Comparison of two assessments of real-world data and real-world evidence for regulatory decision-making

Linkage of Clinical Trial Data to Routinely Collected Data Sources: A Scoping Review

Importance

Patients who participate in clinical trials generate valuable routinely collected data (eg, medical records, electronic health records, claims databases, disease registries, or vital statistics) through their routine interactions with the health care system before, during, and after the trial. When this routinely collected data is linked at the participant level, it can supplement active data collection in the trial and provide deeper insights into the benefits, risks, and costs of treatments.

Objective

To review clinical trials linked to routinely collected data in various countries, identifying the use cases and designs of these linkage studies.

Evidence Review

Research articles that reported the linkage of clinical trials to medical records, electronic health records, claims databases, disease registries, or vital statistics in their title or abstract were searched for in PubMed and MEDLINE. The search covered the period from January 1, 2016, through December 30, 2023. Opinion pieces, study protocols, or studies that involved interventions other than medications, dietary supplements, vaccines, devices, procedures, or diagnostics (eg, behavioral interventions) were excluded. Study eligibility and data extraction were performed independently by 2 reviewers to ensure the accuracy of findings.

Findings

Of the 990 abstracts initially screened, a full text review was conducted for 147 articles. In total, 71 studies were included in the results, including 42 medication, vaccine, and dietary supplement trials (59.2%) and 29 device, procedure, or diagnostic trials (40.8%). Of these 71 studies, 24 (32.4%) were conducted in the US. In 32 studies (45.1%), consent for linkage was obtained prospectively as part of the main trial, while 33 studies (46.5%) received a waiver of authorization from the respective ethical review boards. The most frequent use cases of linkage to were posttrial long-term follow-up (22 studies [31.0%]), capturing primary or secondary outcomes of trials (19 studies [26.8%]), validation of routinely collected data outcomes (17 studies [23.9%]), and measuring health care resource utilization and cost in trials (12 studies [16.9%]).

Conclusions and Relevance

This study found that the linkage of patients' clinical trial data to routinely collected data has been implemented in several trials for various use cases and that most studies obtained consent for linkage prospectively as part of the main trial or received a waiver of authorization from ethical review boards. These findings demonstrate the feasibility and provide an overview of the use cases for linking trials to routinely collected data.

Bridging the Gap in FDA Approval for Pediatric Neuromodulation Devices

While neuromodulation devices for managing neurological conditions have significantly advanced, there remains a substantial gap in FDA-approved devices specifically designed for pediatric patients. Devices like deep brain stimulators (DBS), vagus nerve stimulators (VNS), and spinal cord stimulators (SCS) are primarily approved for adults, with few options for children. To meet pediatric needs, off-label use is common; however, unique challenges to pediatric device development-such as ethical concerns, small trial populations, and financial disincentives due to the limited market size-continue to hinder progress. This review examines these barriers to pediatric neuromodulation device development and FDA (Food and Drug Administration) approval, as well as the current efforts, such as FDA initiatives and consortia support, that address regulatory and financial challenges. Furthermore, we discuss pathways like the Humanitarian Device Exemptions and Real-World Evidence programs that aim to streamline the approval process and address unmet clinical needs in pediatric care. Addressing these barriers could expand access to effective neuromodulation treatments and improve patient care.

Comparison of two assessments of real-world data and real-world evidence for regulatory decision-making

Real-world data (RWD) and real-world evidence (RWE) are increasingly used to support regulatory decision making, but regulatory agencies and stakeholders may apply different definitions for RWD and use different criteria to determine when analysis of such data are considered RWE in decisions on drug approvals. To explore this issue, we reviewed two prominent publications that operationalized the definitions of RWD and RWE when describing the use of RWE in drug approvals by the US Food and Drug Administration (FDA) and the European Medicines Agency (EMA). Both publications considered noninterventional (observational) studies, RWD as a comparator arm for a single-arm trial, product-related literature reviews, and RWD to support clinical trial implementation (e.g., to identify potential participants) as generating RWE. In contrast, inconsistencies were identified regarding types of data sources and study designs that were considered as not generating RWE. For example, a lack of agreement existed regarding whether RWE is generated when RWD describe therapeutic contexts or are used in phase I/II interventional trials, open-label extension studies, or pharmacovigilance activities. These discrepancies highlight opportunities to develop a consistent understanding of the role of RWE in regulatory decision making for drug approvals among regulatory agencies and stakeholders.