Draft NIH Resources for Implantable Device Trials
Summary
The NIH has released draft resources to assist researchers in planning for the post-trial needs of participants in implantable device trials. These resources address unique ethical and logistical considerations, including ongoing care, maintenance, and potential removal of devices. The NIH is seeking public comment on these draft materials.
What changed
The National Institutes of Health (NIH) has issued a notice regarding draft resources designed to support clinical trials involving implantable medical devices. These resources, titled "Considerations in Planning for the Post-Trial Needs of Research Participants who Receive an Investigational Implantable Device" and "Informed Consent for Research Using Investigational Implantable Devices: Points to Consider & Sample Language Resource," aim to help researchers navigate the complexities of long-term participant care, device maintenance, and potential surgical removal or explantation. The NIH emphasizes that these are voluntary resources and not intended to replace Institutional Review Board (IRB) review.
NIH is requesting public comment on these draft resources, with a response deadline of May 25, 2026. Researchers and other stakeholders are encouraged to submit feedback electronically via the provided comment form. The purpose of this request for information (RFI) is to gather input to finalize these materials, which are intended to improve planning for post-trial care and enhance informed consent processes for participants in implant trials. While the use of these resources is voluntary, the feedback will help shape guidance for future NIH-supported studies.
What to do next
- Review draft NIH resources for implantable device trials
- Submit comments on draft resources by May 25, 2026
Source document (simplified)
Draft NIH Resources to Support Implantable Device Trials Notice Number: NOT-OD-26-061
Key Dates
Release Date: March 25, 2026 Response Date: May 25, 2026
Related Announcements
None
Issued by
NATIONAL INSTITUTES OF HEALTH (NIH)
Purpose
Clinical trials involving implanted investigational medical devices ("implant trials") present unique ethical considerations that extend beyond the typical duration of research studies. Investigational implantable devices are increasingly used to treat various medical conditions (e.g., the use of deep brain stimulation devices for neurological disorders) but differ from other clinical trials in that devices may either remain in the body after trial completion or require surgical removal, with both scenarios carrying additional risks and potential costs.
Participants may face ongoing care needs including device maintenance (battery replacements, software updates, adjustments), repair of malfunctioning components, monitoring to mitigate complications such as infection, and potential explantation (removal) surgery. Post-trial care remains complex, as investigational devices may not be compatible with commercially available hardware or software, access to replacement parts may become challenging if manufacturers discontinue products or cease operations, and ongoing medical interventions may pose substantial financial burdens that health insurance may not cover. While clinical trials have discrete endpoints, implant trial participants' needs and interests often extend beyond the study's conclusion, making it essential to anticipate post-trial care needs during trial planning to allow for continuity of care.
NIH has developed two interconnected and complementary resources intended to support the research community in navigating these complexities with participants enrolled in implant trials: 1) Considerations in Planning for the Post-Trial Needs of Research Participants who Receive an Investigational Implantable Device and 2) Informed Consent for Research Using Investigational Implantable Devices: Points to Consider & Sample Language Resource. These documents, when finalized, are not intended to replace any IRB review or guidance but rather are intended to serve as a resource to support adequate post-trial planning and effective communication of the unique risks and considerations of implant trials to prospective participants. Use of these resources is voluntary and there are no requirements or expectations that any portion of the sample consent language be used in an informed consent document for NIH-supported studies.
Request for Information
NIH will consider all comments submitted on the draft resources, but there are specific areas where NIH would appreciate specific feedback. These areas are detailed on the comment form found at: https://osp.od.nih.gov/comment-form-draft-nih-resources-to-support-implantable-device-trials/
How to Submit a Response
Comments should be submitted electronically to the following webpage: https://osp.od.nih.gov/comment-form-draft-nih-resources-to-support-implantable-device-trials/. Responses will be accepted through May 25, 2026. Responses to this RFI are voluntary and may be submitted anonymously. You may also voluntarily include your name and contact information with your response. Other than your name and contact information, please do not include in the response any personally identifiable information or any information that you do not wish to make public. Proprietary, classified, confidential, or sensitive information should not be included in your response. After the Office of Science Policy (OSP) has finished reviewing the responses, the responses may be posted to the OSP website without redaction.
Inquiries
Please direct all inquiries to:
NIH Office of Science Policy
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