Stakeholder Comments on Real-World Data Guidance

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IQVIA says it appreciates the FDA effort to provide guidance on the use of registry data to support regulatory decision-making for drug and biological products and the agency’s conceptual approach to defining multiple key terms. The firm’s 2/25 letter commented on an FDA draft guidance, Real-World Data: Assessing Registries to Support Regulatory Decision-Making for Drug and Biological Products. IQVIA provides comments and recommendations about data standardization and terminology, along with line-by-line specific comments.

The comment submitted by the Real-World Evidence Alliance commends FDA for issuing the guidance and says it agrees with the agency’s recognition that registry data can be useful in regulatory decision-making. The alliance says it advocates for policies that will (1) advance FDA’s real-world evidence (RWE) framework; (2) encourage the use of RWE to better understand treatment effects in underrepresented populations; (3) enhance opportunities for RWE organizations to consult with the agency, and (4) increase communication on generation and use of RWE.

The Biotechnology Innovation Organization offers “overarching comments” on collaborating with registry holders/partners, the scope of the guidance (types of registries), and harmonization of RWE guidance. It also provides specific line-by-line comments.

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