Clarity in RWE Guidance is Welcome: Attorneys

Share

FDA’s new draft guidance on “Real-World Evidence (RWE): Considerations Regarding Non-Interventional Studies for Drug and Biological Products” provides “additional clarity” on the agency’s focus when analyzing a RWE program’s adequacy, according to an online post from attorneys at Hogan Lovells. “Notably, unlike previous guidances on the topic, FDA specifies that non-interventional studies can be used to support a demonstration of substantial evidence of effectiveness and/or the safety of a drug,” they write. “Although this may have been implied in the agency’s use of ‘regulatory-decision making’ in earlier RWD/RWE guidances, specifying the substantial evidence standard may indicate FDA is open to placing more reliance or weight on RWE when determining the approvability of a drug or biologic product, including establishing the risk/benefit profile.”

The document provides recommendations for sponsors and investigators who are considering submitting a non-interventional study to the agency to contribute to a demonstration of substantial evidence of effectiveness and/or evidence of the safety of a drug. It specifically discusses attributes regarding the design and analysis of a non-interventional study that sponsors should consider when proposing a non-interventional study for such regulatory purposes.

The post says that due to FDA’s additional clarity on RWE, the agency is “acknowledging the impact that data from electronic health records, medical claims, disease registries, and digital drug development tools can have on approval decisions. Consistent with prior guidance, when seeking to incorporate RWD to support regulatory decisions for product development, sponsors should consult with FDA early in the planning of a study to discuss FDA expectations for design and conduct.”

Read more