3 More Comments on RWD Draft Guidance

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Regeneron says an FDA draft guidance on considerations for using real-world data (RWD) and real-world evidence (RWE) to support regulatory decision-making for drug and biological products should acknowledge the rapidly advancing state of science about RWE. “This guidance should make clear that this is a dynamic topic and highlight the agency’s flexibility and receptivity in engaging with sponsors to advise on and explore approaches, concerns, and considerations specific to individual drug development programs, the company letter says.

Regeneron also says that in its experience with RWD, many of the recommendations outlined in the document around data collection, curation, management, and storage are generally outside of the sponsor’s control because they concern processes that may be considered proprietary for the companies that curate the data and/or may not be readily available to sponsors. The company also provided line-by-line comments.

Gilead said the agency’s RWE framework and this draft guidance “will enhance data collection, analysis, stability, and integrity, which are essential to FDA’s standards for substantial evidence requirements.” The company called on the agency to leverage applicable fit-for-purpose data ecosystems containing data validation tools that could easily be adapted to RWE.

Boehringer Ingelheim submitted line-by-line comments.

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