which ailments it should target with tests.


Companies see a major opportunity in the sea change of health habits triggered by the covid-19 pandemic, said health-tech investor Christina Farr. As millions of Americans swabbed their own nostrils and Zoomed with doctors for the first time, mistrust in scientific authorities ballooned. Many sought to fill gaps in medical information and care with independent research, often aided by online communities.


And affluent tech-oriented consumers expect to be hands-on with their health, embracing a fleet of products such as longevity apps, Oura smart rings, full-body MRIs and other sensors to track and optimize the body.


Disha Narang, an endocrinologist and obesity medicine specialist at Endeavor Health, a health system in Chicago, said that in recent years, “more and more” patients are coming into her clinic with “menus” of results from tests that they have taken on their own.



Disha Narang, an endocrinologist and obesity medicine specialist, says she puts “zero stock” in the tests her patients administer themselves. (Taylor Glascock for The Washington Post)

“I say, I’m not a restaurant!” said Narang, who puts “zero stock” in the tests because she cannot verify their accuracy.


Narang said she understands that many who feel neglected by the medical system are driven to take matters into their own hands. But the solution often makes the problems worse, spawning a “vicious cycle” of unnecessary testing, spending and anxiety — adding to burdens on patients and caretakers.


“I get that it’s empowering,” she said. “But it’s a fine line.”


An exploding online market fueled by distrust

On TikTok and Instagram, the shadow ecosystem of self-testing is fueled by algorithms and influencers — and feeds off lost trust in “Big Health.”


Crystal Jung, a natural health and beauty influencer from Nashville, developed chronic “10 out of 10” pain after her daughter was born 13 years ago. While consulting more than a dozen specialists, she was struck by providers’ disinterest in unraveling the cause of her condition.


The 44-year-old switched to holistic medicine seven years ago, and says she has been able to heal herself with diet, supplements, fasting and acupuncture. She’s stopped going to traditional doctors for her autoimmune issues entirely, relying instead on at-home blood tests from the company LetsGetChecked to monitor thyroid stimulating hormone, a metric her doctors refused to check, she said.


“The number one thing I hear from other women is that they’re tired of being gaslit by doctors,” Jung said.


She is also a LetsGetChecked advertising partner. Jung estimates she has earned $20,000 from promoting blood tests from the company for thyroid health, micronutrients and female hormones.


Julia Cheek was motivated to found Everlywell in 2015 after accruing thousands of dollars in out-of-pocket testing costs for unexplained body aches.



Her fledging start-up got exposure from an appearance on the TV show “Shark Tank” two years later, but its real boost came when Everlywell became the first company to get FDA authorization for a covid-19 self-collection kit. Investors such as BlackRock and Lux Capital poured $250 million into the start-up, enabling it to expand its offerings as the public’s comfort around testing swelled.


Everlywell works with 20- and 30-something lifestyle influencers to sell its tests, some of which are marketed as wellness diagnostics that don’t need FDA approval. For its medical tests, which would otherwise require the FDA to weigh in, the start-up has a network of doctors who review results virtually — a practice that appears to help the company avoid the strict FDA approval process known as premarket review.


But social media platforms are also becoming battlegrounds where doctors raise alarms about the testing boom.


Zachary Rubin, an allergy doctor in the Chicago suburbs with 1.2 million TikTok followers, has made TikTok videos warning patients against taking at-home food sensitivity and allergy tests sold by Everlywell and other companies. He says such sensitivity tests — which screen for antibodies the body produces in response to consuming certain foods — merely indicate a tolerance to something someone eats regularly.


“People go for years thinking they have a diagnosis when they don’t have one,” he said. “They end up eliminating certain foods and possibly developing allergies as a result.” In rare cases, he added, patients have become malnourished after radically altering their diets in response to the tests.



Zachary Rubin, an allergy doctor, makes TikTok videos warning patients against taking at-home food sensitivity and allergy tests. (Taylor Glascock for The Washington Post)

Everlywell is facing a class action lawsuit charging that its claims about food sensitivity tests are misleading marketing. The American Academy of Allergy, Asthma and Immunology also warns people not to use these home tests. Everlywell declined to comment on pending litigation, but said its tests are backed by clinical research.


“Peddling of health-care wares directly to patients [makes it] pretty tough for them to discern the difference between a legitimate test or not,” said Bob Wachter, chair of the department of medicine at the University of California at San Francisco.


Wachter, who is an adviser to health-tech start-ups, says the explosion of self-testing is a promising way to address gaping shortfalls in the medical system, but there’s “a lot of snake oil.”


Regulators vs. innovators

The FDA made a fateful decision in 1976 when it imposed new regulations for medical devices. Tests made by conventional manufacturers would have to undergo an intensive review to demonstrate they work before they can be used on patients. But tests made and analyzed in a single laboratory — a much smaller universe at the time — would be off the hook.


As the market for lab tests has exploded, including for life-threatening conditions, the FDA has started to raise alarms. In a 2015 report, the agency warned that the rising volume and complexity of new tests creates a risk “that patients will be harmed — and, in fact, have been harmed — and highlights the need for appropriate oversight.”



Agency scientists have recently called the current situation outdated and “untenable.” In a memo listing health concerns on lab-developed tests, the FDA cited a company that sought approval for its test diagnosing Alzheimer’s disease. The FDA declined to authorize it, saying it lacked data to support its accuracy. That test is still being offered to patients, said the memo, thanks to the FDA’s hands-off policy.


A new FDA rule will phase in a process that would require certain lab-developed tests to undergo a rigorous review before hitting the market, meet manufacturing standards and report bad patient outcomes. Opponents say the rule would stifle innovation, and Everlywell has argued it could significantly limit access to critical tests to people in medically underserved areas.



A list of food allergies that Sharma has identified her daughter as having. (Melanie Landsman for The Washington Post)


A nutritionist with Tiny Health recommended a probiotic, sauerkraut and exposure to animal microbes through daily visits to the petting zoo to address 3-year-old Annika's gut issue. (Melanie Landsman for The Washington Post)

Many investors and entrepreneurs endorse self-testing with similar urgency. Tiny Health founder Cheryl Sew Hoy said she raced to develop her baby microbiome testing start-up because of her experience giving birth to a C-section baby with gastrointestinal issues that doctors could not address. Though she and her business partners were aware that the benefits of gut bacteria testing have often been overhyped, they found cutting-edge research showing that the simplicity of a baby’s gut makes it highly responsive to interventions.


To them, it did not seem fair to wait for years — possibly decades — until that research could become standard pediatric advice.


“It will eventually get to the point where you get screened with a stool test every time you go to the hospital, but that’s not going to happen next year or the next couple of years,” said Ruben Mars, a microbiologist at the Gut Microbiome Laboratory at the Mayo Clinic, and a scientific adviser to Tiny Health. “But these kids are getting chronic disease now. … They shouldn’t have to wait until it becomes standard of care.”


As long as the medical system remains slow there is going to be a market for people who take matters into their own hands, said Anarghya Vardhana, a Silicon Valley investor. “If you don’t give patients the tools, they will go figure it out themselves,” she added.