At the Center for Devices and Radiological Health (CDRH), we strive to ensure patients and their care partners stay at the center of our regulatory decision-making process. One way we do that is by encouraging the inclusion of clinical outcome assessments (COAs) in the evaluation of medical devices.
On this page:
- What are Clinical Outcome Assessments?
- How CDRH Uses COAs in Regulatory Decision Making
- CDRH Collaborations, Studies, Articles, and Workshops on PROs
- Planning to Incorporate COAs in a Regulatory Submission?
- Contact Us
A clinical outcome assessment (COA) describes or reflects how a person feels, functions, or survives and can be reported by a healthcare provider or a non-clinical observer (such as a parent), through performance of an activity or task, or by the patient. There are four types of COAs:
- Patient-reported outcomes (PROs),
- Clinician-reported outcomes (ClinROs),
- Observer-reported outcomes (ObsROs), and
- Performance outcomes (PerfOs).
While each COA focuses on the patient, they provide a different perspective on a patient's health status.
PROs provide information on the patient's health condition as directly reported by the patient, without outside interpretation from anyone. These outcomes are assessed using PRO instruments such as questionnaires, numeric rating scales, or diaries.
ClinROs are reports coming from a trained health-care professional regarding their interpretation of signs or behaviors that can be observed related to a patient's disease or condition.
ObsROs are assessments of observable signs, events, or behaviors related to a patient's health condition as reported by individuals who observe the patient in daily life, like parents or caregivers.
PerfOs are measurements collected when a patient is asked to complete a well-defined, repeatable, and standardized task such as reading an eye chart.
For regulatory purposes, high-quality information from COAs can provide valuable evidence for benefit-risk assessments. They can also be used in medical device labeling to communicate the effect of a treatment on patient symptoms and functioning. COAs may be used to determine who is eligible for a clinical study and measure how well the device performs in treating or diagnosing the condition. COAs may also be used to help measure the safety of the device. Evidence from COAs may also be useful to payors and healthcare providers.
CDRH regularly collaborates with professional societies, academic researchers, patient groups, public-private partnerships, and other stakeholders to advance the development and validation of COAs for regulatory use. For additional information about our workshops on COAs, see Medical Devices Virtual Public Meeting - Patient-Reported Outcomes (PROs) and Medical Device Evaluation: From Conception to Implementation.
- LASIK Quality of Life Collaboration Project (National Eye Institute and Department of Defense)
- The Impact of Race and Ethnicity on Responses to Heart Failure Patient-Reported Outcome Measures (UCSF-Stanford CERSI)
- Adapting a Measure of Heart Failure to an Adolescent Population (UCSF-Stanford CERSI)
- Qualitative analysis of gender differences in heart failure PROs (Duke University, Yale-Mayo CERSI)
- Patient-Reported Outcomes for Dialysis Vascular Access (Kidney Health Initiative)
- Patient-Reported Outcomes for Muscle Cramping in Patients on Dialysis (Kidney Health Initiative)
- Patient-Reported Outcome Measure Development for Intraocular Lens Symptoms (American Academy of Ophthalmology Task Force & Industry Collaboration)
- Patient Reported Outcomes for Minimally Invasive Glaucoma Surgery (MIGS) (UCSF-Stanford CERSI, Johns Hopkins University CERSI)
- Post-market surveillance with a novel mHealth platform (Yale-Mayo CERSI)
- Value and Use of Patient-Reported Outcomes (PROs) in Assessing Effects of Medical Devices (CDRH Strategic Priorities 2016-2017)
- FDA issues first report on patient reported outcomes in medical device premarket submissions and postmarket studies (FDA In Brief)
- Articles from the LASIK Quality of Life Collaboration Project
If you are interested in incorporating COAs in your regulatory submissions, CDRH has multiple resources to help with selecting, using, developing and modifying appropriate COAs. FDA has issued guidance documents and discussion guides that may help inform your approach to including COAs in the evaluation of medical devices.
Q-submission: We invite sponsors to discuss their plan to use COAs, including adapting or developing PRO instruments, with CDRH through the Q-submission program. A pre-submission can initiate early discussions with regulatory staff, as described in the guidance document Requests for Feedback and Meetings for Medical Device Submissions: The Q-Submission Program.
Medical Device Development Tools: The Medical Device Development Tools (MDDT) program enables the FDA to qualify tools that medical device sponsors can use in the development and evaluation of medical devices. Qualification means CDRH has evaluated the tool and concurs with available supporting evidence that the tool produces scientifically-plausible measurements and works as intended within the specified context of use. COAs are one type of tool that can be qualified under the MDDT program.
PRO Report: This document provides more detailed information on PROs. It discusses the value of using PROs in regulatory submissions, reimbursement decisions, and clinical practice. Additionally, CDRH efforts and accomplishments to date relating to PROs are highlighted.
PRO Case Studies: To clarify the potential application of PROs in clinical investigations, the PRO Case Studies (PDF) includes detailed and self-contained examples of PROs used in approved and cleared CDRH regulatory submissions. These examples highlight various contexts in which PROs have been used as safety and effectiveness endpoints.
PRO Compendium: The PRO Compendium (XLS) lists some, but not all, PRO instruments that have been used and reported in medical device premarket clinical investigations submitted to CDRH. We encourage sponsors interested in using a PRO instrument in a clinical investigation to schedule a pre-submission meeting to discuss their plans.
If you have questions about clinical outcome assessments, email CDRH-PRO@fda.hhs.gov