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Davenport C, Gravel P, Wang Y, Williams SA, Wieland A, Mitlak B. Real-World Evidence to Support the Registration of a New Osteoporosis Medicinal Product in Europe. Ther Innov Regul Sci 2024; 58:505-518. [PMID: 38341388 PMCID: PMC11043175 DOI: 10.1007/s43441-024-00616-7] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [MESH Headings] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Received: 07/21/2023] [Accepted: 01/08/2024] [Indexed: 02/12/2024]
Abstract
Real-World Evidence (RWE), which has historically been used to support post-approval safety studies, has recently gained acceptance for new drug applications as supportive evidence or as new clinical evidence for medicinal products with orphan designation and/or in disease areas with high unmet need. Here, we present a case study for the use of RWE in the approval of abaloparatide in the European Union (EU) under the tradename Eladynos. In addition to data from the pivotal Phase 3 study, the marketing authorization application (MAA) included clinical data from additional interventional and observational studies, as well as post-marketing data obtained from the United States (US) market since approval of abaloparatide by the Food and Drug Administration (FDA) in 2017. The new interventional studies were not designed to assess fracture efficacy and cardiovascular safety which were topics of concern raised by the Committee for Medicinal Products for Human Use (CHMP) during their review of the initial MAA submitted in 2015. However, these studies taken together with the RWE formed the basis for a new MAA. Prior to the planned resubmission in the EU, national Scientific Advice (SA) was sought on the proposed clinical program, specifically on the relevance of Real-World Data (RWD) derived from an observational study to support and complement the efficacy and safety data already available from prospective randomized clinical trials. This case study demonstrates successful use of RWE to address a previously identified gap raised by the CHMP during the review of an earlier MAA, which led to the approval of Eladynos for the treatment of osteoporosis in the EU.
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Affiliation(s)
- Colleen Davenport
- Radius Health, Inc., 22 Boston Wharf Road, 7th Floor, Boston, MA, 02210, USA.
| | | | - Yamei Wang
- Radius Health, Inc., 22 Boston Wharf Road, 7th Floor, Boston, MA, 02210, USA
| | | | | | - Bruce Mitlak
- Radius Health, Inc., 22 Boston Wharf Road, 7th Floor, Boston, MA, 02210, USA
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Burns L, Roux NL, Kalesnik-Orszulak R, Christian J, Hukkelhoven M, Rockhold F, O'Donnell J. Real-World Evidence for Regulatory Decision-Making: Guidance From Around the World. Clin Ther 2022; 44:420-437. [PMID: 35181179 DOI: 10.1016/j.clinthera.2022.01.012] [Citation(s) in RCA: 25] [Impact Index Per Article: 12.5] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Received: 10/12/2021] [Revised: 01/19/2022] [Accepted: 01/21/2022] [Indexed: 11/29/2022]
Abstract
PURPOSE Interest in leveraging real-world evidence (RWE) to support regulatory decision making for product effectiveness has been increasing globally as evident by the increasing number of regulatory frameworks and guidance documents. However, acceptance of RWE, especially before marketing for regulatory approval, differs across countries. In addition, guidance on the design and conduct of innovative clinical trials, such as randomized controlled registry studies, pragmatic trials, and other hybrid studies, is lacking. METHODS We assessed the global regulatory environment with regard to RWE based on regional availability of the following 3 key regulatory elements: (1) RWE regulatory framework, (2) data quality and standards guidance. and (3) study methods guidance. FINDINGS This article reviews the available frameworks and existing guidance from across the globe and discusses the observed gaps and opportunities for further development and harmonization. IMPLICATIONS Cross-country collaborations are encouraged to further shape and align RWE policies and help establish frameworks in countries without current policies with the goal of creating efficiencies when considering RWE to support regulatory decision-making globally.
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Affiliation(s)
- Leah Burns
- Worldwide Health Economics and Outcomes Research, Bristol Myers Squibb, Princeton, New Jersey.
| | - Nadege Le Roux
- Regulatory Intelligence, Bristol Myers-Squibb, Boudry, Switzerland
| | | | | | | | - Frank Rockhold
- Department of Biostatistics and Bioinformatics, Duke Clinical Research Institute, Durham, North Carolina
| | - John O'Donnell
- Worldwide Health Economics and Outcomes Research, Bristol Myers Squibb, Princeton, New Jersey
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Abstract
PURPOSE OF REVIEW Patient reported outcomes (PROs) are increasingly utilized in cancer drug development, and are of particular importance in genitourinary cancers due to symptom burden, multiple treatment options with similar efficacy, and often prolonged duration of disease. Here we review current data and perspectives related to use of PROs in drug development for genitourinary cancers, including insights on the regulatory process for drug approval. RECENT FINDINGS The FDA is committed to incorporating PRO data into the regulatory process for development and approval of new cancer drugs, but challenges exist due to lack of standardization of PRO instrument choice and analytic approach, missing data, and difficulty isolating treatment effect from disease-related effects. We review guidance for standardization of PRO methodology that is nonetheless tailored to disease state and anticipated effects of treatment. PRO and efficacy data should be simultaneously analyzed and reported for best clinical practice. Multiple disease-specific PRO instruments exist for genitourinary cancers. While clinicians, researchers, and regulatory bodies alike recognize the importance of PROs in cancer drug development, challenges remain regarding implementation of best practices.
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Affiliation(s)
- Risa L Wong
- Department of Medicine, Division of Oncology, University of Washington, Seattle, WA, USA.,Clinical Research Division, Fred Hutchinson Cancer Research Center, Seattle, WA, USA
| | - Alicia K Morgans
- Robert H. Lurie Comprehensive Cancer Center, Northwestern University, Chicago, IL, USA.
