Externally Controlled Trial Guidance

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FDA has published a draft guidance, Considerations for the Design and Conduct of Externally Controlled Trials for Drug and Biological Products, with recommendations for sponsors and investigators considering the use of externally controlled clinical trials to provide evidence of the safety and effectiveness of a drug product. The document addresses considerations for the design and analysis of externally controlled trials to study the safety and effectiveness of drugs, including a discussion of threats to the validity of trial results from potential bias.

“Although various sources of data can serve as the control arm in an externally controlled trial, this guidance focuses on the use of patient-level data from other clinical trials or real-world data sources, such as registries, as well as electronic health records and medical claims,” the draft says. “The guidance also describes considerations related to communicating with FDA and ensuring access by FDA to data from an externally controlled trial.”

The guidance does not address other types of external controls, such as using summary-level estimates instead of patient-level data. It also does not discuss details of the design and analysis of a natural history study nor the reliability and relevance of various sources of real-world data that could be used in an externally controlled trial. Finally, the document says, the guidance also does not discuss considerations for using external control data to supplement a control arm in a traditional randomized controlled clinical trial.

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