<?xml version="1.0" encoding="UTF-8"?><rss version="2.0"
	xmlns:content="http://purl.org/rss/1.0/modules/content/"
	xmlns:dc="http://purl.org/dc/elements/1.1/"
	xmlns:atom="http://www.w3.org/2005/Atom"
	xmlns:sy="http://purl.org/rss/1.0/modules/syndication/"
		>
<channel>
	<title>Comments on: Punishing health-care innovation – part 1</title>
	<atom:link href="http://blog.aynrandcenter.org/punishing-health-care-innovation-part-1/feed/" rel="self" type="application/rss+xml" />
	<link>http://blog.aynrandcenter.org/punishing-health-care-innovation-part-1/</link>
	<description></description>
	<lastBuildDate>Mon, 24 Oct 2011 16:44:58 +0000</lastBuildDate>
	<sy:updatePeriod>hourly</sy:updatePeriod>
	<sy:updateFrequency>1</sy:updateFrequency>
	
	<item>
		<title>By: House Health Care Punishes Medical Device Innovation &#124; www.statehousecall.org</title>
		<link>http://blog.aynrandcenter.org/punishing-health-care-innovation-part-1/comment-page-1/#comment-1997</link>
		<dc:creator>House Health Care Punishes Medical Device Innovation &#124; www.statehousecall.org</dc:creator>
		<pubDate>Thu, 19 Nov 2009 16:20:21 +0000</pubDate>
		<guid isPermaLink="false">http://blog.aynrandcenter.org/?p=4467#comment-1997</guid>
		<description>[...] the whole post: Punishing health-care innovation &#8211; part 1.  Here’s an excerpt from part 2 on how the legislation would stifle innovation: The Max Baucus [...]</description>
		<content:encoded><![CDATA[<p>[...] the whole post: Punishing health-care innovation &#8211; part 1.  Here’s an excerpt from part 2 on how the legislation would stifle innovation: The Max Baucus [...]</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Health care bill punishes medical device innovation &#124; Independence Institute: Patient Power</title>
		<link>http://blog.aynrandcenter.org/punishing-health-care-innovation-part-1/comment-page-1/#comment-1989</link>
		<dc:creator>Health care bill punishes medical device innovation &#124; Independence Institute: Patient Power</dc:creator>
		<pubDate>Wed, 18 Nov 2009 08:01:51 +0000</pubDate>
		<guid isPermaLink="false">http://blog.aynrandcenter.org/?p=4467#comment-1989</guid>
		<description>[...] the whole post: Punishing health-care innovation - part 1.  Here&#8217;s an excerpt from part 2 on how the legislation would stifle innovation: The Max [...]</description>
		<content:encoded><![CDATA[<p>[...] the whole post: Punishing health-care innovation &#8211; part 1.  Here&#8217;s an excerpt from part 2 on how the legislation would stifle innovation: The Max [...]</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Alex</title>
		<link>http://blog.aynrandcenter.org/punishing-health-care-innovation-part-1/comment-page-1/#comment-1979</link>
		<dc:creator>Alex</dc:creator>
		<pubDate>Sat, 14 Nov 2009 21:17:17 +0000</pubDate>
		<guid isPermaLink="false">http://blog.aynrandcenter.org/?p=4467#comment-1979</guid>
		<description>Existing medical device innovation would come to market more quickly and medical devices would be far less expensive were it not for massive FDA imposed &quot;Good Manufacturing Practices&quot; (GMP) &quot;design controls&quot; that require a huge system of documentation and organizational processes to prove to FDA inspectors that the company follows detailed regulatory prescriptions on the entire design and manufacturing process. These prescriptions apply to almost every facet of the device manufacturer organizational processes - product requirements, engineering specifications and design,  manufacturing and inventory control, response to complaints from the customers, etc. Here is the link to the core regulation: http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm070627.htm. There are dozens more guidance documents. 

An FDA inspector can cause millions of dollars of losses by shutting down operations or triggering recalls if he feels that any of these regulations are not being followed strictly, which by FDA definition compromises safety. He requires no actual evidence of product quality problems to do so, and there is significant precedence of recalls for quality system regulation violations with no demonstration of actual product quality problems.