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Wong L, Noble B, Hanna K. Water Quality Monitoring to Support Cumulative Effects Assessment and Decision Making in the Mackenzie Valley, Northwest Territories, Canada. Integr Environ Assess Manag 2019; 15:988-999. [PMID: 31231934 DOI: 10.1002/ieam.4179] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [MESH Headings] [Track Full Text] [Subscribe] [Scholar Register] [Received: 04/23/2019] [Revised: 05/15/2019] [Accepted: 06/17/2019] [Indexed: 06/09/2023]
Abstract
Project proponent- and government-led environmental monitoring are required to identify, understand, and manage cumulative effects (CE), yet such monitoring initiatives are rarely mutually supportive. Notwithstanding the need for a more integrated and complementary approach to monitoring, monitoring efforts are often less effective than intended for addressing CE. This paper examines current monitoring programs in the Mackenzie Valley, Northwest Territories, Canada, based on 7 attributes: consistency, compatibility, observability, detectability, adaptability, accessibility, and usability. Results indicate a tenuous link between and across proponent-led monitoring requirements under project-specific water licenses and government-led monitoring of regional baseline conditions. There is some consistency in what is monitored, but data are often incompatible, insufficient to understand baseline change, not transferable across projects or scales, inaccessible to end users, and ultimately unsuitable to understanding CE. Lessons from the Mackenzie Valley highlight the need for improved alignment of monitoring efforts across programs and scales, characterized by a set of common parameters that are most useful for early detection of cumulative change and supporting regulatory decisions at the project scale. This alignment must be accompanied by more open and accessible data for both proponents and regulators, while protecting the sensitivity of proprietary information. Importantly, there must be conceptual guidance for CE, such that the role of monitoring is clear, providing the types of CE questions to be asked, identifying the hypotheses to be tested, and ensuring timely and meaningful results to support regulatory decisions. © 2019 SETAC.
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Affiliation(s)
- Lindsay Wong
- Department of Geography and Planning, University of Saskatchewan, Saskatoon, Saskatchewan, Canada
| | - Bram Noble
- Department of Geography and Planning, University of Saskatchewan, Saskatoon, Saskatchewan, Canada
| | - Kevin Hanna
- Center for Environmental Assessment Research, University of British Columbia, Vancouver, British Columbia, Canada
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Rudén C, Adams J, Ågerstrand M, Brock TC, Poulsen V, Schlekat CE, Wheeler JR, Henry TR. Assessing the relevance of ecotoxicological studies for regulatory decision making. Integr Environ Assess Manag 2017; 13:652-663. [PMID: 27599457 DOI: 10.1002/ieam.1846] [Citation(s) in RCA: 19] [Impact Index Per Article: 2.7] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [MESH Headings] [Track Full Text] [Subscribe] [Scholar Register] [Received: 06/22/2016] [Revised: 07/15/2016] [Accepted: 07/15/2016] [Indexed: 06/06/2023]
Abstract
Regulatory policies in many parts of the world recognize either the utility of or the mandate that all available studies be considered in environmental or ecological hazard and risk assessment (ERA) of chemicals, including studies from the peer-reviewed literature. Consequently, a vast array of different studies and data types need to be considered. The first steps in the evaluation process involve determining whether the study is relevant to the ERA and sufficiently reliable. Relevance evaluation is typically performed using existing guidance but involves application of "expert judgment" by risk assessors. In the present paper, we review published guidance for relevance evaluation and, on the basis of the practical experience within the group of authors, we identify additional aspects and further develop already proposed aspects that should be considered when conducting a relevance assessment for ecotoxicological studies. From a regulatory point of view, the overarching key aspect of relevance concerns the ability to directly or indirectly use the study in ERA with the purpose of addressing specific protection goals and ultimately regulatory decision making. Because ERA schemes are based on the appropriate linking of exposure and effect estimates, important features of ecotoxicological studies relate to exposure relevance and biological relevance. Exposure relevance addresses the representativeness of the test substance, environmental exposure media, and exposure regime. Biological relevance deals with the environmental significance of the test organism and the endpoints selected, the ecological realism of the test conditions simulated in the study, as well as a mechanistic link of treatment-related effects for endpoints to the protection goal identified in the ERA. In addition, uncertainties associated with relevance should be considered in the assessment. A systematic and transparent assessment of relevance is needed for regulatory decision making. The relevance aspects also need to be considered by scientists when designing, performing, and reporting ecotoxicological studies to facilitate their use in ERA. Integr Environ Assess Manag 2017;13:652-663. © 2016 The Authors. Integrated Environmental Assessment and Management published by Wiley Periodicals, Inc. on behalf of Society of Environmental Toxicology & Chemistry (SETAC).
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Affiliation(s)
- Christina Rudén
- Department of Environmental Science and Analytical Chemistry (ACES), Stockholm University, Stockholm, Sweden
| | - Julie Adams
- School of Environmental Studies, Queen's University, Kingston, Ontario, Canada
| | - Marlene Ågerstrand
- Department of Environmental Science and Analytical Chemistry (ACES), Stockholm University, Stockholm, Sweden
| | | | | | | | | | - Tala R Henry
- US Environmental Protection Agency, Washington, DC
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Evans SJW, Leufkens HGM. Regulatory decision-making: are we getting it right? Pharmacoepidemiol Drug Saf 2014; 23:1012-6. [PMID: 25111962 DOI: 10.1002/pds.3695] [Citation(s) in RCA: 1] [Impact Index Per Article: 0.1] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Key Words] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Received: 05/23/2014] [Revised: 07/09/2014] [Accepted: 07/21/2014] [Indexed: 11/09/2022]
Affiliation(s)
- Stephen J W Evans
- Department of Medical Statistics, The London School of Hygiene and Tropical Medicine, London, UK
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