Recently, the FDA has determined that FMT is a biological
drug and needs to be regulated; part of that regulation is that
clinicians using FMT as a treatment need to submit a treatment
protocol and an institutional review board (IRB) approval
from their center to obtain an Investigational New Drug (IND)
number from the FDA.
25
An IND sponsor has to conduct their
work in accordance with the protocol described in the IND,
must report any deviations, and must file reports, among other
requirements. This is an intensive process, but thankfully, for
now the FDA has decided to use their executive discretion and
not enforce the IND process. It remains to be seen how long
this will continue before an increased regulatory oversight of
one kind or another is going to be the norm.