The Total Product Life Cycle Advisory Program (TAP) is a voluntary pilot program launched by the FDA’s Center for Devices and Radiological Health (CDRH) in October 2023. The TAP Pilot is one of the commitments between the FDA and industry as part of the MDUFA V reauthorization, which aims to provide faster patient access to safe and effective medical devices, increase innovation, improve patient safety through enhanced surveillance and data collection, and provide a more efficient regulatory process for FDA and industry.  

Taking a medical device from concept to commercialization in the United States is often a long and challenging process that involves participation and adoption from FDA, clinicians, payers, and patients. The TAP program is addressing the obstacles that device manufacturers often encounter throughout this process with:

• Early and frequent interactions: FDA will provide more opportunities for sponsors to interact with the agency early in the development process, which can help to identify and address potential issues early on.
• Strategic input from stakeholders: The program will involve input from a variety of stakeholders, including clinicians, patient advocates, and payers, which can help to ensure that the development of new devices is meeting the needs of patients and the healthcare system.
• Proactive, strategic advice from CDRH: FDA will provide proactive and strategic advice to sponsors throughout the development process, which can help to reduce the risk of regulatory delays.

Currently, TAP program membership includes the companies or individuals developing the medical devices, the medical device sponsors, dedicated staff within the CDRH, stakeholders consisting of clinicians, patient advocates, payers, and academic experts, and independent advisors. However, It is unclear if independent advisors will continue to be part of the program as TAP expands. Additionally, specific individuals involved in the TAP program at a given time will vary based on the device being developed and the stage of the development process.

While currently still in its pilot phase, the TAP program is open to a limited number of medical devices. To be considered for the program, device manufacturers must have breakthrough designation with no previous pre-submission meetings. The TAP program started with 15 cardiovascular devices last fall and is now at 31 enrolled devices as of February 2024. Enrollment could reach as high as 60 devices by the end of 2024.

As part of the MDUFA V reauthorization, the TAP Program shares the goal of facilitating the development of high-quality, safe, effective, and innovative medical devices. Additionally, the TAP Program strives to reduce device development time and costs through early and frequent feedback from FDA, increase innovation with more predictable and efficient regulatory pathways for new devices, and improve patient access to new devices.

Overall, the TAP program’s focus is on improving the medical device landscape by addressing various challenges and opportunities throughout the product lifecycle. The program's success will be measured by its ability to expedite development, foster innovation, ensure device quality, and ultimately, improve patient access to these potentially life-changing technologies. For more information about the TAP program and enrollment in it, visit FDA’s website.  

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