Comments on Patient-Reported Outcomes Guidance

Share

The Biotechnology Innovation Organization (BIO) says it appreciates efforts by CDRH and CBER to develop a guidance on patient-reported outcome (PRO) instruments for use in medical product evaluation. BIO’s comment letter says that while PROs are an important tool for collecting and reporting patient experiences, the trade group believes that a patient-centric approach to drug review includes additional clinical outcome assessments. It encourages CDRH and CBER to consider the other types of outcome assessments, such as observer, clinician, and performance, when finalizing the guidance.

AdvaMed said it supports the development of the draft patient-reported outcomes guidance as a step toward meeting the MDUFA 5 commitment letter. “However,” the association writes, “the guidance should be strengthened to include examples of least burdensome ways in which existing broad PRO instruments can be used for other subpopulations without having to conduct cognitive debriefing or validation. Given the cost and time associated with revalidating PRO instruments, we also recommend that the guidance include several examples of the types of modifications that would require revalidation of the PRO instrument for cohorts that differ from the original PRO instrument cohort as well as other modifications that may be appropriate to implement an existing PRO instrument without extensive revalidation of the entire instrument.”

Otsuka submitted a specific technical comment.

Read more