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#4 Practical RWE – Clinical Study Classification: Non-Interventional Study or Observational Study?

#4 Practical RWE – Clinical Study Classification: Non-Interventional Study or Observational Study?

 

It’s a simple question. Actually…no it isn’t.

The EU defines a non-interventional study as a “clinical study other than a clinical  trial” 😳 [ref 1].  Whereas the US FDA talks about “non-interventional (observational) studies”[ref 2].

So…let’s simplify things…for the sake of your sanity and mine.

In Europe, by definition [ref 1], a non-interventional study must involve a drug.  If your clinical study does not involve a drug…then by regulatory definition it cannot be a non-interventional study. Meaning?  Any other type of study with a non-interventional design will be an observational study…which may or may not be defined at the local level.

The EMA list of metadata for the Real World Data catalogues (which go live in February 2024) [ref 3] define the drug study types as ‘clinical trial’ or ‘non-interventional study’.  The non-interventional study, study designs are defined as: cohort| case-control| case-only| cross-sectional| ecological| cluster design| systematic review and meta-analysis.  Note the absence of ‘observational’.

In the USA, the terms ‘non-interventional study’ and observational study are used interchangeably:

A non-interventional study (also referred to as an observational study) is a type of study in which patients received the marketed drug of interest during routine medical practice and are not assigned to an intervention according to a protocol (as per Section II of the FDA Guidance) [ref 2].

However, the FDA definition implies that a non-interventional study must involve a drug.

In summary, in both Europe and America, a non-interventional study must involve a drug.  If your clinical study does not involve a (marketed) drug…then by regulatory definition it cannot be a non-interventional study.

 

References:

[1] Article 2.2(4) of Regulation EU/536/2014: https://eur-lex.europa.eu/eli/reg/2014/536

[2] Section II of the FDA Guidance – Considerations for the Use of Real-World Data and Real-World Evidence to Support Regulatory Decision-Making for Drug and Biological Products (August 2023): https://www.fda.gov/media/171667/download

[3] Section 2.2(II) of the EMA List of Metadata for Real World Data Catalogues (May 2022): https://www.ema.europa.eu/en/documents/other/list-metadata-real-world-data-catalogues_en.pdf

In essence, definitions lay the groundwork for accurate, consistent, and meaningful research, especially in areas where the data and its sources are as diverse and complex as in RWD and RWE.

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#4 Practical RWE – Clinical Study Classification: Non-Interventional Study or Observational Study?2024-02-01T14:38:55+00:00

#3 Practical RWE – Clinical Study Classification: What is it?

#3 Practical RWE – Clinical Study Classification: What is it?

 

Running a clinical study is complicated.  From a regulatory compliance…perspective you need to know what type of study it is. This drives the direction of ‘what you need to do’ (regulatory compliance) versus what you ‘should’ do (best practice considerations).

As discussed previously, definitions, or more correctly ‘regulatory definitions’, are very important.  These definitions (e.g., non-interventional study) describe the boundaries of the study (what the study is and is not) and direct researchers to the applicable regulations and guidelines (hopefully).

When you intend to conduct of clinical study to answer a research question, it is important that you understand what the clinical study is.  Is it…(1) a clinical trial, (2) a non-interventional (drug) study, or (3) an observational study (e.g., natural history study)?

Why are these questions important?  Each of these three clinical study types are regulated differently…and to make matters worse…the regulatory framework for non-interventional (drug) studies and observational (disease) studies is different…in every country…globally.

For example, regulatory compliance considerations include:

[1] Clinical Trials = Clinical trial regulations + compliance with ICH GCP (very similar requirements globally)

[2] Non-Interventional Study = Local biomedical research regulations + pharmacovigilance requirements + consideration of/ compliance with best practices (e.g., ISPE GPP, ENCePP Guide on  Methodological Standards in Pharmacoepidemiology etc )

[3] Observational Study = Local biomedical research regulations

As you can see, the regulatory requirements for clinical trials are very different to those for non-interventional (drug) studies and observational (not drug) studies. Knowing what type of clinical study (regulatory classification) you intend to run is key to understanding what your regulatory obligations are, who you need to get approvals from, who you need to notify, what you need to notify…and what you need to tell patients so that they are adequately informed before they make the decision to participate in your research.

In summary, recognizing (correctly classifying) the study type is crucial for fulfilling regulatory obligations, obtaining necessary approvals, notifying relevant parties, and ensuring informed patient participation.