Generally, the FDA regulations are reasonable design and development practices for high reliability, safety critical products. However, because the FDA requires proof in their terms for following them, this imposes a large cost overhead. This cost overhead serves as an impediment for new small companies to compete with inefficient, existing larger manufacturers. For this reason, medical device design and development cycles are generally slower and device evolution takes years longer than other comparable unregulated high-reliability industries. For evidence, compare the technology age of the CPU in an average medical device and compare it to the age of the CPU in any unregulated high reliability, hi-tech product (e.g. disk drive storage). The unregulated product product will generally be designed with newer, cheaper, more state-of-the-art options because their design and development cycles are far shorter. Yet, I have seen no evidence that regulated products have higher quality and reliability. This regulatory burden is also a significant contributor to the overall cost of health care.</description>
		<content:encoded><![CDATA[<p>Existing medical device innovation would come to market more quickly and medical devices would be far less expensive were it not for massive FDA imposed &#8220;Good Manufacturing Practices&#8221; (GMP) &#8220;design controls&#8221; that require a huge system of documentation and organizational processes to prove to FDA inspectors that the company follows detailed regulatory prescriptions on the entire design and manufacturing process. These prescriptions apply to almost every facet of the device manufacturer organizational processes &#8211; product requirements, engineering specifications and design,  manufacturing and inventory control, response to complaints from the customers, etc. Here is the link to the core regulation: <a href="http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm070627.htm" rel="nofollow">http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm070627.htm</a>. There are dozens more guidance documents. </p>
<p>An FDA inspector can cause millions of dollars of losses by shutting down operations or triggering recalls if he feels that any of these regulations are not being followed strictly, which by FDA definition compromises safety. He requires no actual evidence of product quality problems to do so, and there is significant precedence of recalls for quality system regulation violations with no demonstration of actual product quality problems.</p>
<p>Generally, the FDA regulations are reasonable design and development practices for high reliability, safety critical products. However, because the FDA requires proof in their terms for following them, this imposes a large cost overhead. This cost overhead serves as an impediment for new small companies to compete with inefficient, existing larger manufacturers. For this reason, medical device design and development cycles are generally slower and device evolution takes years longer than other comparable unregulated high-reliability industries. For evidence, compare the technology age of the CPU in an average medical device and compare it to the age of the CPU in any unregulated high reliability, hi-tech product (e.g. disk drive storage). The unregulated product product will generally be designed with newer, cheaper, more state-of-the-art options because their design and development cycles are far shorter. Yet, I have seen no evidence that regulated products have higher quality and reliability. This regulatory burden is also a significant contributor to the overall cost of health care.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Rhett Yurgin</title>
		<link>http://blog.aynrandcenter.org/punishing-health-care-innovation-part-1/comment-page-1/#comment-1977</link>
		<dc:creator>Rhett Yurgin</dc:creator>
		<pubDate>Sat, 14 Nov 2009 15:17:51 +0000</pubDate>
		<guid isPermaLink="false">http://blog.aynrandcenter.org/?p=4467#comment-1977</guid>
		<description>You published this article just as I was re-reading Hayek&#039;s Constitution of Liberty. In the first few chapters it&#039;s mentioned how the only way to &quot;progress,&quot; is for wealthy individuals to try new technologies first, and then progressively make the new ideas available to less and less wealthy people through production innovations/etc.

Of course, as soon as I read the paragraph I connected it to health care. It&#039;s not going to be instant obviously, but we will get to a point where we no longer develop new treatments or drugs simply because insurance companies won&#039;t want to pay for them, whether due to lack of funds from providing mandatory coverage or from medical providers seeing no purpose in providing a service/product cheaper when the government is footing the bill.

In short, the free market is the only thing that could possibly save our form of the health industry. The GOP&#039;s bill introduced a few days before the Democrat&#039;s plan was a far better step towards a solution, but still not right. The barrier to entry into any medical business is too high; you have to get federal licenses, state licenses, and FDA approvals. If you really want to bring costs down, quit strangling the market with the vine of regulations.</description>
		<content:encoded><![CDATA[<p>You published this article just as I was re-reading Hayek&#8217;s Constitution of Liberty. In the first few chapters it&#8217;s mentioned how the only way to &#8220;progress,&#8221; is for wealthy individuals to try new technologies first, and then progressively make the new ideas available to less and less wealthy people through production innovations/etc.</p>
<p>Of course, as soon as I read the paragraph I connected it to health care. It&#8217;s not going to be instant obviously, but we will get to a point where we no longer develop new treatments or drugs simply because insurance companies won&#8217;t want to pay for them, whether due to lack of funds from providing mandatory coverage or from medical providers seeing no purpose in providing a service/product cheaper when the government is footing the bill.</p>
<p>In short, the free market is the only thing that could possibly save our form of the health industry. The GOP&#8217;s bill introduced a few days before the Democrat&#8217;s plan was a far better step towards a solution, but still not right. The barrier to entry into any medical business is too high; you have to get federal licenses, state licenses, and FDA approvals. If you really want to bring costs down, quit strangling the market with the vine of regulations.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Joanna</title>
		<link>http://blog.aynrandcenter.org/punishing-health-care-innovation-part-1/comment-page-1/#comment-1975</link>
		<dc:creator>Joanna</dc:creator>
		<pubDate>Sat, 14 Nov 2009 01:39:47 +0000</pubDate>
		<guid isPermaLink="false">http://blog.aynrandcenter.org/?p=4467#comment-1975</guid>
		<description>Your piece &#039;Punishing health-care innovation – part 1&#039; rings so true to a graduate student like myself! I&#039;m more interested in drug development and I know how tough and expensive it is to bring new drugs to market. I feel quite threatened that by the time I graduate there will be little opportunity in the pharma/biotech industry if the proposed health care bills pass. Health care innovation is key to high quality of life!</description>
		<content:encoded><![CDATA[<p>Your piece &#8216;Punishing health-care innovation – part 1&#8242; rings so true to a graduate student like myself! I&#8217;m more interested in drug development and I know how tough and expensive it is to bring new drugs to market. I feel quite threatened that by the time I graduate there will be little opportunity in the pharma/biotech industry if the proposed health care bills pass. Health care innovation is key to high quality of life!</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Rachel</title>
		<link>http://blog.aynrandcenter.org/punishing-health-care-innovation-part-1/comment-page-1/#comment-1973</link>
		<dc:creator>Rachel</dc:creator>
		<pubDate>Fri, 13 Nov 2009 16:30:09 +0000</pubDate>
		<guid isPermaLink="false">http://blog.aynrandcenter.org/?p=4467#comment-1973</guid>
		<description>You have a typo: eighty percent of medical device companies employer fewer than fifty workers</description>
		<content:encoded><![CDATA[<p>You have a typo: eighty percent of medical device companies employer fewer than fifty workers</p>
]]></content:encoded>
	</item>
</channel>
</rss>

