A Failure to Comply: An Initial Assessment of Gaps in IOM’s Medical Device Study Committee
Ralph Hall, JD
University of Minnesota, Twin Cities - School of Law
affiliation not provided to SSRN
May 19, 2011
Minnesota Journal of Law, Science & Technology, Vol. 12, No. 1, 2011
The Institute of Medicine (IOM) is increasingly engaged in policy analysis and recommendations including a current project to assess medical devices and the 51'6k) process. In addition to internal IOM policies and good practices, any IOM committee commissioned by a federal agency must abide by FACA Sec. 15. This paper examines the issues relating to the composition and processes of the IOM 51'6k) committee and concludes that it fails to satisfy FACA Sec. 15. As such FDA is statutorily prohibited from using any report from this committee.
Number of Pages in PDF File: 18
Keywords: Medical Devices, IOM, FDA, Oversight, Regulation, Compliance
Date posted: July 20, 2011
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