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#3 Practical RWE – Clinical Study Classification: What is it?2024-01-09T18:19:26+00:00

#2 Practical RWE – Terminology: Real World Research (RWR), Real World Data (RWD), and Real World Evidence (RWE)

#2 Practical RWE – Terminology: Real World Research (RWR), Real World Data (RWD), and Real World Evidence (RWE)

 

Real-world research, in the context of Real-World Data (RWD) and Real-World Evidence (RWE), takes on a specific meaning, particularly in the fields of healthcare and pharmaceutical research. Let’s break down these concepts:

  1. Real-World Data (RWD): This refers to data that is collected from sources outside of traditional clinical trials. RWD can come from a variety of sources such as electronic health records (EHRs), medical claims and billing activities, product and disease registries, patient-generated data including in home-use settings, data gathered from other devices that are a part of health care and real-life environments, and data from social media platforms. Essentially, it’s data that reflects the patient experience in real-world settings, not in the controlled environment of a clinical trial.
  2. Real-World Evidence (RWE): RWE is the clinical evidence regarding the usage and potential benefits or risks of a medical product derived from the analysis of RWD. This evidence is increasingly being used to support regulatory decisions and to help develop guidelines and decision-making in clinical practice. RWE studies can provide insights on how a drug or therapy performs in a broader, more diverse population and in routine clinical practice, outside the constraints of controlled clinical trials.

When conducting real-world research in this context, the focus is on understanding and analyzing the effectiveness, safety, and value of healthcare interventions in the everyday, diverse clinical settings. The methodology of such research might include:

– Observational studies, often using large datasets.

– Pragmatic clinical trials designed to evaluate the effectiveness of interventions under the usual conditions in which they will be applied.

– Analysis of treatment outcomes, side effects, and patient adherence using RWD sources.

– Use of advanced data analytics and big data techniques to extract insights from complex, large-scale RWD.

Real-world research using RWD and RWE is becoming increasingly important in the healthcare sector. It complements findings from randomized controlled trials (RCTs), which are often the gold standard for clinical research but can be limited in terms of the diversity of participants and strict inclusion criteria. RWE, on the other hand, can provide a more comprehensive view of how treatments work in diverse populations and real-life settings, which is invaluable for healthcare providers, policymakers, and patients.

In essence, definitions lay the groundwork for accurate, consistent, and meaningful research, especially in areas where the data and its sources are as diverse and complex as in RWD and RWE.

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#2 Practical RWE – Terminology: Real World Research (RWR), Real World Data (RWD), and Real World Evidence (RWE)2024-01-09T17:44:46+00:00

#1 Practical RWE – The Importance of Harmonised Definitions (RWR, RWD, RWE)

#1 Practical RWE – The Importance of Harmonised Definitions (RWR, RWD, RWE)

 

Definitions are crucial in the context of real-world research (RWR), real-world data (RWD), and real-world evidence (RWE) for several reasons:

  1. Clarity and Precision: In research, clear definitions ensure that everyone understands exactly what is being discussed. This is particularly important in RWD and RWE, where the data comes from a variety of sources and might be interpreted in different ways.
  2. Consistency: Definitions help maintain consistency across studies. In the realms of RWD and RWE, where studies often use data collected for other purposes, having standard definitions allows for more reliable comparisons and aggregations of data.
  3. Data Quality: Good definitions help ensure high-quality data. In real-world research, where data is not collected in controlled experimental settings (e.g., randomised controlled trials), clear definitions are essential for filtering and processing data effectively.
  4. Regulatory Compliance: In many fields, particularly in healthcare and pharmaceuticals, RWE is used to support regulatory decisions. Precise definitions are critical to meet the regulatory standards for evidence.
  5. Interdisciplinary Communication: RWD and RWE often involve collaboration across various disciplines. Clear definitions facilitate better communication and understanding among diverse groups of researchers, clinicians, policymakers, and other stakeholders.
  6. Replicability and Scalability: Well-defined concepts and methods enable other researchers to replicate studies or scale up research projects. This is vital for the advancement of science and policy-making.
  7. Data Integration: In real-world research, data often comes from multiple sources. Consistent definitions allow for more effective integration and analysis of this heterogeneous data.
  8. Targeted Interventions and Policies: In applied research, such as public health or market research, clear definitions help in designing more effective interventions and policies, as they allow for a precise understanding of the phenomena being addressed.

In essence, definitions lay the groundwork for accurate, consistent, and meaningful research, especially in areas where the data and its sources are as diverse and complex as in RWD and RWE.

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#1 Practical RWE – The Importance of Harmonised Definitions (RWR, RWD, RWE)2024-01-09T17:38:50+00:00

USA | FDA Finalises RWD Guidance on Assessing Registries To Support Regulatory Decision-Making for Drug and Biological Products

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USA | FDA Finalises RWD Guidance on Assessing Registries To Support Regulatory Decision-Making for Drug and Biological Products2024-01-09T14:36:31+00:00

USA | FDA Finalises Guidance on “Data Standards for Drug and Biological Product Submissions Containing Real-World Data

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USA | FDA Finalises Guidance on “Data Standards for Drug and Biological Product Submissions Containing Real-World Data2024-01-09T14:24:58+00:00
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