FDA’s position that it may regulate device as drugs is plainly not authorized under the FDCA. To the contrary, if a product is within the definition of a device, Congress has decreed that it must be regulated under the device authorities.
— Read on www.fdalawblog.net/2018/11/may-fda-regulate-medical-devices-as-if-they-were-drugs/
Interesting ideas here. The boundaries between a device and a drug are becoming more and more blurred, and frankly I am not sure if this is the right way to move forward, but this is good reading.
Investigations of a Dog 